Don’t Like Your Test Results? Just Get a Different Test!

            When confronted with the fact that coal ash does not qualify as a “hazardous waste” based on standard accepted laboratory tests, anti-coal environmental activists have a simple answer:  Find a test that gives different results.

            The standard used by the U.S. Environmental Protection Agency to determine whether a substance is hazardous is the “Toxicity Characteristic Leaching Procedure,” or “TCLP” test.  This test measures whether toxic metals that are present in almost everything can “leach,” or migrate, out of the materials and into liquids where they may come in contact with humans or the environment.

            TCLP testing is used to characterize all sorts of substances – not just coal ash. It’s also a fact that coal ash rarely, if ever, exceeds hazardous waste criteria contained in the procedure.

            So anti-coal environmentalists have begun to argue that TCLP should no longer be used on coal ash. Instead, they favor using a new procedure that (surprise!) may show higher potential for leaching.

What is this procedure? EPA has been developing a new test for coal ash to provide a more comprehensive set of data than TCLP produces, covering a wide range of possible environmental conditions including extremes.  This procedure may prove very useful in making site specific management decisions regarding coal ash disposal.

Note that it MAY prove very useful.  The test is still in the developmental stages.  EPA is just beginning validation tests for the laboratory procedure, and guidelines for interpreting the large amounts of data it would produce have not yet been developed. It is not scientifically suitable for concluding whether an entire class of materials is “hazardous” and it may never be suitable for that purpose.

Activists who use extreme data derived from un-validated testing procedures to try to justify wholesale changes to environmental regulations that have been developed over decades are not pursuing what’s best for the environment.  They are pursuing a political agenda dedicated to the elimination of coal-fueled energy.

The best approach for the environment is to encourage the safe recycling of coal ash as a preferred alternative to its disposal.  Then, if some coal ash still must be disposed, it may become desirable to use tests like the new one being developed by EPA to ensure that the disposal is conducted in a manner that best protects human health and the environment.

Posted by: on: Mar 30, 2010 @ 06:47