An estimated 91% of U.S. coal power plants that submitted groundwater monitoring data as required by the Environmental Protection Agency’s (EPA’s) 2015 Coal Combustion Residuals (CCR) rule have unsafe levels of one or more contaminants, a collaborative analysis of the monitoring data by several environmental groups suggests.
The March 4 report is significant because power companies posted individual results from initial groundwater monitoring of their coal ash landfills and surface impoundments on separate websites starting in March 2018 as required by the coal ash rule. The individual datasets are vast and convoluted. Duke Energy’s data, for example, is about 25,000 pages, and Alabama Power’s exceeds 1,000 pages. Until now, they haven’t been accessible as a single collected resource.
The report was compiled by the Environmental Integrity Project (EIP), a nonprofit organization that advocates for more effective enforcement of environmental laws, in collaboration with the Sierra Club, Prairie Rivers Network, and other organizations. The EIP said it obtained and analyzed all groundwater monitoring data that companies made publicly available on separate websites.
However, while the EPA’s Regulatory Impact Analysis (RIA) associated with the July 2018 final rule to amend the 2015 CCR Rule covers 922 coal ash landfills and surface impoundments at 414 coal-fired power plants, the EIP’s dataset covers only 265 coal plants or offsite coal ash disposal areas, including more than 550 individual coal ash ponds and landfills that are monitored by more than 4,600 groundwater monitoring wells. According to the EIP, “The rest of the coal plants have not posted groundwater data either because they closed their ash dumps before the Coal Ash Rule took effect in 2015, or because they were eligible for an extension or exemption.”
Under the final 2015 rule, some coal ash ponds are eligible for an extension, which means they are not required to complete baseline monitoring until April 17, 2019. Meanwhile, companies that committed to closing an ash pond by April 2018 were originally exempt from groundwater monitoring requirements, but the EPA vacated the loophole in August 2016, and the rule now requires that “early closure” ponds must post their monitoring data by September 2019.
‘Virtually All’ Coal Plant Groundwater Is Contaminated
Also important to note is that the EIP’s report is based on the initial round of baseline monitoring, which required coal generators to sample each wells at least eight times to measure all 21 pollutants identified in the CCR Rule. But it also covers, in most cases, the first round of detection monitoring, which required generators to look for a “short list” of chemicals that indicated coal ash pollution. According to the EIP, “most” coal plant owners posted the results of their initial groundwater monitoring by March 2018. “A handful of owners failed to provide all of the required data, but most owners complied,” it noted. The monitoring schedule was designed to take place over a period of years.
The report assesses several pollutants from coal ash—identified by the EPA in a 2014 risk assessment—that pose the most adverse health impacts, comparing them to health-based thresholds for arsenic, boron, cadmium, cobalt, chromium, fluoride, lead, lithium, mercury, molybdenum, radium, selenium, and thallium, among others. “These thresholds were generally identical to the groundwater protection standards in the Coal Ash Rule, with the exceptions being boron and sulfate (which do not have groundwater protection standards in the Coal Ash Rule), and molybdenum (for which we used a slightly more stringent health-based value),” the report notes.
However, it described a lengthy list of caveats. The EIP essentially compared average concentrations of each pollutant in each well to health-based thresholds to come up with “exceedances,” which may or may not constitute legal violations under the 2015 CCR Rule. It then tallied up these exceedances.
“To do this, we excluded all downgradient [wells that monitor groundwater after if passes through an ash unit] mean values that were less than the highest mean value from wells designated as upgradient [wells that are upstream of the unit] of the same coal ash dump,” the EIP said. While it acknowledged the method is not “perfect,” the organization concluded that 91% of the 264 coal ash sites it analyzed had unsafe groundwater.
“All things considered, our approach will tend to underestimate the extent of coal ash contamination at coal plants. If we include all data in our analysis – including upgradient wells and all downgradient data – then we find that 96 percent of coal plants have unsafe levels of coal ash pollutants in their groundwater,” it said.
Among the report’s notable findings are that coal ash landfills are contaminating groundwater nearly as often as coal ash ponds, refuting an EPA assumption that landfills pose a much lower risk than impoundments. “At the coal plant level, 76 percent of plants with regulated landfills have one or more leaking landfills, and 92 percent of plants with regulated ash ponds have one or more leaking ash ponds,” it concludes.
Finally, it ranks, by name and location, 10 facilities that it alleges are the most contaminated in the country. These include:
- The San Miguel Electric Plant in Texas, south of San Antonio, which is owned by the San Miguel Electric Power Cooperative.
