Coal Ash Rule Public Data Postings: An Opportunity for Effective Risk Communication and Risk Management
May 9, 2019
The U.S. Environmental Protection Agency (EPA) Coal Ash Rule requires online public access to reporting of groundwater monitoring data for coal ash impoundments and landfills.1 Advocacy groups and the media have used the data presented in these reports to imply that coal ash sites pose a risk to the public based simply on the presence of constituents in groundwater at concentrations above regulatory threshold values. 2,3 Such scientifically inaccurate communications leads to public perceptions that can discourage the selection of corrective actions that are optimally protective of human health and the environment. For example, under certain circumstances, closure-in-place may be more protective overall than closure-by-removal, given the array of environmental and health impacts that may be associated with transport and disposal at an alternative location. However, advocacy groups frequently demand closure-by-removal without fully considering the public health and environmental implications of that option.

The Coal Ash Rule’s groundwater monitoring data posting requirement should be viewed as an important opportunity for factual scientific communication, effective stakeholder engagement, and trust building. This can be accomplished through carefully planned and implemented communications that share information together with the context necessary to bring risk perception closer to reality and facilitate a shared understanding for all stakeholders about the implications for public and environmental health. This means that communications must not only address constituent concentrations present in groundwater in relation to regulatory thresholds but must also address whether humans or animals could come in contact with these constituents in sufficient quantity to pose a risk of harm.

Ultimately, to support the selection and implementation of optimally protective corrective action for coal ash facilities, clear communication with stakeholders about risks is critical. The groundwater monitoring data postings required under the Coal Ash Rule provide an opportunity for effective risk communication that should be undertaken with considerable care.

Sources:
140 CFR § 257.90(e) and § 257.107(h).

2https://www.washingtonpost.com/national/health-science/report-finds-widespread-contamination-at-nations-coal-ash-sites/2019/03/03/d80c82e6-3ac8-11e9-aaae-69364b2ed137_story.html

3https://earthjustice.org/sites/default/files/files/National%20Coal%20Ash%20Report%203.4.19.pdf.

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