Coal Combustion Residuals (CCRs) are generated from the combustion of coal in producing steam for generation of electricity by electric utilities and independent power producers. CCR material includes fly ash, bottom ash, boiler slag, and flue gas desulfurization materials. EPA’s 2014 Coal Combustion Residual rule established technical requirements for CCR landfills and surface impoundments. In May 2023, EPA proposed to extend the CCR rule to management of coal ash at legacy CCR surface impoundments at inactive power plants (88 FR 31982) and is proposing to address coal ash that may have been applied directly to land in areas outside of regulated impoundments.
Recently, addressing potential cumulative impacts from CCR units near communities susceptible to disproportionate environmental impacts has been identified as a priority in EPA’s EJ (Environmental Justice) Action Plan.1 EPA’s EJ Action Plan has a stated goal to use opportunities provided by CCR rulemaking to identify and address EJ issues for communities near CCR facilities, as well as increasing public participation and community safeguards. Of the approximately 278 coal-fired power plants in the US and Puerto Rico, 22 are in areas with populations exceeding the 80th percentile for low income, and 6 are in communities with populations exceeding the 80th percentile for people of color (source: EPA Power Plants and Neighboring Communities Mapping Tool). Risk assessments are driven by these EJ, civil rights, and cumulative impact assessment (CIA) priorities outlined by the EPA.
ToxStrategies is poised to assist electric power generating clients and owners of CCR legacy sites with ecological and human health risk assessments related to coal combustion activities, including CIAs where required. ToxStrategies has been extensively involved in assisting with the preparation and review of human and ecological risk assessments for six Tennessee Valley Authority (TVA) CCR sites under the Tennessee Department of Environment and Conservation (TDEC) program. The ToxStrategies team has in-house experts on bioaccessibility and bioavailability of metals, dose assessment for radioactive compounds, exposure and risk assessment, and human and ecological toxicology. Additionally, ToxStrategies is an authoritative leader in CIA within the context of state and federal EJ requirements, including screening tools, cumulative impact characterization, fit-for-purpose design and problem formulation, identification of vulnerable communities, and chemical and non-chemical stressor assessment. Please see our Coal Combustion Residuals webpage for additional information.
If we can assist you with your CCR management, including EJ considerations, please contact Camarie Perry (cperry@toxstrategies.com), Stephanie Kennedy (skennedy@toxstrategies.com), or Bill Rish (wrish@toxstrategies.com).
1 EJ Action Plan. United States Environmental Protection Agency, Office of Land and Emergency Management. EPA 502/P-21/001. September 2022.