A review from the Fluoride Network

This new report by The Environmental Integrity Project, Coal’s Poisonous Legacy. Groundwater Contaminated by Coal Ash Across the U.S., is a much needed update on the issue. Throughout the report, the health-based threshold that was used for fluoride was 4 mg/L. For “unsafe groundwater caused by coal ash” 7% of the plants (18/265) exceeded this threshold for fluoride. This threshold of 4 mg/L is what the Environmental Protection Agency (EPA) still has on its books for both the Maximum Contaminant Level (MCL) and its goal (MCLG), even though the 2006 report of the National Research Council of the National Academies,  Fluoride in Drinking Water: A Scientific Review of EPA’s Standards, stated the following:

* Page 10: Maximum-Contaminant-Level Goal. In light of the collective evidence on various health end points and total exposure to fluoride, the committee concludes that EPA’s MCLG of 4 mg/L should be lowered… To develop an MCLG that is protective against severe enamel fluorosis, clinical stage II skeletal fluorosis, and bone fractures, EPA should update the risk assessment of fluoride to include new data on health risks and better estimates of total exposure (relative source contribution) for individuals. EPA should use current approaches for quantifying risk, considering susceptible subpopulations, and characterizing uncertainties and variability.

The report is often called the National Coal Ash report and its authors did their homework on the toxics of concern in ash by noting that fluoride was a neurotoxin.

The EPA’s Toxic Release Inventory has consistently reported on fluoride releases from coal-fired electric utilities, which are among the largest emitters of fluoride in the U.S. For example, the Fluoride Action Network distilled the following:

TRI: Rank by Industrial Sector for Hydrogen Fluoride Releases in 2010-2015 (see more)
Category (TRI Code)	2010 In Pounds	2012 In Pounds	2014 In Pounds	2015 In Pounds	2016 In Pounds
Coal-fired electric utilities (NAICS 2211)	Releases= 30,564,185 Wastes= 95,760,703	Releases= 21,590,813 Wastes= 81,872,956	Releases= 15,766,413 Wastes= 84,395,448	Releases= 12,296,177 Wastes = 60,411,985	Releases= 9,084,392 Wastes = 52,679,789

About the report

“The nonprofit Environmental Integrity Project (EIP), in collaboration with Earthjustice, the Sierra Club, Prairie Rivers Network, and other organizations, obtained and analyzed all of the groundwater monitoring data that power companies posted on their websites in 2018. The data cover 265 coal plants or offsite coal ash disposal areas, including over 550 individual coal ash ponds and landfills that are monitored by over 4,600 groundwater monitoring wells. This represents roughly three quarters of the coal power plants across the U.S. The rest of the coal plants have not posted groundwater data either because they closed their ash dumps before the Coal Ash Rule took effect in 2015, or because they were eligible for an extension or exemption.

… While the EPA was studying the need for the rule, it conducted a risk assessment, in which the Agency tried to estimate the magnitude of the risk, and the pollutants posing the greatest risk, from coal ash dumps.¹⁰ The EPA eventually determined that some pollutants were dangerous enough that they warranted routine monitoring, including the following:

• Arsenic causes many adverse health impacts, including multiple forms of cancer, neurological impairments in children, and skin conditions.¹¹ EPA’s risk assessment predicted significant risks of both cancer and non-cancer health effects near unlined coal ash ponds and landfills.¹²

• Boron is associated with developmental and reproductive toxicity (e.g., low birthweight and testicular atrophy),¹³ and is also toxic to aquatic life.¹⁴ EPA’s risk assessment predicted significant risks to both humans and aquatic plants and animals.¹⁵

• Cadmium causes kidney damage, and is, according to EPA, a “probable carcinogen.”¹⁶ In a preliminary screening analysis, EPA found potential risks to humans through both drinking water and contaminated fish.¹⁷ Cadmium is also toxic to fish themselves,¹⁸ and EPA’s risk assessment predicted significant ecological risks from cadmium.¹⁹

• Cobalt is associated with blood disease, thyroid damage, and other endpoints.²⁰ EPA’s risk assessment predicted significant cobalt risks in association with certain types of ash ponds.²¹

• Chromium, particularly the form known as hexavalent chromium, can cause cancer at low doses, and can also cause liver damage and other non-cancer health effects.²²

• Fluoride is a neurotoxin²³ that can also cause tooth and bone damage,²⁴ and may be carcinogenic.²⁵

• Lead is a well-known and potent neurotoxin. It is also, according to EPA, a “probable carcinogen,”²⁶ and can be toxic to aquatic life.²⁷ There is no truly “safe” level of lead exposure, especially for children.²⁸

• Lithium can cause kidney damage, neurological damage, decreased thyroid function, and birth defects.²⁹ EPA’s risk assessment predicted significant lithium risks to humans via drinking water.³⁰

• Mercury is a potent neurotoxin that bioaccumulates in aquatic food chains.³¹ EPA’s risk assessment predicted significant mercury risks via fish consumption, but not through drinking water.³² This is important because it suggests that mercury may present a significant risk even where groundwater concentrations are below drinking water standards.

