20150042 Ver 1_Theresa Vick DEMLR Mining Permit Comments_20150516

Burdette, Jennifer a
From: Therese Vick <therese.vick @gmail.com>
Sent: Saturday, May 16, 2015 6:54 PM
To: Higgins, Karen
Subject: Fwd:: 5306 -STRUC -2015, Colon Mine Site Structural Fill in conjunction with NCDENR
DEMLR Mine Permit 53 -05 and 1910 -STRU
Attachments: Compliance and Financial Assurance.zip_renamed; Air Quality.zip_renamed;
Postclosure_Cost_Issues.pdf
Dear Ms. Higgins:
Please accept these attachments to comments on the draft permits listed above on behalf of Chatham Citizens
Against Coal Ash Dump, EnvironmentaLEE, NC WARN, and Blue Ridge Environmental Defense League.
This is the third of (3) emails.
Thank You,
Therese Vick
Therese Vick
North Carolina Healthy Sustainable Communities Campaign Coordinator
Blue Ridge Environmental Defense League
therese.vickggmail.com
919- 345 -3673
@tvickBREDL Twitter
https:// www. facebook. com/ BlueRidgeEnvironmentalDefenseLeague ?ref =hl
From Where I Sit: Reports From The North Carolina Mining and Energy Commission Meetings
BPEDL 19184..20114,: 1 "F/ebra it�g Thiry tears q Grassroots letio
Be kind to all you ineet, each of us carries a burden that others cannot see

Therese Vick
North Carolina Healthy Sustainable Communities Campaign Coordinator
Blue Ridge Environmental Defense League
therese.vickggmail.com
919- 345 -3673
@tvickBREDL Twitter
https:// www. facebook. com/ BlueRidgeEnvironmentalDefenseLeague ?ref =hl
From Where I Sit: Reports From The North Carolina Mining and Energy Commission Meetings
BREDL 1934 ..201141: 1 "FIebra it�g Thir )1 Years q Grassroots Action
Be kind to all you ineet, each of us carries a burden that others cannot see

Review of Potential Impacts of Landfills & Associated Postclosure Cost Issues
G Fred Lee, PhD, PE, BCEE, F.ASCE and Anne Jones -Lee, PhD
G. Fred Lee & Associates
El Macero, California
Ph 530 753 -9630
gfredlee33 @gmail.com www.gfredlee.com
April 2012
US EPA RCRA Subtitle D establishes the regulatory framework and minimum prescriptive
standards for the landfilling of municipal solid waste (MSW) and what are classified as "non-
hazardous" solid wastes with the intent of protecting public health and environmental quality from
adverse impacts of the wastes. The approach to landfilling outlined in Subtitle D can be described
as creating a "dry- tomb" for the wastes — with engineered containment systems including a liner
and leachate removal system, a cover to keep moisture out, and a groundwater monitoring program
to detect liner failure before offsite groundwater pollution occurs. The objective for the design is to
keep the buried wastes dry after landfill closure to prevent future formation of landfill gas and
leachate so as to protect groundwater from pollution with landfill- derived chemicals.
Many permitted landfills in the US and some other countries are designed to just meet minimum US
EPA Subtitle D prescriptive regulatory requirements for liners and covers. It has, however, been
recognized in the technical literature and by US EPA staff for decades that the provisions of
Subtitle D are inadequate at all locations to protect groundwater resources and public health from
pollution by landfills for as long as the wastes will be a threat. Among other deficiencies,
inadequate attention is given to the inevitable deterioration of the engineered systems, the inability
to thoroughly and reliably inspect and repair system components, fundamental flaws in the
monitoring systems allowed, the truly hazardous and otherwise deleterious nature of landfill gas
and leachate, and the fact that as long as the wastes are kept dry, gas and leachate will not be
generated. Subtitle D "dry- tomb" landfilling does not render buried wastes innocuous; at best, it
only postpones groundwater pollution. Thus, meeting the minimal requirements of Subtitle D
cannot be relied upon to prevent pollution for as long as the wastes represent a threat.
Compounding deficiencies in the allowed design of "dry- tomb" landfills is the fact that current US
EPA Subtitle D regulatory provisions only require that a landfill owner /developer provide assured
postclosure funding for 30 years. The states /counties and other political jurisdictions in which
landfills are located are, or should be, justifiably concerned that private landfill companies that
develop landfills will not provide reliable protection of the area water resources for as long as the
wastes in the landfill will be a threat to generate leachate that can pollute groundwater —which can
be expected to be hundreds of years or more. Under some regulations, if a private landfill company
fails to provide adequate postclosure monitoring, maintenance and groundwater remediation when
the landfill liner system fails, the responsibility for postclosure care becomes the responsibility of
the people of the state, county, or local community. Even if the landfill owner meets its obligations
for 30 -year postclosure care, the hazards of a dry -tomb landfill continue long after that period.
While a local political jurisdiction, such as a county/ municipality, receives permit fees and fees for
hosting the landfill during the active life of the landfill, the amount of funds received can readily be
far -less than amounts that will be required the after the postclosure period funds needed to properly

monitor and maintain the landfill and remediate polluted groundwater. That responsibility can pose
a significant long -term financial burden to the state /county and or local political jurisdiction.
Local /regional /state jurisdictions that will bear the impacts of landfill failures and to which
responsibility for ad infinitum landfill care will eventually fall often do not have full understanding
of the truly long -term nature of the hazards posed by Subtitle D- permitted "dry- tomb" landfills.
This report highlights technical issues associated with the ability of the minimum design and near
minimum Subtitle D landfill to provide protection of public health and environmental quality for as
long as the wastes in the landfills will be a threat to generate leachate that can pollute groundwater,
and release landfill gas. It also provides an overview discussion of issues that need to be evaluated
to assess the potential post - postclosure care costs for monitoring and maintaining such landfills
after the postclosure period, and long -term threats to public health /welfare and environmental
quality posed by these landfills that could require remedial corrective and reparative action by the
jurisdiction at some time in the future. In this discussion the term "post - postclosure" is used to
identify the period of time beyond the required "postclosure" period during which a landfill owner
is responsible for implementing and funding maintenance, monitoring, and other activities that are
needed to control releases of hazardous and deleterious chemicals from the landfill to the
environment.
These comments are based on Dr. Lee's expertise and 50 years of experience reviewing the impacts
of about 85 existing and proposed landfills in various areas of the US and Canada. Additional
information on the authors' qualifications and experience on the matters addressed in these
comments is provided on their website, www.gfredlee.com, in the "About G. Fred Lee &
Associates" section at http : / /www.gfredlee.com /gflinfo.html.
Overall Issues of Protection Provided by "Dry- Tomb" -Type Subtitle D Landfills
Following the approach set forth by the US EPA, many state landfill regulatory agencies allows the
development of "dry- tomb" -type solid waste landfills that, while giving the appearance of being
protective, actually pose predictable threats to the health, welfare, and interests of those who
own /use property in the sphere of influence of the landfills, as well as to groundwater resources and
other aspects of environmental quality in the sphere of influence of the landfills. The sphere of
influence can extend for several miles from a landfill. The superficiality of the protection
provisions enables the disposal of wastes for costs to waste generators including the public far at
less than those which would be required to provide for true long -term protection of public health
and environmental quality for as long as the wastes in the landfill represent a threat. While the
current approach leads to cheaper- than - real -cost initial solid waste management for the waste
generators, in the long term it will be very costly to future generations who will have to pay the
balance in monetary resources, public health and environmental compromise, lost resources, and
"Superfund- like" cleanup of polluted groundwater.
Today's "dry- tomb" -type landfills typically incorporate plastic sheeting and clay liners, and low -
permeability covers at closure in an effort to keep the buried wastes dry. The principle of the
design approach is that if the wastes are kept dry, bacterial decomposition of organic matter and
solubilization /leaching of waste components will not occur, and thus leachate and landfill gas
should not be generated. However, as moisture enters the wastes, these processes will occur, and
gas and leachate will be generated. Well- designed, installed, and maintained engineered
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containment features of "dry- tomb" -type landfills — the cover, liners, and leachate collection and
removal systems — can be anticipated to initially provide for isolation of the wastes. However, such
systems are not generally amenable to rigorous and effective inspection and repair; they are buried
beneath surficial coverings or beneath the wastes, themselves. Even with rigorous visual and other
achievable inspection, as those systems age and deteriorate, moisture can be expected to enter the
wastes; leachate containment and management systems can be expected to fail; and leachate can be
expected to pass out of the landfill into the surrounding strata initially at many locations as finger -
like plumes.
Groundwater monitoring systems that are typically incorporated into post - closure care requirements
are inadequate to detect incipient leakage from the landfill before pollution of area groundwater.
Furthermore, chemical parameters analyzed in such monitoring programs include only a few of the
myriad hazardous and otherwise deleterious chemicals that are reasonably expected to be present in
solid wastes, in addition to those that are not yet known or not yet recognized or regulated.
Groundwater contaminated with waste components could be judged "not contaminated" by virtue
of the results of the typical monitoring program yet be unhealthful or unusable for domestic,
agricultural, or other purposes.
It may be expected that in the short -term, permitted landfill "containment" systems that are well -
designed and placed may forestall leachate and gas generation for tens of years and give the
appearance of protecting public health and environmental quality, over time they will deteriorate
and diminish in their effectiveness. As moisture enters the wastes, leachate will be generated and
will eventually begin to escape the containment systems. Leachate can be expected to be generated
as long as there are leachable components buried in the landfill, for hundreds to thousands of years
— effectively forever. A technical discussion of these and related issues, with references to the
professional literature, is provided in our "Flawed Technology" review:
Lee, G. F., and Jones -Lee, A., "Flawed Technology of Subtitle D Landfilling of Municipal
Solid Waste," Report of G. Fred Lee & Associates, El Macero, CA, December (2004). Updated
July (2011). http: / /www.gfredlee.com/ Landfills /SubtitleDFlawedTechnPap.pdf
We periodically update our "Flawed Technology" review with new and emerging information and
commentary; the page and section references that are given in this report refer to the July 2011
update of the review, which is the version that presently appears on our website. When our review
is updated in the future, the page references that appear in this paper may no longer be accurate, but
they should be close to the proper pages in the updated reviews.
Some state landfill regulatory agencies require that private developers of certain types of landfills
(ash, C &D and industrial) provide post - closure monitoring and maintenance for only 20 years. As
noted above, a well- designed, constructed, and maintained landfill may well be able to prevent
leakage of leachate and gas collection for 20 or more years, and evidence of leakage that does occur
may be obscured for decades owing to inadequacies in allowed groundwater monitoring programs.
Even if leachate and gas generation were to be prevented during the post - closure period, two
decades is a very small part of the period during which landfilled wastes are a threat to cause
environmental pollution through the release of waste - derived constituents in leachate and landfill
gas. Limiting the responsibility of a private landfill developer for post - closure monitoring,
maintenance, and remediation to 20 -30 years virtually ensures that the real problems caused by
landfilling of wastes and the associated costs, in addition to perpetual routine maintenance and

monitoring, will be passed on to parties who did not share in the profits of the landfilling operation.
Likewise, if the fees charged to those who deposit wastes in a landfill are not sufficient to provide
reliable and adequate funding for perpetual care of the landfill and remediation of public
health /welfare and environmental quality impacts of the landfill ad infinitum, the waste generators
are benefitting from less expensive waste disposal and are also passing the balance of the costs on
to the state /county and local political jurisdiction.
For some types of landfills, state /county could require that the host county assume very large
financial obligations for perpetual post - post - closure landfill care (monitoring, maintenance and
groundwater remediation) should the private landfill developer fail to provide this care without their
being a reliable enforced mechanism for collecting adequate funds from the landfill owner and
waste generators during the active life of the landfill to cover the post - post - closure funding needs;
after closure, there is no income stream from the landfill. That approach could in effect relieve the
private landfill developer /owner from long -term financial responsibility for protection of public
health and the environment and places the real financial responsibility for the landfill and its
consequences onto the state /host county /community.
The growing understanding of the inability of today's "dry- tomb" -type landfills to provide reliable,
ad infinitum protection of public health /welfare and environmental quality from adverse impacts
from landfilled wastes, and the transfer of the long -term financial consequences of landfills to the
public lead to justified NIMBY ( "not in my backyard ") attitudes by nearby property owners /users;
virtually everyone becomes a NIMBY when faced with the prospect of having a landfill sited
nearby. A discussions of issues associated with justified NIMBY begin on page 65 of our "Flawed
Technology" review; a summary of key concerns with today's "dry- tomb" -type landfills, including
those that contribute to justified NIMBY attitudes, is presented below.
Summary of Key Dry -Tomb Landfill Technology Flaws
Landfill Location (Siting)
Current federal and state landfilling regulations do not restrict the siting of landfills based on the
degree of "natural protection" provided by the underlying geological strata or on the presence or
utility of waters down - groundwater gradient from the landfill. Landfills located in hydrogeological
areas that are sandy and will thus allow fairly rapid transport of liquid downgradient from the
landfill (a foot or so per day). Such areas and many other less permeable strata provide essentially
no natural protection of groundwater quality from leachate that penetrates through the landfill liner.
Thus, when the liner in a dry tomb type landfill fails to collect all leachate that is generated in the
landfill, off -site groundwaters will be polluted by chemicals derived from the wastes in the landfill.
(See "Flawed Technology" review page 64 for further discussion of this issue.)
Landfill Design
Subtitle D type landfills are designed as "dry- tomb" -type landfills. The "dry- tomb" -type landfilling
approach was first adopted in the early 1980s by the federal congress at the suggestion of
environmental groups. Because bacterial decomposition of organic matter with production of gas,
and the leaching of waste components both require moisture, "dry tomb" landfills were conceived
as a way to keep wastes "dry;" the belief was that if the wastes were kept dry, no leachate or landfill
gas would be generated. However, it was recognized in the technical community at the time the
regulations requiring "dry- tomb" -type landfills were promulgated by the US EPA in the early
il

1980s, and is now widely recognized, that in practice the approach has serious flaws; it only serves
to postpone release of waste - derived constituents to the environment. A "dry- tomb" -type landfill
relies on a cover to keep moisture out of the landfill, and a liner system to contain leachate that is
generated and allow it to be removed so it does not migrate to groundwater. Also incorporated is a
groundwater monitoring system intended to ensure that leachate has not migrated to offsite
groundwater downgradient from the landfill.
Liners. The liners in minimum design landfills allowed in Subtitle D landfills are single- composite
liners comprised of a layer of plastic sheeting (high density polyethylene — HDPE) and either a clay
layer or a geosynthetic clay liner (GCL). With high quality construction and adequate waste
placement to protect the liners, these landfills can be expected to initially provide for collection of
leachate generated in the landfill to protect groundwater quality. However, there are numerous
factors that preclude this protection's extending for the duration of time that the wastes in the
landfills will be a threat. For example, over time the plastic sheeting layer in the liner will
deteriorate and fail to prevent leachate from entering the groundwater underlying the landfill.
Intrinsic in the clay liner is a finite rate of transport of leachate through it; the rate depends on a
number of factors. (See "Flawed Technology" review pages 9 and 10 for further discussion of this
issue.) The initial leakage of the landfill liner will be through holes, rips, and points of deterioration
that can lead to finger -like plumes that can pass by the monitoring wells undetected. Of particular
concern is liner failure near the down - groundwater - gradient edge of the liner where the lateral
spread of the plume would be the least. (See "Flawed Technology" review page 27 for further
discussion of this issue.)
Landfill Cover. Once a "dry- tomb" -type landfill is closed and no longer accepts wastes, the key to
keeping the wastes dry is the integrity of the landfill cover. The typical Subtitle D landfills have
standard US EPA Subtitle D landfill covers consisting of a soil base that covers the wastes, overlain
by a thin plastic sheeting layer of low density polyethylene, overlain by a soil layer and a top soil
layer. In principle, water that penetrates the top soil layer of the cover will be conveyed to the edge
of the landfill on the plastic sheeting layer and therefore not enter the wastes. As discussed in the
"Flawed Technology" review, if this type of landfill cover is constructed properly it should have the
ability to prevent water that falls on the landfill surface as rain or snow melt from entering the
wastes when the cover is new. However, over time the plastic sheeting layer will deteriorate in its
ability to prevent water from penetrating the cover; as that water contacts the landfilled wastes,
leachate and landfill gas will be generated. A variety of factors can cause compromises in the
ability of the plastic sheeting layer in the cover to prevent entrance of water into the wastes.
Differential settling of the waste will put additional stress on the plastic sheeting layer, which would
tend to increase the rate of deterioration. Ultimately, the plastic sheeting layer will succumb to free
radical attack. Such attack can be much more pronounced and significant in the cover layer than in
the bottom liner because of the proximity of the surface plastic sheeting layer to the atmosphere
where oxygen, the source of the free radicals, is present.
Landfill permits carry requirements for visual cover inspection and repair of defects. However,
breaches of the low permeability layer of the cover can occur in many ways that are not readily
visible. Further, deterioration of the integrity of the plastic sheeting layer is not visible from the
surface of the landfill since it is buried under the top soil and other soil /drainage layers above the
plastic sheeting. The presence of leachate in the leachate collection system after the landfill has

been closed is evidence that the landfill cover has not been properly installed. The appearance of
leachate in the leachate collection system after a period of there being none, is evidence that the
integrity of the plastic sheeting layer of the cover has deteriorated and needs to be repaired.
Even if it is found that the cover is allowing moisture to enter the landfill, identification of the areas
of breach in the plastic sheeting layer of the cover, and the repair of those areas will not be easily
accomplished because the plastic sheeting layer is not visible from the surface of the landfill.
Further, since many landfills have a single sump for collection of all leachate generated in the
landfill, it will not be possible to even isolate a part of the landfill cover that has deteriorated to the
point at which it is allowing sufficient water to enter into the landfill waste to generate leachate.
Considerable exploratory work will have to be done by the landfill owner during the post - closure,
and by the state /county during the post - post - closure period to find all areas of the cover that have
deteriorated to the point of allowing sufficient water to enter waste and generate leachate. This
could make the cost of repairing the cover considerably greater than the cost of replacing the plastic
sheeting layer that has deteriorated.
Landfill developers such as Waste Management, Inc. have made assertions that a landfill owner's
obligation to provide post - closure care should terminate once the cover is installed and leachate
generation that occurred before covering has ceased. Such an assertion ignores the fact that over
time the integrity of the plastic sheeting layer will deteriorate and allow water that reaches the
plastic sheeting layer to enter the wastes. While the rate of deterioration of the integrity of the
plastic sheeting layer in a landfill cover depends on a variety of factors, as with the landfill liner the
plastic sheeting layer will ultimately fail to prevent water from penetrating through the plastic
sheeting layer. (See "Flawed Technology" review page 20 for further discussion of this issue.)
Landfill permit applications mention that the HELP model was used to estimate the rate of leachate
generation in the closed landfill. While that model can provide useful information when applied to
a landfill with a new, well- designed and well - constructed cover, its reliability diminishes for
assessing leachate generation over time. It does not reliably account for the deterioration of the
integrity of the plastic sheeting layer and the much greater amounts of water that will be allowed to
enter the wastes and generate leachate as well as landfill gas. While this deficiency is readily
recognized by examining the components of the HELP model, it is routinely ignored by landfill
consultants and the regulatory agency staff that review landfill permit applications. State landfill
regulatory agencies' staff allowed the landfill owners to develop post - closure funding estimates
without adequate provision for funds for repair of the plastic sheeting layer in the cover.
Leachate Collection System. Leachate collection systems included in Subtitle D landfills rely on an
intact liner along which leachate would flow to a sump. Leachate collects at the sump to a point at
which it gets pumped from the landfill. Over time, however, areas in the leachate collection system
will become increasingly plugged with accumulations of chemical precipitates and physical
blockages within the collection system, which will impede or halt the flow of leachate to the sump.
These blockages will create areas of pooling of leachate on the upgradient side of the blockage,
which will increase the head (depth of leachate) on the liner, which, in turn, can diminish the
expected efficacy of the liner. Leachate leakage through areas of deterioration or holes in the liner
will be enhanced by the increased head. Because the leachate collection system is located beneath
the buried wastes, it is not subject to thorough routine inspection and repair. As the leachate
no

