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Coal Combustion Waste Impoundment 

Task 3- Dam Assessment Report 

John E. Amos Plant (Site 26) 

Bottom Ash Dam 

American Electric Power 

St. Albans, West Virginia 

Project # 0-381 

Assessment of Dam Safety 

Coal Combustion Surface Impoundments 

For the REAC Program 

Prepared for: 

Lockheed Martin Services, Inc. 

Edison, New Jersey 

For 

United States Environmental Protection Agency 

Prepared by:

Dewberry & Davis, LLC 

Fairfax, Virginia 

Under Contract Number: EP-C-04-032: REAC 

October 2009 

Revised December 9, 2009 
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INTRODUCTION, SUMMARY CONCLUSION, AND RECOMMENDATION

The release of over five million cubic yards of coal ash from the Tennessee Valley Authority's Kingston, Tennessee, facility 

in December 2008, which flooded more than 300 acres of land, damaging homes and property, is a wake-up call for 

diligence on coal combustion waste disposal units. We must marshal our best efforts to prevent such catastrophic failure 

and damage. A first step toward this goal is to assess the stability and functionality of the ash impoundments and other 

units, then quickly take any needed corrective measures. 

This assessment of the stability and functionality of the John Amos Bottom Ash Dam management unit is based on a review 

of available documents and on the site assessment conducted by Dewberry & Davis, LLC, personnel on Tuesday, 

September 8, 2009. Although we found the supporting technical documentation inadequate (Section 1.1.3), visual 

observations permit the conclusion that the embankments appear to be well maintained, safe, and structurally sound. 

There are no apparent indications of any unsafe conditions. The surveillance and monitoring program, however, are 

inadequate because no instrumentation is used to detect settling, displacement, and seismicity for the dam embankments. 

As detailed in Section 1.2.6, there are nine recommendations that may help to maintain a safe and trouble-free operation. 

In summary, the John Amos Dam is SATISFACTORY for continued safe and reliable operation, with no recognized existing or 

potential management unit safety deficiencies. We expect acceptable performance under hydrologic loading; our 

evaluation, suggests that performance against static and seismic loadings will be acceptable for the proposed modified 

conditions of the dam. Planned dam modification should assure structural stability, but if the existing conditions remain for 

several years, we recommend a structural stability analysis for various embankments in the Bottom Ash Pond Complex. 

The John Amos Coal Combustion Waste management system includes a separate Fly Ash pond. As assessment of the Fly Ash 

Pond dam is provided in a separate report. 

PURPOSE AND SCOPE 

This report evaluates the condition of and potential for waste release from selected High Hazard Potential management 

units. To protect lives and property from the consequences of a dam failure or the improper release of impounded slurry 

at electric utilities, the U.S. Environmental Protection Agency (EPA) has begun investigating the potential for catastrophic 

failure of Coal Combustion Surface Impoundments (management units). EPA seeks to identify conditions that may 

destabilize the structure and functionality of a management unit and any appurtenant structures; to note the maintenance 

status and any deterioration calling for immediate repair; to evaluate conformity with current design and construction 

practices; and to determine the hazard potential classification for units not currently classified by the management unit 

owner or by a state or federal agency. The initiative will address management units classified as having a Less-than-Low, 

Low, Significant or High Hazard Potential ranking. (For Classification, see pp. 3-8 of the 2004 Federal Guidelines for Dam 

Safety.) 

In February 2009, under CERCLA Section 104(e), EPA sent letters to coal-fired electric utilities for information on the safety 

of surface impoundments and similar facilities that receive liquid-borne material and store or dispose of coal combustion 

waste. The utilities’ responses were to help the Agency assess the structural stability and functionality of such 

management units and highlight facilities that should be inspected for the safety of the berms, dikes, and dams used to 

build them. 
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EPA asked utility companies to identify all management units: surface impoundments or similar diked or bermed structures; 

and landfills receiving liquid-borne material that store or dispose of coal-combustion residuals or by-products, including, 

but not limited to, fly ash, bottom ash, boiler slag, and flue gas emission control residuals. Utility companies responded 

with information on the size, design, age, and the amount of material placed in the units so that EPA could gauge which 

management units had or potentially could rank as having High Hazard Potential. 

The USEPA and its contractors used the following definitions for this study: 

"Surface Impoundment or impoundment means a facility or part of a facility which is a natural topographic 

depression, man-made excavation, or diked area formed primarily of earthen materials (although it may be lined 

with man-made materials), which is designed to hold an accumulation of liquid wastes or wastes containing free 

liquids, and which is not an injection well. Examples of surface impoundments are holding, storage, settling, and 

aeration pits, ponds, and lagoons." 

For this study, the earthen materials could include coal combustion residuals. EPA did not provide an exclusion 

for small units or based on whether the placement was temporary or permanent. Furthermore, the study covers 

not only waste units designated as surface impoundments, but also other units designated as landfills which 

receive free liquids. 

EPA is addressing any land-based units that receive fly ash, bottom ash, boiler slag, or flue gas emission control 

wastes along with free liquids. If the landfill is receiving coal combustion wastes with liquids limited to that for 

proper compaction, then there should not be free liquids present and EPA did not seek information on such units 

which are appropriately designated a landfill. 

In some cases coal combustion wastes are separated from the water, and the water containing de minimus levels 

of fly ash, bottom ash, slag, or flue gas emission control wastes, are sent to an impoundment. EPA is including 

such impoundments in this study, because chemicals of concern may have leached from the solid coal combustion 

wastes into the waste waters, and suspended solids from the coal combustion wastes remain. 

We also took into account the Amos Plant’s operating history and geographic location relative to down-gradient population 

centers and/or sensitive environmental systems. 

This report presents the opinion of the assessment team as to the potential of catastrophic failure and reports on the 

condition of the management unit(s). The team considered criteria in evaluating dams under the National Inventory of Dams 

in making these determinations 

LIMITATIONS

The assessment of dam safety reported here is based on field observations and review of readily available information 

from the owner/operator of the subject coal combustion waste management unit(s). Qualified Dewberry engineers 

performed the field observations and review and made the assessment in conformance with the required scope of work 

and in accordance with reasonable and acceptable engineering practices. No other warranty, either written or implied, is 

made with regard to our assessment of dam safety. 
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Table of Contents 

INTRODUCTION, SUMMARY CONCLUSION, AND RECOMMENDATION........................................................................................................ ii

PURPOSE AND SCOPE ................................................................................................................................................................................ ii

1.0 CONCLUSIONS AND RECOMMENDATIONS ................................................................................................................................... 1

1.1 CONCLUSIONS ..........................................................................................................1

1.1.1 Conclusions Regarding the Structural Soundness of the Management Unit(s) ........1

1.1.2 Conclusions Regarding the Hydrologic/Hydraulic Safety of the Management 

Unit(s) 1

1.1.3 Conclusions Regarding the Adequacy of Supporting Technical Documentation .....1

1.1.4 Conclusions Regarding the Description of the Management Unit(s) .......................1

1.1.5 Conclusions Regarding the Field Observations ......................................................1

1.1.6 Conclusions Regarding the Adequacy of Maintenance and Methods of Operation .2

1.1.7 Conclusions Regarding the Adequacy of the Surveillance and Monitoring Program

 2

1.1.8 Classification Regarding Suitability for Continued Safe and Reliable Operation ....2

1.2 RECOMMENDATIONS ..............................................................................................2

1.2.1 Recommendations Regarding the Structural Stability ............................................2

1.2.2 Recommendations Regarding the Hydrologic/Hydraulic Safety .............................2

1.2.3 Recommendations Regarding the Supporting Technical Documentation ................2

1.2.4 Recommendations Regarding the Description of the Management Unit(s) .............2

1.2.5 Recommendations Regarding the Field Observations ............................................3

1.2.6 Recommendations Regarding the Maintenance and Methods of Operation ............3

1.2.7 Recommendations Regarding the Surveillance and Monitoring Program ...............3

1.2.8 Recommendations Regarding Continued Safe and Reliable Operation ...................4

1.3 PARTICIPANTS AND ACKNOWLEDGEMENT .......................................................4

1.3.1 List of Participants .......................................................................................................4

