EPA/OSWER/ORCR

CCR Damage Case Database

Technical Support Document on Damage Cases, Docket # 

EPA-HQ-RCRA-2009-0640

Alexander Livnat, Ph.D.

12/18/2014

The enclosed excel spreadsheet summarizes the universe of Coal Combustion Residual (CCR) damage 

cases confirmed by EPA at the signature of the final rule. This database comprises three groups, each 

with its own tab: Proven Damage Cases, Potential Damage Cases, and Rejected Damage Cases. Subject 

to information limits, the database summarizes the following key data on CCR management units: type 

of unit (landfill, surface impoundment, structural fill), status and type of liners, waste unit’s 

commissioning year, categorization of the damage type (groundwater, surface water, ecological), first 

damage detection year, Contaminants of Concern and standard(s) exceeded, state actions in response 

to the impact, key litigation cases, remedial measures taken, and site-specific background information. 

Each entry in the database (40 proven, 113 potential, four undesignated, and 18 ‘newly rejected’ 

Introduction to the database of CCR Damage Cases

The enclosed excel spreadsheet summarizes the universe of Coal Combustion Residuals (CCR) damage 

cases confirmed by EPA at the signature of the final rule.[1] This database comprises three groups, each 

with a corresponding tab: Proven Damage Cases, Potential Damage Cases, and Rejected Damage Cases.

The information pertaining to the great majority of these damage cases derives primarily from four 

reports: CCW DC Assessments, [2] Out of Control ,

[3] In Harm’s Way ,[4] and Risky Business. [5] A limited 

subset of the cases derives from additional sources. These include primarily stakeholder comments to 

the dockets of the June 21, 2010 proposed CCR rule - primarily EPRI's Evaluation of Coal Combustion 

Product Damage Cases,[6] and the October 12, 2011 Notice of Data Availability (NODA); and data 

retrieved from EPA’s 2009-2014 CCR impoundment assessment reports[7] and EPA’s 2009 information 

All the damage cases included in EPA’s 2007 report as well as the three cases included in the 2010 

proposed CCR rule were reassessed against ‘test of proof’ criteria; all the ‘newly alleged’ and other 

candidate cases were assessed also against the same criteria.[9] For complete information on the 

methodology of these assessments, the reader is referred to Unit XI, Summary of Damage Cases, in the 
Each of the damage cases with sufficient information is accompanied by a case-specific module: these 

modules are compiled into a compendium, an accompanying technical support document on damage 

cases.[10] The technical support document on damage cases comprises five individual volumes (i.e., 

electronic files): (1) Document I, for those of the cases that based on an assessment or a reassessment 

are now designated as ‘proven’ cases (case numbers PR01 to PR40); (2) Document IIa, for cases that 

based on a reassessment are now designated as ‘potential’ (case numbers PTa01 to PTa42); (3-4) 

Document IIb, for ‘newly alleged’ damage cases that based on an assessment are now designated as 

‘potential.’ Due to its size, this document is split into two parts: Part One (case numbs PTb01 to PTb32); 

and Part Two (case numbers PTb33 to PTb55). Finally, (5) Document III, for those of the cases that 

Proven Damage Cases:

Paraphrasing from EPA’s 2007 report, according to the 2000 Regulatory Determination, 65 FR 32224 

and the Technical Background Document to the Report to Congress on Remaining Waste from Fossil 

Fuel Combustion: Potential Damage Cases (1999), classifying damage to groundwater as a proven 

1) Scientific investigation: Damages that are found to exist as part of the findings of a scientific study. 

Such studies should include both formal investigations supporting litigation or a state enforcement 

action, and the results of technical tests (such as monitoring of wells). Scientific studies must 

demonstrate that damages are significant in terms of impacts on human health or the environment. For 

2) Administrative ruling. Damages are found to exist through a formal administrative ruling, such as 

the conclusions of a site report by a field inspector, or through existence of an enforcement that cited 

3) Court decision. Damages are found to exist through the ruling of a court or through an out-of-court 

4) Fossil fuel combustion wastes must be clearly implicated in the damage observed.

The above definition does not limit proven damage cases only to those sites with a primary MCL 

exceedance(s) in ground water distant from the waste management unit (‘offsite’). A case still may be 

considered proven under the scientific investigation test if a scientific study demonstrates there is 

documented evidence of another type of damage to human health or the environment, e.g., ecological 

Currently, there are 40 confirmed proven damage cases. They comprise (1) those that EPA confirmed 

through an assessment of ‘newly alleged’ damage cases submitted to the Agency by environmental 

advocacy groups in their three cited reports; (2) those that EPA confirmed through a re-assessment of 

the proven, potential and rejected damage cases in EPA’s 2007 report and in the 2010 proposed rule; 

(3) those brought to the Agency’s attention in the course of recent information collection campaigns 

waged shortly after the December 2008 TVA Kingston incident (i.e., the CCR impoundment assessment 

Each of the 40 ‘proven’ damage cases is accompanied by a site-specific module in the damage case 

compendium. A link to these ‘proven’ damage case modules (PR01 to PR40) is provided in the crossPotential Damage Cases:
According to the May 2000 Regulatory Determination, 65 FR 3224, potential damage cases are those 

with (1) documented exceedances of primary MCLs or other health-based standards only directly 

beneath or in very close proximity to the waste source, and/or (2) documented exceedances of 

secondary MCLs or other health-based standards on-site or off-site. Currently, there are 113 confirmed 

potential damage cases. Similarly to the proven damage cases, these cases hail from the very same 

resources. Finally, there are four additional, state-endorsed damage cases from Wisconsin. While EPA 

has insufficiently-detailed information (including the extent, if any, that the contaminants have 

Ninety seven of the 113 ‘potential’ damage cases are accompanied by individual, site-specific modules 

in the damage case compendium. These modules can be recognized by their prefix: all those damage 

cases that are designated as ‘potential’ based on a reassessment of the inventory included in EPA’s 

2007 report and in the 2010 proposed rule are included in document IIa (case numbers PTa01 to 

PTa42). All those damage cases that are designated as ‘potential’ based on an assessment of the ‘newly 

alleged’ damage cases included in the three reports by the environmental advocacy groups are included 

in the two-volume document IIb (case numbers PTb01 to PTb32 in Part One, and case numbers PTb33 

Rejected Damage Cases:

This tab contains all those CCR damage cases that were included in the four reports cited above; some, 

such as those in EPA’s 2007 report, were designated as ‘rejected’ from the outset; the remainder have 

failed EPA’s renewed scrutiny. For a CCR damage case to be rejected, it has to fail at least one of the 

following criteria: (1) the disposal setting, and/or the original boiler combustion residue, and/or the 

generating sector of the CCR is out of scope of the final rule (e.g., disposal in open coal mine pits; 

and/or waste from oil-fueled boilers, and/or CCR from industrial- or other non-utility electrical facility 

boilers); (2) CCR has been commingled with other waste types (such as hazardous waste) to the extent 

that masks the role of CCR in the resulting contamination; (3) the information at hand is inadequate to 

Cases from three distinct categories ended under this tab: (i) those of the original 18 cases designated 

in EPA's 2007 report as ‘rejected’ (cases #68-85) that are now re-designated as ‘potential’ or ‘proven’ 

based on new information obtained since that report was issued; (ii) those cases that were originally 

designated in the 2007 report as ‘potential’ or ‘proven’, but upon reassessment failed the scrutiny of 

EPA’s ‘test of proof’ criteria. These cases are re-designated as ‘rejected’; and (iii) the remaining damage 

cases, designated in the 2007 report as ‘rejected’, that in the wake of the reassessment have retained 

The ‘rejected’ cases that are referenced to the three environmental advocacy group reports have been 

submitted to EPA among a total of 90 ‘newly alleged’ damage cases. Upon assessment of all these 

cases, EPA decided they do not qualify as confirmed damage cases for one or more of the reasons 

discussed above, and consequently designated them as ‘rejected’. For details, see the information 

Fifteen of the ‘rejected’ damage cases are accompanied each by a site-specific module in the damage 

case compendium of the technical support document on damage cases. A link to these ‘rejected’ 

damage case modules (R01 to R15) is provided in the cross-walk column of the ‘rejected’ tab of the 

spreadsheet. Similar links are also provided in the crosswalk column for those cases that while originally 

designated as ‘rejected’ are now re-designated as ‘proven’ or ‘potential’ (e.g., PR08, re-designated as 
Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface 

impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion 

waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – 

damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – 

Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - 

Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; 

CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - 

Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum 

Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality 

Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - 

Secondary Drinking Water Standard; CCC - Chronic Criterion Concentration; LHA - Life Health Advisory; 

Standard Symbols: COCs/GW and COCs/Surface Water columns: Ni (or any other monitored 

constituent) – a reported exceedance; (Ni) (or any other monitored constituent) – an exceedance that 

industry rejects, claiming the alleged exceedance is due to one of the following: an outlier, a nonAction columns on the right hand side end of each tab (e.g., NOV, CO/Admin Order, etc.): Y – the 

measure associated with this column’s header was or is being implemented; (Y) – the measure is yet to 

[1] Prior to the June 2010 propose CCR rule, EPA used the term Coal Combustion Waste (CCW) in lieu of CCR.

