When you think of Cumberland County, Tennessee, you think of the 'Golf Capital' of the state. However, that is not exactly what Smith Mountain Solutions, LLC has in mind for the partially reclaimed Turner Mine on Smith Mountain.

The Cumberland County Chapter of SOCM has been knee-deep in the struggle to keep Cumberland County free from a Coal Combustion Waste (CCW) landfill. Coal ash is severely toxic and inherently unsafe. To place it in a partially reclaimed mine that sits within the most toxic coal seam in the state, the Sewanee coal seam, has indeterminate severe consequences to the land and waters surrounding, the air and the health of the people in the Smith Mountain Community and Cumberland County. Do you live in Cumberland County? Join SOCM today, and help us save Cumberland County from becoming the 'ashtray' of Tennessee! We meet once a month on Mondays at 5:30pm (cst) in Crossville. To join, contact Ann League at ann@socm.org or call the SOCM office at (865)426-9455. For more information, visit us online.

Coal Ash in Landfills and Mine Reclamation

Where does all that coal ash go?
U.S. coal-fired power plants produce 131-million tons of coal ash every year. In December of 2008, 5.4-million cubic yards of coal ash roared out of its containment pond and into the Emory River and adjacent communities in Roane County, Tennessee. Now TVA has to find a place to perpanently dispose of this coal ash as they clean it up, and many companies may come forward who want a shot at a contract with TVA to dispose of it.

What's in coal ash? What happens when you put it in landfills or use it to reclaim old minesites? Will adjacent communities be at risk?

These are questions being asked by many people in Cumberland County (and many others) in Tennessee. Why? Because a plan to bring TVA coal ash to an old mine site near Crossville is already in the works.

But citizens have organized to monitor these plans and hold elected officials, regulators and solid waste entrepeneurs accountable for any coal combustion waste disposal facilities in their communities.

TVA Kingston Fossil Plant Coal Ash Pond

This TVA Kingston Fossil Plant coal ash pond failed on December 22, 2008 sending 5.4 million cubic yards of coal ash into the Emory River and adjacent communities in Roane County, TN (photo by John Wathen)

Ash Plume in the Clinch River

Ash plume in the Clinch River at its confluence with the Tennessee River following the TVA coal ash disaster in December of 2008. (John Wathen photo.)

Please help keep our community safe!

Write OSM & TDEC Officials to let them know your concerns.

Cumberland Stewards
931-484-2633

Take Action

Comments to Office of Surface Mining
Deadline: Sept. 20, 2009 (Although the deadline has passed, it doesn't hurt to make sure your voice is heard by responding.)

Send by email or mail to:

Mr. William Winters, Supervisor (bwinters@osmre.gov)
Technical Group
Office of Surface Mining Reclamation and Enforcement (OSMRE)
710 Locust Street, Second Floor
Knoxville, Tennessee 37902

CC: Barry Atnip (Barry.Atnip@tn.gov),
Chuck Head (Chuck.Head@tn.gov)
Tennessee Department of Environment and Conservation
Tennessee Division of Solid Waste Management (DSWM)

Reference: Proposed Smith Mountain Solutions, LLC Monofill IDL 18-0217
Crossville Coal Inc.
Turner Surface Mine SMCRA Permit 3189 and
Mine No. 1 SMCRA Permit 3190,
Revision Number .04 and Revision Number .06

Both application revisions are to change the post-mining land use to implement an experimental application of an industrial / commercial facility to facilitate the site being utilized as a solid waste mono-fill to accept coal combustions products in the Sewanee coal seam of the Emory watershed.

An informal conference already has been granted.

Scope of the Revision Request: Crossville Coal Inc. has requested for a revision of its post-mining land use plan to an industrial/commercial land use, which will facilitate the installation of an experimental monofill site for coal ash. The proposal includes the construction by SMS of a structural monofill for coal ash only to assist with an environmental crisis at the TVA Kingston Steam Plant and to reclaim the surface coalmine.

Talking Points

Please Include Points 1 and 2 in all Comments

1. Full EIS required for this application as revision of end use to a coal ash landfill is a major federal action. The mine was never intended to be a landfill.
• Under NEPA guidelines a full EIS must be considered for this application to cover all the potential harms for a “first of its kind” coal combustion products (CCP) disposal facility in the Sewanee coal seam. The proposed industrial use for site, a coal ash landfill in the Sewanee coal seam, has never been done before.
• The application involves an experimental model of acid mine drainage (AMD) and CCP. SMS does not know all that could occur and how to address unexpected consequences.
• The effects of coal ash and AMD on a synthetic liner are unknown. No research has been conducted on the synergistic effects of coal ash and AMD on a synthetic liner. The proposed clay and synthetic liner are both experimental.
• The beneficial use of coal ash in Sewanee coal seam unproven. In this application, will fly ash help in reducing AMD? What evidence does EPA have that fly ash used in reclamation sites across the nation show anticipated impacts at these sites? What is the evidence that the proposed monofill will improve water quality in the Sewanee coal seam? How is it shown that the present treatment reclamation plan is not working?

