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Debunking the Myth that 'Hazardous Waste' Labels Increase Recycling

 One of the most mind boggling claims by anti coal environmental activists and the U.S. Environmental Protection Agency is this: Recycling rates for coal ash will increase if EPA designates the material a "hazardous waste."

 Yes, you read that correctly. In the coal ash disposal regulations EPA proposed last year, the Agency predicts that recycling rates would actually increase if coal ash is designated a hazardous waste. Supporting that position are public comments by a handful of environmental activists who claim that concerns of the people who are actually engaged in recycling activities are unfounded.

 There's a reason why EPA and the activists would take these positions. EPA's regulatory impact analysis hinges on an assumption that less coal ash will get disposed in the future. If the Agency is wrong and a hazardous waste designation really does result in less coal ash being recycled, then the amount of ash being disposed will skyrocket and the actual cost of EPA's regulations will be many times higher than the Agency would like to admit.  Environmental activists who are dug in supporting federal enforceability of coal ash regulations -- which can only be achieved under current law with a "hazardous waste" designation -- similarly need to deny the damaging side effects of EPA's proposal on coal ash recycling. So a "hazardous waste" designation is good for you, that's their story and they're sticking to it,

 Of course, people who are actually engaged in recycling coal ash have a different view.  In eight day-long public hearings last year and tens of thousands of written comments submitted to EPA, recyclers and users of coal ash were unanimous in predicting devastating consequences from a "hazardous waste" designation.  These recyclers and users were particularly perplexed because the actual landfill engineering standards being proposed by EPA are essentially the same under both the "hazardous" and "non-hazardous" regulatory approaches.  Recyclers and coal ash users wonder why the Agency and its activist supporters are willing to risk an industry that recycles millions of tons of material every year just so that the federal government can seize enforcement powers from the states.

 To defend their position that a "hazardous waste" designation would be good for coal ash recycling, the Agency and its activist supporters point to materials that have been designated "hazardous" in the past and seen recycling rates go up afterwards.  The materials cited by EPA include electric arc furnace dust, electroplating wastewater sludge, chat from lead and zinc mining, used oil, spent etchants and spent solvents.

 The problem is that none of those materials are anything like coal ash.  Most of them actually qualify as a hazardous waste based on their toxicity. (Coal ash does not.) Almost all of them are reprocessed prior to recycling. (Coal ash is not.) Most of them get recycled in industrial processes, often by the same companies that produced the materials in the first place.  (Coal ash is distributed for recycling by thousands of other companies in tens of thousands of public and residential locations all over the country.) Many of them are produced and recycled very small quantities.  (Coal ash recycling is measured in the millions of tons.)

 Anti-coal activists also claim that the recycling industry will be able to "educate" coal ash consumers on the different regulatory classifications for disposal and recycling, thereby making consumers feel secure in continuing to use the product.  (Unfortunately, these same activists churn out a steady stream of propaganda referring to "toxic coal ash" and never even mention on their web sites or in their news releases that ash can be safely and beneficially recycled.)

In the end, the discussion comes down to a couple of common sense questions.  If coal ash is considered a hazardous waste on the property of the company that produces it, do you really think that company is going to want to spread it around thousands of locations in the community even if EPA says it's OK to do so for now?  Do you, as a consumer, want a material in your home, school or office that the EPA considers "hazardous waste" on the property of the person who made it?

The best solution for coal ash disposal problems is to stop throwing it away.  EPA and groups who purport to care about the environment should support policies that encourage safe and environmentally beneficial recycling of coal ash as a preferred alternative to disposal.  Instead, they persist in trying to build roadblocks instead of bridges.

Posted by: on: Apr 12, 2011 @ 06:19