Question

Kingston Ash Slide Case study. On December 22, 2008. When a dike failed at Tennessee Valley Authority's (TVA) Kingston Fossil Plant, millions of cubic yards of coal ash cascaded into the Emory and Clinch rivers and covered numerous acres of land. A slow-moving wave of toxic sludge polluted the river water. The spill prompted TVA and other utilities across the nation to re-evaluate how they store coal ash, a byproduct from burning coal to produce electricity. Congress held hearings in the aftermath. The U.S. Environmental Protection Agency proposed new rules regulating coal ash, including classifying it as a hazardous material. Unfortunately, 5 years later, coal ash remains largely unregulated. The EPA and Congress have not yet acted to strengthen oversight of the material. Industry groups and some lawmakers continue to oppose classifying coal ash as hazardous.

The questions are:

How do we think that the Environmental Protection Agency (EPA) should proceed with regulating coal ash?

Who are the major stakeholders that need to be involved in regulating coal ash?

Do new policies need to be written and implemented related to the management of coal ash?

If we believe new polices should be written, what policies do we propose and why? If we do not believe new policies should be written, why not?

Answer 1

1- We are writing to strongly oppose several of the changes the Environmental Protection Agency (EPA) has proposed making to the Coal Combustion Residuals (CCR) rule.The changes risk effectively exempting businesses from preventing, monitoring, and correcting pollution emanating from many coal ash piles, apparently including the 400,000-ton mountain of coal ash in Puerto Rico. In doing so, the EPA threatens the health of people living near coal ash piles by exposing them to unacceptable risk of air and groundwater pollution.

Human Rights Watch is an independent nongovernmental organization that monitors and reports on human rights abuses in close to 100 countries around the world, including the United States. A significant issue that Human Rights Watch monitors is compliance with the rights to safe water and a healthy environment.

Coal ash, a toxic byproduct of coal combustion, is the second-largest waste stream in the United States, with over 110 million tons produced each year.Until the EPA enacted the CCR rule in 2015,most coal ash not sold for reuse was disposed of in unlined surface impoundments or landfills. The extent of pollution from these sites only became clear last year, after disclosure groundwater monitoring rules went into effect.

According to EarthJustice, an independent nonprofit organization that closely tracks coal ash pollution, 91 percent of reporting coal-fired units have contaminated groundwater with toxic substances, such as arsenic, boron, lead, and radium, at levels exceeding federal safety standards.Groundwater pollution is especially problematic in rural areas, where coal ash disposal sites are frequently located, because rural communities also frequently rely on private wells that are not monitored or regulated by the state or federal government. According to the EPA, six million people live near coal plants affected by these regulations.Some of the toxic metals in coal ash, such as arsenic, are imperceptible to human senses and cannot be removed from water using standard household filters.

According to EarthJustice, an independent nonprofit organization that closely tracks coal ash pollution, 91 percent of reporting coal-fired units have contaminated groundwater with toxic substances, such as arsenic, boron, lead, and radium, at levels exceeding federal safety standards.Groundwater pollution is especially problematic in rural areas, where coal ash disposal sites are frequently located, because rural communities also frequently rely on private wells that are not monitored or regulated by the state or federal government. According to the EPA, six million people live near coal plants affected by these regulations.Some of the toxic metals in coal ash, such as arsenic, are imperceptible to human senses and cannot be removed from water using standard household filters.

The risk of contamination is exacerbated by more frequent and extreme storms due to climate change. Heavy rains from Hurricane Florence, a 2018 storm that hit North Carolina, eroded a coal ash landfill, spilling the toxic coal ash onto a local roadway, and later breached a dam that sent coal ash spilling into a nearby river.After Hurricane Maria pounded a coal ash pile in Puerto Rico with 15 inches of rain, tests of a monitoring well found a two-fold increase in arsenic levels, according to a local news report.

2-

Multiple stakeholders are currently involved in how coal combustion residuals (CCR or coal ash) will be disposed of in the future, and what effects legacy disposal sites have had on the environment. For example, insurance carriers underwrite policies and process claims for disposal operations. Also, consultants are hired by utility companies to certify required environmental compliance documents. And non-governmental agencies and the public respond to, for example, public notices for disposal area closure plans and new disposal area designs. The science associated with coal ash compliance and risk mitigation is complex.  