[2] EPA (2007): 2007 Coal Combustion Waste Damage Case Assessments:

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2006-0796-0015

[3] Out of Control: Mounting Damages from Coal Ash Waste Sites; Environmental Integrity Project, EarthJustice; February 24, 

2010: http://www.environmentalintegrity.org/news_reports/news_02_24_10.php

[4] In Harm’s Way: Lack of Federal Coal Ash Regulations Endangers Americans and Their Environment, Thirty-nine New 

Damage Cases of Contamination from Improperly Disposed Coal Combustion Waste, Environmental Integrity Project, 

http://www.environmentalintegrity.org/news_reports/08_26_10.php

[5] Risky Business: Coal Ash Threatens America’s Groundwater Resources at 19 More Sites. Environmental Integrity Project 

Report, Dec. 13, 2011; also: EPA-HQ-RCRA-2011-0392-0259.

http://www.environmentalintegrity.org/documents/121311EIPThirdDamageReport.pdf 

[6] A key source for industry’s perspective on damage cases is: Evaluation of Coal Combustion Product Damage Cases, 

Volumes 1 and 2: 1020554, EPRI Final Report, September 2010. http://www.epri.com/search/Pages/results.aspx?sq=1&k=Evaluation%20of%20Coal%20Combustion%20Product%20Damag

e%20Cases [7] http://www.epa.gov/osw/nonhaz/industrial/special/fossil/surveys2/index.htm

[8] http://www.epa.gov/osw/nonhaz/industrial/special/fossil/surveys/index.htm

[9] A major part of the assessment and reassessment of the damage cases record was performed by ICF International. The 

following documents are included in the docket of the final rule (EPA-HQ-RCRA-2009-0640):

Assessment of Previously Identified Proven Damage and Recently Alleged Damage Cases. ICF International. Prepared for U.S. 

EPA, Office of Resource Conservation and Recovery, EPA Contract No. EP-W-07-003, Work Assignment No. 3-88. October 

Appendix A: Reassessment of Previously Identified Proven Damage Cases (EPA 2007 and proposed rule).

Appendix B: Assessment of February 2010 Alleged Damage Cases (Out of Control).

Appendix C: Assessment of August 2010 Alleged Damage Cases (In Harm’s Way).
[10] Volumes 1-5 of the technical support document on damage cases (Compendium) are included in the docket to the final 

rule (EPA-HQ-RCRA-2009-0640).
No. Crosswalk Facility Location State References Waste Unit Type

1 PR01 Plant Bowen, Georgia 

Power 

Cartersville, 

Bartow Co.

GA CCW DC Ass #8 One Primary, unlined SI; 

and an ash stack.

2 PR02 Eagle Valley Station, 

Illinois Power & Light

Martinsville IN Response to U.S. EPA 

l04(e) Information 

Request, 2009 

Five unlined 

impoundments

3 PR03 Gibson Generating 

Station Plant, Duke 

Energy

Princeton IN Out of Control #6 2 LFs (one of which is 

unlined - implicated), 4 

Primary SIs (implicated) 

and 2 settling/decant 

basins, and a-3,500 acre 

Cooling Reservoir 

(implicated). 
4 PR04 NIPSCO Yard 520 Pines IN CCW DC Ass #19 LF & BU

5 PR05 BBSS S&G Quarries, 

Constellation Energy 

Gambrills MD CCR Proposed Rule, 

6/2010

2 S&G pits

6 PR06 Morgantwon Faulkner 

Offsite Landfill, PEPCO 

(Mirant, GenOn, NRG) 

Morgantown, 

Charles Co.

MD CCW DC Ass #5 and 

MDE Notice of Intent 

to Sue Mirant , 

January 3, 2011

3 LFs & 3 associated sets 

of stormwater/ leachate 

management ponds 

(implicated); artificial 

wetland.

7 PR07 Range Road Landfill, 

Detroit Edison 

East China 

Township

MI EPA-HQ-RCRA-2009-

0640-6815, 

Attachment 5.

An offsite LF

8 PR08 JR Whiting Generating 

Plant, 

CMS/Consumers 

Energy

Erie MI CCW DC Ass #76 6 Primary Sis; SIs #3, #4, 

and #5 are implicated.
9 PR09 North Lansing Landfill, 

Lansing Board of 

Water & Light 

North Lansing MI CCW DC Ass #18 and 

EPA-HQ-RCRA-2009-

0640-6815, 

Attachment 5.

S&G pit

10 PR10 Colstrip Power Plant, 

PPL Montana

Colstrip MT Out of Control #10 14 active ponds 

(including evaporation 

ponds), 5 inactive ponds, 

2 ponds that are capped 

and/or reclaimed, and a 

160-acre Cooling Lake. 

Both Primary and 

Secondary Ponds 

implicated.

11 PR11 Reid Gardner 

Generating, Nevada 

Energy

Moapa NV Out of Control #18 Originally: 3 SIs, 5 

evaporation ponds; LF, 

Both dry and wet 

disposal WUs implicated. 

Recently: 8 evaporation 

ponds (zero discharge 

cooling system). 

12 PR12 Cayuga Coal Ash 

Disposal Landfill, AES

Lansing NY In Harm's Way #22 

(Table C)

LF (implicated) and 

Leachate Pond (possibly 

implicated)

13 PR13 Don Frame Trucking 

Fly Ash Landfill

Pomfret NY CCW DC Ass #3 Offsite LF, preceded by a 

structural fill.
14 PR14 Belews Lake Station, 

Duke Energy

Stokes, 

Rockingham, 

Guilford, and 

Forsyth counties.

NC CCW DC Ass #11 SI discharge into cooling 

reservoir.

15 PR15 Dan River Steam 

Station, Duke Energy

Eden NC NC DENR, Feb. 2014 2 contiguous SIs (one 

Primary and one 

Scondary)

16 PR16 Hyco Lake Roxboro NC CCW DC Ass #7 SI discharge into cooling 

reservoir.

17 PR17 Swift Creek Structural 

Fill Site ReUse 

Technology

Rocky Mount NC Out of Control #14 Struct Fill
18 PR18 Conesville FGD 

Landfill, AEP

Conseville OH CCW DC Ass #63; EPRI 

(1984)

FGD sludge (Poz-O-Tec) 

LF associated with an 

FGD emergency sludge 

pond (implicated), a 

closed (1988) LF; and 4 

SIs: Fly Ash Storage, Fly 

Ash Pond, Bottom Ash 

Pond, and Clearwater 

Pond. SIs are dredged 

and contents transferred 

to LF. 

19 PR19 Bruce Mansfield 

Power Station, First 

Energy 

Shippingport PA In Harm's Way #29 One, very large disposal 

SI

No. Crosswalk Facility Location State References Waste Unit Type

20 PR20 Fern Valley Landfill, 

Orion Power Holdings

Elrama PA Out of Control #22 LF (implicated) with a 

leachate 

collection/storm water 

pond.
21 PR21 Hatfield's Ferry Power 

Station, Allegheny 

Energy 

Masontown PA In Harm's Way #30 LF (Phases 1, 2, and 3).

22 PR22 Martins Creek Power 

Plant, PPL

Mt Bethel 

Township

PA CCR Proposed Rule, 

6/2010

4 SI: two closed (# 2 &3); 

one retired during the 

spill and partially closed 

since 1999, and 

completely closed 

afterwards (# 1, 

implicated in GW 

impact), and one active 

during spill (# 4, 

implicated in dike 

breach) subsequently 

decommissioned. 23 PR23 Canadys Plant, SCE&G Walterboro SC CCW DC Ass #10 2 Primary SIs. Old pond 

deactivated 1989 and a 

new one kicked in (both 

implicated). Also, waste 

water treatment ponds 

(i.e., Coal pile runoff 

basins #1 and #2, coal 

pile runoff detention 

basin, low-volume waste 

ponds A, B, and C, and 

spray pond.

24 PR24 Savannah River DArea, DOE Savannah River SC CCW DC Ass #12 SIs: two (Primary) 

settling basins and a 

drainage swamp - all 

implicated. In 2001, 

switched to a LF, with 

cells being closed/ 

capped as they fill up.
25 PR25 Urquhart Station, 

SCE&G

Beech Island SC Out of Control #26 LF & SIs (2 Settling 

basins, receiving only 

small amount of fly ash 

and stormwater, and 

dredged every 12-18 

months - implicated). 

Also, wastewater 

treatment ponds (i.e., 

metals pond, lowvolume waste pond, ashlandfill runoff basin, lowvolume waste polishing 

pond, and stormwater 

runoff pond.) 

26 PR26 Kingston Fossil 

Station, TVA 

Harriman TN CCR Proposed Rule, 

6/2010

Before 12/2008: Several 

SIs (implicated in spill) 

and stacking area - Main 

Ash Pond, Stilling Pond, 

Fly Ash Stacking Area 

(Dredge Cells 1 and 2 & 

Emergency Dredge Cell), 

and Stack RunoffLeachate Pond. Postspill: all pond areas (with 

the exception of the 

stilling pond) converted 

to ash stacking areas, 

and a new gypsum 

dewatering facility 

(implicated). 

