On July 21 – July 22, 2016, SACE staff attended the Coal Ash Management Forum in Charlotte, NC. The forum was organized by the Environmental Research and Education Foundation (EREF) which funds research on waste management practices. SACE manages Southeastcoalash.org which maps coal ash facilities throughout the region and provides the latest information on coal ash risks and disposal practices. We joined over 300 scientists, utility staff, and engineers to learn more about the emerging trends in the business of coal ash management.
As utilities move to comply with federal and state regulations, the industry is generally moving from wet to dry storage of coal ash, and many utilities will finally have to grapple with the complicated costs of long-term improper storage of coal ash waste. Utilities are analyzing the costs and benefits of storing ash on utility property or moving it to potentially controversial landfills where environmental justice concerns are mounting. While new opportunities to “beneficially re-use” coal ash are exciting the industry, concerns about these practices are growing as well. Now is a key moment for communities across our region to call on utilities to properly dispose of and store coal ash, and for regulators to require utilities to do so.
Shifting from wet to dry coal ash storage
Industry experts are predicting that utilities will shift from disposing of ash in wastewater-filled pits to dry storage over the next 5-7 years. The shift is a response by utilities to the Environmental Protection Agency’s (EPA) coal ash rule and effluent limitations rule which set minimum federal standards for coal ash disposal and liquid waste from coal ash pits respectively. The southeast is home to nearly 450 wastewater-filled ash pits, 40% of the nation’s total.
Utilities across our region are already making the shift from wet to dry storage. The safest dry storage method is to fully excavate coal ash and move it to lined, dry landfills, away from our waterways and in a manner conscious of environmental justice. However, utilities like the Tennessee Valley Authority and Georgia Power are planning to leave millions of tons of ash where it’s currently stored through a closure method called cap-in-place. The method involves removing the visible water from an ash pit and placing a liner on top. These pits would not be lined underneath to prevent ash from contaminating groundwater. That’s why SACE is urging state regulators to require utilities to remove coal ash to dry landfills.
Despite the disproportionate levels of ash in our region, so far, South Carolina is the only state where all major utilities are committed to excavating coal ash across the state to lined, dry storage. Already, one excavated site shows a dramatic reduction of arsenic contamination in groundwater.
Studying onsite and offsite coal ash storage
As utilities shift from wet to dry storage, they are considering the costs and benefits of storing ash onsite (near the source of power generation) or in landfills located away from power stations, even in other states. Coal ash is a liability for utilities now and in the future. Removing ash off utility property, while probably more expensive than leaving ash where it is, reduces the utility’s exposure to legal liability for spills, leaks, and contamination.
For onsite storage, utilities and engineers are concerned with whether land that meets the requirements of EPA’s coal ash rule for disposal are available. They are also considering the capital costs of storing ash on site along with potential risks of groundwater or surface water contamination and costs of remediation if groundwater contamination is discovered. As SACE and our allies have frequently pointed out, utilities could reduce risks of groundwater contamination by ensuring coal ash is stored in facilities with bottom liners and removing ash that is already in contact with groundwater.
Growing concern with environmental justice of coal ash disposal
It’s also critical that permanent coal ash disposal options do not have an unfair impact on low-income residents and communities of color who have disproportionally and historically borne the brunt of pollution–in other words, environmental justice communities. Communities in Alabama, South Carolina, North Carolina, and Georgia have all raised concerns about the risks of storing coal ash in landfills near their homes and have actively resisted the practice. Industry experts noted that these debates become particularly heated when ash crosses state lines with concerns that one state will become the dumping ground for another.
Clearly, these movements have reached a level where their outcry has forced utilities and regulators to at least acknowledge them at some level and, in some cases, take action. In North Carolina, the state’s environmental regulator called on the U.S. Commission on Civil Rights and EPA Office of Civil Rights to conduct an environmental justice analysis before permits were issued for a coal ash disposal landfill. Georgia’s General Assembly passed a bill to ensure that Georgians are notified of toxic leaks at landfills. In South Carolina, community outrage sparked the General Assembly to pass a bill that prevents out-of-state coal ash from being dumped in some Class 2 landfills. Instead, out-of-state ash must be dumped in lined, Class 3 landfills with more protective standards. U.S. Congressman Hank Johnson (GA-04) also introduced a bill to close loopholes in EPA’s coal ash rule that exempt household garbage landfills from protections required for other coal ash storage facilities.
Increasing “beneficial re-use” of coal ash
If utilities can avoid disputes with communities over coal ash, they seem eager to do so. The industry is looking to “beneficial re-use” or “recycling” to alleviate reputational, financial, and legal risks of both onsite and offsite storage. Between now and 2018, utilities will be creating compliance and closure plans for their coal ash pits across the southeast in response to EPA’s coal ash rule and state regulations. As utilities look for ways to dispose of coal ash without running afoul of regulations or creating new liabilities, the percentage of coal ash recycling and beneficial reuse should increase.
In 2014, 48% of the coal ash produced was “recycled,” however, valid concerns exist around the safety of re-using coal ash, as it could pose routes for human and environmental exposure. Under EPA’s coal ash rule, projects using more than 12,400 tons of coal ash on the land, are required to make some health and safety demonstrations, but these are not required for projects using less than 12,400 tons, roadway applications, or the controversial practice of filling mines with coal ash (mine filling).
Mine filling is particularly dangerous because it involves dumping coal ash directly into abandoned mines and quarries where it can be in direct contact with the water table, which has resulted in significant contamination. Unlike coal ash disposal sites, practices that meet EPA’s definition of beneficial re-use are exempted from the operating, monitoring, design, and location restrictions in EPA’s coal ash rule.
Ash is also sometimes used in less controversial ways like making materials such as bowling balls, concrete, and bricks. These uses fully “encapsulate” coal ash, in theory locking the ash and its toxic contaminants away. Encapsulated re-uses also reduce the need for extraction of virgin natural resources – coal ash can replace a significant amount of high-carbon-footprint materials like Portland Cement.
What happens next?
As utilities move from wet to dry storage, many will attempt to avoid costs by creating plans to store coal ash in ways that are not fully protective of environmental and human health. It’s critical that folks across the southeast jump on the scales as utilities weigh costs and benefits of storage options for coal ash. We must encourage utilities to explore beneficial re-use where appropriate and demand that our regulators protect our communities and ensure utilities are absorbing the true costs of burning coal by properly storing and handling their coal ash. Finally, we must insist that utilities move as quickly as possible toward a renewable energy future. After all, the best way to start eliminating all the risks of coal is to stop burning it.
Want to learn more?
EREF funds coal ash research projects on behalf of the industry. Below you can find materials about these projects that were shared at the Coal Ash Management Conference:
- Exploring Opportunities For The Beneficial Use of Waste to Energy Ash
- Recovering Strategic Metals from Fly Ash
- Water Repellency for Ash Containment and Reuse
- Immobilization of Heavy Metals by Solidification/Stabilization in Challenging Coal Fly Ash and in Co-Disposed Coal Fly Ash and Concentrated Brines
- Geopolymer-Based Solutions for Coal Combustion Product Solidification and Stabilization
- Chelant-Enhanced Selective Leaching and Capture of Rare Metals from Coal Ash