collection system deteriorates, increased leakage of leachate from the landfill can be anticipated and
will have to be addressed as increased pollution of groundwater.
Lysimeter Liner Leak Detection. Some landfills include a "lysimeter" liner leak detection system.
This system consists of a small HDPE /clay liner under the leachate sump where the leachate
collects before being pumped to the surface, and is intended to enable early detection of a failure of
the landfill liner at that location. Locating the Lysimeter under the sump is somewhat justified
because, with an intact liner, the sump area is the site of the greatest depth (head) of leachate, and
the rate of leachate passage through a hole in the liner is proportional to the depth of leachate above
the hole. However, it will not identify and warn of leachate build -up and leakage at sites of
blockage in other areas of the liner system. The very limited number of specific areas known to be
vulnerable to liner failure at which lysimeters may be incorporated can be expected to comprise a
small portion of the areas at which, over time, the landfill liner will deteriorate and allow leachate to
pass through it into underlying clay liner system. A far more reliable approach for detecting the
deterioration and failure of the composite liner would be to incorporate a second composite liner
with a leak detection system between the two liners throughout the bottom of the landfill. Such a
double- composite liner system is already being used in several states, including Michigan. (See
"Flawed Technology" review page 33 for further discussion of this issue.)
Landfill Gas Management
MSW landfills and some other types of landfills contain organic wastes that through bacterial action
produce landfill gas. This gas is primarily methane and carbon dioxide. Methane is a gas that can
explode and cause fires. MSW landfill gas contains highly obnoxious odorous chemicals that at
times without adequate control can be detected by smell at several miles from the landfill. MSW
landfill gas also contains VOCs that are a threat to human and animal health through causing
cancer. MSW landfills should be constructed with landfill gas collection systems that are effective
in collecting and treating the landfill gas to destroy the methane and VOCs. A landfill gas
collection piping system should be constructed in the area of the leachate collection system to
collect all landfill gas that is present in this area to prevent it from migrating through the landfill
liner. This migration can occur through intact liners without holes by diffusion. A landfill gas
management system needs to be operated and maintained for as long as the wastes in the landfill
can generate landfill gas when contacted by water. MSW has a very large potential to pollute
groundwater with a variety of hazardous and otherwise deleterious chemicals. Our "Flawed
Technology" review contains an extensive discussion of the pollution of groundwater by MSW
landfill gas and information on managing landfill gas to protect public health and the environment
beginning on page 39.
End of Postclosure Care
Neither the states nor the US EPA provides guidance on how to determine when postclosure care
can be ended without compromise of public health /welfare or environmental quality. While a 30-
year postclosure care period is typically incorporated into landfill permits, landfills will continue to
pose a threat to public health /welfare and environmental quality until such time that the wastes in
the landfill can no longer generate leachate that could cause groundwater pollution and /or release
landfill gas. As suggested in our "Flawed Technology" review a reasonable approach to
determining an appropriate endpoint for postclosure care could be to collect representative samples
7

of the wastes from throughout the landfill and properly expose them to water; if the wastes do not
produce gas or leachate that could impair the use of groundwater or surface water for domestic or
other purposes, including animal water supply, a compelling argument could be made for cessation
of postclosure care. However, protocols for collecting an adequate number of truly representative
samples of the landfilled wastes for this purpose and for reliable evaluation of gas /leachate
production potential do not exist; existing protocols used for assessing leaching potential of wastes
are known to be unreliable. Furthermore, commonly used "indicators" of the "quality" of
groundwater, e.g., comparison with MCL levels for a limited list of "pollutants" is not reliable for
assessing the impairment of groundwater quality. States and /or the US EPA need to develop a
protocol to make reliable, objective evaluations of when postclosure care can be terminated without
compromising long -term protection of public health /welfare and environmental quality.
The postclosure period during which the wastes continue to present a threat to public health /welfare
and environmental quality can be very long (decades to hundreds of years or more) depending on
how well the wastes are kept dry. Because dry -tomb landfilling does not render the buried wastes
innocuous, the longer the wastes are kept dry, the longer the postclosure care period needs to be.
On page 57 of the "Flawed Technology" review, the potential for construction and demolition
(C &D) wastes to generate leachate that can pollute groundwater with chemicals that are hazardous
and /or otherwise detrimental to the use of the groundwater is discussed. As with MSW, burying
C &D wastes in a dry -tomb landfill does not render them innocuous; the longer they are kept dry,
the longer groundwater pollution may be postponed. Unless demonstrated otherwise by site -
specific studies the C &D landfills of interest should be considered to represent very long -term
threats to pollute groundwater.
Overall, in time, all minimum design landfills of the type allowed by US EPA Subtitle D
regulations, that are located in areas where the underlying geology /hydrology does not provide
natural protection, will pollute groundwater under the landfill. It is not known when that pollution
of groundwater will occur; it could occur within a few years of waste deposition at the landfill or
may be delayed for many years, decades, to hundreds of years or more depending on the quality of
liner construction and other site - specific factors. From the perspective of post - post - closure care
funding, it should recognized that evidence of groundwater pollution may well be delayed past the
period during which the landfill owner has financial responsibility, and if possible prepare to fund
the post - post - closure care and groundwater remediation.
Groundwater Monitoring
The groundwater monitoring programs that states typically permit for landfills involve vertical
monitoring wells spaced hundreds of feet apart near the edge of the landfill liner, with each well
capable of sampling water within only about one foot of the well. Since initial leakage of the
landfill liner will be through the holes, rips, and points of deterioration that can lead to finger -like
leachate plumes, the monitoring regimen will leave hundreds of feet between each down -
groundwater- gradient well through which leachate- polluted groundwater can pass without being
detected by the monitoring wells. While as discussed in the "Flawed Technology" review this
fundamental deficiency in conventional groundwater monitoring programs at landfills has been
well -known for decades, the states and US EPA are still allowing such monitoring programs that

have little likelihood of detecting groundwater pollution when it first occurs as required in Subtitle
D regulations. Of particular concern is liner failure near the down - groundwater - gradient edge of
the liner from which there would be the least lateral spread of the leachate plume. (See "Flawed
Technology" review page 27 for further discussion of this issue.) The reliability of the groundwater
monitoring program that is developed as part of the permitting of a landfill is a key issue in
determining the magnitude of the cost of groundwater remediation..
Inadequate Buffer Land
Adequate landfill- owner -owned buffer land between waste deposition areas and adjacent properties
is essential in order to provide a reasonable opportunity for dissipation of gaseous emissions /odors
and attenuation /dilution of polluted groundwater before either trespasses onto adjacent and nearby
properties. The greater the amount of such buffer land the greater the attenuation /dilution of waste -
derived pollutants that can occur in groundwater beneath landfill- owner -owned property before the
polluted groundwater trespasses to adjacent properties. In a sandy aquifer system pollutants
released from an MSW landfill may be attenuated /diluted to levels below those of water quality and
environmental quality consequence within a mile or two of the landfill. However, many landfills
are developed with only few tens of feet between waste deposition areas and adjacent properties.
This provides very limited opportunity for dilution /attenuation of polluted groundwater under the
landfill before it trespasses onto adjacent properties. The very limited buffer lands at Subtitle D
landfills means that the state, county, and /or local political jurisdictions face having to address
significant off -site groundwater pollution on nearby properties.
The minimal buffer lands at landfills also provide minimal opportunity for dissipation of landfill
gas before it trespasses onto adjacent properties. MSW landfill odors have been found to travel a
mile or more from the landfill. As discussed in the "Flawed Technology" review, hazardous
chemicals in MSW landfill gas pose a significant public health threat. It has also been well -
established that MSW landfill odors cause illness in some individuals. Gas released from landfills
sited without adequate buffer lands can be expected to trespass onto adjacent and nearby properties
and threaten public health and welfare because of hazardous chemicals in the gas and the odors of
the gas. (See "Flawed Technology" review page 66 for further discussion of this issue.) The
amount of buffer land between waste deposition areas and adjacent properties, especially those
down - groundwater - gradient, affects the cost of remediation of leachate- polluted groundwater.
Plastic- Bagged Wastes
MSW landfills accept MSW that is bagged in plastic. Plastic bags that are only crushed by
compaction equipment during disposal tend to hide associated wastes from moisture that is present
early in the landfilling process. This shielding of pockets of waste throughout the landfill from
moisture can be expected to delay the fermentation of organics and leaching of those waste residues
and associated formation of gas and leachate from them beyond the time that landfill gas and
leachate generated could be managed by the new or well- maintained liner and gas management
system. This delay can also contribute to the misleading appearance of cessation of gas and
leachate production in the landfill when, in fact, gas and leachate production can be expected to
resume as the plastic bags eventually deteriorates sufficiently over decades or centuries, well after
the state /county has assumed responsibility for funding maintenance and remediation. (See
"Flawed Technology" review page 39 for further discussion of this issue.)
I

Key Issues Not Adequately Addressed in Subtitle D
Stormwater Runoff Water Quality Impacts
It has been our experience that stormwater runoff from landfill areas is often inadequately
monitored for occurrence, and especially impacts on water quality. Attention to the occurrence of
stormwater runoff is especially important at landfills at which leachate has been used for dust
control. (See "Flawed Technology" review page 43 for further discussion of this issue.)
Surface Water Impacts
Groundwaters beneath some landfills enter surface waters indirectly via spring discharges, or by
direct discharge. Leachates from MSW and other types of landfills contain chemicals that can
adversely affect aquatic life; in fact, aquatic life can be much more sensitive to adverse impact from
some chemical than are humans who drink the water. Even if landfill- derived pollutants
transported via groundwater to a large river of other waterbody, and the pollutants in the polluted
groundwater are sufficiently diluted by the waterbody to prevent them from causing water quality
problems in the waterbody overall, they could adversely impact nearshore aquatic life in areas
where the leachate- polluted groundwater enters the waterbody. Concentrations of landfill- derived
pollutants and conservative components should be monitored along the flow path of leachate-
pollution plume to determine if they are diluted /attenuated to inconsequential levels prior to the
groundwater's reaching a surface waterbody.
Full Range of Domestic Water Supply Pollutants
The very limited extent of buffer land between waste deposition areas and adjacent property lines
for most MSW landfills makes it highly unlikely that there will be significant dilution /attenuation of
landfill- derived pollutants in the groundwaters beneath the landfills of interest to the state /county or
other local jurisdiction. This means that off -site groundwater pollution can be expected. The
current groundwater monitoring required by states for the landfills focus on chemicals with
regulatory limits for primarily chemicals of human health concern in drinking water. In addition to
those chemicals there is a wide variety of other hazardous and otherwise deleterious and obnoxious
chemicals in MSW, C &D wastes, and ash, and leachates from those landfilled wastes that can
pollute groundwater to impair its use for domestic and other purposes. There can be expected to be
chemicals that are currently unknown, unrecognized, unmeasured, or unregulated but that can be
reasonably expected to adversely affect human health and welfare. In addition, other chemicals of
concern include those that cause taste and odors, salts, and others, which while not necessarily
considered to be "hazardous," can render groundwater unusable for domestic and some other
purposes. Even if the groundwater monitoring program were adequate for characterizing leachate
migration, it would be inappropriate for a regulatory agency to determine that a landfill leachate is
not polluting groundwater on the basis of the finding that none of the measured constituents MCLs
are exceeded in samples of groundwater. Groundwater monitoring for the landfills of interest to the
state /county should be expanded to include all parameters that can impair the use of groundwater
for domestic and other purposes.
Isolating the Landfill from Flood Waters
If dikes are used to try to prevent flood waters from entering the area of the landfill, postclosure
care should include thorough, independent, yearly inspection of the dikes to check on the adequacy
10

of maintenance by the landfill owner to repair cracks, and other defects caused by burrowing
animals, plant roots, etc.
Deed Restrictions and Future Land Use
Each closed MSW landfill should have a deed restriction on future land use and activities to prevent
uses /activities that would disrupt or interfere with the functioning or integrity of the landfill cover
and monitoring system. Typically landfill developers claim that once the landfill is closed the
landfill cover area can be put into a beneficial use such as a golf course, park, farm land, wildlife
area etc. For example Waste Management, Inc. has made claims on national TV ads that its closed
landfills make ideal wildlife habitat, and sites for golf courses and public recreation areas including
dirt bike trails. Such claims appear in its "Think Green" campaign at http: / /www.thinkgreen.com/ in
its discussion of `Beneficial Land Reuse," as well as in a number of television advertisements. It
cites locations at which such reuse has been made of landfill cover areas. The unmistakable
implication is that the public should not be concerned about the potential long term threats to public
health, groundwater and surface water quality, or to wildlife, at a closed landfill. However, as
discussed by Lee and Jones -Lee paper entitled, "Closed Landfill Cover Space Reuse: Park, Golf
Course, or a Tomb ?" many of the touted reuse activities atop closed landfills are ill- advised at best,
and such implications are highly misleading. One reason for this is that many of the land
"enhancements" and activities being promoted stand to damage the integrity of the landfill cover
upon which the integrity of the landfill containment system depends. As discussed elsewhere
herein, in order to prevent formation of landfill gas and leachate that will eventually escape the
landfill containment, the wastes must be kept dry. Placing water features such as ponds, wetlands,
idyllic streams, or water hazards on a golf course, or deep- rooted vegetation such as trees and
shrubs, atop or in close association with landfill covers promotes entrance of moisture into the
cover.
A plan for effective ad infinitum implementation of the deed restrictions needs to be in place to
ensure that future agencies responsible for implementation of the deed restriction adequately
implement its requirements. At no time in the future should uses be permitted on the area of the
landfill cover that include addition of irrigation water to the surface of the landfill. Severe land use
restrictions should be enforced for as long as the wastes in the landfill when contacted by water can
generate leachate /landfill gas.
Post - Closure and Post - Post - Closure Care Funding
The landfill permit applications and some operations reports provide a "standard" listing of post -
closure care (monitoring and maintenance) activities and associated projected costs over the post -
closure care period. The annual post - closure funding over the 30 years appears to be established
based on prior years' estimates, multipliers, and adjustments for estimated rates of inflation.
A rudimentary estimate of amount of money that the state /county will need to spend for post -post-
closure care in year -31 and beyond after landfill closure can be made based on the estimates of
year -30 post - closure funding provisions. To the estimate based on the minimal monitoring and
maintenance of the landfill covered by the year -30 -based estimate must be added costs of
addressing readily anticipated problems such as the repair of the landfill cover as the landfill starts,
or continues, to generate leachate. Typically the landfill owners are not required to provide assured
funding for repair of the cover should that be required during the 30 -year post - closure period; the
11

cover will unquestionably need repair /replacement during the post - post - closure period. Landfill
cover repair will be required periodically over the time that the wastes in the landfill will be a
threat.
Another major issue that can be anticipated, but is not typically included in post - closure care cost
estimates, is remediation of polluted groundwater. Funding for remediation of polluted
groundwater and dealing with consequences of polluted aquifers can be expected to be needed
during post - post - closure. Again, over the very long period of time during which the wastes in the
landfills will be a threat to generate leachate that have been required to post contingency funding in
the form of a Surety Bond, Performance Bond, or other source of funding for unexpected
expenditures. There is need to understand how regulatory agencies establish the contingency
funding levels for the landfills. It is often not clear how these funds can be used, if at all, by county
or other agency or whether they are reserved for use by the state in the event the landfill owner fails
to meet its obligations during the operating and monitored 30 year post - closure period. Such
contingency funding should be required for the period of time that the wastes in a landfill can
generate leachate when contacted by water which will be well beyond the 30 year period of funded
postclosure care.
County Host Fee. Landfill owners provide the county /local jurisdiction with permit and host fees of
a specified amount per ton of waste deposited. These fees are only paid during the active life of the
landfill, while wastes are being deposited. The landfill owners pay for post - closure care from funds
they have generated during the active life of the landfill. The state /county /local political
jurisdiction may need to fund post - post - closure care from the host fees it accumulated during the
active life of the landfill, and other unspecified sources as necessary. This approach will greatly
increase the amount of host fees that need to be paid to the local community /county to cover post
postclosure funding needs.
Post- Postclosure Funding. An issue that will need to be addressed is whether or not the
state /county administration has an understanding of long -term funding issues. From a public
health /environmental quality perspective, the period during which post - post - closure care will be
required for the landfills in may be indefinite; the issues that will inevitably need to be addressed
during the post - post - closure period at the closed landfills are enormous. The state /county /local
community should collect sufficient host fees during the landfill active life of the landfill to
establish a trust fund of sufficient magnitude to generate adequate annual interest during the post-
closure and post - post - closure period to enable the state /county to pay for post - post - closure care and
contingencies that will likely occur. This will place the financial responsibility for waste
management more on those who generate and deposit the wastes in the landfill and potentially less
on those who happen to reside in the county and area of the landfill for decades or centuries into the
future.
A number of years ago, the Barons financial newsletter carried an article about the long -term
liability associated with post - closure care of landfills developed by private companies under US
EPA Subtitle D regulations. While those regulations obligate private landfill companies to provide
assured funding for 30 years after closure of the landfill, they also contain a provision by which the
US EPA Regional Administrator may determine that post - closure care must continue for as long as
the waste in the landfill are a threat. For example, the California landfilling regulations, in theory,
12

obligate the landfill owner to provide post - closure care for as long as the waste in the landfill are a
threat to pollute groundwater, i.e., impair its use for domestic or other purposes. California has
recently adopted regulations that require landfill owners to provide post closure care funding for
100 years which can be extended.
Characteristics of the Pollution Potential of Solid Wastes Landfills
MSW Landfills
MSW has a very large potential to pollute groundwater with a variety of hazardous and otherwise
deleterious chemicals. Our "Flawed Technology" review contains an extensive discussion of the
pollution of groundwater by MSW.
Electric Generation Ash Landfills
Some landfills receive that electric generating station combustion wastes (ash) that arise from
burning coal. Considerable attention was paid to potential environmental pollution by coal ash
residues following the failure of a large TVA coal ash pond several years ago near Kingston, TN.
"Earth Justice" published a report entitled, "Coal Ash Pollution Contaminates Groundwater,
Increases Cancer Risks," on September 4, 2007 that is available at:
[http://earthjustice.org / news /press/ 2007 /coal- ash - pollution- contaminates - groundwater- increases-
cancer- risks]. It summarizes the results of a report issued by the US EPA entitled, "Human and
Ecological Risk Assessment of Coal Combustion Wastes," Draft report prepared by RTI for U.S.
Environmental Protection Agency, Office of Solid Waste, Research Triangle Park, NC August 2007
[http://earthjustice.org / sites /default /files /library/ reports /epa- coal - combustion- waste -risk-
assessment.pdf]
That incident was also addressed in a report to Congress:
Luther, L., "Managing Coal Combustion Waste (CCW): Issues with Disposal and Use,"
Congressional Research Service report for Congress, January 12 (2010).
[http://www.fas.org/sgp/crs/misc/R40544.pdfl
that provides a summary of potential impacts of coal combustion wastes. That report states,
"...the primary concern regarding the management of CCW usually relates to the potential for
hazardous constituents to leach into surface or groundwater, and hence contaminate drinking
water, surface water, or living organisms. The presence of hazardous constituents in the waste does
not, by itself, mean that they will contaminate the surrounding air, ground, groundwater, or surface
water. There are many complex physical and b iogeochem icalfactors that influence the degree to
which heavy metals can dissolve and migrate offsite such as the mass of toxins in the waste and
the degree to which water is able to flow through it. The Environmental Protection Agency (EPA)
has determined that arsenic and lead and other carcinogens have leached into groundwater and
exceeded safe limits when CCW is disposed of in unlined disposal units."
That report also states that the concerns about CCW management generally center around a number
of issues including:
• The waste likely contains certain hazardous constituents that EPA has determined pose a risk to
human health and the environment. Those constituents include heavy metals such as arsenic,
beryllium, boron, cadmium, chromium, lead, and mercury, and certain toxic organic materials
such as dioxins and polycyclic aromatic hydrocarbon (PAH) compounds.
13