27 PR27 Oak Ridge Y-12 OU# 2, 

DOE 

Oak ridge TN CCW DC Ass #9 Ash retention SI and an 

abandoned (Lst.?) 

quarry. Presently LF (not 

implicated).

28 PR28 CCW Landfill, Trans 

Ash Inc.

Camden TN Out of Control #29 Gravel Pit serving as an 

Offsite Landfill/Structural 

Fill

29 PR29 Pirkey Power Plant 

Brandy Branch 

Reservoir, SW Electric 

Power 

Marshall TX CCW DC Ass #20 SI discharge into cooling 

reservoir
30 PR30 Martin Lake Power 

Plant, Texas Utilities 

Electric

Tatum, Rusk and 

Manola 

counties.

TX CCW DC Ass #22 Cooling Reservoir (5020 

acre) receiving 

unpermitted stormwater 

discharge from SIs

31 PR31 Welsh Reservoir, 

Southwestern Electric 

Power 

Mount Pleasant TX CCW DC Ass #21 SI discharge into cooling 

reservoir

32 PR32 Clinch River Power 

Plant (Carbo power 

plant), AEPAppalachian Power 

Cleveland VA In Harm's Way #36 2 SI (only Area 1 is active - 

implicated in spill; 

Bottom Ash Pond Area 2 

was closed in 1998) and 

LF.

33 PR33 Glen Lyn Plant, 

AEP/Appalachian 

Power

Glen Lyn VA In Harm's Way #37 SIs (2): a fly ash pond 

(since 1965) and a multiunit bottom ash pond 

(1963) - implicated. Also 

(not implicated) a LF 

(1980?-2007?) and a 

structural fill (2007- ) on 

the New River.
34 PR34 Chisman Creek, 

VEPCO 

Yorktown VA CCW DC Ass #6 4 (now abandoned) sand 

and gravel pits and three 

man-made ponds.

35 PR35 John Amos Power 

Plant, 

AEP/Appalachian 

Power Co.

Winfield/St. 

Albans

WV Out of Control #30 6 SIs (One large - fly ash - 

implicated in surface 

water impact; five, 

smaller - bottom ash, 

one of which is closed); 3 

LFs. 

36 PR36 Cedar Sauk Ash 

Landfill, WEPCO 

Cedarburg WI CCW DC Ass #16 S&G pit

37 PR37 Columbia Energy 

Center, Alliant Energy

Pardeeville WI In Harm's Way #38 3 SIs (apparently - all 

implicated): primary ash 

pond, secondary ash 

pond, and a small 

polishing pond; also a 

cooling pond and a LF 

stormwater pond.
38 PR38 Highway 59, We 

Energies

Waukesha WI CCW DC Ass #14 S&G pit

39 PR39 Oak Creek Power 

Plant, Wisconsin 

Energy/Wisconsin 

Electric Power Co.

Oak Creek WI EPA R5 cleanup 

bulletins and general 

media.

Old Structural Fill 

(implicated). Also: 3 LFs 

(two closed and one - 

Caledonia - active). 

40 PR40 E.J. Stoneman, 

Dairyland Power 

Grant Co. WI CCW DC Ass #13 Primary SI

No. Crosswalk Facility Location State References Waste Unit Type

Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and 
Liner Year Commissioned Year Damage 

Noted

Failure Mode COCs/GW

Originally: No; at a later 

stage, lined with 

geosynthetic clay liners 

(GCL) or HDPE liners, 

and/or clay soil liners.

1968 2002 

(sinkhole); 

2008 (dry ash 

pile collapse)

SW, Sediment, 

Ecologic

No 1956; reconfigured in 

2003.

2007, 2008 SW

SIs: No; LF: partial 1970s SW: 2003; 

GW: 2007

GW (mounding 

conjectured), 

SW/Ecol (Elevated 

Se in fish and fish 

mortality; elevated 

hatching mortality 

of endangered 

Least Tern) 

Primary MCL (onsite): 

As; EPA Child Health 

Advisory (HAL; Offsite): 

B; Drinking Water 

Advisory: Na; SMCL 

(onsite): Fe, Mn.
Clay - below the South LF; 

none beneath the North 

LF.

North: 1966; South: 

1983.

2000 GW, Soils, SW Health-based standards 

(in offsite water wells): 

B, Mo, As, Pb, Se; SMCL: 

Fe, Mn, Sf 

Compressed Fly Ash 1995 1998 GW, Fugitive Dust MCL: As, Cd, Pb, Tl, Be, 

Ni; SMCL: Al, Mn, Sf, Li

No 1970; 1979; 1989 1991 GW & SW; Ecol 

(veget. Damage)

MCL: Cd; SMCL: Fe, pH 

(onsite: Al, Cl, Mn, Fe, 

Sf, TDS)

No Early 1950s 1995 GW & SW State's health-based 

standards: B, Li, Mn 

No 3 Implicated ponds: 

1959 and 1974; the 

other 3 ponds: 1952, 

1980.

2008? SW/Ecol Sediments
No 1980 1993 GW MCL (Onsite): Pb, Se; 

State standard: Li; 

SMCL: Mn, B, Sf

Originally unlined or claylined. Progressively lined 

with a single or double 

geosynthetic liner(s), 

some w/leachate 

detection/collection 

system(s). Plant switched 

to high-density paste 

slurry system.

1975-76 (2); 1975; 

1983 (2); 1988 (1); 

1992

Early 1980s GW & SW MCL: Se, As; WHO 

Drinking Water MCL: 

Mo; SMCL: B, Cl, Sf, TDS

SIs: No LF: No. Recent 8 

evaporation ponds have 

double (HDPE 

geomembrane) liners and 

leak detection/ collection 

systems.

1976 1997 GW, SW, Fugitive 

Dust

MCL (offsite GW): As; 

MCL (onsite GW): As, 

Cr, Nitrate, Se, V; SMCL: 

Mo, B, Cl, Mg, Mn, Ti, 

Na, Sf, TDS

LF Phase I: No; LF Phase II: 

Composite

1980s 2000 GW & SW MCL (Offsite ): Pb, Se; 

MCL (Onsite): As, Cd, 

Se; SMCL (Offsite): Fe, 

TDS; SMCL (Onsite): Al, 

Mn, Sf, TDS; State's GW 

Standards: As, Se. 

Unspecified drinking 

water standards: Ba, B, 

Na, Ammonia

No 1971 1989 GW, 

SW/Sediments, 

Soils

MCL: Pb; SMCL: Mn, Fe 

TDS, Sf
No 1970s 1974 SW/Ecol

No 1956; raised in 

1968/69 and 1976/77, 

reconfigured 1976/77.

2014 SW

No 1964 1974 SW/Ecol 

No 1991 2004 GW MCL (onsite and 

offsite): As, Pb; State's 

groundwater quality 

standard (2L) (onsite 

and offsite): Sf 
LF and SIs: No. The 

emergency sluge pond: 

No (1977-1978), then a 

Poz-O-Tec liner that was 

frequently disrupted by 

dredging. The later (1993) 

LF expansion: composite 

liner.

SIs: 1950s ;LF: 1/1977 1979/80 GW PDWS (Onsite and 

offsite): Pb, Cr; PDWS: 

(Onsite): As, Cd, Cr, Se; 

SDWS (Onsite): Ca, Mg, 

Sf, Fe, TDS 

No 1977 1993 GW & SW MCL (Offsite & Onsite): 

As, Cd, Pb, F, Ba; SMCL 

(Offsite and Onsite): B, 

Cl, Sf, Fe, Mn, Na, Al, 

pH, TDS, TSS

Liner Year Commissioned Year Damage 

Noted

Failure Mode COCs/GW

3' Poz-O-Tec over bottom 

ash and drain system. 

Landfilling might have 

diverged outside the lined 

area.

1979 (?) or 1989 1995 GW, SW, ecologic MCL (Onsite): As; 

SMCL/Health 

Advisories (Onsite): B, 

Cl, Sf, TDS;
Phases 1 & 2 LF: No, but 

w/leachate collection 

system. Phase 3 LF 

(2009): composite (double 

synthetic) liner system 

and a lined leachate 

storage impoundment. 

Until 2001, leachate and 

wastewater were 

discharged directly to an 

unlined SI; since then -

into an artificial wetland. 

Since 2007, an FGD 

disposal system: 

equalization basin, 4 

wetland cells, 5 rock drain 

cells, and a sedimentation 

pond.

1984 2001 GW, SW, ecologic MCL (Onsite): As; EPA's 

HAL: B; EPA's RAL: Mo; 

SMCL: Mn,Sf, Al, TDS.

No. 1: No; Nos. 2 & 3: 

unknown; No. 4: lined 

with a 36-mil, synthetic, 

reinforced-rubber 

(Hypalon) liner system. 

During breach of No. 4, 

Plant's ash was diverted 

temporarily to No. 1.

1955 2005 GW, SW MCL (Onsite): Se, (Cr); 

SMCL (Onsite): (Fe).

Old pond: No; New (1989-

) pond: Bentonite slurry 

wall. Slurry wall failed.