2. Unsuitability of the Site
• The proposed landfill is in the toxic Sewanee coal seam. There is no way to prevent additional AMD.
• TN needs to set criteria for any coal ash disposal site suitability in Tennessee especially as it relates to the Sewanee coal seam.
• Hillsborough intends to continue mining near the proposed landfill site. Any additional excavation by Hillsborough or SMS will increase the chance for unanticipated events in the Sewanee coal seam. Excavation within one operation could affect the other in unanticipated ways.

3. Uncertain Waste: The applicant states in its request for revision, "the construction of a structural monofill (just CCP) to assist with an environmental crisis at the TVA Kingston Steam Plant." TVA and the EPA have repeated numerous times that none of the Kingston Coal Ash will be disposed of at Smith Mountain. OSM does not know the waste going into the proposed landfill. Uncertainty of the waste makes it difficult to review application.

4. Need to Wait on EPA Decision: Any proposal for land filling coal ash is premature until EPA sets the final standards for disposal of coal ash and determines whether or not it is hazardous.

5. Water Quality Concerns
• Because the landfill is within the Sewanee coal seam, the treatment plan must be for both AMD and CCP discharges.
• Sediment and ash will enter local streams because of stormwater run-off, leachate pond overflow, or through the settling of airborne particles. SMS describes an inadequate plant to prevent these impacts from occurring.
• The industry estimates that the landfill liners will function for up to 50 years, although failure of liners has occurred before then. Without a functioning barrier between the ash and groundwater, the landfill will have the dynamics of an unlined landfill. When the liner fails, and it will fail eventually, all the poisons contained in the ash will leach into the groundwater, impacting all the life that depends upon that water. No engineer can prevent that from happening.

6. Air Quality Concerns
• The project will have both visible fugitive dust emissions from the disposal operation and truck transport.
• The toxic metal content in coal ash, the sizes of fly ash particulates, and the ionizing radiation exposure (both incorporated and external) will affect human health directly through inhalation of contaminated air and indirectly through the food chains.

7. Public Health Concerns
• A third of the people living near Kingston coal disaster report respiratory problems, according to a TN Department of Health survey. We may find similar effects for those living on Smith Mountain Road. The monetary value of these health impacts is large.
• Based on similar operations, thousands of tons of coal ash will become airborne during truck transport and at the landfill itself. The respiratory problems caused by airborne ash are severe.
• When the landfill liner fails, another set of health problems will arise, especially among residents dependent upon well water.

8. Ecological Concerns
• Ultimate failure of the liner will destroy downstream aquatic life. All the life dependent upon these streams will suffer. Coal ash can decimate fish, bird, and frog populations. It can deform aquatic animals.
• OSM must request a full assessment from U.S. Fish and Wildlife Service (endangered and threatened species) TWRA (impacts on Catoosa WMA), and NPS (impacts on the waters of the OWSR.) The Obed River is a Tier 2 Level protected stream of the state.

9. Transportation Concerns
Smith Mountain Road was never intended to be used as SMS intends. This road now carries cars, some coal trucks, school buses, commercial and emergency vehicles. Adding hundreds of more truck trips per day to this road is courting disaster: loss of life, property damage, and coal ash spills.

Socio-Economic Concerns: OSM needs to conduct a regional economic impact study on the effects of this proposed operation.

Preferred Alternatives

  1. The proposed site is unsuitable for this kind of activity. The applicant needs to find a more suitable site for this project, one that is not located within the Sewanee coal seam. Such a site needs to be less vulnerable to unanticipated events.
    • Site situated with the Sewanee coal seam and has a complicated mining history
    • The transport of coal ash up inadequate mountain roads is an unnecessary hazard to people and the environment. A site needs to be found with less transportation hazards.
    • The site drains into Emory watershed, a protected stream and into the Catoosa WMA.
    • The proposed plan of the applicant is environmentally unworkable. The cumulative impacts create great potential harm for people and the environment.
  2. TVA should landfill coal ash on its own land. TVA needs to behave as a responsible steward and construct its own model coal ash landfill facility on its own land. It can partner with EPA to demonstrate somewhere on its 230,000 acres best management practices for coal ash disposal. We need to quickly end our dependence of coal and nuclear fuel and rely on energy efficiency and renewable energy.