• Under certain conditions, hazardous constituents in CCW migrate and can contaminate
groundwater or surface water, and hence living organisms. For example, EPA determined that
the potential risk of human exposure to arsenic and other metals in CCW (via the groundwater -
to- drinking -water pathway) increased significantly when CCW was disposed of in unlined
landfills. That risk criterion was slightly higher for unlined surface impoundments. "
US EPA minimum- design, single- composite liner and conventional groundwater monitoring wells
spaced hundreds of feet apart, in time the leachate generated in that landfill can be expected to
pollute groundwater with hazardous and otherwise deleterious chemicals.
Refuse- Derived Fuel (RDF) Ash Landfills
Some landfills receive refuse - derived fuel (RDF) ash from the combustion of MSW.
Characteristics of such wastes were described by Hasselriis and Aleshin:
F. Hasselriis, and E. Aleshin "How Residues from Waste to Energy Plants Can Be Used
Safely," Presented at the ASTSWMO Conference, Los Angeles, CA, September (1986).
[http://www.seas.columbia.edu/ earth /wtert/sofos /hasselriis /Abstracts %20 -
%20Hasselriis%20Presentations.pdf]
They stated in the abstract of that paper:
"As the use of combustion as a means of reduction of municipal solid waste increases, methods for
safe disposal of increasing amounts the flyash and bottom ash residues must be provided.
Incinerator ash has been used beneficially for landfill cover, construction fill, highway
construction, and as aggregate for concrete. However, while these residues contain mainly benign
materials similar to natural earth, they also contain heavy metals which, depending upon the
disposal method, might be leached out and result in contamination of the groundwater. Whether or
not these metals could be leached out under the conditions of disposal depends on the chemical
form of the metals. Ash residues appear to have sufficient alkalinity, or buffering ability, to resist
acid rain when stored in ashfills, while the metals are slowly leached out producing leachates with
low metals concentrations. "
C &D Waste Landfills
Our "Flawed Technology" review (beginning on page 57) discusses the potential for C &D wastes
to cause groundwater pollution. There it is stated,
"Potentially significant concentrations, compared to drinking water maximum contaminant
levels (MM), were found of], 2- dichloroethane, methylene chloride, cadmium, iron, lead,
manganese and total dissolved solids (TDS) " have been found in C & D waste leachate." They
report that "Constituents causing groundwaters to exceed the drinking water MCL were iron,
manganese, TDS and lead."
"An issue of increasing concern about waste wood is the potential for treated wood to leach
arsenic, copper and chromium. Townsend and his associates at the University of Florida have
conducted a number of studies on the leaching of these chemicals from treated wood. "
It has also been recently found that some C &D wastes contain PCBs from caulking that was once
used in buildings and other structures. Studies have shown that the demolition debris from old
buildings can contain PCBs that can be released to the environment.
14

While the composition of C &D waste leachate can be somewhat variable depending on the type and
source of C &D wastes deposited in the landfill, in general that type of waste can contain a variety
of potential pollutants that are a threat to pollute groundwater with a hazardous and otherwise
deleterious chemicals.
Industrial "Non Hazardous" Wastes
Some landfills receive "non- hazardous "industrial wastes." The potential for these wastes to cause
groundwater pollution is unknown at this time and requires site specific studies.
Leachate Recycle and Fermentation /Leaching Approaches
Our "Flawed Technology" review includes a summary of the use of leachate recycle and leaching to
enhance the fermentation and leaching of MSW to shorten the period during which the buried
wastes are a threat. As discussed in the paper cited below, MSW that has been shredded and
exposed to leachate can be converted to a residue that no longer will produce landfill gas. This
should be able to be accomplished in about 5 to 10 years provided that the leachate is evenly
distributed and is adequate to ferment the wastes. At the end of landfill gas generation, clean water
(e.g., local groundwater) should be added to the landfilled wastes to leach the readily leachable
components of the remaining residues in the wastes. Leaching should be repeated until the leachate
is of such a character that it would not represent a threat to groundwater. The leaching water should
not be recycled through the waste but rather properly treated before discharge to the environment.
(See "Flawed Technology" review page 78 for further discussion of this issue.)
Lee, G. F. and Jones -Lee, A., "Landfills and Groundwater Pollution Issues: 'Dry Tomb' vs F/L
Wet -Cell Landfills," Proc. Sardinia'93 IV International Landfill Symposium, Sardinia, Italy, pp.
1787 -1796, October (1993).
http: / /www.gfredlee.com /Landfills/ Fermentation - Leaching- Sardinia.pdf
It is important to understand that the fermentation /leaching approach discussed above differs
significantly from today's "leachate recycle." For example, the fermentation /leaching approach
stipulates that the wastes be shredded to reduce the "hiding" of MSW in plastic bags (which are
only crushed in conventional landfilling) so that wastes are more fully and reliably exposed and
subjected to fermentation and leaching. The fermentation /leaching approach also subjects the
fermented wastes to sequential leaching with clean water, such as a local groundwater; that step is a
key to removing residual potential pollutants that could otherwise leach from the fermented wastes
and escape the landfill to pollute groundwater. The practice of fermentation /leaching of wastes
should be restricted to properly designed and constructed double- composite -lined landfills that
incorporate leachate detection systems between the two composite liners. That arrangement better
enables the detection of compromises in the integrity of the upper composite liner to the point at
which it no longer collects all the leachate generated in the landfill, at a time when the bottom liner
still protects groundwater quality. Early detection of compromise of the upper liner provides the
opportunity for termination of leachate recycle and early repair of the cover for better groundwater
protection. Conducting leachate recycle in a single- composite -lined landfill, as is allowed today,
can lead to increased groundwater pollution because of the increased amount of liquid in the landfill
that has the potential to penetrate the liner and move to the groundwater without being detected by
the groundwater monitoring wells that are typically used in today's subtitle D landfills. Increased
15

depth of leachate (head) on the liner will also increase the rate of leachate migration through the
liner (See "Flawed Technology" review page 28 for further discussion of this issue.)
For ash and C &D landfills that do not include fermentable waste components and thus do not
generate landfill gas, leaching of the wastes with clean water should be practiced to remove the
leachable components that are a threat to pollute groundwaters. Of particular concern is the high
salt content of ash landfill leachate. C &D waste landfills that receive tree stumps and other
vegetative debris will produce not only landfill gas but also hydrogen sulfide gas through
interaction with calcium sulfate in wallboard. At this time it is unclear how long wastes in ash
landfills as well as some other types of landfills, such as industrial solid "non- hazardous" waste
landfills, would leach chemicals that have the potential to pollute groundwater, impairing its use for
domestic and other purposes. This will need to be evaluated on a site specific basis to understand
the long -term threat posed by the ash residuals and potential benefits to be derived from leaching of
ash with this process.
Need for Independent Third -Party Monitoring /Surveillance
For a variety of reasons including inadequate funding, regulatory agencies do not provide
sufficiently diligent postclosure and post - postclosure monitoring, inspection, and /or supervision to
ensure, with a high degree of certainty, that public health /welfare and environmental quality are
protected from adverse impacts from landfills. As a supplement to the regulatory agency
inspection, the landfill owner should provide funds to those in the sphere of influence of the landfill
to hire an independent consultant to conduct an independent oversight review and to report findings
to the nearby property owners /users and the regulatory agencies.
One of the components of the ongoing postclosure oversight should be a review of the literature of
recent findings of new, previously unrecognized, and unregulated potential pollutants to determine
if the water quality and air quality monitoring programs need to be expanded to include additional
chemicals that are not included in the current monitoring program. For example, as discussed in
our "Flawed Technology" review, there are numerous examples of what had been previously
unrecognized pollutants in MSW — such as PPCPs, flame retardants, pesticides /herbicides used
around the home /commercial establishments and industry — being found in MSW leachate. Such
chemicals, not included in the typical groundwater monitoring program for MSW landfills, would
need to be added to the monitoring regimen. There is need to have an ongoing review of the
adequacy of the groundwater monitoring program parameters, as well as analytical detection limits
relative to concentrations of concern, to keep it up -to -date with the current knowledge about
chemicals that are a threat to cause water pollution.
As part of postclosure care landfill owners should fund independent, periodic (at least semiannual)
monitoring of all offsite groundwater wells, including those used in agriculture and for animals)
located within several miles of the landfill to determine if landfill leachate components have
reached the well water. This distance may need to be extended in fractured rock aquifer and
cavernous limestone systems to consider that leachate polluted groundwater can travel very long
distances in fractures. The results of the monitoring should be reported to the property owner /user
and the regulatory agency. If MSW leachate has entered the well an alternate water supply source
should be provided, even if the pollutant concentrations are below MCLs, since there could be
unrecognized or unmonitored hazardous chemicals in the well water.
16

Overview of MSW Landfill Development Issues as Related to
Costs of Post - Postclosure Care Costs to Public Agencies
The need for funding provisions for care and remediation of MSW and other types of landfills
during the post - postclosure period, i.e., after the statutory minimum postclosure funding period
expires, has been sorely neglected. Postclosure funding periods are typically established at a given
number of years — e.g., 30 yrs — following formal closure of the landfill in an effort to hold the
landfill owner responsible for aftereffects of the landfilling operation. However, such a postclosure
duration designation has essentially no relationship to the period during which the wastes in the
landfill will pose a threat to public health /welfare or environmental quality.
As discussed herein there are numerous MSW landfill siting, design, operation, closure, and
postclosure issues that state /county and other jurisdictions and public agencies need to evaluate and
address to more reliably define the financial requirements and structure that will be needed to
ensure that the owners of new, privately developed MSW landfills are held responsible for the
totality of landfill monitoring and maintenance, and groundwater remediation for as long as the
wastes in the landfill will be a threat to public health /welfare and environmental quality. The
present practice of cessation of assured postclosure care after a given number of years, irrespective
of the continued threat posed by the landfill ensures that the truly long -term post - postclosure care
costs will be borne not by the waste generators or the landfill owner, but by the public in the
vicinity of the landfill, in money and adverse impacts.
The fundamental problem is that the US EPA Subtitle D MSW landfilling regulations are
inadequate, unreliable, and misleading for the development of MSW landfills that have the ability
to protect public health/welfare, groundwater and surface water resources, and air quality within the
sphere of influence of the landfill (typically a several -mile radius about the landfill) for as long as
the wastes pose a threat. Public landfill developers also face the same long -term impact concerns,
and postclosure and post- postclosure funding needs as private landfill developers. The public
entities that develop landfills (e.g., cities and counties) however, cannot walk away from the
responsibility for funding landfill monitoring, maintenance, and groundwater remediation as easily
as private landfill developers.
Many of the deficiencies in federal and state landfilling regulations have been well- understood in
the technical and regulatory communities since the late 1980s. Political considerations and
administrative expedience have caused the US EPA and states to ignore, dismiss, or evade
addressing these issues largely because it would cause the public that generates the garbage to pay
significantly more for disposal / "management" of their wastes. Further, the overriding waste
management strategy is to remove wastes from the densely populated urban areas and dispose of it
in "remote" or "sparsely populated" areas — where there are fewer people to adversely impact — for
as little money as possible. Thus, by and large, the bulk of the people who generate most of the
waste are not faced with the public health/welfare and environmental quality consequences of the
"disposal" of their waste. Those impacts are disproportionately inflicted upon the "fewer people"
in rural environments in the vicinity of the landfills. This reality continues to lead to justified
NIMBY ( "not in my backyard ") attitudes and actions by those in the vicinities of proposed MSW
landfills. If MSW landfills were located in urban areas where the wastes are primarily generated,
17

the waste - generating public would become much more cognizant of and less complacent about the
deficiencies in today's US EPA and state landfilling regulations in the near -term while the landfill
is receiving wastes as well as in the long -term.
As long as urban dwellers who generate the garbage can have their solid wastes "disappear" from
their homes, businesses, and industry at relatively low cost (a few tens of cents per person per day),
and not have to experience any of the adverse short -term or long -term impacts of MSW landfills,
there will be little motivation to increase the costs of garbage disposal sufficiently to enable proper
management of MSW in landfills that are fully protective of public health /welfare, and
water /environmental resources in the sphere of influence of the landfill. Because of the grossly
inadequate provisions for post - postclosure funding for MSW landfill care for as long as the wastes
in the landfill will be a threat to generate leachate and landfill gas when contacted by water, the
public in both urban and rural areas will have to pay for post - postclosure care and Superfund -like
groundwater remediation costs, which are likely to be several tens of millions of dollars. The
current landfilling approach will not only be a major financial burden to all the people in the area of
the landfill /county /state and disproportionately those of rural areas, but also result in adverse health
impacts and loss of water resources in the area of the landfill.
An approach for addressing this situation could be for local agencies such as municipal, county and
state agencies that face long -term post - postclosure funding liabilities to require improvements in
landfill regulations over the minimum required by the US EPA Subtitle D regulations to provide for
technically valid and reliable landfill development and funding. Several states or parts of states
have understood this situation and have adopted improved landfilling regulations, such as requiring
a double- composite liner system with a leak detection system between the liners to better enable the
early detection of the inevitable failures of the upper composite liner to collect the leachate
generated in the landfill. As discussed herein and in our "Flawed Technology" review, the
detection of leachate in such a leak detection layer would signal the need to locate and repair the
areas of degradation or failure in the cover to stop the entrance of water into the landfill that
generates leachate. The currently allowed landfilling approach for MSW and so- called "non-
hazardous" waste does not provide the funding to make implement such an approach. Instead, as
noted above and discussed in our "Flawed Technology" review, under the current approach there
will inevitably be widespread groundwater pollution by landfills before deterioration and failure of
landfill containment systems are recognized and addressed, consequences that may well be delayed
until after the required postclosure care period has concluded. This leaves the public agencies in the
area of the landfill with the responsibility for addressing the landfill and environmental
consequences and the public with the public health /welfare and environmental quality impacts, as
well as the financial burden of increased taxes to pay for the remediation.
In our writings (see "Flawed Technology" review), we suggest that those who generate solid waste
be required to pay for the full costs of proper, reliable, and protective management of that waste as
part of their garbage disposal fees. Sufficient funds need to be collected and placed in a dedicated
trust fund that could be used only for post - postclosure plausible worst case care needs for as long as
the wastes posed a threat. It is estimated that that approach could double to triple the cost of
garbage disposal for those who generate the wastes, but it would more likely result in people's
paying the true costs for the disposal of the wastes they generate.
IN

Questions or comments on these issues should be directed to Dr. G. Fred Lee
gfredlee33 @gmail.com.
Announcement of American Society of Civil Engineers (ASCE) Election of
Dr. G. Fred Lee as ASCE Fellow
In December 2009 Dr. G. Fred Lee was elected as an ASCE Fellow. This election recognizes Dr. Lee
five decade career as a national/international leader university graduate level educator and
environmental consultant. The ASCE announcement of this election is presented below.
G. FRED LEE, Ph.D., P.E., BCEE, F.ASCE, earned his Master of Science in Public Health from the
University of North Carolina in 1957 and his PhD degree in environmental engineering from Harvard
University in 1960. For 30 years he served on the graduate civil and environmental engineering /science
faculty of several major US universities where he taught, conducted research, mentored the Masters and
PhD work of 90 students, published extensively in professional journals, and actively undertook public
service for the regulatory, professional, and lay communities.
In 1989 Dr. Lee retired from his academic career to focus on private consulting and public service; he is
president of G. Fred Lee & Associates. Areas of emphasis include domestic water supply water quality
focusing on how land use in a water supply watershed impacts water supply water quality; investigation
and management of surface and groundwater quality, stormwater runoff, contaminated sediments, land
surface activities that impact groundwater quality, and use of reclaimed wastewater; and investigation
and management of impacts of solid and hazardous chemicals including MSW and hazardous waste
landfills, Superfund, and other hazardous chemical sites.
Dr. Lee has served on the editorial boards for several professional publications, and currently serves on
the editorial board for the Journals Stormwater and Remediation. Dr. Lee has long served on the
American Academy of Environmental Engineers' (AAEE) examination board for AAEE professional
engineer certification; until 2009 he served as Chief Examiner for Northern California in Water Supply
and Wastewater and in the Hazardous Waste areas for 20 years.
Dr. Lee has published more than 1100 professional papers and reports many of which are posted on his
website [www.gfredlee.com]. In addition, out of the need for greater influence of science and
engineering in water quality regulation and management, he created and authors an email -based
Stormwater Runoff Water Quality Newsletter which he has distributed about monthly for the past 12
years, at no -cost, to about 8,000 subscribers.
19

Exh. Bat 00001
An Evaluation of Particulate Matter, Hydrogen Sulfide, and
TNon- Methane Organic Compounds
From the Arrowhead Landfill
Introduction
A project was undertaken to conduct an air dispersion modeling study of the
atmospheric emissions of certain pollutants from the Arrowhead Landfill (LF) located a
few miles southeast of Uniontown, Alabama. The purpose of the project was to quantify
the impact of two particular air pollutants generated by LF waste disposal activity on
the area surrounding the site. The air pollutants .ofpAnary interest were hydrogen
sulfide (H2S) and total suspended particulate natter (TSP)1. Non - Methane Organic
Coinpound (NMOC) air emissions were briefly addressed in qualitative terms, The year
of interest was 2010.
The purpose of this report is to present the results of an air dispersion modeling study
related to H28 and TSP air emissions from specified portions of the LF. The report
describes the key elements of the methodology used to complete the modeling work, it
presents the results obtained, and it concludes with a rendition of engineering opinions
primarily based on those air dispersion modeling results.
The report is organized in terms of explaining the project outputs; that is, isopleth snaps
depicting the annual average and maximum 1 -hr. average ambient air concentrations of
112S; the annual average, maximum 24 -hr. average, and maximum 1 -11r. average
concentrations of TSP; and a drawing depicting the number of times (at many different
locations) that the odor threshold of H2S was likely exceeded when compared with the
calculated I -hr. average ambient air concentrations of H2S that resulted from
Arrowhead LF waste disposal activities during the year 2010.
Methodology
Emission Inventory: In order to conduct an air dispersion modeling project, an
emission inventory had to be derived. For this project, H2S air emission rates from the
LF surface were calculated. TSP air emission rates from the haul road that runs between
the rail spur track, located on the north side of the LF, and the active disposal area of the
1 For purposes of this work, TSP means particulate natter with an aerodynanhic diameter of 30 microns or
less.

Exh. B at 00002
LF, located at the southeast corner of the LF were calculated. Additionally, TSP air
emission rates from the active disposal area "working face" were quantified.
The calculated air emission rates from each of those sources are:
1.42S = 10.8 lbs. /hr.
TSP from haul road 189 Ibs. /h .
TSP from "working face" = 3.15 lbs. /hr.
The emission inventory calculations are included in the Appendix.
Source Parameters:
In order to conduct the air dispersion modeling study, certain physical dimensions and
operating characteristics of each air emission source had to be specified. Source
locations and dimensions were obtained primarily from two aerial photographs of the
LF sites. Hours of operation of the haul road and "working face" were specified in a
letter to the Alabama Department of Environmental Management from the LF
operator's technical consultant dated March 7, 2008.
Additional physical dimensions assumed for the LF surface (related to H2S emissions)
and each air emission volume source (related to the haul road) are detailed in the
AERMOD modeling files contained in the Appendix. The height of the LF waste pile
was approximated based on a USEPA document¢,
Note that air emission rates for additional sources of H2S and TSP, lulown to exist on
the LF, were not included in the air emission inventory or the related air dispersion
model runs. That choice was primarily dictated by the lack of technical details about
H2S emissions from the leachate storage tank (as those air emissions existed prior to
installation of an air pollution abatement device) as well as TSP air emissions from
cover storage piles and coal ash handling activity at the rail spur track unloading point
and the LF "working face ".
"Aerial View of the Arrowhead Landfill — Uniontown, AL ", TVA, undated; "PCA Arrowhead Landfill
12110109 ", Defendant's Exhibit Hohnes 1.
' See ennission inventory reference 11.
4 "Inhalation of Fugitive Dust; A screening Assessment of the Risks Posed by Coal Combustion Waste
Landfills" (a draft), USEPA, 2009, page D -1.