1974 1988 1982 2008 GW MCL (Offsite): As, Ni; 

(Onsite): Se.

No 1950s Mid 1970s SW/Ecol, Sediments
No LF: Late 1980s to mid1990s; settling basins: 

1977

1989; 2007 GW, Soil MCL (Offsite and 

Onsite): As; State's DWS 

(Onsite): Ni. 

Old WUs: No; The Gypsum 

dewatering (2010): 

initially - clay, replaced by 

an HDPE liner after 

impacted by a sinkhole.

1950s 2008 GW, 

SW/Sediments, 

Soils, ecology

MCL: Se; Life Health 

Advisory (LHA): Mn; 

Federal health-based 

guidelines: Co; SMCL: 

Sb, Al, Ammonia. 

No 1955 1989 SW/Ecol, GW SMCL: Al, Mn, Fe, Zn; 

0.25" geosynthetic, partial 

and improperly installed

2002 2005 GW & SW, 

Sediment

MCL (Offsite) Hg; 

(Onsite): As, Cr, Pb, Hg.

No 1983 1986 SW/Ecol
No 1974 1978 SW/Ecol

Apparently No 1976 1981 SW/Ecol

No 1954-55 1967 SW/Ecol

Fly ash pond: 1-3" clay. 

Bottom ash pond: No.

1963, 1965 Late 1970s SW/Ecol
No 1957 1980 GW & SW MCL: Ni, V, Se; SMCL: Sf

SIs: No; LF - ? 1971 1974 SW/Ecol

No 1969 Early 1980s GW, Ecol MCL: Se; SMCL: Sf; 

State standard (WQS): 

B

SIs: No; LF storm pond: 

HDPE.

1974 1977 SW/Ecol, GW SMCL: B, Na, Sf
No 1969 1988 GW State Preventive Action 

Level (PAL, Offsite): As; 

State Enforcement 

Standards (ES, Offsite): 

B, Mo, Mn, Fe, Cl, Sf. 

State PAL (Onsite): Se, 

Cl; State ES (Onsite): B, 

Mn, Fe,Sf; SMCL: TDS.

2 Inactive LFs: probably 

No; Active LF: Clay (Phase 

I); Composite w/ leachate 

collect (Phase II). 

Structural Fill: No

1960s & 1974; Fill from 

1950s to late 1960s

2002 or 

earlier; Fill's 

partial 

collapse: 

10/31/11

SW: Fill collapsed 

into Lake Michigan

No 1950 1976 GW MCL (Offsite): Cd; SMCL 

(Offsite): B, Fe, Mn, Sf; 

MCL (Onsite): Cd, Cr; 

SMCL (Onsite): Ba, Sf, 

Mn, Fe 

Liner Year Commissioned Year Damage 

Noted

Failure Mode COCs/GW

mpoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC 
COCs/SW Regulatory Action Current Status Comments

EPA Region IV ecological 

sediment screening 

values (ESVs): As, Cd, Cr, 

Pb, Hg, Ni, Cu

State/CO, requiring, among 

others, a fine and corrective 

action. 

Active/modified 2002: Sinkhole developed, releasing 

slurry to creek (2.25 million gallons of 

ash/water mixture was released to a 

tributary of the Euharlee Creek, 

containing 281 tons of ash); elevated Se 

and Cd in invertabrate fauna. 2008: 

extreme rain event collapsed a dry ash 

stockpile; storm water overwhelmed 

perimeter ditching in the ash pond and 

carried ash off of plant property to the 

north to a storm water conveyance and 

across several adjacent properties 

where it was deposited in a sediment 

pond. From the sediment pond, some of 

the ash reached Euharlee Creek. ~ 40 

tons of ash was released with ~ 2 tons 

of ash reaching Euharlee Creek. ~ 14 

offsite properties in the neighborhood 

were affected. CERCLA cleanup ensued.

No data State/CO (2008). IDEM assessed 

IPL a $23,800 civil penalty, 

required IPL to study the site, 

submit its findings to IDEM, 

implement repairs, and follow up 

with regular inspections.

Active Two pond dike breaches, w/30 million gl 

of spilled slurry each. IPL submitted a 

root causal analysis associated with the 

second levee breach and levee repair 

recommendations to IDEM and initiated 

external qualified professional 

inspections of all of its levees in June 

2008.

EPA’s recommended 

Criterion Continued 

Concentration (CCC) in 

water: Se; Unspecified 

standard: As, B 

None. Voluntary closing of cooling 

lake to fishing. Duke supplying 

(voluntarily) bottled drinking 

water to homes 

w/affected/closed wells; no 

enforcement action by the State. 

IDEM considers the surface 

impoundments as temporary CCR 

storage areas that are exempt 

from solid waste regulations.

Active Closed loop water system (no NPDES). 

CCR is periodically scooped out of the 

SIs and sent to an on-site CCR LF. Gibson 

Lake and wetlands are part of a 

designated Important Bird Area (IBA) 

and are vital habitat and migration 

grounds for numerous bird species. 

From 2003-2008, the cooling lake 

discharged into the Cane Ridge Wildlife 

Management Area, a 463-acre section 

of the Patoka River National Wildlife 

Refuge, contaminating the water, soil 

and biota with selenium levels that 

posed a high hazard to wildlife.
Largely exceeded 

background values: B, 

Ammonium.

State/AOC Inactive Groundwater mounding beneath the 

North Landfill. Soil: Crvi, As. A 

Superfund Alternative site. 

Remediation included a clay barrier 

between the South and North sectors of 

the LF, and a 2-stage closure of the LF 

(including a clay capping), and a 

Supplemental Closure Plan for 

contiguous areas. Two AOCs, Human 

health and ecological risk assessments 

and a draft remediation feasibility 

study; and an ongoing radiation 

survey/study.

State/CO, $1 million penalty; 

supply of alternative water. Outof-court settlement of $54 

million.

Inactive/2007 Pump and Treat; mitigation plan in 

place.

Water quality standards: 

Cd, Cu, Pb, Se; elevated 

TSS (>30 mg/l): TDS; 

chronic national nonpriority pollutant water 

quality standard: Cl; Fe; 

pH (2.65 - 4) 

State/CO; State and citizens' 

lawsuit in Federal court

Closed (2010) Protracted history of violations and 

remediation efforts. Liners in newer 

units ('93); slurry wall ('94-'95); closure 

and clay-bentonite capping of older 

units ('97); a leachate collection and 

treatment system in expanded LF; 

artificial wetland (2002). CO (2013) 

requires cap and seal of all closed cells 

in the LF and install liner systems in all 

leachate and stormwater collection 

ponds, perform a study to characterize 

the levels of contamination at the Site, 

and develop and implement a plan to 

control fugitive CCR dust.

State's health-based 

standards: B, Li, Mn 

RI/FS; slurry wall installation; 

leachate collection; hydrological 

monitoring and Remedial studies.

Active (Cuthbertson 

to Livnat, 11/9/2010 

email). One of the 

three associated 

plants retired (2001), 

and another one is 

on the verge of 

retirement.

Leachate migrating off-site in GW and 

reaching 2 small ponds (no drinking 

water source affected). 

Elevated As, Se, Br (in 

Oligochates); several 

time toxic threshold: Se; 

Br, Co, Ni, Cr (in Fish and 

their natural feedstock); 

As, Co, se, Ni (in 

Sediment)

State: Final closure of the 

implicated ponds was approved in 

2005 and is nearing completion. 

Some Active, some 

not

In recent years, fly ash disposal at the 

plant has been minimal, with most 

being sold for reuse by cement 

manufacturers; the rest is landfilled. 

Plant was a candidate for retirement by 

the end of 2015, but retirement date 

deferred to April 2016.
Groundwater mounding. 

State/Remedial Action Plan

Response action plan, RI/FS to 

determine the extent of contamination, 

and the development of a Remedial 

action Plan, to address the release. A 

soil-bentonite slurry wall was 

constructed around the perimeter of 

the facility in 2008.

Recommended 

threshold for cattle: Sf

State issued, in 8/2012 a CO. 

Previous corrective action 

involved installing hundreds of 

monitoring wells, lining the more 

recently installed SIs with a 

rubber-like liners, introduction of 

a pump-and-treat system, 

seepage capture trenches, and 

forced evaporation.

Some active, some 

not

Designed as Zero Liquid Discharge (ZLD) 

facility. Leaking ponds have been either 

retrofitted or closed, and in 2004 the 

Plant switched to a low-water, paste 

slurry system.

Excessive' (no standard 

specified): As, Cd, Ba, B, 

Fe, Mg, Mn, Mo, Al, Cl, 

Sf, TDS 

State/AOCs - 1997 and 2008: 

continue with environmental 

contaminant characterization 

activities and for the 

identification of corrective actions 

and/or clean-up measures for the 

soil and GW at the Site. 

Some active, some 

not

Closure of some of the unlined ponds. 

Three of the Plant's four generation 

units (Units 1-3) are slated to close by 

the end of 2014, with the fourth 

generation unit (Unit 4), to close in 

2017.