2.0 DESCRIPTION OF THE COAL COMBUSTION WASTE MANAGEMENT UNIT(S)............................................................................... 1

2.1 LOCATION ..................................................................................................................1

2.2 SIZE AND HAZARD CLASSIFICATION ...................................................................1

2.3 MAXIMUM CAPACITY AND AMOUNT AND TYPE OF RESIDUALS 

CURRENTLY IN THE UNIT(S) ............................................................................................4

2.4 PRINCIPAL PROJECT STRUCTURES .......................................................................4

2.4.1 Earth Embankment Dam .......................................................................................4
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2.4.2 Outlet Structures .........................................................................................................5

2.5 CRITICAL INFRASTRUCTURE WITHIN FIVE MILES DOWN GRADIENT ..........5

3.0 SUMMARY OF RELEVANT REPORTS, PERMITS AND INCIDENTS.................................................................................................. 1

3.1 SUMMARY OF REPORTS ON THE SAFETY OF THE MANAGEMENT UNIT(S) .1

3.2 SUMMARY OF LOCAL, STATE AND FEDERAL ENVIRONMENTAL PERMITS .2

3.3 SUMMARY OF SPILL/RELEASE INCIDENTS (IF ANY) .........................................2

4.0 SUMMARY OF HISTORY OF CONSTRUCTION AND OPERATION ................................................................................................... 1

4.1 SUMMARY OF CONSTRUCTION HISTORY ...........................................................1

4.1.1 Original Construction ............................................................................................1

4.1.2 Significant Changes/Modifications in Design since Original Construction .............1

4.1.3 Significant Repairs/Rehabilitation since Original Construction ..............................1

4.2 SUMMARY OF OPERATIONAL HISTORY ..............................................................1

4.2.1 Original Operational Procedures ............................................................................1

4.2.2 Significant Changes in Operational Procedures since Original Startup ........................2

4.2.3 Current Operational Procedures ..................................................................................2

4.2.4 Other Notable Events since Original Startup ...............................................................2

5.0 FIELD OBSERVATIONS .................................................................................................................................................................. 1

5.1 PROJECT OVERVIEW AND SIGNIFICANT FINDINGS ..........................................1

5.2 EARTH EMBANKMENT DAM ..................................................................................1

5.2.1 Crest ......................................................................................................................1

5.2.2 Upstream Slope ..........................................................................................................2

5.2.3 Downstream Slope and Toe ........................................................................................2

5.2.4 Abutments and Groin Areas ........................................................................................3

5.3 OUTLET STRUCTURES .............................................................................................4

5.3.1 Overflow Structure .....................................................................................................4

5.3.2 Outlet Conduit ............................................................................................................5

5.3.3 Emergency Spillway ...................................................................................................5

5.3.4 Low Level Outlet ........................................................................................................7

6.0 HYDROLOGIC/HYDRAULIC SAFETY ............................................................................................................................................. 1

6.1 SUPPORTING TECHNICAL DOCUMENTATION ....................................................1

6.1.1 Floods of Record ........................................................................................................1

6.1.2 Inflow Design Flood ...................................................................................................1
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6.1.3 Spillway Rating ..........................................................................................................1

6.1.4 Downstream Flood Analysis .......................................................................................1

6.2 ADEQUACY OF SUPPORTING TECHNICAL DOCUMENTATION ........................1

6.3 ASSESSMENT OF HYDROLOGIC/HYDRAULIC SAFETY .....................................2

7.0 STRUCTURAL STABILITY ............................................................................................................................................................... 1

7.1 SUPPORTING TECHNICAL DOCUMENTATION ....................................................1

7.1.1 Stability Analyses and Load Cases Analyzed .........................................................1

7.1.2 Design Properties and Parameters of Materials ...........................................................1

7.1.3 Uplift and/or Phreatic Surface Assumptions ................................................................1

7.1.4 Factors of Safety and Base Stresses.............................................................................1

7.1.5 Liquefaction Potential .................................................................................................2

7.1.6 Critical Geological Conditions and Seismicity ............................................................2

7.2 ADEQUACY OF SUPPORTING TECHNICAL DOCUMENTATION ........................2

7.3 ASSESSMENT OF STRUCTURAL STABILITY ........................................................3

8.0 ADEQUACY OF MAINTENANCE AND METHODS OF OPERATION ................................................................................................... 1

8.1 OPERATIONAL PROCEDURES.................................................................................1

8.2 MAINTENANCE OF THE DAM AND PROJECT FACILITIES .................................1

8.3 ASSESSMENT OF MAINTENANCE AND METHODS OF OPERATION ................1

8.3.1 Adequacy of Operational Procedures .....................................................................1

8.3.2 Adequacy of Maintenance...........................................................................................1

9.0 ADEQUACY OF SURVEILLANCE AND MONITORING PROGRAM .................................................................................................... 1

9.1 SURVEILLANCE PROCEDURES ..............................................................................1

9.2 INSTRUMENTATION MONITORING .......................................................................1

9.2.1 Instrumentation Plan ..............................................................................................2

9.2.2 Instrumentation Monitoring Results ............................................................................2

9.2.3 Evaluation ..................................................................................................................2

9.3 ASSESSMENT OF SURVEILLANCE AND MONITORING PROGRAM ..................3

9.3.1 Adequacy of Inspection Program.......................................................................................3

9.3.2 Adequacy Instrumentation Monitoring Program..........................................................3
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APPENDICES

APPENDIX A – REFERENCE DOCUMENTS 

 

Doc 01: Dam Location-Google Aerial 

 Doc 02: Application for raising the Dam 

 Doc 03: Review Document List 

 Doc 04: Responses to May 12, 2008, DEP Review Letter John Amos Plant - Bottom Ash Complex 

 Doc 05: West Virginia DEP February 10, 2009, Dam Inspection 

 Doc 06: John Amos 2008 Inspection Report 

 Doc 07: 2009 Dam and Dike Inspection Report - John Amos 

 Doc 08: Responses to February 15, 2005, DEP Review Letter John Amos Plant - Bottom Ash Complex 

 

APPENDIX B – PHOTOGRAPHS 

 Doc 09: Photographs 

APPENDIX C – FIELD OBSERVATION CHECKLIST 

 Doc 10: Dam Inspection Checklist Form 

 
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American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

1.0 CONCLUSIONS AND RECOMMENDATIONS 

In 2005, the owner submitted an application for raising the dam by 4 feet (from 24 ft to 28 ft). The West Virginia Division of 

Water and Wastewater Management, indicated that WV – Dam Safety is in the final stages of issuing the Certificate of 

Approval to modify/raise the John Amos Bottom Ash Complex. Details of the proposed changes and related calculations 

can be found within this report. However, because the modifications have not yet been implemented to the Bottom Ash 

Pond Dam, this report focuses on the existing dam conditions. 

 1.1 CONCLUSIONS 

Conclusions are based on visual observations from a one-day site visit and review of technical documentation 

provided by American Electric Power (AEP). 

1.1.1 Conclusions Regarding the Structural Soundness of the Management Unit(s) 

 The embankment and spillway appear to be structurally sound, based on a review of the engineering data 

provided by the Owner’s technical staff and Dewberry engineers’ observations. 

