Collaborative Report by Superfund Centers Submitted in Comment to EPA Proposed Rulemaking on Coal-Fired Powerplants
May 19, 2022
The University of Arizona Superfund Research Center (UA SRC), in collaboration with sister Superfund Center at the University of New Mexico, teamed up to write a report commissioned by the nonpartisan Center for Applied Environmental Law and Policy (CAELP). The report, "Toxicity Review of Metals Emissions from Coal-fired Power Plants", uses Superfund Center data from mining-related studies from both UA and UNM extensively as a proxy for understanding exposures to particulate emissions from coal-fired power plants. Using these data, the report aims to address data gaps in the 2011 U.S. Environmental Protection Agency (EPA) Mercury and Air Toxics Standards (MATS) rule on hazardous air pollutant (HAP) emissions from coal- and oil-fired power plants.
In addition to mercury, coal combustion is a source for airborne emissions of arsenic, lead, chromium, nickel, cadmium, and a host of other metals including uranium. The report states that although exposures to these metals remains uncertain and health effects in humans continue to be investigated, there is sufficient evidence to conclude that these metals have serious and wide-ranging human health impacts, individually and in mixtures.
The information put forward in the report supports EPA regulation of coal-fired power plants’ emissions of hazardous air pollutants and posits that “additional reductions of coal-fired power plants’ emissions of these toxic metals would yield still unquantified health benefits that would support strengthening the rule.”
The report was submitted to the rulemaking docket (EPA-HQ-OAR-2018-0794) in response to the Feb. 9, 2022 U.S. Environmental Protection Agency’s Notice of Proposed Rulemaking on National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units—Revocation of the 2020 Reconsideration, and Affirmation of the Appropriate and Necessary Supplemental Finding; 87 Fed. Reg. 7624.
The report was a team effort led by Dr. Raina Maier, UA SRC Director and Dr. Johnnye Lewis, UNM SRC Director with contributions from several Superfund Center personnel including Dr. Priyanka Kushwaha from the Department of Environmental Science at the University of Arizona, Dr. Thomas A. De Pree and Dr. Debra A. MacKenzie from the College of Pharmacy, Health Sciences Center at the University of New Mexico.
Maier stated: “It was a pleasure working on this report with our sister Superfund Center at the University of New Mexico. Our Centers brought highly complementary expertise and research outcomes to the report that made its findings more comprehensive and compelling”.