Federal WQCs. Standard 

for protection of human 

health from surface 

water ingestion and fish 

consumption: As; Acute 

toxicity standard for 

aquatic life: Cd; Chronic 

toxicity standard for 

aquatic life: Se; 

Unspecified standards 

(in sediment): Cr, Zn

State/NOV for excess disposal Inactive (Phase I), 

Active (Phase II)

Higher levels than 

control streams, but no 

exceedances: Mn, Sf

State required remedial action, 

court order to cease receiving 

wastes. 

Inactive/1988. 

Dunkirk Steam 

Station mothballed 

in 3/2012.

An 1975-77 study provides early 

information on composition of 

leachate/shallow GW in onsite wells and 

surface water ponds, and 

bioaccumulation of iron and manganese 

in biota residing there. 
Draft freshwater 

Chronic Criterion 

Concentration (CCC): Se 

in fish 

State/CO, Fish advisory. State 

required operating changes to 

mitigate contamination.

Active/modified

Surface Water 

Standard: As, Cu, Fe, 

Al

Failure of a 48" diameter metal 

storm sewer line that runs under 

the inactive ash pond released 

about 27 million gallons (between 

30,000-39,000 tons) of CCR slurry 

into the Dan River. NC DENR 

issued two NOV (2/2014), and NC 

DHHS issued an advisory against 

eating fish and shellfish from the 

Dan River downstream of the 

spill.

Plant retired April 

2012, but implicated 

pond still contained 

water when the 

2/2014 

failure/release 

occurred.

Duke permanently plugged the 

breached sewer pipe and stopped the 

ash slurry’s flow into the Dan River in 

about six days. In mid-July 2014, Duke 

Energy completed the cleanup (suction 

dredging of 3,000 ton of CCR) of the Dan 

River. In a March 12, 2014 letter to NC’s 

Governor and DENR, Duke Energy 

committed to clean-close the plant’s 

inactive ash ponds 'within 24 to 30 

months once the destination for the ash 

is determined and the necessary 

permits secured.' 

Health Advisory 

standard: B; Draft 

freshwater Chronic 

Criterion Concentration 

(CCC): Se in fish; HAL: B

State/Fish advisory; stopped 

temporarily wet handling and 

introduced wastewater 

treatment. The NC DEWQ is 

requiring long-term monitoring of 

the lake. On March 3, 2014, DENR 

issued to the Roxboro Steam 

Plant a Notice of Violation for 

failing to secure a storm water 

permit.

Active

State/NOV, CO (NOV in 2002 for 

failure to bring the fill area into 

compliance with an original plan 

for waste placement. A CO, in 

2006, included a fine and a 

requirement to delineate the 

nature and extent of GW and 

surface water contamination. )

Inactive Three of the five coal-fueled plants still 

operating; one coverted to biofuel, and 

one decommissioned. 
State/LF capped by a 2’ clay cap 

with 6” topsoil cover in 1988. The 

utility voluntarily monitored GW 

starting in the late 1970s (55 wells 

reported in 2002); no monitoring 

is presently required. Post-closure 

inspections continue.

Inactive/1988 Generation Units 1 and 2 (125 MW 

capacity each), were shut in 2005 due to 

corrosion fatigue. Unit 3 (162 MW), 

slated for retirement by end of 2012.

State's WQC: As, Sb, Cd, 

Hexavalent Cr, Pb, Tl; 

State's Chronic Water 

Quality Standards: Se, B; 

Health Advisory: Mo.

State/settlement Agreement; 2 

NOVs (dust). A remedial plan for 

the impacted springs. Settlement 

agreement (6/1994) for GW 

contamination: FirstEnergy was 

required to provide an alternative 

water supply to a private 

residence. Contaminated private 

property buyouts by FirstEnergy.

Active Closure to start 2017 and proceed for 

12 years.

COCs/SW Regulatory Action Current Status Comments

State's CCC: Se. State/NOVs: Due to placement of 

waste outside of the permitted LF 

boundaries and failure to report 

monitoring data, PADEP issued 

several noticed of violation in 

2002. Water quality assessments 

have been required and will 

continue through 2017 in 

response to citizen and regulatory 

concerns. 

Actions and responses by the 

operator have satisfied regulators 

resulting in no further corrective 

regulatory actions.

Inactive/2007 FGD, one of the disposed-off materials, 

might have blocked infiltration and 

contributed to mounding of perched 

GW inside the LF, thus affecting so 

called up-gradient monitoring wells. 

PADEP attributes exceedances to AMD 

from an up-gradient, abandoned 

surface coal mine and leachate from the 

side-gradient, unlined Clairton MSW 

landfill.
NPDES Violations: Tl, Al, 

Mn; State's CCC: Cr, B, 

Se; Federal Water 

Equivalent: Mo; SMCL: 

pH, TDS 

State/COA. PADEP does not deny 

exceedances of B, Mn, sulfate and 

TDS, but attributes them to AMD 

associated with past coal mining 

activities in the landfill’s 

watershed.

Some Active, Some 

Not. The Plant closed 

at the end of 2013. 

PADEP attributes exceedances to AMD 

associated with past coal mining 

activities in the landfill’s watershed. 

Artificial wetland fails to properly treat 

for B, Se, and Mo. 

Pennsylvania's WQC 

(Offsite): As, Pb, Cu, Al; 

New Jersey's WQC 

(Offsite): As, Pb 

State/NOV, CO All four basins are 

inactive. Plant's 2 

coal-fired units 

closed 2007 

(demolished 2009) 

due to air pollution 

impacts on New 

Jersey.

Karstic terrain. Dike failure; release of 

100 million gallons of coal ash slurry. 

Subsequent actions included closure of 

the SI and suction dredging for removal 

of the fly ash from the Delaware river 

bottom and the other impacted areas. 

The part of the Delaware River on which 

the Martins Creek plant is located was 

designated by Congress as the Lower 

Delaware Wild and Scenic River in 2000.

State/CO; slurry wall around old 

and new SIs; dewatering of old SI 

and contents' removal towards 

clean closure; extended 

monitoring well system. 

Mixing/compliance zone 

established.

Inactive since Plant's 

closure (Nov. 2013)

Operator was allowed to buy 

neighboring property under State 

policy. In 1996, DHEC approved a 

mixing zone and compliance boundary 

to accommodate plume from old (pre1989) pond. Mixing zone/compliance 

boundary expanded to include the new 

(1989-), active SI. Vertical extent of 

plume was limited by a confining 

geologic unit 15-30' below the property.

Acute WQC: Cd, Cr, Cu, 

Hg, Se, Zn; Acute and 

Chronic WQC: Al, Fe. 

State/Federal: ROD, capping, and 

institutional control.

Some active, some 

not

Final remediation of the site is expected 

to begin in 2015, concurrent with 

closure of the coal-fired power plant.
Soil (Source and 

standards unknown): 

As, Ba, Cr, Co, Hg, Ni, Zn, 

Mn. 

None as of the start of 2010. 

Utility ia assessing the nature and 

extent of the contamination 

associated with the SIs. According 

to DHEC, no offsite monitoring 

has been required since results in 

wells near the river have not 

exceeded drinking water 

standards; these activities are 

considered to be “informal” 

actions, and no violations or 

orders have been issued to the 

owner. Informal state actions 

have been required, including 

listing site on GW Contamination 

Inventory (2008) for As from ash 

basins.

Active Arsenic plume affects only the shallow, 

unconfined aquifer. DHEC entered into 

a Consent Agreement with SCE&G for 

the closure of the landfill and in 6/2011, 

approved the closure plan. Generation 

Unit 3 - the last coal-fueled unit at 

Urquhart - was converted to burn 

natural gas in 2012. The Plant's 

remaining two units would be retired by 

2018.

Fish threshold of 

toxicity for reproduction 

and growth: As; 

(Sediment); Residential 

Superfund soil screening 

(soil): As, Co, Tl, Fe. 

(Sediment pore waters) 

toxic level for sensitive 

benthic invertebrates: 

As 

State/CO, Fish advisory; 

Federal/CERCLA, impact studies. 

District judge established that 

TVA is legally responsible for the 

December 2008 incident and that 

TVA would have to pay 

unspecified damages to more 

than 800 plaintiffs (8/2012). In 

response to the appearance of 

the sinkhole in the FGD landfill, 

on December 17, 2010, TDEC 

issued an Enforcement Order for 

Corrective Action for KIF’s 

violation of both the State’s 

Water Quality Control Act and the 

State’s Solid Waste Disposal Act.

Active Dike failure (12/2008) and 

contamination of GW due to a sinkhole 

(12/2010).

Max concentration for 

protecting aquatic life: 

As; Fish tissue toxicity 

level: Se, As, Tl (?). 

State/Federal: NPL, RI, Remedial 

Action.

Inactive Remedial Action completed 1997. Due 

to 'unclean closure', site is being 

monitored and under institutional 

control. 

Unknown standards: 

SW: Hg (?); Sediment: Hg 

State/Order, 3 NOV (in one case, 

$160,000 penalty)

Active Expansion, with GW monitoring, 

recently approved. Groundwater 

mounding.

