Comment on the Kingston Coal Ash Landfill
The Tennessee Department of Environment and Conservation (TDEC), Division of Solid Waste Management (DSWM), is receiving public comments on its tentative decision to issue a solid waste disposal facility major modification to the Tennessee Valley Authority (TVA) for construction, operation, closure, and post-closure care of the existing Class II landfill for the disposal of industrial waste consisting of gypsum waste, fly ash, bottom ash boiler slag, cinders, and clinkers generated onsite from the burning of coal and the operation of air pollution control equipment by the TVA Kingston Fossil Plant – IDL730000211. Comments will be accepted until 4:30 pm CST February 9, 2015.

The Tennessee Chapter of the Sierra Club and our partners believe that TDEC should revoke this permit and require TVA to find a geologically suitable location for this landfill on-site.

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Currently the landfill will be located over karst [limestone] topography, in an area that has significant sinkholes and is generally unstable. A bedrock contour diagram of the area suggests many areas where there is a potential of sinkhole collapse.

TVA already had a catastrophic dropout in 2010, during the first filling of the landfill. This dropout was so rapid it caused a vortex in the waste and resulted in contamination to the Clinch River. More sinkholes were discovered when the leak blowout was repaired. It is highly likely that another dropout will dump coal ash waste into the river if TVA is allowed to move forward with this landfill at this site.

TDEC is violating its own regulations if it permits a coal ash dump in an area that is unstable.

Groundwater monitoring requirements in the draft permit are wholly inadequate and do not require monitoring of all coal ash pollutants. TVA’s failure to monitor for these toxic metals is dangerous. TVA has tested for coal ash constituents previously at this site, knows it has found toxics, and needs to expand and improve monitoring. State solid waste regulations strongly encourage monitoring for coal ash constituents. Given the history of coal ash contamination caused by waste at the Kingston plant, it makes no sense for TDEC to allow TVA to operate this landfill without adequate groundwater monitoring requirements.

Adding coal ash to the previously allowed gypsum creates a greater risk from toxic metals being leached from the ash. Fly ash on average has much higher levels of metals than ordinary soils. Fly ash has twice the arsenic, three times the cadmium, almost twice the lead, twice the mercury, 20 time the selenium. TVA earlier detected a plume of selenium from the liquid gypsum slurry first dumped into stage 1 of this landfill.

The draft permit contains variances that pose a significant threat to the surrounding surface and groundwater. TDEC has specially allowed the landfill too close to the Clinch River. TDEC should require a much larger buffer zone because the 2010 sinkhole blowout show waste can reach the river so fast that is not detected and stopped before it hits the water. This landfill full of toxic ash could be flooded when the Clinch floods.

Please add your own comments to those provided and submit them by e-mail on Tuesday at 4:30. or have them postmarked on Tuesday.

TAKE ACTION! Submit Comments here