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Auditors Rap EPA on CCR Risk Studies

Friday, March 25, 2011

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For the second time in five months, Environmental Protection Agency auditors have taken the agency to task for its risk assessment practices and statements regarding the safety of Coal Combustion Residuals (CCRs).

In a sharply critical Evaluation Report, EPA Promoted the Use of Coal Ash Products With Incomplete Risk Information, EPA’s Office of Inspector General says the agency did not “follow accepted and standard practices in determining the safety of the 15 categories of CCR beneficial uses it promoted” through its Coal Combustion Products Partnership, or C2P2, program.

The new 27-page report follows OIG’s “Early Warning Report of Oct. 13, 2010. In that report, OIG concluded that the C2P2 program website conflicted with EPA’s policies and appeared to endorse certain products. EPA was forced to pull the site down.

Promoting Beneficial Use

EPA’s Office of Resource Conservation and Recovery (ORCR) launched the C2P2 program in 2001 with 170 public and private partners. The program was aimed at promoting beneficial use of CCRs, which are generated from burning coal to produce electricity. CCRs contain low concentrations of a range of metals, including arsenic, selenium, cadmium, lead and mercury. More than 136 million tons of CCRs were generated in 2008.

 
EPA Office of Inspector General

Images: EPA Office of Inspector General

Beneficial use of CCRs includes blasting grit, paint
manufacturing, structural fill and concrete products,
according to EPA.

C2P2’s goal was to increase the use of coal combustion ash (then 32%) to 50% by 2011 by promoting its beneficial use in a variety of applications, including blasting grit, paint manufacturing, waste stabilization, brick and concrete products, road bed, structural fill and agricultural applications.

The program followed EPA’s Regulatory Determination in 2000 that it had “not identified any beneficial uses that are likely to present significant risks to human health or the environment” and had identified “no documented cases of damage to human health or the environment.”

“Fossil fuel combustion wastes [CCRs] do not warrant regulation as hazardous waste, and the exemption for these wastes is retained,” EPA said. Based on its conclusions about CCR safety, “we support increases in these beneficial uses of coal combustion wastes,” the agency reported.

‘Significantly Limited’

OIG decided to review the C2P2 program to determine whether EPA “followed accepted and standard practices in determining that coal combustion residuals (CCRs) are safe for the beneficial uses it had promoted.”

The auditors’ conclusion: EPA did not. The report, which cost $759,649 to produce, alleges inadequate testing, lack of information, and lack of due diligence on EPA’s part in promoting CCR beneficial use without fully determining its risks.

“EPA’s application of risk assessment, risk screening, and leachate testing and modeling was significantly limited in scope and applicability,” OIG reported. “Without proper protections, CCR contaminants can leach into ground water and migrate to drinking water sources, posing significant public health concerns.”

EPA relied on state programs to manage risks associated with CCR beneficial use and thus promoted those uses “based on incomplete information, without knowing the risks associated with each type of beneficial use,” OIG said.

 

Beneficial uses of coal ash in 2008

Beneficial use of coal ash in 2008

Source: OIG analysis of EPA C2P2 data.
Note: Numbers indicate total tons for each type of beneficial use.

“EPA did not take sufficient action to ensure that its promotion of CCR beneficial use would not result in unacceptable risk to human health or the environment.”

Focus on Agricultural Use

EPA initiated one risk assessment for one type of CCR, OIG said. That assessment dealt with fluidized bed combustion waste in a specific agricultural application, which comprises only about 7% of CCR use.

The assessment was never finalized, was not peer reviewed, and was not representative of the 15 categories of beneficial use EPA was promoting, OIG said.

Auditors noted a 2005 EPA pledge to “identify environmentally safe and beneficial use practices,” but said EPA had never followed through. “Had EPA implemented its plans, it may have known earlier about risks from large-scale disposal of CCRs described as beneficial use,” auditors said.

‘Good Intentions’

OIG lauded EPA’s “good intentions” in seeking reuse opportunities for the vast CCR waste stream, but said these “do not supersede EPA’s mission to protect human health and the environment.”

It called on EPA to “define and implement risk evaluation practices for beneficial uses of CCRs” and to “determine if further action is warranted to address historical CCR structural fill applications.”

CCR Proposed Rule

The two reports come amid a highly charged public comment period for the EPA’s Proposed Rule for Disposal of Coal Combustion Residuals [CCRs] from Electric Utilities. The proposal, released in June 2010, played to often-packed public hearings throughout last fall. The comment period closed Nov. 19.

The measure addresses regulation of fly ash, bottom ash, boiler (coal) slag, and flue gas desulfurization sludge from coal-burning power plants.

The proposed rule outlines two possible approaches to CCR under the Resource Conservation and Recovery Act (RCRA). One would regulate CCRs destined for disposal as special waste and create a comprehensive program of federally enforceable requirements for waste management and disposal. The other would develop standards to manage CCRs as non-hazardous waste and establish performance standards for waste facilities receiving them.

EPA Response

In a strongly worded response to the OIG report, Assistant EPA Administrator Mathy Stanislaus declared that EPA’s “technical work related to beneficial use of coal ash is much more extensive than recognized in the draft report.” Stanislaus also said:

• “Proven damage cases associated with sand and gravel pits (which have always been considered disposal, not beneficial use) should not be used to draw conclusions regarding beneficial use”;

• “Important distinctions need to be recognized between encapsulated and unencapsulated beneficial uses, as well as the different manner in which EPA addressed those uses”; and

• “Since EPA is still in the process of assessing the comments received on the proposed rule, the OIG draft report should be very cautious in treating the proposal as a final statement.”

While recognizing the need for regulated management of CCRs in landfills and surface impoundments, EPA said it “strongly supports the legitimate, beneficial use of CCRs in a protective, environmentally sound manner because of the significant environmental benefits that accrue both locally and globally.”

   

Tagged categories: Abrasive blasting; Coal Combustion Residuals; Concrete; EPA; Regulations

Comment from paul mellon, (3/28/2011, 11:46 AM)

Very well written recap. Every site owner, blasting contractor and company industrial hygiene department should click and read the full OIG Report because it will effect our industry. The actual report itself is very short, only 12 pages. Paintsquare is correct, the OIG’s is a “sharply worded report”. It has also blown a gaping hole in the coal slag abrasive party line of being “ safe for people and the environment”. Turns out, no data exists to show slag abrasives are safe at the EPA! It is shocking news that EPA never actually tested coal slag abrasives for safety before placing them in the Beneficial Use Program. The program is now suspended. The immediate story for the surface prep industry is that the OIG has confirmed the TCLP is a designed to “ mimic landfill conditions” and “ actual CCR beneficial use applications may differ from a landfill scenario and require testing at different pH values” In other words, if you are blasting with coal slag on the ground surface or over water, the TCLP is NOT VALID! The OIG does not mince words. The most amazing part of the 32 page report is the 22 page response/debate between the OIG and the EPA’s Director of Solid Waste. The EPA repeatedly attempts to refute the OIG on several critical points such as lack of testing data on CCRs, whether EPA vs. states should be responsible for testing and even claiming they need more time to asses the public comments on an issue the have been researching for 11 years. The OIG stands firm and systematically refutes almost every EPA comment. The bottom line: The EPA has to test every one of the 15 categories of CCRs they approved in 2000 and reveal the test method, follow all the rules and then certify each particular CCR product is “ safe for human health and the environment”. This is the common sense approach to national CCR regulations that Director Jackson talked about last May in her press release.


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