1.1.2 Conclusions Regarding the Hydrologic/Hydraulic Safety of the Management Unit(s) 

 Adequate freeboard and capacity exist to safely pass the design storm of 50% PMP based on engineering 

analyses provided and Dewberry engineers’ review. 

1.1.3 Conclusions Regarding the Adequacy of Supporting Technical Documentation 

 Supporting technical documentation is inadequate. The original design documentation is limited to two 

drawings and no other technical documentation about the design of the existing facility was found in the 

reviewed information. Technical documents to verify the adequacy of the pond storage, outlet structures 

and the structural safety of the embankments and various dikes in the pond complex are not available. 

1.1.4 Conclusions Regarding the Description of the Management Unit(s) 

 The descriptions provided are appropriate. 

1.1.5 Conclusions Regarding the Field Observations 

 Embankments visually appear to be well maintained, safe, and structurally sound. There are no apparent 

indications of any unsafe conditions. 
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St. Albans, West Virginia Dam Assessment Report

1.1.6 Conclusions Regarding the Adequacy of Maintenance and Methods of Operation 

 Maintenance and methods of operation are adequate. There was no evidence of repaired embankments or 

prior releases observed during the field assessment. 

1.1.7 Conclusions Regarding the Adequacy of the Surveillance and Monitoring Program 

Surveillance and monitoring program are inadequate because no instrumentation is used to detect 

settling, displacement, and seismicity for the dam embankments. 

 

1.1.8 Classification Regarding Suitability for Continued Safe and Reliable Operation 

Facility is SATISFACTORY for continued safe and reliable operation. No existing or potential 

management unit safety deficiencies are recognized. Acceptable performance is expected under 

hydrologic loading but the performance against static and seismic loadings have only been 

evaluated to be acceptable for the proposed modified conditions of the dam. No theoretical 

calculations were identified to assess the dam safety against static and seismic loadings under 

existing conditions. 

 1.2 RECOMMENDATIONS 

1.2.1 Recommendations Regarding the Structural Stability 

Planned dam modification should assure structural stability, but if the existing conditions remain for 

several years, we recommend a structural stability analysis for various embankments in the Bottom Ash 

Pond Complex.

1.2.2 Recommendations Regarding the Hydrologic/Hydraulic Safety 

 None appear warranted at this time. 

 

1.2.3 Recommendations Regarding the Supporting Technical Documentation 

 None appear warranted at this time. 

1.2.4 Recommendations Regarding the Description of the Management Unit(s) 

 None appear warranted at this time. 
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American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

1.2.5 Recommendations Regarding the Field Observations 

 None appear warranted at this time. 

1.2.6 Recommendations Regarding the Maintenance and Methods of Operation 

 The maintenance and operation of the dam seem to be adequate. However, the following recommendations 

may help maintain safe and trouble-free operation: 

• Upon approval of the proposed upgrades to the Bottom Ash Pond complex, proceed with due speed to 

implement the improvements. 

• The observed crack in the concrete spillway discharge channel and the vegetation in the joints should 

be sealed and repaired as needed, especially if the spillway is not removed with the proposed 

modifications to the complex; 

• Before constructing the proposed modifications, the reservoir’s major trees and sources of floating 

debris should be cut and removed to reduce the chance of blockage of the new pipe spillways; 

• The observed small “vole” tunnels should be filled and the voles controlled as needed to prevent 

damages to the vegetation cover; 

• Verify successful completion of the removal of fill from the emergency spillway at the crest of the 

dam; 

• Monitor slopes showing erosion and backfill erosion gullies; 

• Mowing should be performed at least annually for proper monitoring of slopes (some tall brush was 

observed at several locations in Pond 1B and some minor brush observed along the slopes of the 

Treatment and the Sedimentation ponds); 

• Perform a hydrologic and hydraulic analysis to ensure suitability of the existing drainage shaft 1A (in 

Pond 1B) to handle design storm; 

• Install support to the wooden stairs down to drainage shaft 1A (in Pond 1B). 

1.2.7 Recommendations Regarding the Surveillance and Monitoring Program 

 Continue current program. 
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American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

1.2.8 Recommendations Regarding Continued Safe and Reliable Operation 

 None appear warranted at this time. 

 1.3 PARTICIPANTS AND ACKNOWLEDGEMENT 

1.3.1 List of Participants 

 Clark Stephen Conover- U.S. Environmental Protection Agency (EPA), Region 3 

Behrad Zand, American Electric Power (AEP) 

Gary Zych, American Electric Power (AEP) 

 Alan Wood, American Electric Power (AEP) 

 Son Webster, American Electric Power (AEP) 

 Roger R. Mc Kinney, American Electric Power (AEP) 

 R.T. Carroll, American Electric Power (AEP) 

 Paul Regan, American Electric Power (AEP) 

 James Filson, P.E. – Dewberry 

 Joseph P. Klein, III, P.E. – Dewberry 
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American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

2.0 DESCRIPTION OF THE COAL COMBUSTION WASTE MANAGEMENT UNIT(S) 

 2.1 LOCATION 

The John E. Amos Plant is located by the Kanawha River bank in Putnam County, West Virginia, just across the 

river from Raymond City, West Virginia. The main dam is on the north side of the complex. For a project 

location on aerial photograph see Appendix A – Doc 01. 

 2.2 SIZE AND HAZARD CLASSIFICATION 

The Bottom Ash Pond Complex consists of four cells enclosed by a dam/dike system. Figure 2.2-1 shows the 

Bottom Ash Complex configuration. 

Figure 2.2-1. John Amos Bottom Ash Complex Configuration.
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American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

The Bottom Ash Pond Complex is a multi-pond system where other wastewaters are separately treated in 

contiguous cells. The information here is based on the entire impoundment as regulated under dam safety 

rules. The main dam (labeled as “Main Perimeter Dike” on Figure 2.1-1), on the north side of the complex, has a 

maximum height of 24 feet, impounds about 30 acres, and can store 220 acre-feet. The lowest dam crest 

elevation is at 584 ft and elevation at the lowest downstream toe of the dam is 560 ft. The crests of the 

internal dikes are much lower than the main dike around the Bottom Ash Complex. The four cells in the complex 

are: 

• Raw Water Intake Basin, designated Pond 1A, is on the southeast portion of the Bottom Ash Pond Complex 

and is separated from the other cells by an interior dike. 

• Raw Water Intake Basin, designated Pond 1B, is on the west side of the Bottom Ash Pond Complex and is 

separated from other cells by interior dikes. 

• Primary Clarifier Reservoir, also referred to as the Reclaimed Water Pond, is along the north side of the 

Bottom Ash Complex. 

• Secondary Clarifier Reservoir, also referred to as the Treatment Basin, is in the northeast corner of the 

Bottom Ash Complex. 

The Bottom Ash Complex originally included a fifth cell, located in the northwest corner of the Complex, which 

was reportedly filled during the late 1980s or early 1990s and is no longer part of the complex. 

At the time of the last WV-Dam Safety inspection (February 10, 2009) and Dewberry and Davis LLC dam 

inspection (September 8, 2009), Pond 1B was active and Pond 1A was inactive. Pond 1B is a “raw sludge” cell 

and is being used to settle out bottom ash and sludge from the raw water being pumped to the cell. The decant 

water from this cell discharges into the primary clarifying cell (i.e., the Reclaimed Water Pond, Area No. 3) and 

then into the secondary clarifying cell (Treatment Basin). The discharge from the Treatment Basin enters the 

recycle Reservoir outside of the pond complex which sends the water back to the plant. Bill’s Creek travels 

around the downstream toe of the northern dike (the dam) then turns north toward the Kanawha River near the 

eastern side of the dam. Pond 1A is inactive and is in the process of being dried and cleaned out. The 

active/inactive status alters between Ponds 1A and 1B every one to two years. 

