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Wednesday, July 17, 2024

Coal Ash Slurry Pond Cleanup: EPA’s 2015 Rule Interpreted to Include Groundwater Contact Stands and Will Be Enforced, For Now


     Recent Supreme Court decisions have been seen to weaken regulatory powers and deference, but the EPA was recently vindicated in a U.S. Court of Appeals for the District of Columbia Circuit decision to dismiss challenges to a series of enforcement actions on coal ash. Some utilities and power plant owners were seeking to further delay compliance with coal ash pond requirements. One of these coal ash slurry ponds that will be affected is about 30 minutes from where I live, and that plant may be where my power is sourced.





     Coal ash is the post-combustion ash from power plants that is stored as a slurry in ponds that can be very large. Burning coal produces large amounts of it. Combustion concentrates the toxic heavy metals in the ash, also known as residuals. Inside Climate News noted:

 

As of 2012, more than 470 coal-fired electric utilities in 47 states and Puerto Rico had already generated about 110 million tons of coal ash, one of the nation’s largest industrial waste streams, according to the EPA.”

 

EPA identified over one hundred power plants with over 160 coal ash storage ponds that are very close to or already in contact with underground drinking water sources.





Source: Earthjustice


     In 2015 EPA enacted new Coal Combustion Residuals (CCR) rules. CCR refers to several waste materials from coal combustion and abatement, including fly ash, bottom ash, boiler slag, and flue gas desulfurization sludge. Fly ash from combustion is by far the major component. Unlined ponds were originally required to be excavated and lined by April 2019. In 2018 the compliance deadline was extended to October 2020. The deadline was then extended to April 2021. Most coal plant owners and utilities have complied or submitted acceptable compliance plans. Some have sought to challenge the rules through litigation.

     There is no doubt that coal ash getting into surface water or groundwater is a very serious environmental health concern. I wrote about this in 2020 for my 2021 book Sensible Decarbonization:

 

“According to Environmental Energy Project and Earthjustice 90% of groundwater monitoring wells around coal ash facilities near three-quarters of U.S. coal plants “disclosed unsafe levels of at least one coal ash pollutant, including arsenic, lithium, and other contaminants.” {as well as arsenic, lead, mercury, selenium, radium, lead, beryllium, and cadmium}. The CCR rule mandated that groundwater tests be filed. It did not mandate, however, that drinking water sources near coal ash pits be tested. Several pits are known to be leaking and some major leaks have occurred, dumping large quantities of sludge into local rivers that can accumulate in sediment, damage aquatic wildlife, and make its way up the food chain. Coal ash cleanup can be very costly, reaching into the billions per facility,..”

 

“The EPA also changed the definition of unlined pits to include clay-lined pits which means more ash will have to be excavated. {This change to more stringent rules was done during the Trump administration under EPA chief Andrew Wheeler} Regarding the rule extension Wheeler noted “The public will also be better informed as EPA makes facility groundwater monitoring data more accessible and understandable.”



    Earthjustice claimed in 2022 that coal ash pond owners were attempting to delay and avoid compliance through the following means:

1)                                 They claim the culprit is other coal ash on their property that isn’t regulated due to a loophole;

2)        They blame some other “unnamed source” or "naturally occurring" chemicals for contaminating groundwater with the same coal ash contaminants that are leaking from their dumps;

3)        They use tainted water samples near dirty locations on their property as “background” to show that the contaminated water near their regulated coal ash dumps is not much worse; and

4)        They post “cleanup plans” on their website but never actually initiate cleanup, even years after posting, despite the fact that the federal rule requires plants to choose a cleanup remedy “as soon as feasible.”


    EPA requires that owners of coal ash ponds or CCRs comply with federal regulations or with state regulations that EPA deems are as protective as federal requirements. EPA has approved three states’ plans for CCR compliance, but Alabama’s plan was rejected as not meeting those requirements. The main issue was the state's much cheaper plan to dewater the slurry and then cap it with a synthetic liner to prevent rainwater from getting in. This is much cheaper than the preferred, or rather, required method of “clean closure” where the ash is removed from the impoundment to a lined landfill. Ash is used in some industrial products, such as concrete. Apparently, after capping some ponds, groundwater monitoring wells continued to show high concentrations of heavy metals. Thus, Alabama was denied state primacy for CCR remediation. EPA has offered to work with the state to develop an acceptable plan.





     EPA is focused on cleaning up the ponds that are actually in contact with groundwater that is close to drinking water sources. Most coal plants are built near a water source due to the need for water to make steam to run the turbines. Thus, many of these ponds are on lowlands and dug below the water table so that there can be very good contact with groundwater aquifers. The Biden administration EPA changed the rules to require legacy ponds as well as newer ones to comply with the rules. Utilities in Georgia and Alabama have defied the EPA’s change by arguing that the rules require no infiltration into the ash and so synthetic covers should be sufficient. They interpret “infiltration” to mean infiltration only by rainwater, rather than infiltration by groundwater into the ash as well, which is how EPA interprets infiltration.

     A group of utility companies filed suit against the EPA to argue that groundwater contact was not implied in the rule. EPA made clear that it was implied. In late June 2024, the U.S. Court of Appeals for the District of Columbia Circuit dismissed industry challenges to these enforcement actions on coal ash. Now they will have to comply. However, some of these utilities and states may well be holding out hope for a Trump win where a new EPA could easily re-interpret the rules to allow for top liners only. Either way, there will be some improvement in the toxicity of adjacent groundwater. Unfortunately, those toxins can stay in groundwater for a long time and move closer to drinking water wells. Thus, the better long-term solution is to fully line them. However, the high cost that could be passed to ratepayers (including possibly me) is worth considering. Since many of these coal plants are old and scheduled for retirement, there is little upside to them, and the requirements make decommissioning very expensive.

 

 

References:

What is a liquid? Utilities sue to avoid coal ash cleanup — and lose. Gautama Mehta. Grist. July 9, 2024. What is a liquid? Utilities sue to avoid coal ash cleanup — and lose (msn.com)

Court tosses coal ash enforcement challenge in win for EPA. Miranda Willson. Politico. E&E News. Green Wire. June 28, 2024. POLITICO Pro | Article | Court tosses coal ash enforcement challenge in win for EPA

EPA finally takes on abandoned coal ash ponds — but it might be too late. Gautama Mehta. Grist. May 1, 2024. EPA takes on abandoned coal ash ponds, but it might be too late | Grist

101 Coal Plants With Toxic Sludge Threatening Our Drinking Water. Earthjustice. June 14, 2024. 101 Coal Plants With Toxic Sludge Threatening Our Drinking Water - Earthjustice

EPA Formally Denies Alabama’s Plan for Coal Ash Waste. Lee Hedgepeth. Inside Climate News. May 23, 2024. EPA Formally Denies Alabama’s Plan for Coal Ash Waste - Inside Climate News

 





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