Exh. B at 00003
Base Map:
In order to create an expositive depiction of the H2S and TSP modeling results, it was
necessary to first create a base neap. The base map encompassed the L , the nearby
neighborhood, and the southeast portion of Uniontown. The base map was primarily
based on the USGS topographical snap of the Uniontown East Quadrangle and a 1 meter
color ortbo- recitifted digital aerial photograph of Perry County, Alabama. The base ]nap
covered an area within approximately two miles of the center of the LF property.
Drafting of the base neap was done with the computer program Corel Draw Graphics
Suite 1I.
Receptor Grid:
In order to carry out the air dispersion modeling calculations, it was necessary to create
a receptor grid, The purpose of the receptor grid was to designate those points on the
base neap at which ambient air concentrations of H2S and.TSP were calculated.
Receptors were given a "flagpole" height of five feet. In total, ambient air
concentrations were calculated at a total of 5,045 individual receptors,
Almost all of the receptor locations are illustrated in a drawing in the Appendix. The
location of three additional receptors were just off of the base snap. Those three receptor
locations were specified in the AERMOD output files included in the Appendix.
Meteorology:
For the modeling study, surface meteorological observations from the Montgomery
Dannelly field Airport for the year 2010 was used as input. Upper air data for 2010
collected at Birmingham Municipal Airport was also used.
In addition, weather data was used to create a windrose diagram for 2010. That graphic
depiction of wind speed, direction, and frequency is included in the Appendix.
Computer Models:
The air dispersion model used to calculate pollutant ambient air concentrations was the
American Meteorological Society /Environmental Protection Agency Regulatory Model
( AERMOD, version 12060). AERMOD was developed by the USEPA. It is generally
accepted, and used in applications related to the evaluation of air emissions from a wide
variety of industrial sources.
AERMOD is capable of handling multiple point, area, and voluine sources. Calculations
may be made to determine air pollutant impacts for a particular model run for relatively
short averaging times as well as annual average tinges. For this project, AERMOD
calculated annual average and 1 -hr average H2S concentrations as well as ainrual

Bxh. B at 00004
average, niaxiinum 24 -hr average and maximum I -hr average TSP concentrations over
the entire receptor grid for 2010.
A computer model brown as Surfer, Version 8 was used to create concentration isopleth
maps with the output from AERMOD.
Project Outputs;
Number Array: The primary output from AERMOD is a number array that depicts the
air pollutant concentration for the averaging time of interest at each point on the
receptor grid. To create that output, the model calculated a concentration for the first
hour during the timeframe of interest. For this case, that meant the first hour during
2010. The calculated value was then saved in a temporary file. The calculation was then
repeated for the second hour in 2010, for each and every point on the receptor grid, The
model then compared the results found for the first hour with the results found for the
second hour. The highest value at each receptor was saved in the temporary file. The
calculation process continued in life fashion, and arrived at the maximum concentration
for each hour in the year at each receptor (note that may have meant a different value at
different hours of the year at different receptors). The maximum twenty -four hr, average
concentrations were based on deriving 24 -hour average concentrations for each day
during the year in a similar fashion. The annual average concentration was simply the
average of each and every hourly concentration value calculated for the year at each
receptor.
The AERMOD output files containing information related to the modeling of H2S
(maximum 1 -lu•. average, annual average) and TSP (maximum 1 -hr. average,
maximum24 -hr, average, and annual average) are contained in the Appendix. Separate
AERMOD output files related to the number of times that the 1 -lit. average H2S
concentrations exceeded the odor threshold are also included in the Appendix.
Isopleth Map: Isopleth maps depicting the results of each model run for H2S and TSP
are included in the Appendix. A map indicating the number of times that the H2S odor
threshold was exceeded, when compared with all one -hour average 112S concentrations
that were calculated, is also included in the AppendixS.
Other LF Air Emissions:
NMOCs: Gas in generated in landfills primarily as a result of the microbial decay of the
waste placed in the landfill by the operator. When oxygen becomes depleted in the
landfill waste mass, the decay continues primarily th u the action of anaerobic
5 To better understand the results displayed on that map, compare the number at a given location to 8,76D
which is the total number of hours in a year (except a leap year).
4

Exh. B at 00005
microorganisms. That decay generally produces a landfill gas composed primarily of
carbon dioxide and methane. That gas mixture typically also contains a wide range of
NMOCs. Generally, those NMOCs consist of a mixture of numerous individual toxic
chemical compounds including human carcinogens (benzene and vinyl chloride for
example), developmental toxins (ethylene dibromide and toluene for example), very
dangerous poisons (carbon monoxide and carbon disulfide for example), and odorous
compounds other than 1i12S6.
NMOCs were not modeled in this project because of a lack of definitive technical
information concerning those air emissions from the Arrowhead LF It should not be
assumed however that NMOC air emissions from the LF did not have a significant
negative impact on the nearby conmiunity.
Organic Sulfides: The odor that is often associated with landfills has been described as
"rotten ". A class of organic chemical compounds known as organic sulfides are a
significant contributor to that signature smell (in addition to H2S wI.ich, strictly
spearing, is not an organic sulfide).
Some of the organic sulfides frequently found in landfill gas areg;
- methanethiol
- dimethyl sulfide
carbonyl sulfide
- methyl mercaptan
ethyl nlercaptan
Organic sulfides were not modeled in this project because of a lack of definitive
information concerning those air emissions from the Arrowhead LF. It should not be
assumed however that organic sulfide air emissions from the LF did not have a
significant negative impact on the nearby community.
Opinions:
1. During 2010, and the previous year, the Arrowhead LF generated a substantial
amount of 142S and TSP air emissions during normal operation.
(' See emission inventory reference I., page Inventory 1.
7 "Landfill Gas Primer -An Overview for Environmental Health Professionals ", Agency for Toxic
Substances and Disease Registry, November 2001, page 2.
S "Origin and Control of Landfill Odors ", P.J. Young and A, Parker, Chemistry and Industry, No. 9, May
7, 1984, pages 329 -333; and calcrilation reference 1, page Inventory 1.

Exh. B at 00006
2, Those H2S and TSP air emissions resulted in a significant negative impact on
the neighborhoods near the LF boundaries.
3. The odor threshold of H2S was exceeded during more than one - thousand hours
at locations immediately adjacent to the LF during 2010; the odor threshold of
1125 was exceeded more than forty hours at every location illustrated on the
base neap during 2010 (see drawing number Uniontown -7).
4. The original primary ambient air quality standard for TSP (150 micrograms /M3)
was exceeded during 2010 at places just south of the LF boundary (see drawing
number Uniontown -5).
5. The apparent widespread neighborhood impact of TSP air emissions from the
Arrowhead LF defined by this air dispersion modeling project i's further
supported by analytical results of five house dust samples collected near the LF
during February 201.2 (see "Certificate of Analysis ", Stone Lions Environmental
Job No: 137937, Exova Laboratory, March 14, 2012).
Had the Arrowhead LF operator chosen to employ best available control
teclulology on the haul road and at the LF coal ash disposal area, the toxic
chemical impact on the nearby community would have been less detrimental to
the health, well being, and property of those who lived nearby. The more
obvious impacts included TSP dust problems and frequent noxious odors at
many locations around the Arrowhead LF.
OF
5
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RESULTS Landfill flame or Identifier: CASE 2: k = 0.7; Lo = 96
The 80 -year waste acceptance limit of the model has been exceeded before
the Waste Design Capacity was reached. The model will assume the 80th
year of waste acceptance as the final year to estimate emissions. See 2009 = 91,000 Mgm
,section 2.6 of the User's Manual.
Closure Year (with 80 -year limit) = 2087 2010 = 75,500 Mgm
Methane = 50 % by volume
Year
Waste
Accepted
Waste -In -Place
Total
landfill gas
(Mgl ear
(Mg/year)
(short tonslyear)
(Mg)
(short tons)
Mglyear)
m 31 ear)
(av ft "3 1min)
2008
2009
2010
2011
2012
2013
2014
2015
110,158
91,000
75,500
-
38,983
38,983
38,983
38,983
38,983
121,174
_ 100,100
83,050
42 881
�
42,881
42,881
0
110,158
V 201,158
_ 0
- 121,174
0
1 377E *04
1.821E +04
- - - - - --
1,848E +04
1 405E +04......
1.165E +04
0
1,102E +07
'1 '!58,._+07
- 1.480E+07
- 1 12 r.1 07
.� 2'1 fl 0�i
8. 6 13 E, x-06
8.178E +06
0
7.407E +02
9,797E +02
- -
9,942E +02
221,274
_ 27_6,658
315,641
304,324
347,205
390,086
432,968
475,849
7.558E +02 --
6.375E +02
354,624
42,881
421881
393,607
432,590
1. 076E +04
1.021E +04
- 5,787E +02 J
5.495E +02..
Year
Waste
Accepted
Waste-in-Place
Methane
Year
(Mgl ear
short tans/ ear
(Mg)
(short tons)
(Mglyear)
(m 3I oar)
av ft "3 /min
2008
2009
2010
2011
2012
2013
2014
1 2015
110,158
91,000
75,500
38,9 83
38,983
38,983
38,983
38,9831
121,174
100,100
83,050
42,881
42,881
42,881
_T 42,8$1
42,881
0
110,158
201,158
0
121,174
221,274
- 304,324
0
0
5.512E +06
7,291E +06
7.398E +06
5.625E +06
4.744E +06
4.306-E+06
4.089E +06
0
3.7Q4E +02
4.899E +02
4 971E. +02
3.779E +02
3.187E +02
2.8-93 E+02-
2,747E +02
3,677E +03
4.864E +03
276,658
--315,64-1-
354,624
393,607
432,5901
4.936E +03
3.7521= +03
347,205
390,086
4321968
475,849
3.165E +03
2.873E +03
2.728E +03
Year
Waste
Accepted
Waste -In -Place
Carbon dioxide
(M 1 ear
{ 09/1110 "'O
(s'hor" "'NmAlmj.
(Mq)
(short tons)
(Mglyear
(m /year)
av ft"31min)
2008
i -10, •1 r)8
121,174
0
0
0
0
0
2009
t�1,Ot)o
9C11.1,'Ic)Ci
110,158
121,174
1.009E +04
5.512E +06
3.704E+ . 02
2010-
75,500
113,050
201,158
221r274
1.335E +04
7.291E +06
4.899E +02
2011
"Iruti;3
1 2, 81
276,658
304x324
1 354E +04
7.398E +06
4.971 E +02
n12
38,983
42,881
_. 315,641
_ 347,205
,.......1.030E +04
5.625E +06
....
3.779E +02
35 4,624
2013
38,983
42,881
390,086
8.663E +03
4.744E +06
3,187E +02
2014
381983
42,881
393,607
432,968
_7.883E +03
4,306E +06
2.893E +02
432,590
475,849
2015
38,983
- 42,881
7.485E +03
4.089E+06
2.747E +02
Year
Waste
Accepted
Waste -In -Place
IVMOC
(M 1 ear
short tons/ ear
M
short tons
M /year)
(m 3 /year)
_
(qv ft -3 /min
2008
110,158
121,174
0
0
0
0
0
2009
91,000
100,100
1'10,15U
121,174
1.581E +02
4.410E +04
2.963E +00
2.091E +02
2010
75,500
83,050
2Ut'I5b
221,274
5,833E +04
3.919E +00
2011
38,983
42,881
276,658
304,324
2.122E +02
5.919E +04
3.977E +00
2012
38,983
- - -
42,881
i'i 5 641'1
-
347,205
-
1.613E +02
4.500E +04
-
3.023E +00
2013
38,983
42,881
354,624:
390,086
1.360E +02
3.795E +04
2.550E +00
2014
38,983
42,881
393,607
_ 432,968
1.235E +02
3.445E +04
2,315E +00
2015
38,983
-42,881
432,590
- 475,849
- 1.173E +02
3.271E +04
2.198E +00
``1_ "-'

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Exh. B at 00020
STONE
IONS in
ENVIRONMENTAL CORPORATION
SUMMARY OF QUALIFICATIONS:
Stone Lions Environmental Corporation
JIM TARR 655 Deep Valley Drive #303
Rolling Hills Estates, CA 90274
President Phone [phone]
Fax [phone]
www.stonelions.com
More than thirty -nine years experience as an Environmental Engineer in the areas of air pollution
evaluation and control; hazardous waste evaluation, management, and remediation; past and
current toxic chemical and air pollution exposure assessment; and environmental sampling and
analysis. Several decades of experience conducting technical work in the legal field.
PROFESSIONAL ENGAGEMENTS:
Stone Lions Environmental Corporation, (1993- Present) - President
Simon Hydro - Search, (1990 -1992) - Vice President
Toxcon Engineering Company, Inc., (1978 -1990) - President
Texas Air Control Board, (1972 -1978) - Engineer
Monsanto Company, (1969 -1972) - Process Engineer
EDUCATION:
Master of Chemical Engineering, University of Houston, Houston, TX - 1976
B,S., Chemical Engineering, University of Texas, Austin, TX - 1969
LICENSE:
Professional Engineer, Texas
CERTIFICATIONS:
Diplomate, American Academy of Environmental Engineers
Certified Hazardous Material Manager at the Masters Level (inactive)
PROJECT EXPERIENCE:
Performed technical evaluations of the community exposure to lead air emissions associated with
the Doe Run primary lead smelter in the small town of Herculaneum, Missouri, which ended in a
$358.5 million jury award subsequent to a three -month trial.
Performed a critical investigation of certain air emission regulatory issues and violations related to
the Isomerization unit in the BP Refinery in Texas City, Texas, after an explosion and fire killed 15
people and injured at least 170 more on March 23, 2005. The work culminated in court testimony
in Galveston, Texas, in the summer of 2008.

Exh. B at 00021
Stone Lions Environmental Corporation
TONE JIM TARR 655 Deep Valley Drive #303
Rolling Hills Estates, CA 90274
President Phone [phone]
IONS Fax [phone]
ENVIRONMENTAL CORPORATION www.stonelions.com
Conducted an evaluation of toxic chemical exposure problems in a community that was built in
the 1960s on a former Shell ail Company tank farm. The project included ambient air, indoor and
outdoor air sampling, and data analysis.
Conducted a wind tunnel study and an air dispersion modeling analysis of several toxic chemical
air emission sources on and near Beverly Hills High School.
Designed and implemented an ambient air - monitoring project in a community located adjacent to
a.major oil field in Hobbs, New Mexico.
Evaluated elevated levels of mercury in the ambient air linked to an estirn?ted 7,100 metric ton
mercury release into the Carson River basin near Fallon, Nevada, The work included ambient
air, indoor air, soil and dust collection, and data analysis.
Developed an analysis of the toxic chemical issues associated with a warehouse fire. The work
culminated in an air dispersion modeling analysis that quantified neighborhood toxic chemical
exposure in the City of Phoenix as well as a qualitative determination of the neighborhoods most
impacted. The fire was one of the largest in the history of the City of Phoenix.
Performed technical evaluations of proposed commercial Incinerator facilities for the cities of
Corpus Christi, Texas City, La Porte, and Houston, Texas,
Conducted air quality evaluations for proposed municipal landfills in Garland, College Station,
and Houston, Texas; Pindall, Arkansas; and Santa Clarita, California.
Conducted a complete environmental engineering evaluation of a commercial industrial waste
Incineration facility in Baton Rouge, Louisiana.
Conducted air emission evaluations of commercial municipal landfills in Rolling Hills Estates,
West Covina and Granada Hills, California; New Orleans, Louisiana; Sinton, Texas; and Danbury,
Connecticut.
Conducted environmental audits at industrial sites in Texas, Louisiana, Colorado, California,
Illinois, New Mexico, and North Dakota,
Designed and implemented PCB and hazardous waste site remediation projects in Texas,
California, Missouri, New Mexico, Colorado, and North Dakota.
Developed an air emission inventory for approximately fifty maquiladora facilities in Matamoros,
Mexico.
Performed an evaluation of a proposed multi - facility coal fired power plant project in Texas on
behalf of a forty -city consortium.
Conducted air dispersion modeling studies for refining operations; chemical manufacturing plants;
wood treatment facilities; industrial waste disposal sites; crude oil production, processing and
storage; a rocket engine test facility; an electric coil facility; a drum reconditioning plant; storage
and shiploading operations; lead and zinc smelters.

Exh. B at 00022
Stone lions Environmental Corporatlon
TONE JIM TARR 655 Deep Valley Drive #303
Rolling Hills Estates, CA 90274
President Phone [phone]
IONS r3a Fax [phone]
ENVIRONMENTAL CORPORATION www.stonelions.com
Worked on behalf of citizens' groups in Texas, Arkansas, Oklahoma, Louisiana, New Mexico,
Michigan, Hawaii, California, and Alabama.
ITEMS OF NOTE:
Volunteer on Pediatrics Floor at M.D. Anderson Hospital in Houston, Texas.
Named as a person "who makes a difference" in the environmental field by Citizens League for
Environmental Action Now (CLEAN), an environmental advocacy group (n Houston, Texas.
Recipient of the 1977 Ecology Award presented by the San Jacinto Lung Association for
"Outstanding Leadership in the Field of Environmental Health ".,
Taught environmental courses at Rice University, Sam Houston State University, and George
Washington University.
Member of the Advisory Council of the New Mexico Environmental Law Center in Santa Fe, New
Mexico (2001 - 2005).
Member of the Palos Verdes Landfill Citizens Advisory Board, California Department of Toxic
Substances Control (2004 - 2011).
PUBLICATIONS & PRESENTATIONS:
James Dahlgren, Harpreet Takhar, Pamela Anderson - Mahoney, Jenny Kotlerman, Raphael
Warshaw, and Jim Tarr, "Cluster of Systemic Lupus Erythematosus (SLE) Associated
with an Oil Field Waste Site: A Cross Sectional Study," Environmental Health, 6:15, May
17, 2007.
Jim Tarr, "Coal Fired Power Plants —The Air Pollution Problem," University of Houston, Houston,
Texas, February 27, 2007.
Jim Tarr, 'The Toxic Chemical Cioud Over East Harris County, Texas ", University of Texas
School of Public Health, Houston, Texas, April 2000,
Jim Tarr, "Ethics, Threshold Limit Values, and Community Air Pollution Exposures," in
Sacrificing Science for Canyenlence: A Technical and Ethical Evaluation of Texas` Risk
Assessment Process, Downwinders at Risk Education Fund, Cedar Hill, Texas, October
1996,
Jim Tarr, 'The Practical Aspects of Assessing Community Air Pollution Exposures with Air
Dispersion Modeling Techniques," National Bar Association, 69th Annual Convention,
Seattle, Washington, August 1994.