The normal pool elevation for Pond 1B is 579.5 ft with an impounding surface area of about 19.5 acres. (See 

Table 2.3). 
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American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

The classification for size, based on the height and the storage of the dam, is “Small” with the USACE 

Recommended Guidelines for Safety Inspection of Dams ER 1110-2-106 criteria summarized in Table 2.2a. 

Table 2.2a USACE ER 1110-2-106

Size Classification

Category 

Impoundment

Storage (Ac-ft) Height (ft)

Small < 1,000 25 to < 40

Intermediate 1,000 to < 50,000 40 to< 100

Large > 50,000 > 100

The John Amos Bottom Ash Dam has been classified by the West Virginia Dam Safety as a Class “2,” which is a 

structure with “Significant Hazard” potential. The West Virginia Dam Safety rules define Significant Hazard 

dams as: “those dams located where failure may cause minor damage to dwellings, commercial or industrial 

buildings, important public utilities, main railroads, or cause major damage to unoccupied buildings, or where a 

low risk highway may be affected or damaged. The potential for loss of human life resulting from failure of a 

Class 2 dam must be unlikely.” This classification is similar to the “Significant Hazard” classification per the 

Federal Guidelines for Dam Safety of April 2004. The Bottom Ash Dam may be categorized as Significant Hazard 

mainly because of potential for environmental damages and cost for pollution cleanup in case of failure or misoperation. 

 

Table 2.2b FEMA Federal Guidelines for Dam Safety

Hazard Classification 

Hazard Potential Classification Loss of Human Life Economic, Environmental, Lifeline Losses

Low None Expected Low and generally limited to owner

Significant None Expected Yes

High Probable. One or more expected Yes (but not necessary for this classification)

In 2005, the owner submitted an application for raising the dam by 4 feet (from 24 ft to 28 ft) (see Appendix ADoc 02, “Appl for raising.pdf”). Additional planned upgrades include replacing the existing concrete spillway 

(the high inlet principal spillway with a current crest elevation of 581.5 ft) with a two-pipe spillway. No 

discharge from the pipes is expected for events less than the 100-year design storm. The low inlet principal 

spillway with a current crest elevation of 576.1 ft will not change. The entire complex is expected to be still 

approved as a Class “2” structure capable of storing the 50% PMF without any discharge if the pipes were to 

become plugged. The revised hydrologic analysis for the proposed conditions (see Appendix A-Doc 04) shows 

that under the 50% PMF inflow at least 2.2 ft of freeboard would be maintained in the pond complex. The West 

Virginia Division of Water and Wastewater Management, Dam Safety Dam Inspection Report dated February 10, 

2009, indicated that WV – Dam Safety is in the final stages of issuing the Certificate of Approval to 

modify/raise the John Amos Bottom Ash Complex (see Appendix A-Doc 05, “WVDEP Orders - Bottom Ash Pond - 

2009 2.pdf”). Details of the proposed changes and related calculations can be found in Appendix A-Doc 04. 

Because the modifications have not yet been implemented to the Bottom Ash Pond Dam, this report focuses on 

the existing dam conditions. 
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American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

 2.3 MAXIMUM CAPACITY AND AMOUNT AND TYPE OF RESIDUALS CURRENTLY IN THE UNIT(S) 

The active/inactive status alters between BAP-1A and BAP-1B every one to two years. After the active cell 

becomes full, it is placed in inactive status to dry and to be cleaned out. It is not clear from the reviewed 

literature what portion of the pond remains open after each filling or what portion of the original design 

storage is restored after each cleaning cycle. 

Table 2.3: Amount of Residuals and Maximum Capacity of Unit 

John Amos Bottom Ash Pond 

Dam

Surface Area (acre)

19.5 acres at N.P.E. and 

26.5 acres at Max. P.E.

Current Storage Capacity (acre-feet) Data not provided

Total Storage Capacity (acre-feet) 357

Crest Elevation (feet) 584

Normal Pond Level (feet) 576 to 581.5

 

 2.4 PRINCIPAL PROJECT STRUCTURES 

2.4.1 Earth Embankment Dam 

The main dam is an earthen dike on the north side of the complex with a maximum height of 24 feet and a 

crest length of 800 ft. The upstream slope is 2 horizontal to 1 vertical and the downstream slope is 3 

horizontal to 1 vertical. Table 2.4.1 summarizes the main dimensions of the dam.

Table 2.4.1: Summary of Dam Dimensions and Size 

John Amos Bottom Ash Pond Dam

Dam Height (feet) 24 

Crest Width (feet) 15-26

Length (feet) 800

Side Slopes (upstream) (H:V) 2:1

Side Slopes (downstream) (H:V) 3:1

Hazard Classification Significant

 
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American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

2.4.2 Outlet Structures 

Currently there are two principal spillway outlets, one with a low inlet and one with a high inlet. The low 

inlet is an overflow structure with inlet crest elevation of 576.1 ft, and the high inlet spillway is a concrete 

overflow section with invert elevation of 584 ft. The drop inlet structure consists of a square concrete box 

36 inches on each side with a 24-inch long weir on the west side. The outlet pipe is a 24-inch corrugated 

metal pipe, which transfers water from the treatment basin to the outfall at the Kanawha River. There are 

no structures designated as emergency spillway but the high inlet spillway can discharge pond overflow 

and act like an emergency spillway. This spillway is a concrete trapezoidal channel roughly 2 feet deep, 

10 feet wide at the bottom, and 22 feet wide at the top. A small channel has been excavated in the earthen 

embankment to act as an approach channel to direct spilling flow toward the overflow spillway. Reviewed 

data did not include information regarding the size of the overflow dike. 

 2.5 CRITICAL INFRASTRUCTURE WITHIN FIVE MILES DOWN GRADIENT 

The WV-Dam Safety inspection report indicates that there are no residences or highways downstream of the 

Bottom Ash Pond dam. In a 2008 exchange of comments between the WV Dam Safety and Geo/Environmental 

Associates, Inc. (See Appendix A- Doc 04) it is stated that there is no roads or dwellings downstream of the 

dam along Bill’s Creek until its confluence with Kanawha River (this can be verified from the aerial photo in 

Appendix A- Doc 01). The Kanawha River is then so much larger than the volume of the dam that a failure wave 

in the Kanawha River would be insignificant. The WV Dam Safety still insists that the dam should be categorized 

as Significant Hazard due to the significant environmental pollution that it may cause as a result of dam failure. 
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3.0 SUMMARY OF RELEVANT REPORTS, PERMITS AND INCIDENTS 

 3.1 SUMMARY OF REPORTS ON THE SAFETY OF THE MANAGEMENT UNIT(S) 

In response to a Freedom of Information request, WV – Dam Safety provided an extensive package of design 

information, performance monitoring data and past inspection documents for the John Amos Bottom Ash Pond 

dam. The data were provided in form of electronic files. A complete list of data files including general data, the 

Bottom Ash Pond and as well as the Fly Ash Pond data and reports is provided in Appendix A-Doc 03 

“Review_Document_List.pdf”. A few of the most recent reports directly relevant to the safety of the Bottom 

Ash Dam are briefly summarized here. 

