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Heat Advisory: Protecting Health on a Warming Planet
by Dr. Alan Lockwood

Drawing on peer-reviewed scientific and medical research, Dr. Lockwood meticulously details the symptoms of climate change and their medical side effects.

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PSR Meets with EPA on Coal Ash

October 15, 2010

PSR met 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.

PSR’s Barbara 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 environment. 

The report, which was co-released with Earthjustice, is available on PSR’s website.

In 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

Coal ash 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 similar concerns. 

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.

Children 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.

Environmental 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 coal ash

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.

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