Exh. B at 00023
Stone Lions Environmental Corporation
TON E J JIM TARR 656 Deep Valley Drive #303
Rolling Hills Estates, CA 90274
President Phone [phone]
IONS Fax [phone]
ENVIRONMENTAL CORPORATION www.stoneiions.com
Jim Tarr, "Siting Criteria for Industrial Waste Incinerators - An Air Pollution Perspective," The
1989 Incineration Conference sponsored by the University of California, Irvine, CA, at
Knoxville, Tennessee, 1989.
Jim Tarr and J.R. McMurry, "The Control of Vinyl Chloride Emissions in Texas," 71 st Annual
Meeting of the Air Pollution Control Association, Houston, Texas, 1978.
Jim Tarr and Catherine Damme, "Toxicology, Toxic Substances, and the Chemical Engineer: The
Special Relevance of Cancer," Chemical Engineering, p. 86, April 24, 1978.
December 1, 2011

Exh, B at 00024
Stone Lions Environmental Corporation Rate Schedule - 2012
Principal engineer: $300.00 per hour
Senior engineer: $200.00 per hour
Engineer: $150.00 per hour
Senior technical assistant - 1: $150.00 per hour
Senior technical assistant - 2: $100.00 per hour
Administrative assistant: $60.00 per hour
Isopleth map printer cost: $25.00 per full -scale map
Color printer cost: $10.00 per 8 112" by I I" drawing
Dispersion model runs: $100.00 per execution run.
Animation software run: $5,000.00 per execution run
Travel time: billed at normal rates, portal to portal
First class airfare is booked for all trips of 500 miles or greater
Out of pocket expenses: at cost
Terms: net thirty days

Exh. Bat 00025
Project Name; Doe Run Continuation
ALEXANDER/PEDERSEN, Plaintiffs
VS.
FLUOR CORPORATION, et al., Defendants
Cause No. 052 -09567
In the Circuit Court of the City of St. Louis
State of Missouri
Deposition: 5114110
T L 2012
2, Project Name: Ensey
CRAIG ENSEY AND CRYSTAL ENSEY, INDIVIDUALLY, AND AS PARENTS
AND NEXT FRIENDS OF AUSTIN ENSEY, AARON ENSEY AND FAITH ENSEY,
MINOR CHILDREN, Plaintiffs
Vs.
RANKEN ENERGY CORPORATION, AN OKLAHOMA CORPORATION, AND
DOES 1 -20, Defendants
Case No. CJ- 2007 -514
In the District Court of Garvin County
State of Oklahoma
Deposition: 5119110
3. Project Name: Oak Grove
THOMAS B, WHITE, et al, Plaintiffs
VS.
OAK GROVE RESOURCES, LLP, et al, Defendants
Cause No. CV -97 -626
In the Circuit Court of Jefferson County, Bessemer Division
State of Alabama.
Deposition: 8/26110
Court testimony: 1219110
1

Exh. B at 00026
4. Project Name. Port Neches
SHARON E. BROWN, ET UX., Plaintiffs
vs. HUNTSMAN PETROCHEMICAL CORPORATION, et al, Defendants
Cause No, E177408
In the 172"d Judicial District Court of Jefferson County
State of Texas
Deposition: 10/8/10,11/23/10
5. Pro'ectName: Blackwell
BOB COFFEY, LORETTA CORN, AND LARRY AND MARY ELLEN JONES,
INDIVIDUALLY AND ON BEHALF OF ALL OTHER SIMILARLY SITUATED,
Plaintiffs
vs.
1, FREEPORT- McMORAN COPPER & GOLD INC.;
2. PHELPS DODGE CORPORATION;
3. CYPRUS AMAX MINERALS COMPANY;
4. AMAX, INC, Fk/a
AMERICAN METAL CLIMAX, INC. f/k/a
TER AMERICAN METAL COMPANY;
5. BLACKWELL ZINC COMPANY, INC.;
6. BLACKWELL INDUSTRIAL AUTHORITY; and
7. BNSF RAILWAY COMPANY Mc/a
BURLINGTON NORTHERN INC. f/k/a
BURLINGTON NORTHERN RAILROAD COMPANY f/k/a
THE BURLINGTON NORTHERN and
SANTA FE RAILWAY COMPANY
Defendants
Cause No. CJ- 2008 -68
In the District Court of Kay County
State of Oklahoma
Deposition: 11/9/10
2

Exh. B at 00027
6. Project Name: OK-HF
MARGIE L. SOUTHERN, Plaintiff
VS.
COFFEYVILLE RESOURCES REFINING & MARKETING, LLC, a KANSAS
C ORP ORATION,
And STEVESON L.P. GAS COMPANY, AN OKLAHOMA CORPORATION,
Defendants
Cause No. CJ -07 -275
In the District Court of Sequoyah County
State of Oklahoma
Deposition: 3116111
7. Project Name: Doe Run Continuation
PRESTON ALEXANDER, et al., Plaintiffs
VS.
FLUOR CORPORATION, et al., Defendants
Cause No, 052 -9567
In the Circuit Court of the City of St. Louis
State of Missouri
Court Testimony: 5/27/11
8, Project Name: Caride
CARIDE, et al., Plaintiffs
vs.
CHESAPEAKE OPERATING, INC., et al., Defendants
Case No. CJ- 2005 -143
In the District Court of Garvin
State of Oklahoma
Deposition: 7/29111, 8/4/11
9. ProiectNaame: KBR
MARK McMANAWAY, et al., Plaintiffs
Vs.
KBR, INC., et al., Defendants
Civil Action No. 4:10 -cv -01044
In the United States District Court for the Southern District of Texas
Houston Division
Videotaped Deposition: 3/29/12
Court Testimony: 6/20/12
3

Exh. B at 00028
10. Pro'ect Name: Tafolla
Miguell Tafolla, et al. Plaintiffs
vs.
Stan and Joyce Volk Trust, et al., Defendants
Case No. NC053385
In the Superior Court
State of California, City of Los Angeles, Southern District
Deposition,: 4119112
11. Prof ect, Name: MeadWestvaco
BALTAZAR ORTIZ, et al., Plaintiffs
vs.
MEADWESTVACO CORPRATION, et al., Defendants
Docket No, 2009 -0278
In the 36tn Judicial District Court of Beauregard Parish
State of Louisiana
Via Telephone Deposition: 4/20/12 (court reporter became ill; deposition halted)
Via Telephone Deposition: 5/4/12
4

Exh. B at 00029
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LEGEND
+ RECEPTOR
UTM CCCRDINATES (METERS), ° SOURC£
NAD83, ZONE 10
W
,S
0.0 a.b to 1.5 2.11
SCALE IN MILES
IONS
ANO T6P
JT

Exh. B at 00030
3590600
3689000
3588000
3697060
3586000
3586000
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3583000 k--
452000
453000 454000 455000 466000 457000 458900 454000
OIM COORDWAiES tMEWg5G
W083. TONE 16 N
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5
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moldommmilmd
SO&V IN MILES

Exh. B at 00031
WIND ROSE PLOT: DISPLAY:
Station #13895 - MONTGOMERYIWSO ARPT, AL Wind Speed
Direction (blowing from)
i�
II
IWE.
COMMENTS:
NORTH
I
i
10%
WRPLOT View- Lakes Environmental Software
SOUTH
'I
-�� - -- EAST
i
i
f
1
WIND SPEED
(Knots)
>=22
17-21
11 -17
7- 11
Cj 4 -7
1-4
Calms: 27.33%
DATA PERIOD:
COMPANY NAME:
Start Date: 11112010 - 00:00
Stone Lions Environmental Corporation
End Date. 12131/2010 - 23:00
MODELER
Diane Doty
TOTAL COUNT;
CALM WINDS:
27.33%
8423 hrs.
AVG. WIND SPEED:
DATE:
PROJECT NO.:
5.08 Knots
811312012
Uniontown

4
ng
gm
tinII
MOM
1 161 11 rMil

ake a deep breath. But if you live near
t
a coal -burning power plant that dumps
�6?
coal ash into a nearby landfill or lagoon,
don't inhale too deeply because you're probably
breathing fugitive dust made up of airborne coal
ash filled with dangerous and toxic pollutants.
Whether blown from an uncovered dump site or
from the back of an open truck, toxic dust con-
taminates hundreds of fence line communities
across the country. Acrid dust stings residents'
eyes and throats, and asthmatics, young and
old, are forced to reach for inhalers. Breathing
this toxic dust can be deadly, and yet no federal
standards exist to protect affected communities.
This report describes the health impacts of the
pollution found in coal ash dust. It also points to
the imminent need for federal controls to limit
exposure and protect the health of millions of
Americans who live near coal ash dumps.
Coal combustion waste (or coal ash'), par-
ticularly fly ash, a major component of coal ash
waste, poses significant health threats because of'
the toxic metals present in the ash, such as arse-
nic, mercury, chromium (including the highly
toxic and carcinogenic chromium VI), lead,
uranium, selenium, molybdenum, antimony,
nickel, boron, cadmium, thallium, cobalt, copper,
manganese, strontium, thorium, vanadium and
others. Ironically, as coal plant pollution controls
like electrostatic precipitators and baghouse
filters become more effective at trapping fly ash
and decreasing coal plant air pollution, the waste
being dumped into coal ash waste streams is
becoming more toxic.
Coal ash is best known for polluting our
drinking water, lakes, rivers and streams, and
the threat it poses when dumped into large
earthen dams that can and do break, caus-
ing catastrophic spills and leaks. In February
2014, just days after the U.S. Environmental
Protection Agency (EPA) announced a deadline
for finalizing federal coal ash regulations, an
underground pipe beneath a coal ash pond in
North Carolina ruptured, sending 82,000 tons
of coal ash into the Dan River. In December
Zoo8, a massive coal ash pond at the Tennessee
HOW BREATHING COAL ASH IS HAZARDOUS TO YOUR HEALTH 1
Toxic coal ash dust
at the Making Money
Having Fun Landfill in
Bokoshe, Old.

t
Coal ash spilled from the TVA Kingston bower Plant covered 30o acres and damaged 4o nearby homes.

CATEGORIES OF COAL COMBUSTION WASTE
FLY ASH 50%
BOTTOM ASH 10%
BOILER SLAG 2%
FLUE GAS
DESULPHURIZATION 38%
(FGD] SLUDGE
Valley Authority's Kingston Fossil Plant in
Harriman, Tennessee, burst, sending more
than i billion gallons of coal ash sludge across
30o acres, destroying and damaging 4o nearby
homes and polluting miles of two nearby rivers.
These are two examples of more than 20o docu-
mented instances of coal ash contaminating
nearby waters across the country., Large-scale
catastrophes are dangerous, well documented
and publicized; but less visible dangers of coal
ash pose another threat. When suspended
in the air as dust, coal ash is a serious health
hazard. The inhalation of toxic dust from dis-
posal, transport and plant operations can cause
serious injuries to workers and communities
residing near coal ash dumps.
The huge volume of ash produced by the
nation's 495 coal -burning power plants amplifies
the risk.; In 2oo7, these plants together generated
more than 140 million tons of coal ash, enough
to fill train cars stretching from the North Pole
to the South P01e.4 This ash was disposed of in
approximately 1,070 wet impoundments (or
ponds), 435 landfills, hundreds of mines and
uncounted numbers of gravel pits, piles and
other sites., When disposed, coal ash dust is
emitted into the air by loading and unload-
ing, transport and wind. Once in the air, it can
migrate off-site as fugitive dust. As a result, work-
ers and nearby residents could be exposed to
significant amounts of coarse particulate matter
(PM,,) and fine particulate matter (PM2.5).
Protective practices to control toxic dust,
such as moistening dry ash or covering it daily
in a landfill, can minimize the dangers to public
health. Yet there are currently no federal require-
ments to control fugitive toxic dust. At most coal
ash dumps state regulations do not mandate
daily cover, and adequate cover may only be
required monthly or even yearly. The EPA found
that such infrequent dust suppression has "the
potential to lead to significant risks."'
WHY INHALING COAL ASH
ISHARMFUL
EXPOSURE TO SMA(...(._. PARTICLE
PG(....I....UTIO
Coal ash dust is small particles; the smaller the
particle, the greater the health risks. The very
smallest particles are inhaled into the deepest
part of the lungs where they trigger inflammation
and immunological reactions. Some particles
gain access to the systemic circulation and travel
to distant organs where they produce heart or
lung disease, while others may enter the brain
directly via the nerves in the nose. The disease -
causing potential of small particles, particularly
those less than 2.5 micrometers in their aero-
dynamic diameter (PM2.5), has led the EPA to
include them among the six criteria pollutants
under the Clean Air Act, which requires national
HOW BREATHING COAL ASH IS HAZARDOUS TO YOUR HEALTH
Coal ash is comprised
of four categories of
combustion waste.
Fly ash makes up the
largest percentage
(about half) by weight.
Fly ash is the tightest
of the four wastes
and the most likely to
become airborne. It
is carried up with hot
flue gases and trapped
by stack filters.
;DORSI WW`."J FF A.COw
FAD ATI ON/T NORM/
COALA NUCOALASH.H TML

air quality standards for certain pollutants that
cause adverse health impacts, including PMz.s.7
As epidemiological research becomes more
sophisticated due to improved techniques for
monitoring air quality and advances in statisti-
cal and population sampling methods, it seems
likely that there is no level at which PM, S is
assuredly free from causing adverse health
effects. This principle became clear in a study
of 51 metropolitan areas published in the New
England Journal of Medicine, the world's leading
peer-reviewed medical journal. The investigators
who wrote this paper retrieved PM2.5 and mor-
tality data from the late 1970s and early 198os
and compared it to data obtained about two
decades later. Uniformly, these analyses showed
important increases in health benefits as the
PM2,.5 concentrations fell. For example, in the
Buffalo, New York, metropolitan area, a reduc-
tion of 13 micrograms per cubic meter of air was
associated with a three- to four-year increase in
life expectancy.
Many other studies published in leading
peer-reviewed medical journals have shown
similar results—higher particulate concentra-
tions are associated with higher mortality rates.
These studies link coal -derived particulates,
including those from fly ash, to the four lead-
ing causes of death in the U.S.; heart disease,
cancer, respiratory diseases and stroke. In
addition, preliminary data may lead to adding
Alzheimer's disease and Type II diabetes mel-
litus to this list. One study from the Women's
Health Initiative is particularly instructive and
important for several reasons. For one, it is big:
more than 64,000 post -menopausal women par-
ticipated_ It was also done prospectively, i.e., at
the time the women entered the study they were
judged to be free from cardiovascular disease
and were then followed for an average of about
seven years. Thus, the occurrence of endpoints,
including stroke, heart attack and the need for
coronary artery bypass surgery, could be deter-
mined with great accuracy. The study showed
that for a ten microgram per cubic meter
increase in the concentration of PMzs, there
was a 24 percent increase in the incidence of the
aforementioned diseases.
Whereas initial studies examined long -tern
exposures to particulates, advances in statistical
methods have made it possible to relate even
brief increases in the concentration of PM,.S
to transient increases in the risk for stroke,
fatal heart rhythms and out-of-hospital cardiac
arrest. This is made possible because increas-
ing numbers of patients with heart disease have
implanted cardiac defibrillators that can detect
a potentially fatal heart rhythm and deliver a
strong shock to the heart to restore a lifesav-
ing normal rhythm. The painful shock causes
patients to go to the hospital emergency room,
where technicians are able to "talk" to the defi-
brillator using radio signals and retrieve the exact
heart rhythm and the time at which the device
went off. Investigators then compare this time
and rhythm data to additional data from air pol-
lution monitoring sites near the patient in order
to relate the two seemingly separate data sets,
J oined by a common time. Times and pollutant
levels chosen when the device did not fire off
serve as controls.
Although burning coal is not the biggest
source of PM�,_y improvements in analytical
techniques have made it possible to point the
finger at coal with increasing confidence. Initially
it was only possible to measure and identify the
source of relatively large particulates. Subsequent
improvements then made it possible to segregate
particles in terms of size. Recently, investiga-
tors have applied statistical techniques coupled
with advances in analytical chemistry to clearly
identify the source of particles. Those with large
amounts of silicon dioxide, the principle com-
ponent of sand, arise from the earth's crust; par-
ticles with lead come from motor vehicles; and
particles marked with selenium result from burn-
ing coal. Source -specific analytical techniques
then showed that the selenium -containing par-
ticles were the most damaging to health—that is,
the particles that arose from coal.
4 ASH IN LUNGS

While inhalation of coal ash fine particle pol-
lution poses the greatest threat to human health
from fugitive coal ash dust, the composition of
the coal ash dust poses additional inhalation
effects as well.
HARMFUL L EFFECTS OF SILICA
EXPOSURE VIA INHALATION
F COAL ASH
The composition of fly ash dust can vary consid-
erably depending on the coal that was burned,
but all fly ash contains significant amounts
of silica, in both crystalline and amorphous
form.' Respirable crystalline silica in coal ash
can lodge in the lungs and cause silicosis, or
scarring of the lung tissue, which can result in
a disabling and sometimes fatal lung disease.
Chronic silicosis can occur after many years of
mild overexposure to silica. While the damage
may at first go undetected, irreversible damage
can occur to the lungs from chronic exposure.
Such exposure can result in fever, shortness
of breath, loss of appetite and cyanosis (blue
skin). In addition, the International Agency for
Research on Cancer (IARC) has determined
that silica causes lung cancer in humans, and
the National Toxicology Program (NTP) and
National Institute for Occupational Safety and
Health (NIOSH) have also classified silica as a
human carcinogen.
HARMFUL EXPOSURE Thi
EXCESSIVE RADIOACTIVITY
Fugitive coal ash dust also contains radioactive
metals.° While each coal seam will have differ-
ent levels of radioactive metals attached to the
carbon, all coals have at least some level of natu-
rally occurring radioactive materials, including
uranium, thorium, potassium and their radioac-
tive decay products including radium." Burning
coal concentrates the radionuclides approxi-
mately three to ten times the levels found in the
initial coal seams. The radioactive metals stay
with the coal ash when the carbon is burned off.'
If these dusts are inhaled, they can transport
radioactive metals into a person's lungs. The
CHRIS JORDAN-BLOCH, CARTHIiiSTICC
radioactive metals will undergo radioactive
decay and the resulting water-soluble radium
can be transported to a person's bones where it
will replace calcium. It will also undergo further
decay to radon gas, the second leading cause of
lung cancer after tobacco smoke in the United
States. Radon gas is generated from the decay of
radium. Being heavier than air, it tends to lay in
pockets in low-lying areas unless mixed with air
and carried away by wind. In addition, the dust
does not have to be inhaled to be dangerous.
Dust can contaminate surface water supplies
HOW BREATHING COAL ASH IS HAZARDOUS TO YOUR HEALTH 5

where the soluble radium can contaminate
drinking water and be ingested by humans or
other species.
HARMFUL FUL EXPOS RE TO
MERCURY VIA COAL ASF
Mercury is of particular concern due to its
high toxicity and its accumulation in fly ash
and eventually into the coal ash waste stream.
Implementation of the federal Clean Air
Mercury Rule will significantly increase the
mercury content in fly ash because the mercury
capture required by the rule will result in more
mercury ending up in the solid waste created by
coal burning. According to EPA testing of fly ash
at plants that had mercury controls, the mer-
cury in ash increased by a median factor of 8.5,
and in one case, by a factor of 70.12 At the same
time, other contaminants in fly ash such as arse-
nic and selenium also increased, concurrently
elevating the risk to human health via inhala-
tion of fugitive dust.
HARMFUL EXPOSI RE TO HYDROGEN
SULFIDE E VIA COAL. ASH
Hydrogen sulfide is a flammable, colorless gas
with the characteristic odor of rotten eggs.
Hydrogen sulfide is released primarily as a
gas and spreads in the air. Because of the high
sulfur level in coal ash, hydrogen sulfide is often
released at coal ash landfills and impoundments.
Communities near dumps or coal plants and
workers at these facilities may be exposed to
hydrogen sulfide by breathing contaminated air.
Exposure to low concentrations of hydrogen
sulfide may cause nausea and irritation to the
eyes, nose or throat. 13 It may also cause difficulty
in breathing for some asthmatics. Children are
sometimes exposed to more hydrogen sulfide
than adults because hydrogen sulfide is heavier
than air and children are shorter than adults. The
sulfurous stench from coal ash dumps can also
significantly degrade the quality of life of com-
munities near disposal sites.
DANGERS TO WORKERS
FROM INHALATION OF
COAL ASH
The primary workplace health risks are associ-
ated with inhaling airborne fly ash. Depending
on conditions in the plant, regulations may
require employees to use respirators, wear dis-
posable clothing or both when performing spe-
cific tasks. These employees may be the safest
while performing those tasks since they are
wearing protective gear. However, it is likely that
many employees are exposed to and inhale sub-
stantial concentrations of fly ash in power plants
while they are not wearing respirators or other
protections. In a published study, the Electric
Power Research Institute found that silica expo-
sure in U.S. coal-fired power plants frequently
exceeded NIOSH health standards in areas
where fly ash was handled, particularly during
activities involving the maintenance of air pollu-
tion devices (e.g., maintenance of baghouses or
electrostatic precipitators). 14
Landfill employees and workers handling
coal ash in "beneficial use" operations (e.g., at
structural fills and minefills) may also experi-
ence harmful exposure to airborne ash. Workers
at the Arrowhead Landfill in Uniontown,
Alabama,' which received 4 million tons of coal
ash from the cleanup of the TVA, Kingston spill
in aoog—nolo, reported significant injuries to
health. 16 A construction manager overseeing
the use of coal ash in the construction of a golf
course has also claimed serious injury due to
inhalation of fly ash.17
L ASH IN LUNGS

DANGER
M Egli Vuilgl � IllCOMMUNITIES
NEAR COAL -BURNING
PLANTS
Utility companies have three ways to dispose
of toxic coal ash. An estimated 36 percent of
coal ash is disposed of in dry landfills, usually
at the power plant site where it was generated.
Approximately twenty-one percent of coal ash is
stored in wet impoundments or "ponds"—some
as large as i,000 acres." The remaining 43-46
percent is reused in industrial applications,
including many that involve large-scale disposal,
such as large structural fill projects and fill-
ing mines with coal ash. More than 6o percent
of all coal -burning plants have some type of
onsite coal ash disposal, frequently consisting
of at least one landfill, pond or silo."- Most have
multiple disposal areas. Thus communities near
power plants are frequently at risk of exposure to
toxic dust.
All forms of coal ash disposal can generate
dangerous quantities of airborne ash due to
mismanagement of ponds, landfills and reuse
projects. Ponds in and environments may be
allowed to dry, resulting in wind dispersion of
CHRS JORDAN -F11 OCH / EARTHJUS! ICE
dried ash. Landfills may not be covered daily
or capped, also resulting in unsafe levels of ash
blowing from dumps. Also, where coal ash is
used for fill in construction or on agricultural
fields as a "soil amendment," the ash can readily
blow or erode. Windblown particulates called
"fugitive dust" also arise when ash is loaded,
unloaded and transported.
REUSE SE E ASH
Reuse can cause harinfut levels of
toxic dust and water pollution
so
iCE. AMER _ AN COAL A'HASSOCIATION. H12 CO I. OMBUSTI0N PRODUCT
[CL � PRODUCT ON - 'JRVEV RF PORT_.
HOW BREATHING COAL ASH IS HAZARDOUS TO YOUR HEALTH
Much like other
residents of
Uniontown, AL,
William Gibbs started
seeing the paint
peeling off his truck a
few months after coal
ash from the spill in
Tennessee arrived at
a nearby landfill. "If
that's what it's doing
to my truck, imagine
what it's doing to me,"
said Gibbs.