In the wake of the failure of the Kingston Power Plant in Tennessee, West Virginal Dam Safety issued an order to 

verify that the “Ash Dams” in West Virginia were visually inspected and evaluated to insure that they were in 

good visual condition and meet or exceed the requirements of the Dam Safety Act and Regulations and standard 

dam safety engineering fundamentals. To meet part of the requirements of that order, West Virginia 

Department of Environmental Protection (DEP) Dam Safety Staff inspected the Bottom Ash Dam on February 10, 

2009 and summarized their finding in a March 12, 2009 inspection report (see Appendix A-Doc 05, “WVDEP 

Orders - Bottom Ash Pond - 2009 2.pdf”). This report concluded that “In general, the John Amos Bottom Ash 

Complex appears to be working well and in good condition.” 

A third party consultant (Stantec Consulting Services Inc.) submitted the 2009 Dam and Dike Inspection report 

dated May 15, 2009 to AEP (see Appendix A-Doc 07, “2009 Dam and Dike Inspection Report - John Amos”). This 

report was prepared based on field reconnaissance and existing data and provided observations and 

recommendations for both the Fly Ash and Bottom Ash facilities. The inspection was conducted for Pond 1A, 

Pond 1B, the Reclaimed Water Pond, the Treatment Plant and the Sedimentation Pond. According to this report 

the overall condition of various parts of the Bottom Ash Complex was good and only several minor issues were 

observed and several maintenance recommendations were made. 

AEP annually conducts inspection of both the Fly Ash and Bottom Ash facilities. The 2008 report is included in 

Appendix A- Doc 06, “John Amos 2008 Inspection Report.pdf”. No major problems were reported in this report 

and the report concludes “Overall, the main perimeter and splitter dikes are in satisfactory condition.” Several 

maintenance recommendations were made the most important of which was to repair the concrete chute 

associated with the emergency spillway from the reclaim pond. The owner’s 2008 inspection report indicated a 

wet area near the toe of the main dam in the area of the Reclamation and Treatment Ponds. No free flowing 

water was observed. Monthly inspections reported for the period January 2008 through May 2009 do not note 

similar observations. 

 

 
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The monthly inspection reports for the period January 2008 through May 2009 indicate observed corrosion in 

two cells of the Bottom Ash Complex: 

• Drainage shaft #2 and through the weir of Pond 1A, and 

• Drainage shaft and pipe in pond 1B. 

The extent of corrosion is not described. The 2008 owner’s inspection report indicates that the discharge 

structure and shaft at pond 1A, and the discharge structure at pond 1B were in satisfactory condition. The 

owner’s 2008 report also indicated observations of an erosion gully on the upstream slope of an interior dike 

of pond 1B, and of erosion undermining the concrete lining of the emergency spillway near the toe of the dam. 

No other significant deterioration was indicated in the data reviewed. 

 3.2 SUMMARY OF LOCAL, STATE AND FEDERAL ENVIRONMENTAL PERMITS 

The facility is under regulation by the West Virginia Division of Water and Wastewater Management, Dam Safety 

regulations. West Virginia inspects the dam on a biannual basis. However, in response to the Kingston Dam 

failure, the State conducted a supplemental review. The main dam and appurtenances are inspected by plant 

personnel on a quarterly basis and by qualified engineers annually. 

In 2005 an application for raising the dam by 4 feet was submitted by the owner (see Appendix A- Doc 02, “Appl 

for raising.pdf”). The WV – Dam Safety is in the final stages of issuing the Certificate of Approval for this 

application. 

 3.3 SUMMARY OF SPILL/RELEASE INCIDENTS (IF ANY) 

Data included in the review documentation did not indicate any spills, unpermitted release, or other 

performance related problems with the dam over the last 10 years. 
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4.0 SUMMARY OF HISTORY OF CONSTRUCTION AND OPERATION

 4.1 SUMMARY OF CONSTRUCTION HISTORY 

4.1.1 Original Construction 

The reviewed documents did not include the original design and construction records. However, it is 

understood that the Bottom Ash Pond construction coincided the Fly Ash Pond construction in early to mid1970s. Appendix III (Project narrative) in recent correspondences relating to the proposed modification to 

the Bottom Ash Pond (see Appendix A-Doc 08, “Responses To February 15, 2005 DEP Review Letter John 

Amos Plant - Bottom Ash Complex.pdf”) states that “The earliest record available of the Bottom Ash 

Complex is dated 6/28/70.” This report enclosed a drawing entitled “Bottom Ash Arca Dikes,” that 

illustrates the original extent and configuration and elevation of the earthen embankment. 

4.1.2 Significant Changes/Modifications in Design since Original Construction 

 According to the information included in the report in Appendix A- Doc 08, the Bottom Ash Complex has 

undergone some modifications since 1970. In 1977 a road embankment on the northwest corner of the 

Pond 1B, a sedimentation pond and a splitter dike on the southeast corner of the Pond 1A were added. While 

the original 1970 drawing shows an open channel that acted as emergency spillway, the 1977 shows no 

emergency spillway. Thus, it is believed that by 1977, the channel spillway had been filled and taken out of 

service. Since 1977 subsequent modifications were taken place mostly related to the operation of the 

ponds. The sedimentation pond located along the west side of Pond 1B was eliminated from active use. 

That cell was reportedly filled during the late 1980s or early 1990s and is no longer part of the complex.

4.1.3 Significant Repairs/Rehabilitation since Original Construction 

No information was provided regarding any major repairs or rehabilitation. No evidence of prior releases, 

failures, or patchwork was observed on the earthen embankment during the visual site assessment and no 

documents or statements were provided to the dam assessor that indicates prior failures have occurred.

4.2 SUMMARY OF OPERATIONAL HISTORY 

4.2.1 Original Operational Procedures 

 

 The Bottom Ash Complex was designed and operated for bottom ash sedimentation and control. The inflow 

water is treated through gravity settling and deposition, and treated process water and stormwater runoff 

are discharged through an unregulated overflow outlet structure. The reviewed documentation did not 

include the original operation procedures. 
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4.2.2 Significant Changes in Operational Procedures since Original Startup 

 No documents are provided to indicate any operational procedures have changed. However, the 

elimination of the sedimentation pond (see Section 4.1.2) implies a change in operation procedure.

4.2.3 Current Operational Procedures 

Current operation of the ponds consist of sluicing bottom ash into Ponds 1A or 1B, allowing particles to 

settle and the overflow to circulate to the reclaim pond. The active/inactive status alters between Ponds 

1A and 1B approximately every one to two years. After the active cell becomes full, it is placed in inactive 

status to dry and to be cleaned out. The decant water from either cell discharges into the primary 

clarifying cell and then into the secondary clarifying cell (Treatment Basin). The discharge from the 

Treatment Basin enters the recycle Reservoir located outside of the pond complex which sends the water 

back to the plant. Bill’s Creek travels around the downstream toe of the northern dike (the dam) and then it 

turns north toward the Kanawha River near the eastern side of the dam. 

4.2.4 Other Notable Events since Original Startup 

The owner’s July 28, 2009, response to EPA’s Request for Information concerning the dam indicates that 

the dam has experienced no spills or unpermitted releases in the last 10 years. No additional information 

was provided. 
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5.0 FIELD OBSERVATIONS 

5.1 PROJECT OVERVIEW AND SIGNIFICANT FINDINGS 

 Dewberry & Davis, LLC performed a site visit on Tuesday, September 8th, 2009. The site visit began at 09:00 

AM. The Weather was warm and cloudy. The overall assessment of the dam was that it was in satisfactory 

condition and no significant findings were noted. Please refer to photographs in Appendix B taken by Dewberry 

& Davis, LLC during the 9/8/09 dam inspection and the Dam Inspection Checklist in Appendix C- Doc 10. 

Selected photographs are included here for ease of visual reference. All of these pictures were taken by 

Dewberry personnel during the 9/8/09 dam inspection. The overall assessment of the dam was that it was in 

satisfactory condition and no significant findings were noted.

