Coal Ash_ The Toxic Threat to our Health and Environment

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					   EPA Options
      for the
Federal Regulation
        of
 Coal Combustion
      Waste


     Lisa Evans
     Earthjustice
   October 22, 2010
The Problem
• 141 million tons of coal ash generated
   annually in the U.S.

• Hazardous pollutants (arsenic, mercury,
   lead, etc) captured by CAA pollution
   control devices are transferred to the solid
   waste (CCR).

• No federal regulation of CCR. State laws
   are inadequate.

• Water contamination via mismanagement
   documented at 137 sites in 34 states.

• Toxic leaching of coal ash poses high
   risk. People living near some unlined ash
   ponds have 1 in 50 chance of cancer.
Options for CCR Regulation under RCRA

 • Subtitle C: Regulation as a “special waste” with “cradle to grave”
    management requirements, including phase-out of ash ponds.

 • Subtitle D: Regulation of CCR as a nonhazardous waste with self-
    implementing requirements allowing operation of lined ash ponds.

 • Subtitle D Prime: Same as Subtitle D, with allowance for continued
    operation of unlined coal ash ponds.

 • Subtitle C Prime: Regulation as a hazardous waste with tighter
    timelines and requirements for closure of both ash ponds and
    unlined landfills.
       COMPARISON OF                                                        Subtitle C
                                                                                Prime
                                                                                         Subtitle
                                                                                             C
                                                                                                    Subtitle
                                                                                                        D
                                                                                                               Subtitle D
                                                                                                                   Prime
REGULATORY REQUIREMENTS

Requirements mandatory for states                                           √            √

Regulations enforceable by EPA                                              √            √


Solid waste permits                                                         √            √

Requirements for storage and transport                                      √            √

Phase out surface impoundments                                              √            √

RCRA facility-wide inspections                                              √            √

RCRA facility-wide corrective action                                        √            √

Financial Assurance                                                         √            √

Continued operation of unlined surface impoundments                                                            √

Phase out unlined and clay-lined landfills                                  √

Phase out surface impoundments within 3 years                               √

Remove all CCR from surface impoundments and clean close                    √

Monitor and remediate, as necessary, all off-site CCR fill/disposal sites   √

Install air monitoring at disposal sites                                    √

Prohibit unencapsulated use of CCR until EPA determines use is safe         √
Economic Impact                 Subtitle C “Special                     Subtitle “D
                                                      Subtitle D
According to RIA                Waste”                                  prime”

Regulatory Compliance                                 *Reduction in cost based on EPA’s
Costs:                                                estimate of percent of noncompliance

1. Engineering controls costs   100%                  48%*              48%*

2. Ancillary costs              100%                  48%*              48%*

3. Dry conversion costs         100%                  40%               0%
                                                      Reduction in benefits based on failure
                                                      to monitor and take timely action to
Regulatory Benefits:
                                                      address contamination** or on
                                                      continued operation of waste ponds***

1. Groundwater contamination
prevention benefits:


Groundwater remediation
                                100%                  48%**             30%**
costs avoided

Monetized value of human
                                100%                  48%**             30%**
cancer risks avoided

2. Impoundment structural
                                100%                  45%***            23%***
failure cleanup costs avoided
 Timeline for Compliance
                   EFFECTIVE DATE OF                        Mandated Closure of
                   REGULATIONS                              Unlined and Clay-lined
                   (Assuming final rule                     Surface Impoundments
                   published Jan 2012)

Subtitle C         Contingent on adoption of state          2020-2024
                   regulations: Estimated 1-5 years after
                   promulgation of final rule

Subtitle D         Six months after promulgation of final   2019
                   rule

Subtitle D Prime   Six months after promulgation of final   none
                   rule

Subtitle C         Six months after promulgation of final   2015
                   rule. (Adoption by state or use of EPA
Prime              authority where state has not adopted
                   regulations.)

				
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