Toxicity level: Se in fish State/Fish advisory; Fish Se study Active USWAG claims that the Pirkey plant's SI 

system was designed as self contained, 

and that runoff from lignitic coal has 

contaminated the cooling resrvoir.
Toxicity level: Se in fish State/Fish advisory, Fish Se study. 

State required operating changes 

to mitigate contamination: (i.e., 

increasing freeboard capacity of 

the CCR management ponds, 

lining ponds with synthetic 

membranes, installing leak 

detection systems, monitoring 

ground- and surface water, and 

biomonitoring of fish). Discharge 

of ash-pond decant water to the 

cooling reservoir was eliminated.

Active

Toxicity level: Se in fish State/Fish advisory, fish Se study. 

State required operating changes 

to mitigate contamination.

Active Generation Unit 2 of the Welsh Plant 

(528 MW; one of three generation 

units), slated to retire by December 31, 

2014.

EPA's WQC: Cu, Al, pH None Some Active, some 

not. Generation Unit 

3 (235 MW) to retire 

by end of 2014; and 

Units 1 and 2 (470 

MW total) would be 

refueled with natural 

gas with a capacity 

of 422 MW by end of 

2014.

Dike failure; release of 130 million 

gallons of coal ash slurry. Subsequent 

actions included closure of the SI, a 

cement bentonite-fly ash cutoff wall 

within the perimeter dike of Ash Pond 1 

(1990), and a wastewater treatment 

plant (1993). All coal-fueled units are 

slated for closure at the end of 2014.

State's WQS: Cd, Cr, Se, 

As, Zn, pH. Steep 

bioaccumulation in 

duckweed: Cd, Ni, Cu

None (In its comment to the 

docket, VADEQ Characterizes this 

incident as a not recent case and 

a legacy issue which is not an 

accurate picture of VA's current 

regulatory program.) Since 2009, 

fly ash is dry-disposed at the New 

River Structural Fill.

Inactive. Plant is 

slated to close by 

end of December 

2014. 

Effluent discharges from the ponds in 

the mid- to late 1970s impacted the 

biota in the stream, reducing the taxon 

richness and diversity, particularly for 

macro-invertebrates and fish and 

impacting microbial measures of aquatic 

ecosystem function and overall health. 

Site is karst-susceptible.
WQC: V, Ni, Sf State/CO Federal/NPL. ROD for 

OU1 included capping the 

disposal pits, GW and leachate 

collection for treatment and to 

lower the water table beneath 

the pits, replacement water 

supply wells to 55 homes with 

contaminated well water, and 

post-closure monitoring. ROD for 

OU2 included relocation of a 600-

foot portion of the tributary to 

minimize contact with the fly ash 

disposal areas, diversion of 

surface runoff, and long-term 

monitoring for the ponds, 

tributary, and estuary. 

Inactive/1974. One 

(out of two) coalfired unit would 

likely close by 2015 

and a second unit 

would likely be 

converted to natural 

gas.

Nearby shallow residential wells 

became contaminated with nickel, 

selenium, and vanadium, leachaed 

from coal ash and petcoke.

State’s Acute and 

Chronic water quality 

standards for the 

protection of aquatic 

life: Se, Hg, As, Cu.

State/Compliance Schedule; NOV 

(2/2009) due to inadequate LF 

stormwater control resulting in 

deposition of fly ash in adjacent 

wetland. Consent Decree 

(8/1/2014) between citizens 

groups and APCo to comply with 

NPDES effluent limitations for Se 

and Hg in Outlet 003.

Active A compliance schedule to meet end-ofpipe chronic toxicity limitations on this 

discharge in the most recent NPDES 

permit (7/2007).

Excessive contents in 

impacted vegetation: B

State: Extraction pumping, GW 

monitoring, and two-phase site 

capping 

Inactive/1977 Impact on GW and vegetation damage 

in wetland.

Ambient Water Quality 

Criteria (AWQC): Cd, Cu; 

Levels toxic to aquatic 

life: As, Se, Pb, Mn; 

Elevated tissue levels in 

Crawfish (accompanied 

by impaired metabolic 

rates): Se, Zn, Fe 

State/CO Acive Series of impoundments - sulfuric acid 

added to reduce the pH from over 10 to 

8 or lower, as required by the discharge 

permit. Construct a sanitary wastewater 

treatment plant. 
State: Remediation plan, capping, 

alternative water source to 

residents.

Inactive/1978 Elevated GW Table.

State's WQC: Cr, As, TCE, 

diesel

Collapse impact study was a multiagency effort.Structural fill: 

Inactive

Collapse of old structural fill used for 

the staging of adjacent Plant expansion 

landed ~23,000 cu yd in the Lake and in 

two coastal settlemt ponds. On 

November 8, 2011, The Sierra Club filed 

a notice of intent to sue WE.

State/Admin Order for long-tem 

GW monitoring, closure.

Inactive. Plant 

recently converted 

into a biomassfueled facility.

Groundwater displays periodic 

mounding. Leachate migrating off-site 

in GW and reaching 2 small ponds (no 

drinking water source affected). Since 

1989, coal ash has been managed in a 

double-lined landfill, with leachate 

collection. 

COCs/SW Regulatory Action Current Status Comments

aste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; T
NOV CO/Admin 

Order

Study Extended- or 

Assmt 

Monitoring

Remedial 

Action

Lawsuit/Petitio

n/Consent 

Decree

Fish Advisory/ 

Fishing Ban

Provide 

Drinking 

Water

Y Y Y

Y Y Y Y .

Y Y
Y Y Y Y Y

Y Y Y Y Y

Y Y Y Y

Y Y

Y
Y Y

Y Y Y Y Y Y Y

Y Y Y Y

Y

Y Y Y Y
Y Y

Y Y Y Y

Y Y Y

Y Y Y Y
Y

Y Y Y Y Y Y

NOV CO/Admin 

Order

Study Extended- or 

Assmt 

Monitoring

Remedial 

Action

Lawsuit/ 

Petition/ 

Consent 

Decree

Fish Advisory/ 

Fishing Ban

Provide 

Drinking 

Water

Y Y
Y Y Y Y Y

Y Y Y Y Y Y

CO Y Y

Y Y
Y

Y Y Y Y

Y Y

Y Y

Y Y Y
Y

YY

YYY
Y Y Y Y Y

Y Y

Y Y

Y Y Y
Y Y Y Y

Y Y

Y Y Y

NOV CO/Admin 

Order

Study Extended- or 

Assmt 

Monitoring

Remedial 

Action

Lawsuit/ 

Petition/ 

Consent 

Decree

Fish Advisory/ 

Fishing Ban

Provide 

Drinking 

Water

 OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - 
Other (Closure) Basis for Consideration

Converted to a dry 

stack operation

Scientific & Administrative

Breached dike 

repaired following 

each failure. Eagle 

Valley to retire and 

be replaced by 2017 

by combined cycle 

gas turbine. 

Administrative

In the process of 

switching from wet to 

dry disposal.

Scientific 
Scientific and Administrative

Penalty; out of court 

settlement

Scientific and Administrative

Lawsuit by state Scientific and Administrative

Scientific and Administrative

Closure Scientific
Closure Scientific and Administrative

Lining of SIs. Citizens' 

suit - out of court 

settlement 

Administrative

Scientific and Administrative

Scientific

Closure Scientific and Administrative
State req'd operating 

changes (wet to dry; 

and ash-basin decant 

water, which 

continued to receive 

minor selenium 

contributions from 

power plant bottom 

ash, being discharged 

into the nearby Dan 

River)

Scientific and Administrative

Administrative

State req'd operating 

changes

Scientific and Administrative

Administrative
Closure Scientific

Settlement 

Agreement (1994). 

Consent Decree 

(12/2012) and 

Impoundment 

Closure Permit 

(4/2014).

Scientific and Administrative

Other (Closure) Basis for Consideration

Closure. Plant slated 

for retirement by 

March 2014.

Scientific and Administrative
LF Phases 1 & 2 

Closed.

Scientific and Administrative

Two coal-fueled units 

(150 MW) 

permanently closed 

2007, but oil/gas - 

fueled units (1690 

MW) still operate.

Scientific and Administrative

Closure. One of three 

coal-fired units at the 

Plant (Unit #1) was 

retired in late 2012, 

and the two others - 

Nov. 2013.

Scientific and Administrative

Closure Scientific and Administrative
Closure Scientific

CERCLA cleanup Scientific and Administrative

NPL Scientific and Administrative

Penalty Scientific and Administrative

Scientific and Administrative
State req'd operating 

changes. 

Scientific and Administrative

State req'd operating 

changes

Scientific and Administrative

None ('pre-regulatory 

era')

Scientific

None Scientific
NPL/Capping. Scientific and Administrative

Compliance schedule Scientific

Closure. The Plant's 

four coal-fueled units 

were replaced with 

two (545 MW each) 

natural-gas fueled 

units in 2005 and 

2008.

Scientific and Administrative

Scientific and Administrative
Closure in 1999. In 

3/2014, WE Energies 

was granted 

permission to convert 

the plant from coalfueled to natural gas 

fueled facility.