LUAL ANN F'ULLU[AN t
In 2009, the EPA documented the health
threat from toxic dust near coal ash landfills in
its draft screening risk assessment, inhalation of
Fugitive Dust: A Screening Assessment of the Risks
Posed by Coal Combustion Waste Landfzlls.11 The
purpose of this screening assessment was to
determine whether the National Ambient Air
Quality Standards (NAAQS) could be violated
through dry handling of coal ash, and if so, what
management options might be needed to reduce
the health risk. Indeed, the EPA found that "there
is not only a possibility, but a strong likelihood
that dry -handling would lead to the NAAQS
being exceeded absent fugitive dust controls."2'
The EPA concluded that only daily controls
carchovascular
# #
asthrm wheezing lun can r
(daily cover) can definitively prevent unhealthy
releases of particulates.
However, a critique of the EPA's screening
assessment found that it considerably under-
estimated the risk to human health from toxic
dust. The EPA considered only one source of
fugitive dust emissions from coal ash—wind ero-
sion—and failed to assess the substantial emis-
sions that occur during unloading and grading
of the ash, as well as from trucks traveling on
the deposited waste at the landfill.22 In addition
to toxic dust from coal ash, communities near
waste disposal operations are exposed to carci-
nogenic diesel particulate emissions from trucks,
on-site landfill equipment and diesel -powered
8 ASH IN LUNGS

pumps and generators. To compound the prob-
lem, high background levels of particulate matter
from nearby equipment may increase the poten-
tial for fugitive dust from coal ash to cause sig-
nificant human health problems. If the EPA had
taken all of these factors into account, it would
have found even greater risks to communities
living near coal ash dumps.
CHALLENGES TC CONTROLLING
HUMAN EXPOSURE
Controlling respirable fugitive ash particles is a
daunting task, principally because of two physical
properties of coal ash. First, fly ash is inherently
water repellant and tends to shed water droplets
rather than absorb them. Thus simply wetting
the material may not be effective in controlling
the ash. Second, the small size of the particles
(similar to talcum powder) adds to the difficulty
of suppressing airborne dust. Unfortunately the
most hazardous dust particles are the ones too
small to see.21
STATE AND FEDERAL REGULATIONS
ARE INADEQUATE AT TO PROTECT
COMMUNITIES
No federal standards exist for
reducing toxic durst
There are currently no federal regulations
addressing the threat of toxic dust from coal ash
disposal or placement operations. In addition,
most state laws do not protect communities
from fugitive dust.
While coal ash is regulated as a solid waste
under the Resource Conservation and Recovery
Act (RCRA), the general standards applying
to fugitive dust at industrial waste landfills do
not address the risks to human health posed
by coal ash.,, Further, while coal ash is classi-
fied as a hazardous substance under the federal
Superfund law, no regulations address its safe
disposal.'> In 2oio, the EPA proposed regulations
under RCRA to address the threat from toxic
coal ash dust, but these regulations have not yet
been finahzed.z,
Protective practices to control toxic dust,
such as moistening dry ash and covering it daily
in a landfill, can minimize the dangers to public
health. Yet at most coal ash dumps, state regula-
tions do not mandate daily cover, and adequate
cover may be required only monthly or annually.
The EPA found such infrequent dust suppres-
sion has "the potential to lead to significant
risks," adding that "yearly management leads to
a PM,o concentration almost an order of mag-
nitude above the [National Ambient Air Quality
Standard]." The EPA concluded that most states
do not require daily cover to control fugitive dust
from landfills, and most states do not require
caps on coal ash ponds to control dust. -
In fact, our survey of 37 of the top coal ash
generating states in the U.S. found that less than
half of the states mandate dust (e.g. moistening)
controls at coal ash landfills, and only a single
state requires dust controls at coal ash ponds_"
In addition, only seven of the 37 states require
daily cover at coal ash landfills." Of the states
that require dust controls, none -require specific
measures for the control of dust on a daily basis;
significant discretion is left in the hands of state
permitting authorities and facility operators. No
state currently requires the specific limit on toxic
dust from landfills and ponds proposed by the
EPA in its 2 -oro proposed coal ash rule (a level
not to exceed 35 micrograms per cubic meter).
Table i indicates the controls currently appli-
cable in 37 of the top coal ash -generating states.
HOW BREATHING COAL ASH IS HAZARDOUS TO YOUR HEALTH

TABLE 1: STATE COAL ASHI FUG71"TIVE DUST CONTROLS
MANDATORY
MANDATORY
MANDATORY
DUST CONTROLS AT
DUST CONTROLS AT
DAILY COVER AT
STATES
COAL ASH LANDFILLS
COAL ASH PONDS
COAL ASH LANDFILLS
AL
NO
NO
NO
AZ
NO
NO
NO
co
NO
NO
N030
FL
NO
NO
NO
GA
NO
NO
N031
IL
YES
NO
YES
IN
YES
NO
NO
[A
YES
NO
NO
KS
NO
NO
NO
KY
NO
NO
NO
LA
NO
NO
YES
MD
NO
NO
NO
M[
YES
NO
NO
IVIN
N 032
NO
N033
MS
NO
NO
N034
MO
YES
NO
N035
MT
NO
NO
NO
NV
YES
NO
YES
NH
NO
NO
NO
NJ
YES
NO
YES
NM
NO
NO
NO
NY
N036
NO
N037
NC
YES
NO
YES
NO
N039
NO
NO3'
OH
NO
NO
NO
OK
N040
NO
N04'
PA
YES
YES
YES
sc
YES
NO
NO
SD
N047
NO
N043
TN
N044
NO
N045
TX
NO
NO
NO
LIT
NO
NO
NO
VA
N046
NO
NO
WA
N047
NO
NO
wl
YES
NO
N048
WV
YES
NO
YES
WY
N049
NO
N050
10 ASH IN LUNGS

HOW COMMUNITIES ARE IMPACTED
BY OXIC DUSTFROM iAI-..A
The following six communities are among hun-
dreds of American communities that are injured
by toxic air emissions from coal ash.
Ice Arrowhead Landfill. Toxic Dust and
Odors Lague an AlabamaTown
After the catastrophic collapse of the coal ash
dam at TVAs Kingston plant in Harriman,
Tennessee, in 2008, the nation's worst coal
ash spill was dumped across state lines into
the lives of residents in Uniontown, Alabama
(population 1,775)''
With the approval of the Alabama Department
of Environmental Management, the TVA chose
to move the 4 million cubic yards of poison-
ous ash to the town's Arrowhead Landfill. But
instead of using protective management tech-
niques, the coal ash was dumped in uncovered
mounds stacked six stories high, just loo feet
from nearby residents. Dust and odors from the
landfill caused residents of Uniontown to experi-
ence health problems, including respiratory ill-
ness, headaches, dizziness, nausea and vomiting.
Dust blanketed their homes, cars and gardens,
and choking wafts of the "rotten egg" stench of
hydrogen sulfide permeated their houses making
life nearly unbearable.
The dumping was a blatant act of environmen-
tal injustice.=1 While the Harriman, Tennessee,
community where the Kingston spill occurred
is almost entirely white (91 percent) and middle
class (median income $36,031), Uniontown is 90
percent African American, and 45.2 percent of
its citizens live below the poverty line (median
income $17,473). The transfer of the TVA coal ash
to a community where the negative effects were
disproportionately borne by African _Americans
sparked residents to file a lawsuit in 2012 under
Title VI of the Civil Rights Act of 1964.5 Under
Title VI, government agencies that receive fed-
eral funds must assess whether their permitting
decisions result, even unintentionally, in racial
inequality. In fall 201-, Earthjustice assumed rep-
resentation of those impacted by the dumping.
The railcars loaded with toxic waste from
Tennessee have ceased. But since the Arrowhead
Landfill's permit allows the dump to continue
to accept coal ash from more than two dozen
states, there is no guarantee that the danger to
the Uniontown residents has passed.
CHRIS _ORDAIN SLOCH / EARTHJUST,CE
HOW BREATHING COAL ASH IS HAZARDOUS TO YOUR HEALTH 11
"I wanted to move
away from the noise
and the hardness of
the city. So I came here
for some peace and
quiet in the country.
I wanted to hunt
and fish and enjoy
the weather in this
beautiful place and
now they've pushed
this thing right on tap
of us. iVow, I'm too old
to move and no one
would want to buy this
place anyways,' said
William Gibbs.

Toxic. coal ash blows
like a sandstorm
straight at the homes
on the Moapa River
Reservation.
m An M WindMows Across a Native
American Community
It starts with a warning. Next it is only a matter
of which way the wind blows. In the evening,
someone will go from house to house and
tell the neighborhood that tomorrow will be a
windy day and, perhaps, a bad air day. The next
afternoon if the conditions are just wrong, coal
ash dust blows from the nearby dump sites of
Nevada Energy's Reid Gardner Power Station and
moves like a sandstorm across the dry desert of
the Moapa River Indian Reservation. The reser-
vation is the ancestral home to a band of Paiute
Indians whose homes sit only 300 yards from the
plant.' Living in the shadow of Reid Gardner, the
tribe has paid dearly with its health, and reaped
little economic benefit.
The Reid Gardner "sandstorm" is made up of
coal ash, and members of the tribe tell of health
M
MOAPA BAND OF PAIIJTES
ASN IN LUNGS

problems resulting from the blowing ash, includ-
ing burning skin, sore throats, hyperthyroidism,
heart problems and asthma. On bad days, resi-
dents stay inside. The toxic dust prevents use
of the tribal lands for traditional activities, and
members are concerned that their soil and water
are poisoned with toxic pollutants from the ash.
3. Louisvi[Le Gas & '
s Cane
Run Generating Station. Years of
B[owing Ash
The LG&E Cane Run Generating Station near
Louisville, Kentucky, stores huge mountains of
coal ash on site. For years, toxic dust clouds and
odors have blown from the power plant's waste
dumps onto the nearby community. Every day
a continuous line of trucks haul ash from the
power plant to the disposal site near a commu-
nity of nearly 40o residents, many of whom live
in rented trailers and mobile homes. A screen
was erected between the ash pile and an adjacent
cemetery in order to minimize the amount of
wind-blown dust that escapes from the property.
However, it seems to be purely cosmetic. In fact,
videos of ash blowing over the top of the screen
are regularly posted online ss
The Louisville Metro Air Pollution Control.
District has repeatedly responded to the toxic
dust with notices of violations and fines.s' In
2013, LG&E agreed to pay $113,25o and comply
with a pollution control plan after ash and odors
blowing from the plant's landfill affected resi-
dents living near the plant s- Two years earlier,
LG&E paid $22,500 for repeatedly disregarding
city regulations and allowing coal ash to blow
into residential neighborhoods se Environmental
samples obtained from three homes near the
plant all showed clear evidence of deposits of fly
ash and bottom ash, as confirmed by scanning
electron microscopy and spectral analysis.59
4. BaffiefieLd GoLf Course® "BeneficiaL
Between 2002 and 2007, Dominion Virginia
Power opted for a cheap way to dispose of
sour+ asrcoaLAsH ORe
1.5 million tons of coal ash. They built an 18 -hole
golf course with the toxic ash in Chesapeake,
Virginia. Ever since, Battlefield Golf Course has
been ground zero in the fight over handful "ben-
eficial uses" of coal ash.
During construction of the golf course,
neighbors and workers reported clouds of
black dust migrating from the construction
site to the adjacent residential neighborhoods.
Homeowners abutting the course reported that
their homes, yards, cars, picnic tables and play
equipment were covered with ash. They were
told it was harmless.
According to a former construction manager
of the golf course, Dominion directed the build-
ing of the course with fly ash to disguise the proj-
ect's true purpose—a coal ash dump_ In a sworn.
statement, Derrick Howell, a former employee
of the builder of the golf course, said, "It was
clear that a golf course wasn't being built," stated
Howell. "It was a coal ash dump. All Dominion
ever cared about was tonnage and how much
more they could dump. 116°
As a result of the toxic dust and water con-
tamination, the golf course has been the subject
of several lawsuits, including a $2 billion lawsuit
brought by nearby residents for damages. In
addition, in 2012, a contractor filed a $lo million
lawsuit against Dominion alleging that his inhala-
tion of fly ash while building the course over five
years contributed to his kidney cancer."'
HOW BREATHING COAL ASH IS HAZARDOUS TO YOUR HEALTH 13
The "mountain" rising
behind the fence is
coal ash generated by
the power plant. The
screen at the Gane Run
Generating Station
cannot stop the toxic
dust from reaching
neighbors.

Coal ash ponds from
APS' Four Corner's
Power Plant rise
more than ioo feet
above the and Navajo
Reservation.
g Dust and Disease from Mine
Dumping in La BeRe, PA
In the small rural community of La Belle,
Pennsylvania, an immense mine dump covers
Soo acres and contains a mountain of 40 million
tons of waste. Because of its conical shape and
a pond at the top, resembling a crater, local resi-
dents refer to the dump as a "volcano" of mine
waste and coal ash. First Energy—the operator
of a power plant 75 miles north—plans to dump
more than 3 million tons of additional coal ash
here every year starting in 2016, when its 1,3oo-
acre Little Blue Run coal ash impoundment in
Beaver County closes.
This is very bad news for the residents of La
Belle. In addition to water contamination, toxic
dust blows from the dump and from uncovered
trucks hauling coal ash. The waste blankets
nearby homes, offices, yards and cars. Residents
have documented large clouds of dust drifting
from the dump. Analyses of the particles on
residential properties reveal the presence of coal
ash, including toxic metals such as antimony,
arsenic, chromium, lead and fine particles.',
The residents of La Belle have turned to the
court for relief. Represented by attorneys from
Public .Justice and the Environmental Integrity
Project, a complaint alleging violations of numer-
ous federal and state environmental statutes was
filed against the dump operator in 2013.'
6. Toxic Ash from Coal Ash Ponds
Threatens the Navajo Nation
In the Four Corners region, the Navajo Nation
hosts one of the biggest coal-fired power plants
in the West—the Arizona Public Service (APS)
Four Corners Power Plant in Fruitland, New
Mexico. Despite the plant's size, 25 percent of
the reservation—an estimated 16,000 Navajo
families—are without access to electricity.14The
Navajo population is instead burdened by the
enormous pollution created by the coal plant,
including clouds of toxic dust from its half-
dozen coal ash ponds and a landfill that rises no
feet above the floor of the high desert.
Since 1962, APS has dumped approximately
30 million tons of coal ash in six immense wet
dumpsites near the power plant. Fugitive dust
from the coal ash ponds is a severe problem_
Ash dries rapidly in the arid climate and is
largely uncontained. Coal ash blown from the
waste impoundments covers hundreds of acres
14 ASH IN LUNGS

of the surrounding desert. On windy days, the
air is literally filled with ash. Health problems,
including asthma, are common among members
of the Navajo Nation.
Additionally, Navajo people use their local
environment to gather medicines for ceremony
and wellness. According to the group Dine'
Citizens Against Ruining the Environment, con-
tamination from coal ash jeopardizes the Navajo
people's ability to practice traditional healings,
which is embedded in their culture.
CONCLUSION
Despite the obvious health risks to communi-
ties living near coal ash dump sites, no federal
regulation regarding the storage and disposal
of this toxic waste exists. The EPA proposed
coal ash regulations in 2oro, but has not
finalized the rules. Earthjustice, on behalf of
Physicians for Social Responsibility, Appalachian
Voices, Chesapeake Climate Action Network,
Environmental Integrity Project, Kentuckians For
The Commonwealth, Moapa Band of Paiutes,
Montana Environmental Information Center,
Prairie Rivers Network, Sierra Club, Southern
Alliance for Clean Energy and Western North
Carolina Alliance, sued the EPA in federal court
for its failure to follow the law and propose coal
ash regulations in a timely manner. As a result of
that lawsuit, the EPA will finalize the nation's first
federal coal ash regulation by December r9, 22014.
But federal regulations for coal ash cannot
come soon enough. An increasingly large
number of studies show clear links between
inhaled coal ash and adverse health outcomes.
The huge volume of coal ash generated in the
United States and the many dangerous ways it is
dumped create a variety of pathways for harm-
ful levels of human exposure. Communities
across the nation are hurt by toxic dust because
adequate controls are not in place to protect
public health. Often those harmed are com-
munities of color or low-income communities
living along the fence lines of these coal ash
dumps whose economic hardships make them
even more vulnerable to injury. Requiring con-
trol of toxic dust through federally enforceable
standards that protect all Americans nation-
wide, and switching from coal to cleaner, renew-
able energy sources, are well-documented and
essential paths to better health.
HOW BREATHING COAL ASH IS HAZARDOUS TO YOUR HEALTH 15

