PSR Meets with EPA on Coal Ash
October 15, 2010
recently with the Environmental Protection Agency (EPA) to present our new
report on coal ash and health, and to urge the Agency to establish strong,
health-protective regulations for coal ash disposal.
Gottlieb joined four environmental organizations in a meeting with Mathy
Stanislaus, EPA Assistant Administrator for Solid Waste and Emergency Response,
and three of his top staffers. Gottlieb outlined
the content of Coal Ash: The toxic threat to our health and
report, which was co-released with Earthjustice, is available on PSR’s website.
speaking with the EPA, Gottlieb stressed health-related concerns that underscore
the need for robust federal regulation – including, in some cases, steps that go
beyond the EPA’s current proposal.
1. Effects of multiple contaminants
typically contains more than a dozen toxic heavy metals, including arsenic,
selenium, mercury, lead, molybdenum, chromium and boron. While
the threats they pose to health are known individually, the EPA has not
examined their possible interactions.
Concurrent exposure to multiple contaminants
can increase the risk to health, either by intensifying existing effects, or by
creating new effects due to interactions and synergies. This is most likely where multiple
contaminants affect the same organ system, or where several contaminants share
a common mechanism of toxicity. Either
could occur with the mix of contaminants in coal ash.
Policy recommendation: EPA coal ash risk assessments
should take into account the potential for increased harm due to cumulative
effects or possible interactions among multiple contaminants. Not to do so runs the risk of
underestimating the threat to human health.
2. Long latency periods
Many health effects caused by coal ash exposure have
long latency periods (the time that elapses from exposure until the onset of
illness). This is true of many diseases
which can be triggered by coal ash, including neurological diseases, heart
disease, and cancer. Thus, damage to
health caused by coal ash may take years, even decades, to manifest.
To take one well-documented example: People who drink well water contaminated with
arsenic, which is commonly found in coal ash, can develop cancer of the urinary
tract (bladder, kidneys and ureters). Scientific
studies of naturally occurring arsenic in groundwater have found that people exposed
from birth to arsenic in drinking water may face an increased risk of urinary
cancer decades later -- even if they stop drinking the contaminated water.
Policy recommendation: Reliance on short-term health assessments is insufficient to
determine whether exposure has caused harm.
Due to long latency periods, long-term
study is often necessary to identify health outcomes. Specifically, it is too soon after the
Kingston, TN coal ash disaster – which occurred less than two years – to declare
that that spill had no health consequences.
Rather, long-term monitoring of
victims would be needed to identify health effects of many long-latency
diseases, including cancer.
3. Appropriate tools for measuring toxicity
PSR is concerned
about the EPA’s continued use of the Toxicity Characteristic Leaching Procedure
(TCLP) to measure the leaching of toxic chemicals from coal ash.
Using the TCLP, coal ash rarely exceeds the
thresholds established by the EPA as hazardous.
However, the EPA’s own Science Advisory Board flagged the need to review
and improve the EPA’s leachability testing procedure, saying the test did not
accurately predict the toxicity of coal ash.
For example, it failed to include important variables that influence the
mobililty of toxicants, such as the acidity of the environment. The National Academy of Science subsequently raised
When coal ash is tested using a new, more accurate
test, leachate can exceed hazardous waste thresholds many times over. Yet the EPA continues to refer to the TCLP as
a meaningful way of measuring the threat, allowing coal ash apologists to claim
that coal ash is less dangerous to human health than it really is.
Policy recommendation: The EPA should adopt the most accurate procedures
available for analyzing coal ash toxicity, so as to create an accurate
understanding of the potential for harm to
human health. It should discontinue use
of inadequate tools such as the TCLP.
4. Vulnerable populations
Several populations are especially
vulnerable to harm from coal ash. Workers
who handle the ash – loading it, unloading it, trucking it from a power plant
to a dump site – may be exposed to large amounts of airborne coal ash particles,
placing them at risk for inhalation of chromium and arsenic, both of which can
cause lung cancer. Similar risks may
exist for residents who live near dry ash landfills. However, airborne toxicants are not taken
into account in defining coal ash damage sites, and neither workers nor nearby
residents are given warnings or protection from airborne ash particles.
eat more, breathe more, and drink more per unit of body
weight than adults do. They also engage
in hand-to-mouth behaviors that may lead to ingestion of coal ash toxicants
that adults would not normally ingest. Finally,
because they weigh less, a small exposure to a toxicant represents a larger
dose for them. All these factors make children
more susceptible to harm from coal ash.
Yet no special safeguards or standards exist to protect them.
justice communities may also be at higher risk.
All people should receive fair treatment and
meaningful involvement in the development, implementation, and enforcement of
environmental laws, regulations, and policies regardless of race, color,
national origin, or income. Yet poor and minority communities are frequently subject to greater exposures to environmental
toxins. In addition, they may suffer
greater vulnerability due to the impacts of stress, poverty and inadequate
diet, and may receive inadequate health treatment. The net result, all too often, is heightened
health disparities between these communities and other, more privileged ones.
Policy recommendation: The EPA should assure that toxicity thresholds are relevant to
vulnerable populations and that vulnerable populations are adequately protected
from coal ash. It should consider
airborne paths to exposure in reaching its findings
in regard to risk assessment and damage sites.
5. Unencapsulated reuse of
Some of the recycling
uses of coal ash appear to pose an
unacceptable degree of risk for leaching.
Those uses where coal ash does not bond chemically with other
substances, but is used in the environment in essentially untreated form – for
example, as cinders on snowy roads and running tracks, as structural fill, or
as mine fill – expose the coal ash to rain, snow and surface waters. The potential for leaching exposes nearby
populations to unnecessary risks from multiple coal ash toxicants.
Policy recommendation: The EPA should restrict the recycling of coal
ash to uses where the ash is chemically unable to leach toxicants into the
environment. While recycling is not on
the agenda under the regulations currently proposed, PSR looks forward to
working with the EPA in the future to end unsafe recycling practices.
The EPA will continue to
receive public comments on coal ash until November 19. PSR urges all its members and readers to
comment. First, see our new study
on coal ash for
background information. Then submit your comments to the EPA via
email. Consult our fact
sheet for tips and the email address.