5.2 EARTH EMBANKMENT DAM 

5.2.1 Crest 

The main dam is an earthen dike on the north side of the complex with a maximum height of 24 feet and a 

crest length of 800 ft. The crest width varies between 15 to 26 feet. The crests of the internal dikes are 

much lower than the main dike around the Bottom Ash Complex. 

 

 The crest had no signs of any depressions, tension cracks or other indications of settlement or shear 

failure, and appeared to be in satisfactory condition. Figure 5.2.1-1 shows the crest of the main dam of the 

Bottom Ash Complex. 

 

Figure 5.2.1-1 Crest of Main Dam Bottom Ash Complex Looking Westward. 
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5.2.2 Upstream Slope 

 The upstream slope mostly consists of unprotected compacted soil except for part of the upstream face of 

the Pond 1B which remains heavily vegetated with woody plants. Figure 5.2.2-1 shows the upstream slope 

of the main dam embankment (on the left side of the picture) on the north side of Area No. 3 where it is 

protected with scattered grass. Scarps, sloughs, bulging, cracks or scraps or depressions or other 

indications of slope instability or signs of erosion were not observed. 

Figure 5.2.2-1. The upstream Slope of the Main Dam (the Embankment on the Left Side of the Picture) 

5.2.3 Downstream Slope and Toe 

 The downstream slope is protected with some grass. Scarps, sloughs, depressions or other indications of 

slope instability or signs of erosion or uncontrolled seepage were not observed. Figure 5.2.3-1 shows the 

downstream slope of the center area of the main dam. Scattered rip-rap was observed along a section of 

the lower slope as shown in this picture. 
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5.2.4 Abutments and Groin Areas 

The abutments and groin areas appeared to be in good condition. Figure 5.2.4-1 shows the West Abutment 

of the main dam is protected with rip-rap. Culvert in this picture carries Bill’s Creek beneath the West 

Abutment. 

Figure 5.2.3-1. Downstream Slope at the Center Area of Bottom Ash Complex Main Dam (Looking Eastward). 

Figure 5.2.4-1. West Abutment of Bottom Ash Complex Main Dam. 
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 5.3 OUTLET STRUCTURES 

5.3.1 Overflow Structure 

 Currently there are two principal spillway outlets, one with a low inlet and one with a high inlet. The low 

inlet is an overflow structure with inlet crest elevation of 576.1 ft and a discharge capacity of 28.2 cfs 

which is the reservoir drain capacity. This drop inlet structure consists of a square concrete box 

approximately 36 inches on each side with an approximately 24 inches long weir on the west side. The 

outlet pipe is a 24 inch corrugated metal pipe which takes the water from the Treatment Basin to the 

outfall at Kanawha River. The primary overflow structure was observed to be working properly, 

discharging flow from the pond, and visually appeared to be in satisfactory condition. There was no sign of 

clogging of the spillway and the water exiting the outlet was flowing clear. Figure 5.3.1-1 shows the low 

inlet overflow structure. 

The high inlet spillway may be viewed as the emergency spillway and will be discussed in Section 5.3.3. 

Figure 5.3.1-1. Low Inlet Overflow Outlet Structure at the North Corner of the Treatment basin.
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5.3.2 Outlet Conduit 

The outlet pipe is a 24 inch corrugated metal pipe which takes the water from the Treatment Basin to the 

outfall at Kanawha River. Figure 5.3.2-1 shows the outlet end of the Treatment Pond Spillway discharging 

water to Kanawha River. There is a minor crack on the headwall of the outlet section. The visible section 

of the outlet conduit seemed to be in good condition with no sign of flow blockage. 

Figure 5.3.2-1 The outlet of the Treatment Pond Spillway Discharging Water to Kanawha River.

 

5.3.3 Emergency Spillway 

The high inlet spillway is an overflow section with invert elevation of 584 ft. This structure is designated 

as emergency spillway in some dam documents. This spillway is a concrete trapezoidal channel roughly 2 

ft deep, 10 ft wide at the bottom and 22 ft wide at the top. A small channel has been excavated in the 

earthen embankment to act as an approach channel to direct spilling flow toward the overflow spillway. 

This channel is shown in Figure 5.3.3-1. The upstream side of the concrete spillway is visible on the left 

side of the spillway. The entrance channel is partially blocked. This probably will present no major 

hindrance of the discharge through the overflow spillway as the water rises above the invert of the 

spillway. Figure 5.3.3-2 shows the downstream view of the emergency spillway. The overflow spillway is in 

fair condition. The lower portion of the concrete on the downstream side has broken off. The broken 

concrete section filled with rip-rap and covered with grass is visible on the downstream side of the 

spillway in Figure 5.3.3-2. .Photo 58 in Doc 07 offers a closer view of the broken section. The concreter 
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on the slope needs to be monitored and repaired with sign of further deterioration. Other than the 

concrete breakage, the spillway appeared to be in good condition with no sign of clogging. 

Figure 5.3.3-1. Approach Channel to Emergency Spillway Excavated to on the Main Dam Embankment. The Upstream Side of the 

Overflow Concrete Spillway is Visible on the Left Side of the Picture. 
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Figure 5.3.3-2. The Downstream View of the Emergency Spillway. The Broken concrete Section Filled 

with Rip-rap and Covered with Grass is Visible on the Downstream Side. 

5.3.4 Low Level Outlet 

 No low level outlet is present. 
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6.0 HYDROLOGIC/HYDRAULIC SAFETY 

6.1 SUPPORTING TECHNICAL DOCUMENTATION 

6.1.1 Floods of Record 

 No documentation has been provided about the floods of record. 

6.1.2 Inflow Design Flood 

 The inflow design flood used for the original design of the pond was not included in the reviewed 

documents. However, in the revised hydrologic analysis for the proposed conditions (see Appendix A-Doc 

04) the design rainfall for the existing dam configuration is listed as a six hour point rainfall of 27 inches. 

This rainfall depth is equivalent to the 6-hr PMP for this location. This suggests that, following the WVdam safety guidelines the dam may have been designed based on an inflow design flood generated by 50% 

of the 6-hr PMP. On the other hand, the same data source identifies the dam with a hazard classification 

of “3”. This classification would only require an inflow design flood between 100-year to 25% of 6-hr PMP, 

according to WV Dam Safety Guidelines. 

6.1.3 Spillway Rating 

The spillway rating for the existing spillway was not found in the reviewed data. The revised hydrologic 

analysis for the proposed conditions (see Appendix A-Doc 04) includes a spillway rating curve for the 

proposed spillway. 

6.1.4 Downstream Flood Analysis 

The reviewed information did not include a dam break analysis and flood inundation mapping for the 

Bottom Ash Pond. The WV – Dam Safety inspection report does not address critical facilities down 

gradient of the unit. Review of submitted documents, field observations and the aerial photo in Appendix ADoc 01 show that there is no roads or dwellings downstream of the dam along Bill’s Creek until its 

confluence with Kanawha River. The Kanawha River is then so much larger than the volume of the dam that 

a failure wave in the Kanawha River would be insignificant. 

 6.2 ADEQUACY OF SUPPORTING TECHNICAL DOCUMENTATION 

Supporting technical documentation is inadequate. The original design documentation is limited to two 

drawings that illustrate the original extent, configuration and elevations of the earthen embankment. No other 

technical documentation about the design of the existing facility was found in the reviewed information. The 

adequacy of the pond storage, outlet structures and the structural safety of the embankments and various 

dikes in the pond complex could not be checked. 
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 6.3 ASSESSMENT OF HYDROLOGIC/HYDRAULIC SAFETY 

 

 The original hydrology/hydraulic assessment used for the design of the Bottom Ash Pond Complex were not 

included in the reviewed documents. 