• Molybdenum has been associated with gout-like symptoms in humans, and reproductive toxicity in laboratory animals.³³ EPA’s risk assessment predicted significant molybdenum risks.³⁴

• Radium (specifically the radium isotopes radium-226 and radium-228) is a radioactive and cancer-causing metal. EPA’s risk assessment did not look at radium, but EPA added radium to the list of groundwater monitoring constituents in the Coal Ash Rule “because there is evidence from several damage cases of exceedances of gross alpha [radiation], indicating that radium from the disposal of CCR may be problematic.”³⁵

• Selenium bioaccumulates in aquatic food chains, and is toxic to fish.³⁶ Selenium can also be toxic to humans, affecting skin, blood, and the nervous system.³⁷ In a preliminary screening analysis, EPA found that potential selenium risks to humans were greater through fish consumption than through drinking water.³⁸ EPA noted that selenium was the “most prevalent” constituent of concern in proven damage cases involving surface water impacts.³⁹ These damage cases typically involve fish kills or other fish toxicity, and have been “extensively studied” in places like North Carolina, South Carolina and Texas.⁴⁰

• Thallium has been associated with a long list of adverse health effects including liver and kidney damage and hair loss.⁴¹ EPA’s risk assessment predicted significant risks via drinking water, and in a preliminary screening analysis also identified potential risks through the consumption of thallium-contaminated fish.

In Table 1: Unsafe groundwater caused by coal ash

In Table 5: The Ten Most Contaminated Sites in the Country, these four plants had high fluoride contaminant levels:
San Miguel Plant (TX), Fluoride (x3)
Allen Steam Station (NC), Fluoride (x1)
Jim Bridger Power Plant (WY), Fluoride (x3)
Allen Fossil Plant (TN), Fluoride (x1)

Excerpts from Appendix A

State	Site Name	Pollutants exceeding safe levels (and by how much)	No. of Regulated Landfills	No. of Regulated Impoundments
AK	Healy Power Plant	Fluoride (x4)	0	4
AZ	Cholla Power Plan t	Fluoride (x1)	1	3
CO	Nucla Generating Station	Fluoride (x1)	1	0
IN	R.M. Schahfer Generating Station	Fluoride (x11)	1	4
KY	Trimble County Generating Station	Fluoride (x1)	0	2
MI	James DeYoung Power Plant	Fluoride (x1)	0	1
NC	Allen Steam Station	Fluoride (x1)	1	2
NC	Roxboro Steam Electric Plant	Fluoride (x1)	1	4
NM	Four Corners Power Plant	Fluoride (x5)	1	4
NV	North Valmy Generating Station	Fluoride (x2)	1	0
OH	Conesville Plant	Fluoride (x2)	1	1
OH	Gavin Power Plant	Fluoride (x2)	1	2
OH	Kyger Creek Station	Fluoride (x1)	1	2
OH	Northeastern 3&4 Power Station	Fluoride (x1)	1	1
TN	Allen Fossil Plant	Fluoride (x1)	0	1
TX	San Miguel Plant	Fluoride (x3)	0	3
TX	W.A. Parish Electric Generating Station	Fluoride (x1)	4	2
WY	Jim Bridger Power Plant	Fluoride (x3)	1	2

The report

Written and researched by Abel Russ and Courtney Bernhardt of the Environmental Integrity Project (EIP) and Lisa Evans of Earthjustice. Data gathering, analysis, and mapping by Keene Kelderman, Mariah Lamm, and Courtney Bernhardt (EIP) and Andrew Rehn of Prairie Rivers Network. Compliance monitoring assistance from Flora Champenois and Henry Weaver (Earthjustice). Data gathering assistance from Kira Burkhart, Flora Ji, Ben Kunstman, Camden Marcucci, Sammie McCormick, Hayley Roy, and Namratha Sivakumar (EIP); Akriti Bhargava, Katherine Clements, Tess Fields, Lauren Hogrewe, Harry Libarle, and Claire Pfitzinger (Sierra Club); Ricki Draper (Appalachian Voices); Susan Lee (NRDC); and Roland Rivera. Graphics and editing by Ari Phillips, with editing assistance by Lisa Evans, Earthjustice. Made possible with help from Earthjustice and the Sierra Club.

The Environmental Integrity Project is a nonprofit, nonpartisan organization that empowers communities and protects public health and the environment by investigating polluters, holding them accountable under the law, and strengthening public policy.

*The report is online at http://fluoridealert.org/wp-content/uploads/national-coal-ash-report.march-2019.pdf