- The G.G. Allen Steam Station, owned and operated by Duke Energy, in Belmont, North Carolina.
- The Jim Bridger Power Plant in Point of Rocks, Wyoming, a facility owned by Berkshire Hathaway subsidiary PacifiCorp.
- The Naughton Power Plant is located outside of Kemmerer, Wyoming, also owned by PacifiCorp.
- The New Castle Generating Station in West Pittsburg, Pennsylvania, which is a GenOn facility (though the report mistakenly says NRG Energy owns it).
- The Allen Fossil Plant near Memphis, Tennessee, which is owned by the Tennessee Valley Authority (TVA).
- The Brandywine Ash Management Facility in Brandywine, Maryland, which is owned by GenOn.
- Hunter Power Plant is located near Castle Dale, Utah, which is owned by PacifiCorp.
- The Morrow Generating Station, also known as “Plant Morrow,” which is owned by Cooperative Energy and located near Purvis, Mississippi.
- The Ghent station near Ghent, Kentucky, which is operated by Kentucky Utilities, a subsidiary of PPL Corp.
Power Companies React to the Findings
In statements to POWER this week, a number of power companies cited in the report stressed their efforts to abide with environmental rules, noting myriad and frequent efforts to ensure coal ash facilities are structurally intact and functioning as designed.
PacifiCorp spokesperson David Eskelsen, for example, told POWER that the company has, as part of the CCR Rule, performed all the monitoring and analysis required by the CCR rule and posted all required data to PacifiCorp’s website. “In all sites, the company has been actively monitoring and conducting control and remediation steps for decades, in connection with the groundwater permits from state departments of environmental quality, and is in full compliance with the law,” he said.
“In addition, monitoring associated with state permits is also conducted to supply information to the states of Utah and Wyoming. PacifiCorp committed to compliance steps that will continue to protect human health and the environment,” he added. The results show “no impacts to drinking water have occurred or are likely to in the future. Further, the natural groundwater quality in all three areas is already low, that is, Class IV—which is not useable for any purpose except for some industrial uses.”
PacifiCorp will conduct additional monitoring and analysis this year. “Additionally, the company will develop a study of corrective measures, conduct a public meeting locally to discuss the corrective measures, continue to implement remedies, and report progress on the site remediation twice yearly,” Eskelsen said.
However, Eskelsen also pointed to uncertainties in the study. “It appears that Environmental Integrity’s analysis compared the monitoring well values with safe levels for drinking water. The groundwater in these area has been naturally degraded by geologic deposits through which the water flows. As a result, background levels of some compounds are naturally higher than regulatory levels,” he said. “A more meaningful comparison is to compare the monitoring well findings against natural background groundwater quality.”
Meanwhile, at Duke Energy, efforts to address coal ash pollution have been heightened since the Feb. 2, 2014, break in a coal ash pond at the Dan River Steam Station in North Carolina sent 39,000 tons of coal ash and 27 million gallons of wastewater into the Dan River. As company spokesperson Bill Norton told POWER, the company has been transparently reporting groundwater issues at its plants for years. “The only thing new is how some critics have repackaged the data to try to mislead,” he said.
“The postings in the CCR rule are intended to drive basin closure decisions, and Duke is already well down the path to safely closing all of our basins in ways that continue to protect people and the environment. This is yet another attempt by some to mislead the public by cherry-picking one or two data points out of thousands in order to advance a misleading narrative and extreme agenda,” he said.
Norton also specifically pointed to a number of inaccuracies in the report. “Drinking and recreational water supplies around Allen Steam Station and our other North Carolina facilities remain safe from coal ash impacts, and our modeling shows they’ll continue to be safe in the future. In fact, their report acknowledges that groundwater data alone does not prove that drinking-water supplies near these facilities have been impacted, and the report does not present such evidence,” he said.
“Among other things, the report inaccurately states that ‘Duke cannot restore local groundwater and surface water quality unless it excavates the ash and moves it to lined, dry storage, elevated above groundwater and away from the river,’ ” Norton said.
“This is not true and not supported by science. Our basin closure plans are followed by a corrective action plan to address groundwater impacts. EPA acknowledges that capping, followed by corrective action plans, can safely address these impacts. The impacts to groundwater on plant property in North Carolina are anticipated in and will be addressed by our closure plans and corrective action plans.”
—Sonal Patel is a POWER associate editor (@sonalcpatel, @POWERmagazine)
Correction (March 7): A previous version of this article stated 27 million gallons of coal ash sludge spilled into the Dan River in February 2014. The official estimate was up to 39,000 tons of coal ash and 27 million gallons of wastewater.