Scientific and Administrative

CERCLA cleanup Scientific and Administrative

Closure Scientific and Administrative

Other (Closure) Basis for Consideration

DS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent O









iciency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - 









ent; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Sec









m Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS 









AL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Stan









WS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter
No. Crosswalk Facility Location State

1 PTa02 Widows Creek Fossil Fuel Plant, TVA Stevenson AL

2 PTa01 Colbert Fossil Fuel Plant, TVA Tuscumbia, 

Colbert Co.

AL

3 PTb01 Flint Creek Power Plant, SWEPCO Gentry AR

4 PTb02 Independence Steam Station – Entrgy/AP&L Newark AR
5 PTa03 Cholla Steam electric Generating Station - Arizona 

Public Service Co. 

Joseph City, 

Navajo County

AZ

6 PTb03 Montville Generating Station - NRG 

Energy/Montville Power 

Montville CT

7 PTb04 Indian River Power Plant Burton Island – NRG Energy Millsboro DE

8 None Crist Plant Ash Landfill - Gulf Power (Southern 

Company)

Pensacola FL

9 PTa04 Lansing Smith Plant - Florida Power & Light Bay Co. FL
10 PTb07 Curtis Stanton Energy Center - Orlando Utility 

Commission

Orlando FL

11 PTb08 Seminole Generating Station – Seminole Electric 

Cooperative

Palatka FL

12 PTb05 Big Bend Station – Tampa Electric Co. Apollo Beach FL

13 PTb06 CD McIntosh Jr. Power Plant – City of Lakeland Lakeland FL

14 PTb13 Lansing Station Ash Ponds and Landfill – 

Alliant/Interstate Power and Light Company (IP&L)

Lansing IA
15 None Fair Station Ash Landfill - Central Iowa Power 

Cooperative 

Montpelier IA

16 PTa19 Muscatine County Landfill Montpelier IA

16 PTb14 George Neal Station North Landfill - MidAmerican 

Energy

Sergeant 

Bluff/Sioux City 

IA

17 PTb15 George Neal Station South Ash Monofill - 

MidAmerican Energy

Salix IA

18 None Prairie Creek Generating Station Ash Landfill - 

Interstate Power and Light (Alliant) 

Cedar Rapids IA
19 None Joppa Steam Plant Ash Ponds - Ameren (Electric 

Energy) 

Joppa IL

20 None Meredosia Power Station Ash Ponds - Ameren 

Energy Generating Company 

Meredosia IL

21 None Dallman Station Ash and FGD Ponds - City Water, 

Light and Power 

Springfield IL

22 PTa09 Powerton Plant Mahoney Landfill and Ash Ponds - 

Midwest Generation (Commonwealth Edison) 

Pekin, Tazewell 

Co.

IL

23 PTa05 Duck Creek Station - Central Illinois Light Co. 

(Ameren, Dynegy) 

Canton, Fulton Co. IL
24 PTa07 Hennepin Power Station - Illinois Power Co. (Dynegy) Hennepin, Putnam 

Co.

IL

25 PTa06 Havana Power Plant - Illinois Power Co. (Dynegy) Havana, Mason 

Co.

IL

26 PTa10 Vermillion Power Station - Illinois Power (Dynegy 

Midwest) 

Oakwood, 

Vermillion Co.

IL

27 PTa08 Hutsonville Power Station - Central Illinois Public 

Service Co. (Ameren) 

Hutsonville, 

Crawford Co.

IL

No. Crosswalk Facility Location State
28 PTa12 Wood River Power Station - Illinois Power Co. 

(Dynegy Midwest)

Alton, Madison 

Co.

IL

29 None Waukegan Generating Station Ash Ponds - Midwest 

Generation (Edison International) 

Waukegan IL

30 PTa11 Coffeen/White & Brewer Trucking Fly Ash Landfill Coffeen, 

Montgomery Co.

IL

31 PTb09 Joliet Generating Station 9 Lincoln Stone Quarry 

Landfill - Midwest Generation 

Joliet IL

32 None Joliet 29 Generating Station Ash Ponds - Midwest 

Generation (Edison International)

Joliet IL
33 None Pearl Station Ash Pond - Prairie Power (Soyland 

Power Coop.) 

Pearl IL

34 PTb10 Marion Plant - Southern Illinois Power Cooperative 

(SIPC)

Marion IL

35 PTb11 Venice Power Station – Union 

Electric/Ameren/AmerenUE

Venice IL

36 PTa16 Michigan City Site, NiSource Michigan City IN

37 PTa13 Bailly Generating Station, NiSource Chesterton IN
38 PTa18 R.M. Schahfer Generation Station, NiSource Wheatfield, Jasper 

Co.

IN

39 PTa14 A.B. Brown Generating Station - Southern Indiana 

Gas & Electric Co. (Vectren) 

Mt. Vernon, Posey 

Co.

IN

40 PTa17 Petersburg Generating Station - Indianapolis Power 

& Light 

Petersburg, Pike 

Co.

IN

41 PTa15 Merom Generating Station CCW Landfill - Hoosier 

Energy 

Sullivan IN

42 PTb12 Clifty Creek Station, Indiana-Kentucky Electric 

Corporation

Madison IN
43 PTa20 East Bend Scrubber Sludge Landfill - Cinergy (Duke 

Energy) 

Rabbit Hash, 

Boone Co.

KY

44 PTb16 Mill Creek Station – Louisville Gas & Electric Louisville KY

45 None Paradise Fossil Plant Ash Ponds, TVA Paradise KY

46 PTb17 Shawnee Fossil Plant, TVA Paducah KY

47 PTb18 Spurlock Power Station - Eastern Kentucky Power 

Cooperative

Maysville KY
48 PTb19 Big Cajun II Power Plant – NRG/Louisiana Generating New Roads LA

49 PTb20 Dolet Hills Power Station - CLECO Power Mansfield LA

50 PTb21 Rodemacher Power Station - CLECO Power Lena LA

51 PTa21 K.R. Rezendes Main Street Ash Landfill, PG&E Freetown MA

52 PTb22 Brandywine Coal Ash Landfill – Mirant Mid-Atlantic Brandywine, 

Prince George's 

County

MD
53 PTb23 Mirant Dickerson’s Generation Station’s Westland 

Disposal Site

Dickerson, 

Montgomery Co.

MD

54 PTb24 Karn/Weadock Generating Facility – Consumer 

Energy

Saginaw MI

55 PTb25 Pine Hill Landfill - Marquette Board of Light & Power Negaunee 

Township

MI

56 PTb26 Presque Isle Power Plant - We Energies Marquette MI

57 PTb27 Muskegon County Type III Landfill Muskegon Co. MI
58 PTb28 John Warden Ash Site L'Anse, Baraga Co. MI

59 PTb29 BC Cobb - Consumers Energy Muskegon Co. MI

60 PTb30 J.H. Campbell, West Olive - Consumers Energy Ottawa Co. MI

No. Crosswalk Facility Location State

61 PTa22 Xcel Energy/Southern Minnesota Municipal Power 

Agency (Sherco) Generating Plant

Becker, Sherburne 

Co.

MN
62 PTa26 Allen Steam Generating Plant - Duke Power Gaston Co. NC

63 PTb37 Sutton Steam Plant – Progress Energy Wilmington NC

64 PTb36 Lee Steam Plant – Progress Energy Goldsboro NC

65 PTb34 Cape Fear Steam Plant – Progress Energy Moncure NC

66 PTb33 Belews Creek Steam Station - Duke Energy Belews Creek NC
67 PTb32 Asheville Steam Electric Plant - Progress Energy Arden NC

68 PTb35 Dan River Steam Station - Duke Energy Eden NC

69 PTa28 R.M. Heskett Station - Montana-Dakota Utilities Mandan, Morton 

Co.

ND

70 PTa29 W.J. Neal Plant - Basin Electric Velva, McHenry 

Co.

ND

71 PTa27 Coal Creek Station - Great River Energy Underwood ND
72 PTb38 Leland Olds Station - Basin Electric Power 

Cooperative

Stanton ND

73 PTb31 Sheldon Station – Nebraska Public Power District Hallam NE

74 PTa24 Weber Ash Disposal Site - AES Creative Resources Fenton, Broome 

Co.

