ACAA’s Junk Science Report Claims Coal Ash Is Like “Common Dirt”

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Earthjustice argues that the American Coal Ash Association (ACAA) produced a 'junk science' report by ignoring critical groundwater exposure pathways, manipulating EPA screening levels for arsenic and chromium, and cherry-picking data from the U.S. Geological Survey (USGS) to make coal ash appear similar to common soil. The critique highlights that fly ash concentrations of chromium and arsenic can be thousands of times higher than groundwater protection screening levels and notes the ACAA's failure to address risks from particulate matter inhalation.

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  • The ACAA report ignored the most significant health threat from coal ash: the ingestion of contaminated groundwater, focusing only on direct contact and inhalation.
  • When compared to EPA soil screening levels for groundwater protection, fly ash contaminants frequently exceed limits by orders of magnitude, with chromium and arsenic exceeding them by more than 10,000 times.
  • The ACAA manipulated the EPA residential soil screening level for arsenic by increasing the target cancer risk from 1 in 1,000,000 to 1 in 10,000, which loosened the screening level 100-fold from 0.4 mg/kg to 40 mg/kg.
  • The ACAA ignored the cancer risk of hexavalent chromium by using a screening level of approximately 110 mg/kg based only on noncancer risks, whereas the EPA residential soil screening level is 0.3 mg/kg and the groundwater protection level is 0.0006 mg/kg.
  • The ACAA cherry-picked USGS data by excluding 57 samples of pure fly ash from an Alaska facility and ignoring samples from Indiana, New Mexico, Ohio, and Wyoming to lower the reported arsenic concentrations.
  • The ACAA failed to analyze the health risks associated with the inhalation of particulate matter in coal ash, despite an EPA draft assessment suggesting a strong likelihood that dry handling would exceed National Ambient Air Quality Standards (NAAQS).
  • The ACAA previously published a 2009 fact sheet claiming the median arsenic level in coal ash was 4.6 mg/kg, while EPA data indicated the median level in fly ash is actually 43.4 mg/kg.

Cite the original document

APA
Earthjustice (n.d.). ACAA’s Junk Science Report Claims Coal Ash Is Like “Common Dirt”. https://earthjustice.org/wp-content/uploads/acaareport.pdf
Chicago
Earthjustice. ACAA’s Junk Science Report Claims Coal Ash Is Like “Common Dirt”. n.d. https://earthjustice.org/wp-content/uploads/acaareport.pdf.
Wikipedia
{{cite report |author=Earthjustice |title=ACAA’s Junk Science Report Claims Coal Ash Is Like “Common Dirt” |url=https://earthjustice.org/wp-content/uploads/acaareport.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{earthjusticendacaas, author = {{Earthjustice}}, title = {{ACAA’s Junk Science Report Claims Coal Ash Is Like “Common Dirt”}}, institution = {Earthjustice}, url = {https://earthjustice.org/wp-content/uploads/acaareport.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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