 A calculation may be performed to assess the adequacy of the existing pond size. From the information in the 

revised hydrologic analysis for the proposed conditions (see Appendix A-Doc 04), the design inflow may be 

calculated using the 6-hr 50% Probable maximum Precipitation (PMP). PMP is defined by American 

Meteorological Society as the theoretically greatest depth of precipitation for a given duration that is physically 

possible over a particular drainage area at a certain time of year. The National Weather Service (NWS) further 

states that in consideration of our limited knowledge of the complicated processes and interrelationships in 

storms, PMP values are identified as estimates. According to West Virginia Dam Safety Rules: “Class 2 dams 

must be designed with either an open channel spillway only or a combination of principal and emergency 

spillways. A Class 2 dam shall be capable of passing that portion of the design storm that cannot be safely 

stored in the impoundment. The design of a Class 2 dam must assure that ninety percent (90%) of the stored 

volume of the design storm will be discharged within ten (10) days after the storm event. “. For the location of 

the Bottom Ash Pond the 6-hr 50% PMP was estimated at 13.90 inches or 1.16 ft. Even if we conservatively 

assume the normal pool elevation to be at its highest level at the invert of the high inlet principal spillway 

(581.50’), there would be 2.50’ of freeboard between that elevation and the elevation at the top of dam 

(584.00’). The Bottom Ash Pond does not receive any considerable amount of runoff from surrounding areas 

and we may assume the direct precipitation is the only source of inflow during large storms. Therefore, the 

maximum rise of the water level in the pond would not be much larger than 1.16 ft which would leave at least 

1.34 ft of freeboard. Hence, with the spillways functioning during the design event, the inflow to the pond is not 

expected to raise the water level above the top of dam and cause an overtopping dam failure. From this simple 

evaluation it appears that the current pond/spillway probably meets the local dam safety requirements. 

 

 In 2005 an application for raising the dam by 4 feet (from 24 ft to 28 ft) was submitted by the owner (see 

Appendix A- Doc 02, “Appl for raising.pdf”) which is near approval. The upgrades include replacing the existing 

concrete spillway (the high inlet principal spillway with a current crest elevation of 581.5 ft) with a two pipe 

spillway. No discharge from the pipes is expected for events less than the 100 year design storm. The entire 

complex is expected to be capable of storing the 50% PMF without any discharge if the pips were to become 

plugged. The revised hydrologic analysis for the proposed conditions (see Appendix A-Doc 04) shows that under 

the 50% PMF inflow at least 2.2 ft of freeboard would be maintained in the pond complex. 
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7.0 STRUCTURAL STABILITY 

7.1 SUPPORTING TECHNICAL DOCUMENTATION 

7.1.1 Stability Analyses and Load Cases Analyzed 

 The reviewed documents did not include a stability analysis, design calculations or field measurements for 

the existing Bottom Ash Pond. Stability analysis is available for the proposed modification to the Bottom 

Ash Pond (see Appendix A- Doc 08).

7.1.2 Design Properties and Parameters of Materials 

 

The design parameters used for the original dam design were not available from the reviewed documents. 

 However, design parameters for the stability analysis for the proposed modification to the Bottom Ash 

Pond (see Appendix A- Doc 08) are available. These parameters at least partially reflect the properties of 

the existing embankment. Although the site is in Seismic Zone 1 (where a seismic coefficient of 0.05 is 

acceptable) in the analysis for the proposed modifications a horizontal seismic load coefficient of 0.1 was 

conservatively used. The effective strength for the Bottom Ash and various other layers in the 

embankment range from 0 to 370 psf and the angle of effective strength ranges from 27.2 to 36.8 

degrees. 

7.1.3 Uplift and/or Phreatic Surface Assumptions 

The reviewed documents did not include any information about the uplift calculations or phreatic surface 

assumptions for the original design of the existing embankments. 

 In the stability analysis section of the report for the proposed modification to the Bottom Ash Pond (see 

Appendix A- Doc 08) a conservative phreatic level was estimated by drawing a straight line from the 

proposed operating pool elevation on the upstream face of the dike to elevation of Bill’s Creek on the 

downstream face of the dike. Also in the proposed modification study seepage analysis was performed on 

two sections to assess the maximum phreatic level that may be expected within the embankment. The 

results include a plot of the calculated free water surface and may be found in Appendix VI of the report in 

Appendix A- Doc 08. 

7.1.4 Factors of Safety and Base Stresses 

The reviewed documents did not include any information about the factors of safety and base stresses for 

the original design of the existing embankments. 

 
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 In the stability analysis section of the report for the proposed modification to the Bottom Ash Pond (see 

Appendix A- Doc 08) the static and pseudostatic stability factor for two embankment sections were 

estimated. The static section stability factors were estimated at 2.08 and 2.19 which are greater than the 

required value of 1.5. The pseudostatic section stability factors were estimated at 1.63 and 1.70 which are 

greater than the required value of 1.2.

 

7.1.5 Liquefaction Potential 

No liquefaction potential data was submitted for the existing conditions of the dam. 

 In the report for the proposed modification to the Bottom Ash Pond (see Appendix A- Doc 08) liquefaction 

and dynamic stability computer analyses were performed on two embankment sections using a design 

earthquake magnitude of 0.10 g. The results showed a number of liquefaction elements near the toe and in 

the clayey gravel layer. The maximum displacement during the earthquake for either of the two analyzed 

sections was less than 0.008 ft. The resulting dynamic stress conditions and the generated pore water 

pressure were then used to assess how the earthquake affects the embankment stability and deformation. 

The minimum factor of the safety for either of the two sections was found to be 2.30 and no permanent 

deformations were predicted in either section. 

 

7.1.6 Critical Geological Conditions and Seismicity 

 The reviewed documents did not include any information regarding the critical geological conditions and 

seismicity as used in the original design of the Bottom Ash Pond. 

 

 The Amos dam site is located in the Allegheny plateau physiographic province. Bedrock belongs to the 

Pennsylvanian System, mainly to the Monongahela and Conemaugh Series. The sedimentary rock includes 

randomly stratified sandstone, siltstone, clay shale and cemented shale. Strata are variable in both 

thickness and lateral continuity. The data reviewed indicate that rock at the site is generally subhorizontally bedded with a maximum dip of 10 degrees. 

In the report for the proposed modification to the Bottom Ash Pond (see Appendix A- Doc 08) a horizontal 

seismic load coefficient of 0.1 was selected although the site is in Seismic Zone 1 (where a seismic 

coefficient of 0.05 is acceptable). No critical geologic conditions were identified. The report states that 

structurally the area is relatively quiescent with no faults having been identified within the study area of 

the Amos facility. Accordingly, there are no seismic impact zones within or near the plant area. 

 7.2 ADEQUACY OF SUPPORTING TECHNICAL DOCUMENTATION 

Structural stability documentation is inadequate for the existing conditions. However, adequate data and 

supporting documentation is available for the proposed modifications to the Bottom Ash pond. 

 
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 7.3 ASSESSMENT OF STRUCTURAL STABILITY 

The WV –Dam Safety inspection report does not include a review of design loads relative to potential credible 

loading conditions. The documents reviewed did not include a structural stability analysis for the existing 

conditions. 

 

Overall, the structural stability of the embankment appears to be satisfactory based on the following 

observations during the September 8th field visit and dam inspection by Dewberry & Davis, LLC, available recent 

dam inspection reports and the 2009 Dam and Dike Inspection Report: 

• There were no indications of major erosion or scarps, sloughs, depressions or major bulging anywhere 

along the dam; 

• Boils, sinks or uncontrolled seepage was not observed along the slopes, groins or toe; 

• The crest appeared free of depressions and no significant vertical or horizontal alignment variations 

were observed; and 

• There was no water against the downstream toe or from the downstream foundation area. 

