FINDING A SOLUTION FOR NORTH CAROLINA’S COAL ASH PROBLEM
MEMORANDUM
TO: N.C. DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES (DENR) SECRETARY, DONALD VAN DER VAART
FROM: CHRISTOPHER VON TÜRK, CONCERNED ENVIRONMENTAL STUDIES STUDENT AT DAVIDSON COLLEGE
SUBJECT: FINDING A SOLUTION FOR NORTH CAROLINA’S COAL ASH PROBLEM
DATE: 4/6/2015
In North Carolina, there are currently over 100 million tons of coal ash stored in open-air pits.[1] In order to protect human and environmental health, policy changes need to be made to prevent coal ash from getting into our drinking water, as was the case in the Dan River accident.
Recent Actions
In light of last year’s coal ash accident at the Dan River, Duke Energy, legislators, and other stakeholders have been attempting to work out a solution with regard to the disposal of such waste. The incident was a dramatic reminder of a smoldering issue, highlighting that approximately 100 million tons of the substance sits in 33 open-air pits at 14 sites in North Carolina.[2] In August 2014, the North Carolina General Assembly passed legislation to deal with this issue.[3] The approved bill deals mostly with who should bear the brunt of the clean up costs: the customers or shareholders of Duke Energy. It only temporarily bans Duke from trying to raise consumers’ rates in order to pay for the coal ash fallout, and it requires a total cleanup of only four of the worst of the 14 sites. Furthermore, under the legislature’s timetable, it could take more than 15 years for Duke to close all its pits and lagoons and dispose of the ash.[4] In this memo, I have outlined three possible options to consider and have analyzed each option using a weighted decision analysis in order to determine the most effective and feasible of these options.
Coal Ash Background
In December 2014, the EPA determined that coal ash is not a hazardous substance.[5] Coal ash use is being reviewed by the N.C. Coal Ash Management Commission and in an ad hoc committee of the Environmental Management Commission, called Beneficial Reuse of Coal Ash, under the state Department of Natural Resources.[6]
Critics of the EPA decision in December denounced the agency for what they called lax regulation of a toxic byproduct. They argue that coal ash is full of chemicals that cause cancer, developmental disorders, and reproductive problems. In particular, critics of the decision fear that the toxins in coal ash can contaminate drinking water and can kill fish and wildlife.[7]
If the N.C. Coal Ash Management Commission determines that the critics are correct, i.e. if they determine that current coal ash disposal practices are problematic, then there are three possible strategies to deal with North Carolina’s coal ash problem, as noted below:
Proposed Strategies
- No change, continue with current regulations– this option would extend the current regulations. It would force Duke Energy to clean 4 of the 14 coal ash ponds.
- Refurbish the coal ash ponds that are currently in use/put ash in lined landfills– this option would prevent the leaking of any toxins associated with coal ash into groundwater. It would force Duke Energy to “cap and seal” all 14 of the coal ash ponds within the next few years.
- Recycle coal ash: use in wallboard, concrete, roofing materials, and bricks– this option would require Duke Energy to sell its coal ash to processing companies, which would make the product viable for construction purposes. It would force Duke to close all the open- air pits. Furthermore, this option has the benefit of “binding the ash in a product,” meaning that it would not be able to leach into groundwater.[8]
Administrative Feasibility
Both options (2) and (3) would require significantly more regulatory oversight and enforcement than option (1). The second option would require regulatory agencies to monitor the refurbishment of all 14 ponds, whereas the “no change” option would only require the monitoring of 4 ponds. In order to regulate option (3), a state-level, regulatory agency would have to monitor the sale and transport of coal ash to processing companies. A new committee within the DENR would have to be established; it could be called the “Beneficial Use of Coal Combustion Residuals Committee (BUCCRC).”
Social Costs/Benefits
The most socially equitable option would be (3) because it would shut down all of the coal ash ponds, which tend to be in the vicinity of poorer neighborhoods. Earthjustice attorney Marianne Lado has framed the case as “an important question of principle.” She asks, “do we as a country continue to look the other way when our waste is threatening the health of low-income communities of color?” [9]
Environmental Costs/Benefits
All three options are more beneficial to the environment than not regulating coal ash ponds at all, so we are making steps in the right direction. Option (3) would be the most environmentally-friendly alternative because it would not only force Duke Energy to close all of its coal ash pits, thereby preventing even the possibility of leaching into water sources, but it would also stimulate the “coal ash beneficiation” [10]industry. By recycling the coal ash for construction purposes, there is the added benefit of not having to use “virgin resources.” In this way, “coal ash beneficiation” has many environmental upsides.[11]
Economic Costs/Benefits
From an economic perspective, option (1) would be the cheapest of the three. I argue that options (2) and (3) would likely have an equivalent cost in that both would either the transport of coal ash, or the refurbishment of current sites. It is unclear exactly what the economic costs and benefits of option (3) would be for Duke Energy, its customers, and its shareholders, but what is known is that Duke is already recycling 43% of coal ash produced in day-to-day operations.[12] It should not be too much of a burden for Duke Energy to sell more of its waste—and if it does increase its costs, Duke can let its shareholders pay that expense.
