The discussion has driven me to look deeper into the docs supporting the rule. I knew about bi accumulation, but had no idea how detailed the analysis can get.. like the difference between lentic and loctic systems (huh?????).. turns out it is the difference between a lake and a stream. The comment below on streams remind me of the old 70's mantra" the solution to pollution is dilution"
https://www.epa.gov/sites/productio...steam-electric_detailed_study_report_2009.pdf
"In lentic aquatic systems, the hydraulic residence time, or the amount of time it takes for the water in the aquatic system to be replaced by influent (i.e., streams, precipitation), is relatively long, allowing pollutants to build up over time and making lentic systems more vulnerable to impacts from coal combustion wastewater"
"Lotic systems are water bodies with flowing water such as streams, rivers, and springs that may provide more rapid dilution of coal combustion wastewater discharges than lentic systems. The moving water in lotic systems provides a transport mechanism to disperse coal combustion constituents greater distances from the power plant, and enables aquatic organisms to move away from the areas of coal combustion wastewater contamination"
The EPA breaks down the effects into three categories: Lethal , sub lethal, and communitiy
"Lethal effects – fish kills and mortality to other organisms;
"Sublethal effects – histopathological changes, or accumulation of trace elements in tissue, and damage to reproductive and developmental success; and
"Population and community effects – changes in species abundance and composition."
You can kill the fish outright
" organisms were exposed to sediments, water, and food from the D-Area Power Facility grounds, and experienced a 75 percent mortality rate after 45 days. These studies and others indicate that the lethal effects of coal combustion wastewater exposure can be quite potent,"
Or you can just make their life miserable with sub lethal effects
"Exposure to coal combustion wastewater has caused a number of organisms to experience reproductive failure and other forms of diminished reproductive success
Or you can just annoy the humans in the area, (green well water ummmmmmm)
"Metals and other pollutants present in coal combustion wastewater may contaminate actual or potential drinking water sources by leaching from surface impoundments or landfills into groundwater or surface waters. For example, at the Chisman Creek Disposal Site, a fly ash landfill in Virginia, water in nearby residential wells turned green and testing revealed the wells were contaminated with selenium and sulfate from groundwater contaminated with leachate from coal combustion wastewater"
The EPA did their homework in promulgating the rule: fish kills, reproductive failure and green well water are not minor trace effects..