i. Coal ash is comprised off our categories of
combustion waste. Fly ash makes up the largest
percentage (about half) by weight. Fly ash is the
lightest of the four wastes and the most Iikelyto
become airborne. It is carried up with hot flue gases
and trapped by stack filters.
2. http://carthjusticc.org/features/coal-ash-
contaminatcd-sites
3. U.S. Energy Information Administration (EIA), Form
EIA -923, Power Plant Operations Report, Schedule 8. Part A.
Annual Byproduct Disposition (20zz Final Release).
4. U.S. Environmental Protection Agency. Hazardous
and Solid Waste Management System Identification and
Listing of Special Wastes; Disposal of Coal Combustion
Residuals from Electric Utilities. Proposed rule. Page 344
http://www.epa.gov/wastes/nonhaz/industrial/special/
fossil/cer-rule/ccr-rule-prop.pdf.
5. See data subm itted pursuant to U. S. Envtl. Prot,
Agency. Environmental Protection Agency: 2oio
Questionnai re for the Steam Electric Power Generating
Effluent Guidelines. OMB Control No. 2040-0281.
Approved May 20, 2010. See also U.S. Environmental
Protection Agency, Effluent Limitations Guidelines
and Standards for the Steam Electric Power Generating
Point Source Category; Proposed Rule, 78 Fed. Reg.
34,432 34516 (June 7, 2013).
6. U.S. Environmental Protecrion Agency. Inhalation of
Fug tive Dust: A ScreeningAssessmentof the Risks Posed by
Coal Combustion Waste Landfills (draft), September 2009.
7. The Clean Air Act established six criteria pollutants
and required the EPA to develop and periodically
review National Ambient Air Quality Standards
(NAAQS) for each ofthem. These standards are
designed to help the Agency achieve its mission "to
protect human health and the environment." As time
has passed, the NAAQS have become more stringent, as
the extent of their health impacts has become more and
more evident.
S. Valencic,Aaron. "Dust Suppression in Coal Ash
Applications," 2or3 World of Coal Ash (WOCA)
Conference, Lexington, KY, avadableathttp://www.
flyash. info/2013/098-Valencic-2or3.pdf.
9. According to EPA, fly ash has atypical radiation level
between a low of 2 pCi/g and a high of 9.7 pCi/g. See http://
vjww.ep,,i.gov/r,idiation/tenorm/coalandcoalash.hrml
10. Id.
11. See Figure 1. Graph from Radioactive Elements
in Coal and Fly Ash: Abundance, Forms, and
Environmental Significance_ U.S. Geological Survey
Fact Sheet FS -163-97- October, 1997.
12. U.S. Environmental Protection Agency, National
Emission Standards for Hazardous Air Pollutants from
the Portland Cement Manufacturing Industry, Federal
Register, Vol 71, No. 244, December 20, 2006.
13. Agency for Toxic Substances and Disease Registry,
Division of Toxicology and Env rcnmental Medicine
'I'oxFAQs, Hydrogen Sulfide, CAS #7783-06-4, July 2006.
14. Edison Electric Institute, Silica Exposure at Electric
Utilities, EEI Safety and Health Webinar, July 22,
2009, 8, availableathttp://www3.eci.org/meetings/
Meeting 12oDocurnents/2oo9-07-22-IHIssuesWeb-
Silica_Hatcher.pcif.
r5. See http://carthjustice.org/slideshow/photo-essay-a-
toxic-inheritance.
16. Holly Haworth, Oxford American, Something Inside
ofUs, Issue 82, Nov. 11, 2013, available athttp://www.
ox_fordamerican.org/articles/2or3/nov/n/something-
inside-us/.
17. See Marj on Rostamf, Norfolk Virginian -Pilot,
"Chesapeake fly ash suit against Dominion refiled,"
February 22, 2012, available at http://hampton roads.
com/2012/o2/chesapeake-fly-ash-suit-against-
dominion-refiled, describing lawsuit by construction
manager at the Battlefield Golf Course who alleges his
cancer is attributable to arsenic exposure.
18. Barry Breen, ActingAssistant Administrator, Office
of Solid Waste and Emergency Response, US EPA.
Testimony delivered to Committee on Transportation
and Infrastructure, Subcommittee on Water Resources
and the Environment, U.S. House of Representatives,
April 301, 2009.
19. U.S. Environmental Protection Agency, Regulatory
Impact Analysis For EPA's Proposed RCRA Regulation
Of Coal Combustion Residues (CCR) Generated by the
Electric Utility Industry, April 30, 2oio at 33.
20. U.S. Environmental Protection Agency. Inhalation of
Fugitive Dust: A Screening Assessment of the Risks Posed by
Coal Combustion WasteLandjzlls (draft), September 2oo9.
21. Id.
22. Comments of Environmental Integrity Project,
Sierra Club, Earthjustice et al., Effluent Limitations
Guidelines and Standards forthe Steam Electric Power
Generating Point Source Category; Proposed Rule,
Docket ID No. EPA-HQ-OW-2oo9-o819,Appendix
G, Petra Press, "Refinement of EPA's 2oo9 Screening
Assessment of Risks Posed by Inhalation of Fugitive
Dust from Coal Combustion Waste Landfills Based on
New Data for Landfill Size," September 20, 2013.
23, Peterson, Edwin. "An Aid to Fugitive Material
Control in Coal Ash Application," 2011 World of
Coal Ash, Denver, Co. availableathttp://www.flyash.
info/2oi1/001-felde2on.pdf
24. See Comments, Earthjustice or al., Hazardous and
Solid Waste Management System; Identification and
ListingofSpecial Wastes; Disposal of Coal Combustion

Residuals From Electric Utilities; Proposed Rule,
Docket ID No. EPA-HQ-RCRA-2oo9-0640, June 21,
2010,34-35.
25. See Eagle-Piclterindustricsv U.S. EPA, 7J9 R2d922
(D -C. Cir. 1985).
26. EPA, Hazardous and Solid Waste Management
System; Identification and Listing ofSpecial Wastes;
Disposal of Coal Combustion Residuals From Electric
Utilities; Proposed Rule, 75 Fed, Reg. 35,128, 35,182
(proposed June 21, 2010).
27- U.S. EPA_ "Estimation of Costs for Regulating
Fossil Fuel Combustion Ash Management at Large
Electric Utilities Under Pan 258." Prepared by DPRA
Incorporated. November 30, 2005.
28. See note 24, supra.
29. Id.
30. Allows variance for daily cover requirement -
31. Allows variance for daily cover requirement.
32. Dust controls can be waived by variance.
33. Allows variance for daily cover requirement.
34. Cover requirement is not daily.
35. Cover requirement is not daily.
36- Dust controls can he waived by variance.
37. Allows variance for daily cover requirement.
38. Dust controls can be waived by variance.
39. Cover requirement is not daily.
40. Dust controls can be waived by variance.
41. Cover requirement is not daily.
42- Dust controls can be waived by variance.
43- Allows variance for daily cover requirement.
44 Dustcontrols can bewaived byvariance.
45. Cover requirement is not daily.
46. Dust controls can be waived by vari ance.
47. Dust controls can be waived byvariance.
48. Cover requirement is not daily.
49. Dust controls can be waived byvariance-
50- Cover requirement is not daily.
Si. Shaila Dewain, New York Times, "Clash in Alabama
Over Tennessee Coal Ash," August 29, 2oo9, available
athttp:Hwww.nytimes.com/2oo9/08/3o/us/3oash.
html%_r=o.
52. Emily Enderle, Earthjusticc, "Tr -ash Talk: Dumping
is a Civil Rights Issue," February 12, 2012, available at
http://earEhjustice.org/blog/2 ol -) -february/ty-ash-talk-
du mping- a- civil-rights -issue.
53- Sue Sturgis, The Institute for Southern Studies,
"Alabama faces civil rights complaint over landfill taking
waste from TVA coal ash disaster," available at http://
www. southernstudies-org/2o 1.2/o1/alabama-faces-civil-
i ghts-complaint-over-landfill-taking-waste-from-tva-
coal-ash-disaster.h.
S4. http://eart4lustice.org/features/campaigns/an-ill-
wind-blows.
55. Seehttp://www,youtuDe.com/
watch?v=BPgQCYsErGY.
36. Erica Petersen, WFPL, "LG&E Fined $65,00o for
Odor Problems at Cane Run Power Plant," August 5,
2013, civailableathttp://wfpl.org/post/ige-fined-65oo0-
odor-problems-cane-rur� power -plant.
57. James Bruggers, Louisville Courier -Journal, "LG&E
to pay $113,250 fine over alleged coal ash violations,"
Nov. 14,2013, availableat http://www.eourier-journal.
com/article/20131113/NEWSo1/3n13o111/.
58. J. Sonka, Leo Weekly, "LG&E is on notice: Air
Pollution Control District uncovers violations at coal
ash landfill," Nov. 9, 2011, available at http://leoweekly.
com/news/Ige-notice. Thev olations included: (1) six
incidents throughout June, July and August 2oi1, in
which clouds of fly ash rose from its sludge processing
plant, causing "nuisance and annoyance to the
residents;" (2) three incidents in July 2o1r where LG&E
"failed to take precautions to prevent particulate matter
from becoming airborne beyond the work site;" and
(3) four incidents in August 2011 in which they failed to
report "excess particulate emissions" from the plant.
59. See RJ Lee Group, Surface Dust Study, July 8, 2011,
available athttp://archives.wfpl.org/wp-content/
upload s/2o11/o7/TL,H1o4154-Nuisance-dust-report-7-
8-1i-FINAL,.pdf and RJ Lee Group, Update on Passive
Deposition Sampling Study, July 13, 2oi1, available at
htEp://archi,,Tes,wfpl.org/wp-content/i-iploadS/201 I/
07/TLH104154-Passive-Sampling-Report_FINAL_
July-i3.pdf.
60. Louis Hansen, The Virginian -Pilot, "Lawsuit
claims Dominion saw golfcourse as `coal ash dump,"'
August 27, 2oo9, availableat http://hamptonroads.com/
2oo9/o8/lawsuit-claims-dominion-saw-golf-course-
coal-ash-dump.
61. Marjon Rostami, TheVirginian-Pilot, "Chesapeake
fly ash suit against Dominion refilled," February 22,
2012, availableat littp://hamptonroads.eom/2012/02/
chesapeakc-fly-ash- suit- again st-dominion-refiled.
62. Environmental Integrity Project, "Citizens Coal
Council Sues Matt Canestrale Contracting for Dumping
Toxic Coal Ash," June 26,2n i S, available at http://
www.enk ironmentalintegritv...org/news_reports/
d oclurlents/o62613%2oLaBelle%a01awsuit%20
release%2oFINALi.pdf. See also, EIP complaint
at http://wvw7-environmentaliniegrity-org/news_
reports/documents/2oi3_o6_26-FINAL-CCC%2o
Canestrale%2oComplaintpdf
63. Id.
64. http://wwiv.ntua.com/.

Environ. Sci, Technol. 2009, 43, 6326-6333
Survey o the Potential
Environmental .l Health
in the Immediate 'Aftermath of thi
�,oal Ash Spill in Kingston,
LAURA RUHL,t AVNER VENGOSH,* t
GARY S. DWYER,'t HEILF.EN HSU-KIM,*
AMRIKA DEONARINE,t MIKE BERGIN,'
AND JULIA KRAVCHENICO"
Division of Earth and Ocean Sciences, Nicholas School of the
Environment, 205 Old Chemistry Building, Box 90227, Duke
University, Durham, North Carolina. 27708, Civil and
Environmental Engineering, 12.1 Hudson Hall, Box 90287,
Duke University, Durham, North Carolina 27708, School of
Civil and Environmental Engineering and School of Earth
and Atmospheric Sciences, 311 Ferst Drive, Georgina Institute of
Technology, Atlanta, Georgia 30332, and Duke Comprehensive
Cancer Center in Duke School of Medicine, 2424 Erwin Road,
Hock- Plaza, Suite 601, Durham, North Carolina 27705
Received March 6, 2009. Revised manuscript received April
15, 2009. Accepted April 17, 2009.
An investigation of the potential environmental and health
impacts in the immediate aftermath of one of the largest coal
ash spills in U.S. history at the Tennessee Valley Authority
(TVA) Kingston coal -burning power plant has revealed three
major findings. First, the surface release of coal ash with high
levels of toxic elements (As = 75 mg/kg; Hg = 150 ug/kg)
and radioactivity (11611a + "Ra = 8 pCi/g) to the environment
has the potential to generate resuspended ambientfine particles
(<10 um) containing these toxics into the atmosphere that
may pose a health risk to local communities. Second, leaching
of contaminants from the coal ash caused contamination of
surface waters in areas of restricted water exchange, but only
trace levels were found in the downstream Emory and
Clinch Rivers due to river dilution. Third, the accumulation of
Hg- and As -rich coal ash in river sediments has the potential to
have an impact on the ecological system in the downstream
rivers byfish poisoning and methylmercuryformation in anaerobic
river sediments.
1r_ 1)
On Monday, December 22, 2008, the containment structure
surrounding the storage of coal ash at the Kingston coal -
burning power plant of the Tennessee Valley Authority (TVA)
collapsed, which resulted in massive release of coal combus-
tion products (CCP) ash to the environment near Harriman,
Tennessee. The CCP material, consisting of fly ash and bottom
ash, spilled into tributaries of the Emory River and directly
* Corresponding author phone: [phone]; fax [phone];
e-mail: [e-mail].
r Division of Earth and Ocean Sciences, Nicholas School of the
Environment, Duke University.
Civil and Environmental Engineering, Duke University.
Georgia Institute of Technology.
Duke Comprehensive Cancer Center in Duke School of Medicine.
6326 ■ ENVIRONMENTAL SCIENCE & TECHNOLOGY / VOL. 43, NO. 16, 2009
into the Emory River (Figure 1), which joins the Clinch River
that flows to the Tennessee River, a major drinking water
source for downstream users. The Kingston coal ash spill
released over 4.1 million cubic meters of ash, which is one
of the largest spills in U.S. history. Some previous coal ash
spills in the United States include the 2000 Martin County
spill in Kentucky, which released over 1.1 million cubic meters
of coal slurry into abandoned mines and nearby creeks (1),
and the 1972 Buffalo Creek incident in West Virginia, which
released almost a half million cubic meters of coal mining
residue slurry into a nearby town (2). Numerous studies have
shown that coal ash contains high levels of toxic metals that
can harm the environment (3-14) and some of these
elements are soluble in water and easily leached in aquatic
systems (13-16).
This paper aims to provide an initial assessment of the
potential environmental impacts and health risks associated
with the Kingston TVA coal ash spill. In particular, the paper
examines the reactivity of trace metals known to be enriched
in CCP ash (9,13) in surface water and the potential ecological
effects associated with the accumulation of CCP ash in river
sediments. Furthermore, the paper emphasizes the relatively
high content of radionuclides in CCP ash and the potential
health impact of their resuspension in the atmosphere. While
most studies have investigated the potential for radon
emanation from cement and fly ash used as building materials
(17-20), here we examine possible health risks associated
with elevated radium activity in CCP ash. The study includes
measurements of trace metals in solid ash, sediments from
the river, and water samples that were collected in the vicinity
of the coal ash spill. Given the limited data collection since
the accident, this paper provides only an initial evaluation,
and does not provide a comprehensive assessment of the
overall environmental impacts of the TVA coal ash spill.
Analytical Methods and Materials
Coal ash, sediments from the rivers, and water samples from
tributaries, the Emory and Clinch Rivers, and springs near
the spill area in Kingston and Harriman,TN (Table Sl; Figure
1) were collected in three fieldtrips on January 9-10, February
6-7, and March 27-28, 2009. The surface water samples
were collected near the river shoreline from sites located
upstream and downstream (at different distances) of the spill.
Each location was determined by availability of public access
and/or allowance by property owners. Water sampling strictly
followed USGS protocol (21); trace metal and cation samples
were filtered in the field (0.45 um syringe filters) into new
and acid -washed polyethylene bottles containing high -purity
HNO3. Trace metals in water were measured by inductively
coupled plasma mass spectrometry (ICP -MS); mercury in
sediments and coal ash was measured by thermal decom-
position, amalgamation, atomic absorption spectroscopy
(Milestone DMA -80) (22); and radium isotopes were mea-
sured by y -spectrometry (see supporting text Sl).
Results and Discussion
Coal Ash and Sediments. A comparison of the chemical
cornposition of the TVA coal ash and local soil in Kingston,
Tennessee (Table 1) shows marginal enrichments of major
elements of calcium (by a factor of 2), magnesium (1.3), and
aluminum (1.5), and large enrichments of trace elements
such as strontium (30), arsenic (21), barium (5), nickel (5),
lithium (5), vanadium (4), copper (3), and chromium (2).
The high arsenic concentration in the TVA coal ash (mean
= 75 mg/kg) is consistent with previously reported As in ash
10.1021/es900714p CCC: $40.75 �, 2009 American Chemical Society
Published on Web 05/04/2009

FIGURE 1. Map of the sampling sites of the TVA coal ash spill in Kingston, Tennessee. Site descriptions are reported in Supporting
Information (Google maps provided the base map).
TABLE 1. Average Metals Concentrations (mg/kg) in TVA Coal Ash and Background Soil in Kingston, TN'
material n
Al
As Ba Be Cd Ca
Cr
Co Cu Fe
Ph
Li Mg
Mn
Mo
Ni Se
Sr V 2n
coal ash
average (mg/kg) 12
14109
74.6 354.2 3.1 0.03 3325
24.8
13.5 46.2 13333
19.0
24.6 1616
102
2.1
23.0 0.2
201.0 76.7 40.4
STD
7264
20.4 248.8 1.8 0.08 1142
7.6
6.0 16.6 2807
6.6
6.8 1531
54
2.0
8.0 0.6
39.3 30.6 12.5
background soil
average (mg/kg) 12
9367
3.5 73.8 0.3 0.01 1418
11.9
7.3 15.9 15200
16.5
5.3 1211
1056
0.2
4.4 0.9
6.8 20.9 29.7
STD
3485
2.3 51.9 0.3 0.21 933
5.3
7.8 35.2 6729
8.4
1.9 5580
1007
0.4
4.7 1.8
4.3 4.4 11.7
ash/soil ratio 1.5 21.4 4.8 9.4 3.0 2.3 2.1 1.9 2.9 0.9 1.1 4.6 1.3 0.1 13.4 5.2 0.2 29.8 3.7 1.4
a Samples were collected and analyzed by the Tennessee Department of Environment and Conservation and the
Tennessee Department of Health.
residue of both hard coal (anthracites, bituminous, and
subbituminous A and B; As = 50 mg/kg) and brown coal
(lignites and subbiturninous C; As = 49 mg/kg) (7). In
addition, the mercury level of the TVA coal ash (an average
of 151.3 f 15.9 yg/kg; Table 2) is higher than background soil
in Tennessee (45 ,ug/kg) (23). These concentrations are
consistent with the range of values reported in fly ash
(100--1500 pg/kg) (24). Likewise, the 226Ra (a mean of 4.4 ±
1.0 pCi/g) and 22811a (3.1 ± 0.4 pCi/g) activities of the coal ash
are higher than those in local soil in Kingston (L1 f 0.2 and
1.4 ± 0.4 pCi/g, respectively; Table 3). The Ra activity of the
TVA coal ash is similar to the levels reported previously for
fly and bottom ash from a Kentucky utility (Table 3) with a
consistent activity 228Ra/226Ra ratio of ^-0.7 (25). The potential
impact of Ra on the environment and human health is an
important consideration in remediation of the spill and is
discussed below.
The Hg concentration increases from 16-54 ag/kg in
upstream sediments, collected at the shoreline of the Emory
and Clinch Rivers, to a level of 53 pg/kg directly across
from the spill site (Site 8; Figure 1), and up to 92-130
eglkg in sediments from the downstream Clinch River at
Sites 9 and 10 (Tables 2 and S1). The Hg concentrations
of the upstream sediments are consistent with previously
reported Hg data for the overall Tennessee River (Table 2)
(23). A historical massive release of Hg from the Oak Ridge
Y-12 plant into East Fork Poplar Creek has resulted in
accumulation of Hg in the sediments from the downstream
Clinch River (26, 27), which could have provided a I -Ig
legacy source for the Clinch River sediments. Our direct
sampling of two sites in the upstream Clinch River (relative
to the coal ash spill; Table 2) and downstream of the Y-12
source in Oak Ridge resulted, however, in low Hg contents
of the river sediments (16 t 5 upstream and 54 ± 11 Pglkg
downstream of Poplar Creek), which are similar to
background values we report for the Emory River (Table
2). In contrast, sediments from the downstream Clinch
River (sites 9 and 10) have higher Hg content (>100pg/kg),
which suggests a significant contribution of Hg from the
coal ash to the river sediments. We therefore conclude
VOL. 43, NO. 16, 2009 /ENVIRONMENTAL SCIENCE & TECHNOLOGY. 6327

