Oct. 15, 2019: The Blue Ridge Environmental Defense League opposes the transfer of the coal ash pollution problem from the private power company to the public. The reintroduction of any poison into the environment under the guise of so-called beneficial use merely transfers the problem from one medium to another and from one community to another. A new way must be found.

Specific Comments on Proposed Changes
Regarding the five issues in this docket:

1. We oppose "replacing the 12,400-ton threshold that triggers an environmental demonstration with specific location-based criteria" because the specific, numerical benchmark provides an equitable and certain level of protection. And it does not prohibit the additional site-specific considerations such as wetlands, floodplains, seismic zones and other factors based on experience elsewhere.

2. Regarding so-called temporary placement of unencapsulated CCR on the land, we believe that this process would be unnecessary under the proposal we call Subtitle Z, which would have all coal ash encapsulated, managed and isolated from the groundwater on-site and above-grade at existing coal-fired power plants.

3. We support making groundwater monitoring and corrective action report data easier to understand so long as such summaries do not omit, misrepresent or gloss over the conclusions based on that data. Moreover, the original data must be made available contemporaneously with all such executive summaries.

4. Based on the adverse health effects of boron ingestion on prenatal development including atrophy of the testes and arrested spermatogenesis, we support establishing a groundwater protection standard for boron at the lowest level protective of human health; that is, a Maximum Contaminant Level at or below the EPA's Health Reference Level of 1.4 milligrams per liter. Boron should be added to the list of constituents for assessment and monitoring of coal ash.

5. We support revising the EPA's CCR website requirements to ensure that relevant facility information required by the regulations is immediately available to the public.

BREDL Full Comments