The United States Environmental Protection Agency is soon expected to make a decision that could have an enormous impact on coal-fired power plants across the nation and, by extension, on the cost of energy and building materials. No, we’re not talking about greenhouse gas regulations here. The question that USEPA Administrator Lisa Jackson must answer is this: Should the ash generated from the burning of coal be classified as a hazardous waste or not? It’s a decision that has the potential to pile more costs onto the price of energy at a time we can least afford it.
The Agency began considering reclassification following a disastrous release of 1.7 million cubic yards of fly ash from the Tennessee Valley Authority’s Kingston plant, a large coal-fired power station located east of Knoxville, Tennessee, in December 2008. That release, caused by the failure of an earthen retention wall, caused many environmental groups to renew their call for the USEPA to classify coal ash as a hazardous waste.
Such an action would be another way to undermine coal-fired power, forcing coal-fired power plants not only to dispose of the ash they generate, but to pay a premium to do so. The cost to dispose of ash as a hazardous waste is typically four or five times higher than the costs to dispose of it under a lesser classification. Coal fired power plants generate about 130 million tons per year of ash. If we conservatively assume that the cost of ash handling would rise by approximately $200 per ton, reclassification would cost over $25 billion per year, and those costs would inevitably be passed along to consumers.
The Sierra Club, and other environmental groups, maintain that this action is necessary because coal ash contains, among other things:”…arsenic, selenium, lead, mercury, cadmium, chromium, boron, thallium, and aluminum – toxic heavy metals that have been linked to cancer, birth defects, and neurological disorders, and which clearly threaten nearby communities and ecosystems.”
True enough, as far as it goes, but your body and mine also naturally contain measurable amounts of arsenic, selenium, lead, mercury, cadmium, chromium, boron, thallium, and aluminum. The relevant question is not whether these elements are present in ash, but how much is present and in what form. The ancient adage, “the dose makes the poison” applies, but the Sierra Club and other environmental groups generally steer well clear of that sort of analysis. Fortunately, USEPA has standard methodologies for determining whether wastes exhibit toxic characteristics sufficient to classify such wastes as hazardous. The Electric Power Research Institute (EPRI) analyzed samples of coal ash from eighty different plants across the country, following USEPA’s evaluation methodology. Results of these analyses showed that none of the ash could be classified as hazardous wastes following USEPA’s own rules.
The worst part of this ill-considered over-reaction to an isolated incident is that it would undercut one of the most successful recycling programs in the nation. Without any government interference, the free market led coal-fired power plant operators to look for markets for coal ash and they have been spectacularly successful in doing so. Today, millions of tons of coal ash are used to produce cement, make bricks, build roadways and in a wide variety of other beneficial ways. According to EPRI’s analysis, recycling ash saves the equivalent of thirty two billion gallons of oil in energy annually, and – for those concerned about global warming – displaces eleven million tons of greenhouse gases per year, simply by utilizing an inert byproduct that could only be replaced by increased mining operations. What’s not to like?
But, if the Sierra Club has its way, coal ash will not be recycled in the future. USEPA rules prohibit the use of hazardous wastes in manufacturing processes. A decision to classify the coal ash as hazardous wastes, despite all of the scientific evidence that they are not, would not only drive up the cost of operating coal-fired power plants, it would also make manufacturing the many products that utilize coal ash as a raw material that much more expensive. Given the state of the economy this would be a foolish, unpardonable decision.
Doug Scott, the Director of the Illinois Environmental Protection Agency, who has been close to the decision-making process, addressed the issue during a City Club of Chicago luncheon earlier this month. For a while, it seemed that USEPA was determined to press on with the reclassification and damn the consequences. According to Scott, that might not happen. In recent weeks, he said, the Agency has been more receptive to creating a multi-faceted regulatory structure instead. Power plants that use surface impoundments to store their ash, like the Kingston plant, would face tougher oversight, but USEPA would not impose rules that would undercut ash recycling.
If this happens, it would be absolutely the right decision. The Agency should work hard to make sure that a release like the Kingston event doesn’t happen again, but it would be foolish and irresponsible to further undermine the power industry, the manufacturing sector and the economy while doing so.