Tell EPA What You Think About Coal Ash!

The document argues that coal ash poses severe health and environmental risks, including cancer and water contamination, and asserts that only federally enforceable safeguards under RCRA Subtitle C can provide adequate protection. It highlights the failure of the Subtitle D approach and cites a 2008 disaster in Tennessee as evidence of the need for stricter regulations.

• Coal ash contains toxins such as arsenic, lead, cadmium, chromium, and selenium, which are linked to neurological damage, respiratory illness, organ disease, cancer, and reproductive and developmental problems. Contamination disproportionately affects the poorest communities.
• EPA risk assessments indicate that drinking water contaminated with arsenic from unlined coal ash waste ponds can be more dangerous than smoking a pack of cigarettes daily. In such areas, the cancer risk can reach 1 in 50, which is 2,000 times the EPA's acceptable risk level.
• The document argues that regulating coal ash under Subtitle D of the Resource Conservation and Recovery Act (RCRA) is an ineffective approach because it does not require states to adopt federal guidelines, thereby maintaining a system of voluntary and patchwork protections.
• A lack of federally enforceable safeguards contributed to a December 2008 disaster in Tennessee where a dam holding over 1 billion gallons of toxic coal ash failed, poisoning the Clinch and Emory Rivers and destroying 300 acres of land and dozens of homes.
• The author advocates for the EPA to regulate coal ash as a "special waste" under Subtitle C of the Resource Conservation and Recovery Act, asserting this is the only way to ensure the phase-out of dangerous waste ponds and the implementation of full protections.

APA

Earthjustice (n.d.). Tell EPA What You Think About Coal Ash! https://earthjustice.org/wp-content/uploads/epa-hearing-handout_coal-ash.pdf

Chicago

Earthjustice. Tell EPA What You Think About Coal Ash! n.d. https://earthjustice.org/wp-content/uploads/epa-hearing-handout_coal-ash.pdf.

Wikipedia

{{cite report |author=Earthjustice |title=Tell EPA What You Think About Coal Ash! |url=https://earthjustice.org/wp-content/uploads/epa-hearing-handout_coal-ash.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{earthjusticendtell, author = {{Earthjustice}}, title = {{Tell EPA What You Think About Coal Ash!}}, institution = {Earthjustice}, url = {https://earthjustice.org/wp-content/uploads/epa-hearing-handout_coal-ash.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }