Sources: Environmental Integrity Project, Washington, D.C.; Earthjustice, San Francisco
By Don Marsh
Proponents of an onerous, Environmental Protection Agency-proposed rule governing disposal of utilities’ coal combustion residuals (CCR) are challenging agency officials’ $23 billion estimate of the value of concrete-grade fly ash and other marketable-CCR recycling.
In a report timed with the two-year anniversary of the Kingston, Tenn., coal ash sludge impoundment failure that triggered the EPA proposal, a coalition of environmental groups claims the figure is about 20 times higher than the actual dollar value of CCR recycled annually. The report is their latest ploy to advance designation of CCR handling and disposal under Resource Conservation & Recovery Act Subtitle C, one of two options in the EPA-proposed rule under review. Such a listing would make recyclable or landfill-bound coal ash synonymous with hazardous waste.
An EPA cost-benefit analysis behind the $23 billion figure factors life-cycle benefits of avoiding pollution and reducing energy costs. In their late-December report, the groups—led by Sierra Club-affiliated Earthjustice—point to federal government data suggesting an annual CCR recycling value of $1.15 billion, and insinuate that cost-benefit analysis flaws appear to have escaped White House Office of Management and Budget scrutiny. OMB officials required the agency to include a CCR designation and disposal option, known as RCRA Subtitle D and calling for state versus federal oversight, favored by ash-marketing interests and some utilities.
Factors driving the CCR recycling estimate discrepancy, the environmentalists argue, include double counting of pollution reductions EPA has already noted would occur separately under August 2010-adopted Clean Air Act rules; overstated emission levels from portland cement kilns; and, unrealistic assumptions about potential savings from reduced cement kiln and gypsum plant energy consumption.