•
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8.0 ADEQUACY OF MAINTENANCE AND METHODS OF OPERATION

 8.1 OPERATIONAL PROCEDURES 

 WV- Dam Safety report of March 12, 2009 (see Appendix A- Doc 05) includes a narrative that describes the 

operation of the Bottom Ash Complex. Also, in a recent correspondence relating to the proposed modification 

to the Bottom Ash Pond (see Appendix A- Doc 08) a brief description of the operation of the Bottom Ash Ponds 

is provided. For a description of the operation procedures see Section 4.2.3.

 8.2 MAINTENANCE OF THE DAM AND PROJECT FACILITIES 

Maintenance procedures for the Bottom Ash Dam can be seen in Appendix VII of in the report for the proposed 

modification to the Bottom Ash Pond (see Appendix A- Doc 08). The maintenance plan includes: 

• Monthly monitoring plan inspection; 

• Annual engineering inspection; 

• Annual embankment mowing; 

• Annual cleaning of embankment outlet pipe; 

• Bi-annual clearing of brush/trees from outlet channel; 

• Removal of vegetation from joints, resealing and repair of joints/cracks in concrete sections as required; 

• Annual removal trees/brush; 

• Repair of vehicle/traffic damages and replacement or repair of access gates as required.

 8.3 ASSESSMENT OF MAINTENANCE AND METHODS OF OPERATION 

8.3.1 Adequacy of Operational Procedures 

 Operation procedures seem to be adequate based on the assessment results. 

8.3.2 Adequacy of Maintenance 

 Various dam inspections reports including the WV- Dam Safety report of March 12, 2009 (see Appendix ADoc 05), Dam Inspection Checklist of September 8th, 2009 by Dewberry & Davis, LLC (see Appendix C- Doc 

10, “Dam Inspection Checklist Form”) as well as the 2009 Dam and Dike Inspection Report by Stantec 

Consulting Services Inc. (see Appendix A- Doc 07) reported no major issues. Although several 

maintenance recommendations were made, none of them are considered critical or imminent. This 
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indicates that the maintenance plan is probably followed in practice and adequate maintenance is provided 

for the dam and the project facilities. 

 Although the maintenance program is adequate, several recommendations have been made to improve the 

maintenance and insure trouble-free operation. 

 The WV- Dam Safety report of March 12, 2009 recommended: 

• The observed crack in the concrete spillway discharge channel and the vegetation in the joints 

should be sealed and repaired as needed, especially if the spillway is not removed this summer 

with the proposed modifications to the complex; 

• Prior to construction of the proposed modifications, all major trees and sources of floating 

debris within the reservoir should be cut and removed to reduce the potential of blockage of the 

new pipe spillways; 

• The small “vole” tunnels observed should be filled and the voles controlled as needed to prevent 

damages to the vegetation cover; 

• Verify successful completion of the removal of fill from the emergency spillway at the crest of 

the dam; 

• Upon approval of the proposed upgrades to the Bottom Ash Pond Complex, proceed with due 

speed to implement the improvements. 

Additional recommendations in the 2009 Dam and Dike Inspection Report by Stantec Consulting Services 

Inc. included: 

• Monitor slopes exhibiting erosion and backfill erosion gullies; 

• Mowing should be performed at least annually for proper monitoring of slopes (some tall brush 

was observed at several locations in Pond 1B and some minor brush observed along the slopes of 

the Treatment Pond and the Sedimentation Pond); 

• Perform a hydrologic and hydraulic analysis to ensure suitability of the existing drainage shaft 1A 

(in Pond 1B) to handle design storm; 

• Provide support to the wooden stairs down to drainage shaft 1A (in Pond 1B). 

The Dewberry assessment of the Bottom Ash Pond (September 8, 2009) did not result in any other major 

observations or additional maintenance recommendations to the items listed above. 
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St. Albans, West Virginia Dam Assessment Report

9.0 ADEQUACY OF SURVEILLANCE AND MONITORING PROGRAM 

 9.1 SURVEILLANCE PROCEDURES 

 

Quarterly Inspections:

Quarterly dam and dike inspections are conducted by the AEP. Data from the dam monitoring system is 

collected monthly. Inspection reports are submitted to the WV DEP. 

Annual Inspections:

Annual dam engineering inspections are conducted by the AEP and inspection reports are submitted to the WV 

DEP. A third party consultant (Stantec Consulting Services Inc.) submitted the 2009 Dam and Dike Inspection 

report to American Electric Power (AEP) dated May 15, 2009 (see Appendix A- Doc 07, “2009 Dam and Dike 

Inspection Report - John Amos.pdf”). 

Special Inspections:

 In the wake of the failure of the Kingston Power Plant in Tennessee, West Virginal Dam Safety issued an order to 

verify that the “Ash Dams” in West Virginia were visually inspected and evaluated to insure that they were in 

good visual condition and meet or exceed the requirements of the Dam Safety Act and Regulations and standard 

dam safety engineering fundamentals. To meet part of the requirements of that order, West Virginia 

Department of Environmental Protection (DEP) Dam Safety Staff inspected the Bottom Ash Dam on February 10, 

2009 and summarized their finding in a March 12, 2009 letter (see Appendix A-Doc 05). This report concluded 

that in general, the John Amos Bottom Ash Complex appears to be working well and in good condition. No major 

problems or maintenance items were observed during this inspection. 

 9.2 INSTRUMENTATION MONITORING 

There are no indications that any dam instrumentations were in use prior to the studies for the proposed dam 

modification in 2005. However, in conjunction with the proposed modifications to the embankments three 

piezometers were installed and readings were taken since 2005 (see Appendix A- Doc 08). Also, eight borings 

were drilled through the main dike in August 2005 and the observations from these boring logs were analyzed. 

This information may be useful in any future studies related to the embankment safety of the dam. 
FINAL 

John E. Amos Bottom Ash Pond 9-2

American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

9.2.1 Instrumentation Plan 

There was no instrumentation plan provided. Figure 9.2.1-1 shows the location of the piezometers and the 

borings used for the dam modification study (image from Appendix A- Doc 04). 

Figure 9.2.1-1- John Amos Bottom Ash Pond Piezometer and Boring Locations for the Dam Modification Study. 

9.2.2 Instrumentation Monitoring Results 

The reviewed documents did not include any information regarding the results from monitoring 

instrumentation for settlement, displacement, or seismicity. As explained previously, three piezometers 

were installed and readings were taken in 2005 (see Appendix A- Doc 08). The monthly inspections for the 

period April 2008 through May 2009 documents include quarterly piezometer readings for locations 

identified as east, middle, and west. Groundwater level for the period reviewed showed relatively small 

fluctuations of 0.5 to 0.6 feet, typical of seasonal changes. 

9.2.3 Evaluation 

 The historical data indicates that the embankment dam is performing adequately. 
FINAL 

John E. Amos Bottom Ash Pond 9-3

American Electric Power Coal Combustion Waste Impoundment 

St. Albans, West Virginia Dam Assessment Report

 9.3 ASSESSMENT OF SURVEILLANCE AND MONITORING PROGRAM 

9.3.1 Adequacy of Inspection Program 

 The inspection program is adequate based on the data reviewed by Dewberry and onsite observations. 

9.3.2 Adequacy Instrumentation Monitoring Program 

 Instrumentation monitoring program is inadequate. The data reviewed does not show that adequate 

instrumentation for displacement or seismicity has been implemented for this dam.