TABLE 2. Ng Results (,ug/kg) in Coal Ash and River Sediments Associated with the Spill Area in Kingston, TN'
total Hg, ,ug/kg average
± SD In - 3)
sample ID
site no. in Figure 1
description
210 -Ph total Ra
22BRa/221Ra
the cove
Feb 7
March 28
RC8S1 coal ash
4.9
upstream
3.57 8.1
0.65
LR2
site 2
upstream Emory River
43 ± 0.5
10 (n = 1)
LR1 1
upstream of site 3
upstream Clinch River
NA
1615
TDEC data
(just downstream of Oak Ridge)
LR10
site 3
upstream Clinch River
NA
54 ± 11
LR1
site 7
close to the spill on Emory River
29.7 ± 3
22 ± 0.2
Kentucky coal ash
coal ash
RC8S1
site 6
spilled ash pile
139 ± 5
NA
RC8S2
site 6
spilled ash pile
145 ± 12
NA
'TDEC data are from the Tennessee Department of Environment
and Conservation
downstream
Department of
Health. Kentucky coal ash data are from ref 25.
RC3
site 8
across from spill on Emory River
53+3
NA
LR9
site 9
convergence of Clinch and Emory Rivers
130 ± 5
104 ± 12
LR8
site 10
downstream Clinch River (1-40)
115 ± 9
92 ± 32
LR6
site 11
downstream Clinch River
NA
81 ± 38
LR7
downstream of
downstream Clinch River
site 11
(before convergence with TN river)
NA
51 ± 10
Background soil, Tennessee
Lower Clinch River (n = 9)
45 ± 12
Upper Tennessee hydrological unit (n - 73)
47 ± 27
Roane County
56 ± 23
' Background data of Hg in Tennessee soil from ref 23.
that ash transport and deposition in the Clinch River has
increased the Hg content in the river sediments.
Water Contamination. Results show that the tributary
that was dammed by the coal ash spill and turned into a
standing pond ("the Cove" in the area of Swan Pond Circle
Road; Figure 1) has relatively high levels of leachable coal
ash contaminants (LCAC), including arsenic, calcium, mag-
nesium, aluminum, strontium, manganese, lithium, and
boron (Table 4; Figure 2). Some of these elements are highly
enriched in coal ash (6, 8) (Table 1), and are known to be
highly soluble in aquatic systems (8). Among the LCACs,
arsenic stands out with concentrations of up to 86 pg/L in
the Cove area. Groundwater data from the other tributary
(Figure 1) show negligible LCAC levels, thus indicating that
the shallow groundwater is not contaminated. In this
hydrological setting, noncontaminated groundwater dis-
charges into the dammed tributary and causes leachingb of
LCAC from the coal ash. Under restricted water exchange,
the formation of standing water in the Cove resulted in
contaminated surface water. In contrast, surface waters from
the Emory River and Emory- Clinch River downstream from
the breached dam show only slight LCAC levels, and all river
inorganic dissolved constituents concentrations are below
the EPA Maximum Contaminant Levels (MCL) and EPA
6328 ® ENVIRONMENTAL SCIENCE & TECHNOLOGY / VOL. 43, NO. 16, 2009
Criterion Continuous Concentration (CCC) for aquatic life
(Table 4) (28, 29).
The upstream Clinch River has a distinct chemical
composition (higher Na', Ca `, Mg", Sr2', and SO4'-) relative
to the upstream Emory (Table 4), and thus the major inorganic
constituents show mixing relationships between these two
water sources (Line MI in Figure 2) downstream from
the confluence of the Emory and Clinch rivers (Figure 1).
The concentrations of arsenic, strontium, and boron in the
downstream river samples deviate toward higher values,
however, relative to these river mixing relationships (Figure
2). These geochemical shifts reflect a small but traceable
indication of leaching of contaminants from coal ash that
was spilled into the river and further mixing with the
uncontaminated river water (Line M2 in Figure 2). The data
show that the river flow is effective in reducing the LCAC's
contents by an order of magnitude relative to directly
contaminated water measured in the Cove.
The water samples were collected near the shoreline of
the river, which may be an underestimate of the concentration
of dissolved elements throughout the river vertical profile.
The spatial distribution of contaminants (dissolved and
suspended particulate fractions) in a river water column
depends on a number of factors including particulate size,
TABLE 3. Radioactivity Data (pCi/g Unit) and Activity Ratios of Coal Ash and Background Data from the Spill Area
TN8
in Kingston,
samplelsite material
226Ra
22BRa
210 -Ph total Ra
22BRa/221Ra
the cove
RC8S1 coal ash
4.9
3.2
3.57 8.1
0.65
RC5S coal ash
2.6
2.1
154 4.6
0.79
RC8S2 coal ash
4.9
3.1
5.01 7.9
0.63
TDEC data
average for coal ash (n = 12) coal ash
4.4 ± 1.0
3.1 ± 0.4
7.5 ± 1.4
0.70 ± 0.07
average background soil (n = 15) soil
1.1 ± 0.2
1.4 ± 0.6
2.6 ± 0.7
1.21 ± 0.28
Kentucky coal ash
fly ash (average, n = 17) fly ash
4.4 ± 0.6
3.4 ± 0.6
6.5 ± 1.9 7.8 ± 0.9
0.77 ± 0.15
bottom ash (average, n -- 6) bottom ash
4.0 ± 1.2
2.9 ± 0.9
2.2 ± 2.9 7.3 ± 1.3
0.71 ± 0.21
'TDEC data are from the Tennessee Department of Environment
and Conservation
and the Tennessee
Department of
Health. Kentucky coal ash data are from ref 25.
that ash transport and deposition in the Clinch River has
increased the Hg content in the river sediments.
Water Contamination. Results show that the tributary
that was dammed by the coal ash spill and turned into a
standing pond ("the Cove" in the area of Swan Pond Circle
Road; Figure 1) has relatively high levels of leachable coal
ash contaminants (LCAC), including arsenic, calcium, mag-
nesium, aluminum, strontium, manganese, lithium, and
boron (Table 4; Figure 2). Some of these elements are highly
enriched in coal ash (6, 8) (Table 1), and are known to be
highly soluble in aquatic systems (8). Among the LCACs,
arsenic stands out with concentrations of up to 86 pg/L in
the Cove area. Groundwater data from the other tributary
(Figure 1) show negligible LCAC levels, thus indicating that
the shallow groundwater is not contaminated. In this
hydrological setting, noncontaminated groundwater dis-
charges into the dammed tributary and causes leachingb of
LCAC from the coal ash. Under restricted water exchange,
the formation of standing water in the Cove resulted in
contaminated surface water. In contrast, surface waters from
the Emory River and Emory- Clinch River downstream from
the breached dam show only slight LCAC levels, and all river
inorganic dissolved constituents concentrations are below
the EPA Maximum Contaminant Levels (MCL) and EPA
6328 ® ENVIRONMENTAL SCIENCE & TECHNOLOGY / VOL. 43, NO. 16, 2009
Criterion Continuous Concentration (CCC) for aquatic life
(Table 4) (28, 29).
The upstream Clinch River has a distinct chemical
composition (higher Na', Ca `, Mg", Sr2', and SO4'-) relative
to the upstream Emory (Table 4), and thus the major inorganic
constituents show mixing relationships between these two
water sources (Line MI in Figure 2) downstream from
the confluence of the Emory and Clinch rivers (Figure 1).
The concentrations of arsenic, strontium, and boron in the
downstream river samples deviate toward higher values,
however, relative to these river mixing relationships (Figure
2). These geochemical shifts reflect a small but traceable
indication of leaching of contaminants from coal ash that
was spilled into the river and further mixing with the
uncontaminated river water (Line M2 in Figure 2). The data
show that the river flow is effective in reducing the LCAC's
contents by an order of magnitude relative to directly
contaminated water measured in the Cove.
The water samples were collected near the shoreline of
the river, which may be an underestimate of the concentration
of dissolved elements throughout the river vertical profile.
The spatial distribution of contaminants (dissolved and
suspended particulate fractions) in a river water column
depends on a number of factors including particulate size,

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VOL. 43, NO. 16, 2009 / ENVIRONMENTAL SCIENCE & TECHNOLOGY- 6329

10
8
r�
M�1 6
O2J
E
d„s
i-
4
2
0
IN
2 4 6 8 10 12 14 16 18
Cl_ (mg/L)
10,
10'
rda
bA
1
0.1
0.01
lo,
10'
r�
0.1
jj
dl _ 'r®
A
®fir
r '
I
C
10 Ca 2+ (m /L) 100
1 1 1 1 0.01
10 1002+ 1000 10 100 1000
Sr (}Lg/L) Sr 2+(gg/L)
FIGURE 2. Variations of Na- and Cl- (A), Cat- and As (B), Sr 2' and B (D), and Sr'- and As (D) in water samples from the Cove
(triangles), Emory River upstream (open circles) and downstream (closed circles), and Emory—Clinch upstream (open squares) and
downstream (closed squares). Mixing of Emory and Clinch Rivers (Line 1) is identified by the major ion composition (A). Elements
that are enriched in coal ash, as reflected by the high concentrations in the Cove area (dashed line), show higher concentrations in
the downstream Emory—Clinch river samples relative to the expected Emory—Clinch river mixing composition (Line M1). Line M2
reflects possible mixing of contaminants derived from coal ash leaching near the spill area (dashed line) and the uncontaminated
Clinch River composition (Line Mi►.
turbulent flow conditions, seasonal flow changes, and
channel morphology (30). The dissolved phase, which was
measured in this study, is typically homogeneously distrib-
uted in a river, but can vary with the proximity to a point
source of pollution (30). Assuming that metal mobilization
in the river derives from both suspended ash and bottom
sediments, the distribution of dissolved constituents in the
water column would depend on numerous factors such as
differential river velocity, rate of mobilization, and water
depth (31). Further investigation is therefore required to
determine the vertical distribution of metals in the river water,
and whether sampling of the upper river section represents
the most diluted segment of the river flow.
Potential Environmental Impacts. While the downstream
river water shows only trace levels of LCACs (at the surface),
the downstream river sediments show high Hg concentrations
similar to the coal ash levels (115-130 pg/kg; Table 2). The
ecological effects of Hg in the coal ash and sediments depend
on the chemical lability of Hg in the solids and the potential
for mercury methylation in the impacted area. While previous
studies have demonstrated that Hg in CCP ash is not readily
soluble through acid -leaching protocols (32), Hg has a high
6330 ■ ENVIRONMENTAL SCIENCE & TECHNOLOGY / VOL. 43, NO. 16, 2009
affinity for natural organic matter (33, 34), which can promote
desorption if the Hg is associated with weaker binding sites
on metal -oxide minerals in the ash material (35). Further-
more, the transformation of Hg to methylmercury by
anaerobic bacteria in river sediments is a concern because
of bioaccumulation of methylmercury in food webs. Previous
studies have shown that sulfate addition can promote
methylation in freshwater ecosystems by stimulating sulfate -
reducing bacteria (36), the primary organisms responsible
for producing methylmercury in the environment (377. In
coal -ash -containing waters, a 10- to 20-foldincrease in SO4'_
concentrationswas observed in the Cove area relative to
unaffected upstream sites (Table 4). Therefore, the meth-
ylation potential of mercury from this material could be high
because the coal ash also provides an essential nutrient
(SO42-) that encourages microbial methylation. In addition,
accumulation of arsenic -rich fly ash in bottom sediment in
an aquatic system could cause fish poisoning via both food
chains and decrease Of benthic fauna that is a vital food
source (7, 38).
Potential Health Impacts. Of particular concern to human
health is the wind-blown resuspension of fly ash into the
r
D
r'
r
®r
r
r
r
M2
C
M 1
`5
E
1 1 1 1 0.01
10 1002+ 1000 10 100 1000
Sr (}Lg/L) Sr 2+(gg/L)
FIGURE 2. Variations of Na- and Cl- (A), Cat- and As (B), Sr 2' and B (D), and Sr'- and As (D) in water samples from the Cove
(triangles), Emory River upstream (open circles) and downstream (closed circles), and Emory—Clinch upstream (open squares) and
downstream (closed squares). Mixing of Emory and Clinch Rivers (Line 1) is identified by the major ion composition (A). Elements
that are enriched in coal ash, as reflected by the high concentrations in the Cove area (dashed line), show higher concentrations in
the downstream Emory—Clinch river samples relative to the expected Emory—Clinch river mixing composition (Line M1). Line M2
reflects possible mixing of contaminants derived from coal ash leaching near the spill area (dashed line) and the uncontaminated
Clinch River composition (Line Mi►.
turbulent flow conditions, seasonal flow changes, and
channel morphology (30). The dissolved phase, which was
measured in this study, is typically homogeneously distrib-
uted in a river, but can vary with the proximity to a point
source of pollution (30). Assuming that metal mobilization
in the river derives from both suspended ash and bottom
sediments, the distribution of dissolved constituents in the
water column would depend on numerous factors such as
differential river velocity, rate of mobilization, and water
depth (31). Further investigation is therefore required to
determine the vertical distribution of metals in the river water,
and whether sampling of the upper river section represents
the most diluted segment of the river flow.
Potential Environmental Impacts. While the downstream
river water shows only trace levels of LCACs (at the surface),
the downstream river sediments show high Hg concentrations
similar to the coal ash levels (115-130 pg/kg; Table 2). The
ecological effects of Hg in the coal ash and sediments depend
on the chemical lability of Hg in the solids and the potential
for mercury methylation in the impacted area. While previous
studies have demonstrated that Hg in CCP ash is not readily
soluble through acid -leaching protocols (32), Hg has a high
6330 ■ ENVIRONMENTAL SCIENCE & TECHNOLOGY / VOL. 43, NO. 16, 2009
affinity for natural organic matter (33, 34), which can promote
desorption if the Hg is associated with weaker binding sites
on metal -oxide minerals in the ash material (35). Further-
more, the transformation of Hg to methylmercury by
anaerobic bacteria in river sediments is a concern because
of bioaccumulation of methylmercury in food webs. Previous
studies have shown that sulfate addition can promote
methylation in freshwater ecosystems by stimulating sulfate -
reducing bacteria (36), the primary organisms responsible
for producing methylmercury in the environment (377. In
coal -ash -containing waters, a 10- to 20-foldincrease in SO4'_
concentrationswas observed in the Cove area relative to
unaffected upstream sites (Table 4). Therefore, the meth-
ylation potential of mercury from this material could be high
because the coal ash also provides an essential nutrient
(SO42-) that encourages microbial methylation. In addition,
accumulation of arsenic -rich fly ash in bottom sediment in
an aquatic system could cause fish poisoning via both food
chains and decrease Of benthic fauna that is a vital food
source (7, 38).
Potential Health Impacts. Of particular concern to human
health is the wind-blown resuspension of fly ash into the

atmosphere. It is well-known that wind-blown dust can travel
long distances, as exemplified byAsian dust storms that result
in transport to locations as far away as the U.S (39). It is
possible that coal ash exposed to the atmosphere can be
resuspended and transported to populated areas where
human exposure may occur. Fly ash -airborne particles with
diameters less thanl0 pm (PM10) are regarded as respirable
and may affect the human lung and bronchus (40-42). The
process of particulate resuspension will depend on a variety
of factors, including the fly ash particulate size and related
chemical and physical properties, wind speed and atmo-
spheric turbulence, and likely the relative humidity and
surface moisture (43, 44). The particles that are of most
importance for human health are in the fine particulate
(PM2.5) mode, which readily deposit deep in the lung (45).
Past work has shown that CCP ash has particulate sizes
ranging from less than 1 /gym to 100s of micrometers in size
(46, 47). In addition, there is a compositional relationship as
a function of fly ash particle size (46). Several studies have
also measured ambient fine particulate matter associated
with elevated concentrations of toxic metals in the vicinity
of coal-fired power plants (42, 48-50). In some cases, fly
ash -airborne particles were also found in remote areas (up
to 30 km from power stations) (42, 51). Overall, past work
indicates that coal ash contains inhalable particulate matter,
and that fly ash emitted from the burning of coal is readily
transported in the atmosphere.
The high concentrations of trace metals (Tables 1 and 2)
and radioactivity (Table 3) reported in this study for the bulk
TVA coal ash are expected to magnify, as fine fractions of fly
ash (which maybe resuspended and deposited in the human
respiratory system) are typically 4-10 times enriched in
metals relative to the bulk ash and the coarse size fraction
(7, 461. The toxic metal content in coal ash, the sizes of fly
ash particulates, and the ionizing radiation (IR) exposure
(both incorporated and external) may act synergistically or,
less frequent, antagonistically, affecting human health directly
(predominantly through inhalation of contaminated air) and
indirectly through the food chains (consuming contaminated
agricultural products) (14). Coal ash was recognized as a
Group I human carcinogen (based on occupational exposure
studies) associated with increased risks of skin, lung, and
bladder cancers (52). Arsenic and radium exposures in
humans are associated with increased risks of skin, lung,
liver, leukemia, breast, bladder, and bone cancers (53) for
exposure predominantly due to chronic ingestion or chronic
inhalation, with the dose—response curve dependent on
location, sources, and population susceptibility and/or
tolerance.
Health impacts of CCP ash have been predominantly
studied on animal models and human cell lines, with few
short-term epidemiological follow-ups. CCP ash particulates
affect lung epithelia] and red blood cells in animal studies
and human in vitro models, causing inflammation, changing
the sensitivity of epithelia, altering immunological mecha-
nisms and lymphocyte blastogenesis, and increasing the risk
of cardiopulmonary disease (e.g., pulmonary vasculitis/
hypertention) (54-57). Individuals with pre-existing chronic
obstructive pulmonary disease, lung infection, or asthma
are more susceptible to the coal ash affliction (58). Several
epidemiological studies have proved the significant health
hazards (such as enhanced risk for adverse cardiovascular
events) of fine -particulate air pollution for individuals with
type II diabetes mellitus and people with genetic and/or
disease -related susceptibility to vascular dysfunction, who
are a large part of the population (59).
Radium -226 and 22111a, which are the main sources of
low-dose IR exposure in coal ash, can remain in the human
lung for several months after their inhalation, gradually
entering the blood circulation and depositing in bones and
teeth with this portion remaining for the lifetime of the
individual. When inhaled, the radionuclides can affect the
respiratory system even without the presence of the other
coal ash components. Thus, the airborne particles containing
radioactive elements inhaled by cleanup workers of the
nuclear accident at the Chernobyl nuclear power plant caused
bronchial mucosa lesions, in some cases preneoplastic, with
an increased susceptibility to the invasion of microorganisms
in bronchial mucosa (60, 61). Consequently, the combined
radioactivity of coal ash at the TVA spill, together with other
enriched trace metals such as Ni, Pb, and As, may increase
the overall health impact in exposed populations, depending
on duration of exposure, and particularly for susceptible
groups of the population. It is important to underscore the
fact that at this time it is not possible to estimate the health
impacts of CCP ash resuspended particulates due to a lack
of information on the rate at which they are entrained into
the atmosphere, as well as their chemical, physical, and
synergistic properties linked to morbidity and mortality.
Clearly future studies are needed linking ambient element
and radionuclide concentrations with ground level CCP ash
characteristics, ambient meteorological characteristics, and
human population exposure.
This study has provided an initial assessment of the
environmental impacts and potential health effects associated
with the TVA coal ash spill in Kingston, Tennessee. The study
shows that the high metals contents of coal ash and their
high solubility resulted in contamination (e.g_, As) of surface
water associated with the coal ash spill in areas of restricted
water exchange. In the downstream Emory and Clinch Rivers
the leaching of trace metals is significantly diluted by the
river flows. While the levels of contaminants in the down-
stream Emory and Clinch Rivers are below the MCL levels,
high concentrations of Hg found in the river sediments pose
a serious long-term threat for the ecological system of these
rivers. This study also highlights the high probability of
atmospheric resuspension of fine fly ash particulates, which
are enriched in toxic metals and radioactivity, and could
have a severe health impact on local communities and
workers. Based on these initial results, this study provides
a framework for future and long-term monitoring of the TVA
coal ash spill and remediation efforts. Future studies should
focus on evaluating the ecological ramifications, such as
methylmercury formation in the sediments in the down-
stream Emory and Clinch Rivers, and the composition of
particulate matter in the air in the vicinity of the spill area.
Finally, future prognoses of the health impacts of residents
exposed to coal ash requires long-term follow-ups of various
population groups, including children and adolescents,
pregnant women, persons exposed in utero, and individuals
with pre-existing broncho -pulmonary diseases and diabetes
mellitus. All these factors must be included in remediation
efforts for the TVA Kingston coal ash spill.
We thank Bill Chameides, the Dean of the Nicholas School
of Environment, for his support and for initiating this study.
We also thank two anonymous reviewers and Jim Hower for
their informative, valuable, and timely comments that
improved the quality of this article. We acknowledge the
generous gift of Fred and Alice Stanback, which partly
supported this work.
Supporting Information Available
Supplementary description of the analytical techniques and
sample location. This material is available free of charge via
the Internet at http://pubs.acs.org.
VOL. 43, NO. 16, 2009 1 ENVIRONMENTAL SCIENCE & TECHNOLOGY. 6331

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