Coal Ash: the toxic legacy of the nation’s dependence on coal burning
March 2, 2012
This essay is in response to: How toxic is coal ash, the waste material left after coal is burned? How does it come to poison the waters and dust the land in communities across the nation? And what can be done to prevent further toxic contamination?
The myriad potential dangers of coal
combustion waste, or “coal ash,” have been highlighted in the news in the three
years since the fateful collapse of a coal ash impoundment dam at TVA’s
Kingston Plant. But what exactly is coal ash? What are the exposure pathways by which its pollutants pose risks
to human health and the environment? Has it actually done serious harm yet?
What Is Coal Ash,
and How Is It Disposed of in the United States?
Coal ash is the by-product of
burning coal for electricity, and every year an additional 140 million tons of coal ash are generated by coal-burning power
This waste material is dangerous to human health and the environment, containing
a toxic soup of pollutants, especially heavy metals, often at extremely high
Once generated, much of this waste gets
Unfortunately, although the law that governs waste disposal was passed over 30
years ago, coal ash regulation was exempted from that regulation. So, there are NO federal regulations for
disposal of coal ash.
Consequently, power plants have
dumped coal ash into three main types of sites: 1) landfills, which are dry sites;
2) surface impoundments, which are wet ponds; and 3) minefills, the extremely
dangerous practice of dumping coal ash into abandoned coal mines. In the
absence of composite liners, groundwater monitoring systems, leachate
collection systems, covers, and other rudimentary environmental controls, all
of these disposal units can be perilous to nearby communities and ecosystems.
The toxic constituents of coal ash can leach into groundwater, discharge into
surface waters, or blow as fugitive dust into the air, making living near a
coal ash site dangerous to anyone who drinks well water, fishes, drinks stream
water, or simply breathes. An EPA risk assessment found that drinking groundwater
near an unlined coal ash surface impoundment can pose as high as a 1 in 50
cancer risk (2,000 times the safety threshold of 1 in 100,000), but further
found that converting to a dry landfill and including a composite liner could
reduce that risk almost to zero.
Evidence of Damage: what constitutes a damage case?
The scope of this environmental
problem is vast, as coal ash is located almost everywhere where there is or
ever has been a facility that has burned coal. Documented evidence of harm to
human health or the environment (or both) has been found in at least 35 states
EPA was ordered by Congress to
study “proven” and “potential” coal ash damage cases. According to EPA, proven damage cases are those where
contaminants at levels exceeding the “maximum contaminant levels” for drinking
water are found in ground water at a sufficient distance from the waste
management unit to indicate that hazardous constituents had migrated to the
extent that “they could cause human health concerns.” Potential damage cases were those with “documented MCL exceedances
that were measured in ground water beneath or close to the waste source.”
In addition, exceedances of standard high enough to cause “large scale, system
level ecological disruptions” (as opposed to just human health threats) also
constitute damage. To
date, there are a total of 157 damage
cases – 90 identified by the Environmental Integrity Project and its
partners, and 67 identified by EPA.
What Does It Mean
if a Coal Ash Site Has a High Hazard Dam?
the 2008 breach of a dam at the TVA Kingston Fossil Plant in Tennessee that
spilled over one billion gallons of
coal ash, the EPA asked utilities to self-rank each of their coal ash surface
impoundments based on the U.S. Army
Corps of Engineers’ criteria for the potential impacts of a dam collapse. Dams
at an alarming forty-nine coal ash
impoundments were ranked “high hazard” – meaning that a breach of any of these
dams would result in probable loss of human life.
Have Any Coal Ash
Sites Been Deemed Superfund Sites?
sites have been cleaned up pursuant to the Superfund program guidelines
(including the Kingston disaster), but two coal ash sites have actually been
listed as Superfund sites.
Excess Landfill Superfund Site, Uniontown, Ohio: At this former sand and gravel quarry,
there were exceedances of Maximum Contaminant
Levels (MCLs) for at least 10 pollutants—antimony, arsenic,
barium, beryllium, cadmium, chromium, lead, mercury, nickel, and thallium—in
off-site residential wells. Dozens of residential wells were contaminated by
the dumping of at least one million tons
of industrial coal ash in the 1960s and ‘70s before the site was closed and
eventually became a Superfund National Priorities List site in 1986. Court
documents establish that coal ash was the only metal-laden waste dumped at this
site that could have caused the exceedances.
of Pines, Indiana. The use
of coal ash for construction projects throughout the Town of Pines, Indiana,
including as uncovered roads, led to the entire town being declared a Superfund
Site after health-threatening or environment-threatening levels of boron,
molybdenum, arsenic, and other metals were found in residential wells.
many grave risks posed by irresponsible coal ash disposal, the only prudent
path forward is for EPA to ban the riskiest disposal practices and require federally
enforceable, common-sense safeguards at all sites where coal ash is disposed.
PSR invites concerned readers to sign our petition urging
President Obama to direct the EPA to issue strong coal ash protections.
 Linda Luther, “Managing Coal
Combustion Waste (CCW): Issues with Disposal and Use,” Congressional Research Service 1 (Jan.
12, 2010); U.S. Environmental
Protection Agency (EPA), Human and Ecological Risk Assessment of Coal
Combustion Wastes (Aug. 6, 2007) (draft), available at http://www.earthjustice.org/library/reports/epa-coal-combustion-waste-risk-assessment.pdf
(hereinafter EPA, 2007 CCW Risk
 Some coal ash gets recycled
into various uses (some of which are deemed safe, some of which have been more
controversial due to the potential for toxic pollutants to leach from the
products and into the surrounding environment, and all of which warrant more
Office of Solid Waste & Emergency
Response, EPA, Human and Ecological Risk Assessment of Coal
Combustion Wastes (draft) (Apr. 2010).
The states are: Alabama, Arkansas, Arizona, Connecticut, Delaware, Florida,
Georgia, Illinois, Indiana, Iowa, Kentucky, Louisiana, Massachusetts, Maryland,
Michigan, Minnesota, Montana, North Carolina, North Dakota, Nebraska, New
Mexico, Nevada, New York, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina,
South Dakota, Tennessee, Texas, Virginia, Wisconsin, West Virginia, and
 EPA, Notice of Regulatory Determination on Wastes
From the Combustion of Fossil Fuels, 65 Fed. Reg. 32,214, 32,224 (May
Unfortunately for the public, other disposal units such as landfills were not
Earthjustice, et al, Comments on EPA’s Proposed Coal Combustion Waste
Regulatory Proposal (Nov.19, 2010).