Coal ash became known to the general public after the 2008 collapse of a diked surface impoundment at the Tennessee Valley Authority, Kingston Plant. That collapse resulted in millions of cubic yards of coal ash flowing onto private property and into adjacent rivers. Some of the coal ash traveled many miles downstream, affecting private property and water resources along the way. As a result, the US EPA passed regulations in 2015 (aka the CCR Rule) to establish standards for closure of legacy disposal areas, designing and constructing new areas, and operating and monitoring those disposal areas.

In my experience of researching coal ash disposal sites around the country since the 2008 TVA dike failure, the data are very clear:

• Unlined coal ash disposal sites, and especially unlined surface impoundments, have commonly contaminated groundwater. Many times, utilities even constructed unlined impoundments over existing streams, making connectivity with shallow groundwater inevitable.
• Legacy disposal operations complicate groundwater monitoring evaluations for old and new disposal areas because the required background sampling required by the CCR Rule might already show contamination from those old disposal areas. Background samples are meant to be the baseline to which future samples are compared to know whether or not a current disposal area is leaking in the future. So, unless the groundwater quality gets worse from possibly already high concentrations, the future data may not trigger the regulatory requirement to initiate assessment to define the nature and extent of contamination or the requirement to actually clean up groundwater.
• Groundwater monitoring wells are oftentimes drilled and screened too deep and can miss the uppermost portion of the uppermost aquifer nearest the bottom of the disposal area. As a result, groundwater samples may not represent the highest concentrations of contaminants that flow into streams and onto adjacent properties.
• Chemical contaminants commonly found in coal ash can be incorrectly blamed on naturally occurring conditions (e.g., metals such as arsenic), unless one understands such details as the leaching mechanisms of contaminants (e.g., changes in pH affect how constituents can leach); the chemical signatures of coal ash contaminants; and how water quality can vary substantially from the standing water in the impoundment, water in the pore space of saturated coal ash, and the deeper underlying groundwater.

3- The South Korean government is pursuing a national project to use the complex carbonates found in coal ash to capture CO2 and promote coal ash recycling. One possible approach is the use of coal ash as fill material in mine reclamation, but environmental concerns have so far blocked the implementation of this procedure, and no relevant regulations or guidelines exist. In this study, we review international approaches to the environmental management of coal ash recycling and consider how the lessons learned can be applied to South Korea. Each studied country was proactively using coal ash for beneficial uses under locally suitable conditions. The United States, European Union, United Kingdom, Australia, and Japan are all putting coal ash to beneficial use following thorough analyses of the environmental impact based on several considerations, including bulk concentration, coal ash leachate concentration, field inspections, and water quality monitoring. Our findings can contribute to the development of proper regulations and policies to encourage the use of recycled coal ash in South Korea as an approach to managing carbon emissions and climate changes. There are currently no relevant regulations in South Korea, so we consider the adoption of the strictest standards at each stage of the other cases at the time of introduction. Based on our findings, detailed and appropriate management guidelines can be developed in the future. Establishing management plans for complex carbonates, verifying their environmental stability, and using them as fill material will provide clear benefits for South Korea in the future.