News

An estimated 3.9 million tons of coal ash destined for Perry County landfill
Cleanup of coal ash at the TVA Kingston site could mean a revenue windfall for Alabama's Perry County, but some say the costs to the residents of county, one of the poorest in the state, could exceed the benefits…(6/28/09)
http://www.tuscaloosanews.com/article/20090628/NEWS/906279948/1007?Title=An-estimated-3-9-million-tons-of-coal-ash-destined-for-Perry-County-landfill

Was the Tennessee coal ash disaster really a once-in-a-lifetime event?
A new report from an engineering firm hired by the Tennessee Valley Authority identified factors behind last year's disaster that unleashed more than a billion of gallons of toxic ash from a massive storage pond at the federal company's Kingston plant in eastern Tennessee. It claims that the disaster was a one-of-a-kind event -- but skeptical coal ash watchdogs are calling for a more thorough investigation by federal authorities…(6/27/09)
http://www.southernstudies.org/2009/06/was-the-tennessee-coal-ash-disaster-really-a-once-in-a-lifetime-event.html

Unstable layer contributed to TVA's massive coal ash spill
Several factors that included a slime-like layer of unstable ash deep in TVA’s mountain of coal waste contributed to the massive failure at the Kingston power plant along the Emory River in December, a report released today says…(6/25/09)
http://www.tennessean.com/article/20090625/GREEN02/90625029/TVA+s+massive+coal+ash+spill+caused+by+slimes++other+factors

County approves SMS proposal to reclaim Smith Mountain mine
In a sardine-like packed courtroom, Cumberland County commissioners approved a proposed project that could bring fly ash into the county to reclaim a mine on Smith Mountain as well as at least $5 million in revenue into the county's general fund and highway department budget over the next three years…(6/16/09)
http://www.crossville-chronicle.com/homepage/local_story_167172018.html

Dominion kept 7-year secret on fly ash's environmental risks
CHESAPEAKE -- Dominion Virginia Power was warned as far back as 2001 that building a golf course with fly ash from its local coal-fired power plant might pose environmental risks…(May 2009)
http://hamptonroads.com/2009/05/dominion-kept-7year-secret-fly-ashs-environmental-risks

Coal ash dumps a ‘time bomb’ for Michigan water, environmentalists say
The dangers associated with waste from coal-fired power plants got some attention last month when a billion gallons of coal ash spilled from a storage pond in Tennessee, contaminating surface waters with arsenic, mercury and lead. Michigan has plenty of its own problems stemming from coal ash contamination, regulators and environmentalists say, but because the ash is stored underground the problems have largely gone unnoticed…(1/16/09)
http://michiganmessenger.com/11691/coal-ash-dumps-a-time-bomb-for-michigan-water-environmentalists-say

Important Links

EPA Wastes Home Page
http://www.epa.gov/epawaste/index.htm

EPA’s Fossil Fuel Combustion page.
http://www.epa.gov/osw/nonhaz/industrial/special/fossil/index.htm

EPA CCP Regulatory Determinations
Links to 2 key EPA determinations on coal combustion products and waste.
http://www.epa.gov/epawaste/conserve/rrr/imr/ccps/resources.htm

RCRA Online
http://www.epa.gov/epawaste/inforesources/online/index.htm

Subtitle D -- Resource Conservation and Recovery Act Page
http://yosemite.epa.gov/R10/OWCM.NSF/webpage/RCRA+Subtitle+D:+Managing+Municipal+and+Solid+Waste

C2 P2 Home
http://www.epa.gov/epawaste/partnerships/c2p2/index.htm

EPA: Benefits & Risks of Coal Combustion Products
http://www.epa.gov/epawaste/partnerships/c2p2/use/benefits.htm

EPA: Environmental Health Issues related to coal combustion products
http://www.epa.gov/epawaste/partnerships/c2p2/use/effects.htm

CCP State Reviews
Summarizes regulations of coal and non-coal solid wastes in different states.
http://www.epa.gov/epawaste/partnerships/c2p2/use/state.htm

EPA’s Guide to Managing Industrial Waste
http://www.epa.gov/epawaste/nonhaz/industrial/guide/index.htm

Coal Impoundment Website
http://www.coalimpoundment.org/default.asp

OHVEC Sludge Page
http://www.ohvec.org/issues/slurry_impoundments/index.html

Sludge Safety Project
http://www.sludgesafety.org/

Environmental Integrity Project
http://www.environmentalintegrity.org/

Sierra Ground Zero Report Executive Summary
http://www.sierraclub.org/groundzero/report2005_executivesummary.pdf

Full Ground Zero report:
http://www.sierraclub.org/groundzero/report2005.pdf

Ground Zero 2006 report
http://www.sierraclub.org/groundzero/report2006.pdf

Coal Waste Impoundments study - NRC: inspired by Martin County spill
http://www.nap.edu/catalog.php?record_id=10212

Managing Coal Combustion Residues in Mines
(This is a major study by the National Research Council that is also a foundation reference document for current proposed rules by the EPA. It can be read free online. The Executive Summary PDF can be downloaded free. You may also purchase the book or buy individual chapters and download them online.)
http://books.nap.edu/catalog.php?record_id=11592

Contact

Ann League, SOCM Organizer
ann@socm.org
865.426.9455