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Abel Russ is an attorney with the Environmental Integrity Project in Washington DC who works on coal ash. Before becoming a lawyer, Abel worked in the field of human health risk assessment and toxicology. This post summarizes some of Abel's key points made in this video prepared for the June 11 People's Hearing on the risks of leaving coal ash on the banks of the Middle Fork of the Vermilion River.

Why Be Concerned about Coal Ash? It's Toxic!
Coal ash is the material that's left over after burning coal. But chemicals naturally found in coal are concentrated in the ash after coal is burned. Today, air pollution control devices capture what used to go up the smokestack. Now, fly ash, bottom ash, flue gas desulfurization, and sludge that is placed in dry or wet landfills have high concentrations of heavy metals and other pollutants that can be toxic to humans and our environment. When coal ash comes in contact with water over an extended period of  time, it leaches out of the solids and becomes a water contaminant.

Coal ash contaminants are leaching from two of Dynegy's unlined ash pits located on the banks of the Middle Fork of the Vermilion River. Photo by Pam Richart, Eco-Justice Collaborative.  June 2017.

How Hazardous is Coal Ash?
Strictly speaking, the U.S. EPA has not made a decision about whether coal ash is hazardous or nonhazardous. With that said, when conducting its risk assessment for the 2015 coal ash rule, the U.S. EPA identified nine constituents that present an unacceptable risk to human health and the environment. They include: lead, mercury, arsenic, manganese and multiple carcinogens like arsenic and chromium (lead also is a probable carcinogen according to the U.S. EPA).  Chemicals in coal ash can cause cancers; neurological effects, such as IQ loss in children; and developmental and reproductive risks.  For example, boron, the leading coal ash indicator, causes developmental risks like low birth weight. It also causes reproductive risks like testicular atrophy. In addition, boron is toxic to plants and aquatic animals.  Because the U.S. EPA determined coal ash contains chemicals unsafe for both humans and ecosystems, they chose to regulate it.  

No One Accepts Coal Ash Risks Voluntarily
Unfortunately, risks to human health from coal ash are imposed on people who live near these facilities, often against their will. They don’t actually know how large the risk is. This is considered to be a basic justice issue, because risks from living near coal ash are highest for children. While it is true that no one accepts these risks voluntarily, that is especially true for children.  Kids exposed to coal ash contaminants might have an IQ that’s five or ten points lower than it would have been otherwise. And, there is really no way to tie that back to its original cause. That’s a scary prospect for families, and rightfully so.

What About a Cap and Leave Plan
Like Dynegy is Proposing?

The problem with capping coal ash in place with an impermeable membrane, is that no matter how much one is able to keep water from percolating down through the cap, if the groundwater is saturating the coal ash some or all of the time, coal ash contaminants (or leachate) will continue to exit the unit; enter groundwater; and move off site. So capping a wet landfill impoundment in place doesn’t really do anything to reduce the risk from coal ash contaminants.

Cross-section prepared by Prairie Rivers Network, September 2016.

When a unit is capped in place and buried partially or completely beneath the water table, an area is created that will continue to be contaminated indefinitely. It could be hundreds of years or thousands of years.  And no one will ever be able to drink that water unless the ash is removed.

At a certain point, you either decide to leave it a sacrifice zone - or you clean it up. - Abel Russ, Environmental Integrity Project

 

While an owner of a wet coal ash impoundment has obligations for a certain amount of time, ultimately, the corporation will leave. What’s left is essentially a toxic waste dump - not in the sense that you picture it with the big oil cans and things - but the groundwater is unsafe to drink. Those who become responsible for that mess when the utility leaves, are the taxpayers. At a certain point, you either decide to leave it a sacrifice zone - or you clean it up. 

So, from a policy perspective, it is much better to clean up the coal ash before the utility leaves.  And, it’s much easier to clean up the source of contamination before it all leaches out and migrates off-site.  It’s not that expensive to dig up the ash and put it in a properly-lined landfill.  That’s what owners (like Dynegy) of these coal ash impoundment sites should be doing.

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