Let’s say someone wakes up with chest pains and heads to the emergency room. Eventually he is greeted by professional nurses and doctors who start the diagnostic process. His blood pressure is monitored. A cardiogram is performed. Blood samples are drawn. More testing and evaluation are recommended by a cardiologist.
But what if we had a law that required open-heart surgery for everyone with chest pains? No need for additional scientific data. No need for professional expertise.
This remains our predicament with the Coal Ash Management Act. As noted in a letter from the National Ash Management Advisory Board to the N.C. Department of Environmental Quality, the act specified the means, methods and timeline of coal ash impoundment closure. Such prescriptions are better left to licensed engineers.
Over the last year, ash impoundments have been subjected to an unprecedented level of scrutiny, with more than 1,000 monitoring wells installed or in progress. The data provide empirical evidence that contaminants from coal ash will indeed leach from unlined impoundments and migrate into the prevailing groundwater at levels that exceed standards.
The good news is that these contaminants already occur naturally and haven’t moved very far. Those that have migrated have done so in a direction away from residential drinking water wells and toward the nearest lake or river, at which point they’re virtually unmeasurable.
While more data are required, these ponds do not pose an imminent hazard. Excavation and redisposal of coal ash is one method of addressing groundwater or stability concerns. But is it really the safest and most effective alternative?
If the concern is drinking water, then the solution is to tap a new drinking water source, not excavate coal ash for decades. Other alternatives – including capping, monitored natural attenuation, slurry cutoff walls, stabilization/fixation, pumping wells and permeable reactive barriers – have all been successfully implemented with real hazardous waste. Remember, if coal ash is toxic, then so is the soil in your backyard, household garbage and ordinary Portland cement.
The additional risk imposed by excavating and transporting ash from one location to another can easily exceed the potential risk posed by leaving the ash in place. Risk drivers include the statistical certainty of traffic fatalities and injuries. Likewise, excavation results in ecological disturbance, ongoing site releases from ash disturbance for years and broader environmental effects from resource use and emissions.
These should be calculated and considered before embarking on the mass movement of tens of millions of tons of material throughout our neighborhoods, highways and railways.
The legislative fix is easy. Don’t mandate excavation with an arbitrary timeline. Instead, any impoundment labeled intermediate or high priority should be eligible for the same remedial options as allowed for low risk. The options and schedule should come from a licensed professional engineer with review and approval by NCDEQ – and a commission if one is ultimately reconstituted.
This advice represents industrywide standard of care, and it’s consistent with regulations from the EPA. Let’s diagnose, treat and move on.
Dr. John L. Daniels
Chair, National Ash Management Advisory Board; professor, Department of Civil and Environmental Engineering, UNC Charlotte
The length limit was waived to permit a fuller response.