A technical review of the final report of the National Academy of Sciences "managing Coal Combustion Residues in Mines"

Abstract

On March 1, 2006, the National Research Council released to the public its final report by the National Academy of Sciences "Managing Coal Combustion Residues (CCRs) in Mines." Based on the news release of the National Academy of Sciences (NAS), putting coal ash back into mines for reclamation is a viable option for disposal, as long as precautions are taken to protect the environment and public health. The report also acknowledged that CCRs could serve a useful purpose in mine reclamation, lessen the need for new landfills, and potentially neutralize acid mine drainage. The report recommends development of enforceable Federal standards that give the States authority to permit the use of CCRs at mines but allows them to adopt requirements for local conditions. The report lists 40 findings or recommendations under 12 categories. This paper addresses the merits of these findings on a case by case basis against existing regulatory requirements, the applicability of data evaluated, and consideration of extensive data and scientific studies relevant to the subject. The NAS has chosen to use the term "Coal Combustion Residues" where OSM has historically used the term "Coal Combustion By-Products." The terms are interchangeable. The author is in agreement with the NAS findings that support: (1) the use of these materials in mine reclamation; (2) the need for specific Federal regulations under the Surface Mining Control and Reclamation Act of 1977 (SMCRA) that spells out the minimum permitting, bonding, and environmental performance standard requirements when they are placed on active coal mines; (3) the research priorities to specifically address the hydrogeologic fate of CCBs and any leachate generated by those CCBs in relation to public health and environmental quality; and (4) to develop mining appropriate leachate tests. A limitation of the report is its inability to: (1) acknowledge the significant differences between regulatory programs that control placement of CCBs at mines; (2) evaluate available ground water monitoring data and scientific research within the context of the applicable regulatory programs; and (3) acknowledge the volumes of scientific studies and State regulatory data that shows no degradation of water quality due to placement of CCBs at SMCRA mines for the last 29 years. The following review is strictly the opinion of the author and carries no institutional endorsement.