Political Feasibility
Politically, option (3) would be the least feasible because of its necessity to establish a state-level, regulatory agency that would monitor the sale and transport of coal ash to processing companies. However, politicians might be able to frame this requirement to sell coal ash to processing companies as an opportunity for new jobs in a growing and “green” industry. I argue that options (1) and (2) are comparable in terms of their political feasibility—the only difference being the number of pits being refurbished (4 vs. 14).
Recommendation
Based on the decision analysis, the recycling option would provide the largest benefit to the greater public. Moreover, this would require the processing companies to use less “virgin resources.” However, health threats still remain an issue of concern, but in comparison to the alternative (leaving the coal ash in the open-air pits), the recycling option has far fewer health risks.
When dealing with a substance such as coal ash, which is known to contain toxins, including mercury and arsenic,[13] it is better to be precautionary than to neglect its potential harm. If we establish this coal ash recycling program swiftly, it can help to protect not only freshwater resources and human health, but also the environment (including fish and wildlife), before the damage done becomes irreversible.
| Options | Administrative Feasibility | Social Benefits | Environmental Benefits | Economic Benefits | Political Feasibility | Option Score (Weighted) |
| No Change | 3 | 1 | 1 | 3 | 2 | 1.875 |
| Refurbish coal ash ponds/ put ash in lined landfills | 2 | 2 | 2 | 2 | 2 | 2 |
| Recycle | 2 | 3 | 3 | 2 | 1 | 2.375 |
| Criteria Weight | .125 | .25 | .25 | .25 | .125 |
Five Criteria for Decision Analysis
I have presented a decision analysis for each of the three options based on five criteria: administrative feasibility, social costs and benefits, environmental costs and benefits, economic costs and benefits, and political feasibility. The idea behind considering all of these criteria is that the outcome should result in the greatest amount of benefit for as many stakeholders as possible. In my analysis, I argue that the social, environmental, and economic costs and benefits should receive the most weight (.25) whereas the administrative and political feasibility should receive less (.125). Each option is rated on a scale of 1 to 3. A score of “1” is associated with a low feasibility or where the costs outweigh the benefits. A score of “2” means that the decision has a medium feasibility, and the costs and benefits are about equal. A score of “3” is associated with a high feasibility, and the benefits outweigh the costs.
[1] Kenney, Andrew. “NC Lawmakers Pass Coal Ash Legislation; Adjourn Very Long Short Session.” Newspaper. Newsobserver. Accessed April 5, 2015. http://www.newsobserver.com/news/politics-government/state-politics/article10035944.html.
[2] Ibid.
[3] Bruce Henderson. “NC Senate Approves Ash-Pond Cleanup Schedule for Duke Energy.” Newspaper. Newsobserver. Accessed April 5, 2015. http://www.newsobserver.com/news/local/coal-ash-issue/article10335986.html.
[4] Ibid.
[5] US EPA. “2014 Final Rule: Disposal of Coal Combustion Residuals from Electric Utilities.” US EPA. Epa.gov. Accessed April 5, 2015. http://www2.epa.gov/coalash/coal-ash-rule
[6] Tonya Maxwell. “Coal Ash Upside? State, Duke Seek Benefical Uses.” Citizen Times, February 11, 2015. http://www.citizen-times.com/story/news/local/2015/02/11/state-duke-energy-seek-beneficial-coal-ash-uses/23254743/.
[7] “Coal Ash Contaminates Our Lives.” Earthjustice. Accessed April 5, 2015. http://earthjustice.org/advocacy-campaigns/coal-ash.
[8] US EPA. “Coal Ash Reuse.” Policies and Guidance. Accessed April 5, 2015. http://www2.epa.gov/coalash/coal-ash-reuse.
[9] “Ashes: A Community’s Toxic Inheritance.” Earthjustice. Accessed April 5, 2015. http://earthjustice.org/features/campaigns/photos-a-toxic-inheritance.
[10] Rathje, William L., and Carl A. Zimring. Encyclopedia Of Consumption And Waste : The Social Science Of Garbage. Thousand Oaks, Calif: SAGE Publications, Inc, 2012. eBook Academic Collection (EBSCOhost). Web. 5 Apr. 2015.
[11] US EPA. “Coal Ash Reuse.” Policies and Guidance. Accessed April 5, 2015.http://www2.epa.gov/coalash/coal-ash-reuse.
[12]Kenney, Andrew. “NC Lawmakers Pass Coal Ash Legislation; Adjourn Very Long Short Session.” Newspaper. Newsobserver. Accessed April 5, 2015. http://www.newsobserver.com/news/politics-government/state-politics/article10035944.html.
About Christopher Von Turk
I am a junior majoring in Political Science at Davidson College, and I have a keen interest in energy and sustainability issues, in particular the Energiewende in Germany.
Recent Comments