Despite commitments and efforts to increase the share of renewable energy in the global energy supply, coal remains one of the world’s biggest energy sources, generating considerable amounts of coal fly ash. Globally, many efforts are being made to recycle the 7.8 billion tons of coal ash currently being generated annually, only 53.3% of which is currently recycled. For example, in 2016, the United States reused 60.2 million tons of coal combustion products (CCPs) out of 107.4 million tons produced. Although the rate of ash utilization thus increased from 52% to 56%, the total volume of material utilized stayed about the same as production declined. Even though the coal ash production volume has declined 7% since 2015 as coal’s share of the total energy generation shrank in response to environmental regulations and competition from other energy sources, the coal ash utilization volume remained approximately level with that of the prior year. Coal ash has been successfully used formany years in a wide range of applications, including in building material, asphalt, concrete pavement, soil stabilization, road base, structural fill, embankments, mine reclamation, mineral filler, and fertilizer, as well as in small-scale applications, such as the production of zeolites and geopolymers.The United States and Australia, which have large land areas and many developed mines, also recycle coal ash as landfill material and filling.
South Korea generated about 9 million tons of coal ash in 2016; this figure is expected to reach 14 million tons in 2021 and increase about 1.6 times over the next 10 years. The construction of circulating fluidized bed combustion (CFBC) power plants generates coal ash containing 40% CaO or more. The capacity of current South Korean disposal facilities is nearing saturation, and some recently built power plants are targeting 100% recycling of generated coal ash.Recently, South Korea has been developing complex carbonate minerals that use coal ash to capture carbon dioxide, an important approach to carbon dioxide reduction and coal ash recycling. Although these materials are intended for use as a high-function green cement and mine fill, they cannot be legally used for the latter purpose at present. In South Korea, coal ash (the main component of complex carbonates) can only be legally used for 15 applications, not including fill material in mine reclamation sites. There is a movement to legalize the use of coal ash at mine reclamation sites, but this effort is on hiatus due to concerns regarding the environmental impact, including the potential contamination of soil, ground surfaces, and groundwater resulting from the presence of soluble metal species in ash leachate.Therefore, in order to safely use coal ash at mine reclamation sites in South Korea, its environmental impacts must first be assessed and predicted.

4- Environmental issues typically addressed by environmental policy include (but are not limited to) air and water pollution, waste management, ecosystem management, biodiversity protection, the protection of natural resources, wildlife and endangered species, and the management of these natural resources for future ...

As can be seen throughout this report, good environmental policy benefits society by
protecting human health and the environment.
But for progress to be made across environmental policy areas (whether air quality, water, waste or biodiversity) cross-cutting, systemic flaws need
to be addressed. Laws and regulations need to be clear, feasible and enforceable. Policy instruments need to be well designed and packaged. Implementation needs to be supported by adequate compliance assurance strategies. All this requires effective supporting institutions.
Good environmental regulation has also
important consequences in terms of achieving political, economic and public administration
goals. For countries aspiring to EU membership, environmental legislation is a major area for convergence. For countries seeking to make the most of globalisation, environmental regulation plays an increasingly important role in guaranteeing a level-playing field for businesses in the global marketplace. For countries aiming to strengthen the rule of law and improving governance, effective environmental compliance assurance systems help to reinforce the credibility of regulation in general.
Moreover, in coming years the bar for governments in general and for environmental regulators in particular will be set higher – the public will demand better environmental performance,
while businesses will expect policy solutions that minimise compliance costs and bureaucracy.
As of early 2007, EECCA countries still face a large environmental policy and institutional reform agenda. Institutions suffer from weak authority, scarcity of resources, out-dated management approaches, high turnover of professionals and frequent restructuring, thereby lacking both the incentives and means to ensure the achievement of environmental results. Policies are generally not aimed at achieving specific targets, rely on unreformed or poorly combined instruments
and are often dominated by revenue-raising objectives. Environmental legislation is extensive
but inconsistent and unenforceable. Compliance levels are very low – almost every on-site inspection discovers one or several violations of varying severity.
This chapter discusses recent progress with environmental policy and institutional reform in EECCA countries. It has been prepared with dedicated input by EAP Task Force Secretariat staff. It also draws on the most recent UNECE Environmental Performance Reviews of EECCA countries.

It generally covers air and water pollution, waste management, ecosystem management, biodiversity protection, and the protection of natural resources, wildlife, and endangered species. ... Issues like these, affect everyone across the globe and cannot be ignored.

Having an environmental policy can provide significant benefits to your business. These include: helping you to stay within the law. improving information for employees about their environmental roles and responsibilities.

we should be need environmental policies-

Environmental Policies & Practices

• Site – Optimize site potential.
• Energy – Minimize non-renewable energy consumption.
• Materials – Use environmentally preferable products.
• Water – Protect and conserve water.
• Indoor Environmental Quality – Enhance indoor environmental quality.
• Operations and Maintenance – Optimize operational and maintenance practices.