NY

75 PTa23 Danskammer Waste Management Facility, NY - 

Central Hudson Gas & Electric Corporation 

Newburgh NY

76 PTa25 C.R. Huntley Flyash Landfill Tonawanda NY
77 PTa31 Miamiview Landfill - Cincinnati Gas & Electric Co. Hamilton Co. OH

78 None Stuart Station Impoundments - Dayton Power & 

Light 

Adams Co. OH

79 PTa30 Beckjord Station - Cinergy W.C. New Richmond OH

80 PTb39 Cardinal Fly Ash Reservoir (FAR) 1 & 2 – AEP Brilliant OH

81 PTb40 General James M. Gavin Power Plant – AEP/Ohio 

Power

Cheshire OH
82 PTb41 Muskingum River Plant – AEP/Ohio Power Beverly OH

83 PTb42 Northeastern Station Ash Landfill, AEP/Public Service 

Co. of Oklahoma

Oologah OK

84 PTb45 Mitchell Power Station, Allegheny Energy Courtney PA

85 PTb43 Phillips Power Plant – Duquesne Light Co. Crescent Tonshp PA

86 PTb47 Seward Generating Station – RRI Energy, Inc. New Florence PA
87 PTb44 Hunlock Power Station – UGI Development Co. Hunlock Creek PA

88 PTb46 Portland Generating Station’s Bangor Quarry Ash 

Disposal Site – RRI Energy, Inc

Bangor PA

89 None McMeekin Station Ash Landfill and Ponds - South 

Carolina Electric & Gas Company (SCANA) 

Columbia SC

90 PTb49 Wateree Station – South Carolina Electric & Gas Eastover SC

91 None Cross Generating Station Ash Landfill and Ponds - 

South Carolina Public Service Authority (SCPSA; 

Santee Cooper) 

Pineville SC
92 PTb48 Dolphus M. Grainger Generating Station - South 

Carolina Public Service Authority 

Conway SC

93 None Winyah Generating Station Ash and FGD Ponds - 

South Caroline Public Service Company (Santee 

Cooper) 

Georgetown SC

No. Crosswalk Facility Location State

94 None Allen Fossil Plant Ash Ponds, TVA Memphis TN

95 PTa32 Bull Run Steam Plant, TVA Oak Ridge TN
96 PTb52 John Sevier Fossil Plant, TVA Rogersville TN

97 PTb50 Cumberland Steam Plant, TVA Cumberland City TN

98 PTb51 Gallatin Fossil Plant, TVA Gallatin TN

99 PTb53 Johnsonville Fossil Plant – TVA New Johnsonville TN

100 None Coleto Creek Power Station - International Power Fannin TX
101 PTb54 Fayette Power Project (Sam Seymour) – Lower 

Colorado River Authority

Le Grange TX

102 None Parish Generating Station - Texas Genco II (NRG 

Energy) 

Thompsons TX

103 PTa33 Battlefield Golf Course - Dominion Power Chesapeake VA

104 PTa41 Rock River Ash Disposal Facility - Alliant (WP&L) Beloit, Rock Co. WI

105 PTa36 Edgewater 1-4 Ash Disposal Site - Alliant Sheboygan WI
106 PTa40 Pulliam ash Disposal Site - Wisconsin Power Supply 

Co. 

Green Bay WI

107 PTa35 Alma On-site Fly Ash Landfill - Dairyland Power Buffalo Co. WI

108 PTa34 Alma Off-site Fly Ash Landfill - Dairyland Power Alma, Belvidere 

Township

WI

109 PTa38 Nelson Dewey Ash Landfill, Cassville Grant Co. WI

110 PTb55 Oak Creek Power Plant Caledonia Landfill – 

Wisconsin Energy/Wisconsin Electric Power

Oak Creek WI
111 PTa39 Druecker Quarry Fly Ash Site - WEPCO Port 

Washington Facility

Ozaukee Co. WI

112 PTa37 Lemberger Landfill, Wisconsin Whitelaw, Franklin 

Township, 

Manitowoc 

County

WI

113 PTa42 Dave Johnston Power Plant, WY Glenrock, 

Converse Co.

WY

114 None Pleasant Prairie Landfill, WEPCO Kenosha Co. WI

115 None Highway 32 Landfill, WEPCO Ozaukee Co. WI
116 None Woodfield Landfill - NSP (Northern States Power) Bayfield Co. WI

117 None Weston #3 Ash Disposal Landfill - WPSC (Wisconsin 

Public Service Co.) 

Marathon Co. WI

No. Crosswalk Facility Location State
References Waste Unit Type Liner Year Commissioned

2007 DC Ass #32 3 major SIs (ash pond, gypsum 

pond, and gypsum settling pond) 

and several minor (de-minimis) 

ponds.

3 SIs: No Main Ash Pond: 1950; 

Gypsum Stack: early to 

mid-1980s.

2007 DC Ass #33 2 SIs (one for CCR, one runoff 

pond), & 2 LFs (one of which is 

closed); a (no longer used) 

chemical pond is apparently GW 

contamination source.

SIs: None; Chemical pond: 

Clay; LFs: None

SI: 1972 LF: 1975, 1984

In Harm's Way #1 LF (implicated in impact); and 2 

SIs: one Primary and one 

Secondary (implicated in impact; 

both unregulated, because they 

are dredged periodically for BU). 

Also, 500 acres cooling lake.

LF: No (till 1994); 6" Clay 

liner thereafter. SIs: No

All: 1978

In Harm's Way #2 LF; 2 wastewater recycle ponds & 

1 surge pond. Along with CCR, 

the surge pond and the recycle 

ponds handle various process 

wastewaters. Apparently, all WUs 

are implicated.

LF: 90% - no liner; half of 

the most recent cell was 

built with 18” of compacted 

clay, max. hydraulic 

conductivity of 1 x 10-5 

cm/sec.

1983, 1990
2007 DC Ass #67 Two primary SIs (one fly ash, the 

other bottom ash) and 2 small deminimis (ash contact) wastewater 

ponds: a Sedimentation Pond and 

a Retention Pond (Zero discharge 

facility); also, a cooling lake. Fly 

Ash pond assoc. w/impact.

2 Primary SIs: No SIs: 1978; cooling lake: 

1961.

In Harm's Way #3 Several primary coal ash settling 

ponds and disposal lagoon (active 

until 1971, when plant switched 

to oil) - implicated; and 3 

unregulated, off site dumping 

areas. 

No 1919

Out of Control #1 An island-sited Primary 'SI' and 

mainland-sited LF: all implicated.

SI: No; LF-I: No 1957; 1980

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #1)

Fly ash and bottom ash storage 

areas (SW of the plant) and 2 

gypsum storage areas (NE of the 

plant). Both WUs implicated.

? ?

2007 DC Ass #36 A Primary SI (with 3 cells) No 1965
Out of Control #2 Active LF; 3 CCR and coal storage 

area runoff ponds, a recycled 

water pond (zero-discharge 

facility), and a plant wastewater 

pond. Both LF and ash ponds 

implicated.

Yes 1981

Out of Control #3 Active, unlined FGD LF 

(implicated); 3 lined process 

wastewater ponds; and 2 unlined 

storm water runoff ponds. 

LF: No; 3 process 

wastewater ponds: Yes; 2 

storm water runoff ponds: 

No.

1984

Out of Control #4 Three economizer fly ash ponds, 2 

bottom ash ponds, 2 wastewater 

recycling ponds, one FGD gypsum 

settling pond; bottom ash dry 

storage unit, and waste disposal 

management unit. waste disposal 

management unit clearly 

implicated, but apparently wetdisposal units are also a source 

LF – Yes; FGD Storage Area: 

No (but liner to be 

implemented 2013-2015); 8 

SIs: Yes (in 3 of the ponds - 

first installed in 2001). Five 

ponds have compacted 

structural fill and 60 mil 

HDPE liners; the remaining 3 

- compacted structural fill 

Bottom ash ponds and LF - 

late 1960s -early 1970s?; 

Economizer ponds: 1984; 

settling-recycle ponds: 

2009. 

In Harm's Way #4 2 LFs (implicated); FGD sludge 

dewatering area, process 

wastewater ponds (implicated); 

artificial wetland. 

LFs: Originally - No; 

presently - a double liner(?). 

SIs: One pond has a double 

liner (?). Other ponds: 

unknown.

1981

In Harm's Way #7 LF; 2 Ash Ponds (Primary and 

Polishing).

LF: No; Ponds: No LF: 1985. Ponds: ~ 1975.
EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #3)

Ash monofill ? 1974

2007 DC Ass #64 LF (now closed) assoc w/impact. 

Also an active LF.

Both LFs: No 1964; 1975

In Harm's Way #5 One LF (two closed sections), in a 

former S&G Pit (implicated); 3 

unlined SIs.

LF; No; SIs: No LF: 1978; 2 SIs: 1972; 1 SI: 

1975

In Harm's Way #6 LF in a former S&G Pit. Apparently No Early 1980s

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #4)

LF (implicated), in a former 

limestone quarry. 12 small (each 

less than an acre) SIs, 10 of which 

receive CCR and 2 receive coal pile 

runoff. Facility permit No. 57-SDP35-04.

? LF: ? 11 Sis: 1965; one of 

the coal pile runoff ponds: 

2009.
EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #8)

2 SIs, one active, other inactive 

and capped. Also 

runoff/settlement pond and 

sewage lagoon.

No Inactive: mid-1950s; 

Active: 1973 (modified 

1985); sewage lagoon: 

1995

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #9)

2 active SIs (Fly Ash pond and 

Bottom Ash pond); three inactive 

Sis (Fly Ash, Bottom Ash, ?).

No Active: Fly Ash: 1968; 

Bottom Ash: 1972. Old Fly 

Ash and Old Bottom Ash 

established: 1948? 

Capped in 1970s. 

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #6)

2 active Sis (implicated); FGD LF 

(Facility operates under IEPA 

Permit IL0024767.)

No Sis: ?; FGD LF: 1986

Mahoney LF: 2007 DC Ass 

#40; Ash Ponds: EPA-HQRCRA-2011-0392-0259 and 

Risky Business #11 (EIP, 

2011). IEPA Permit 

IL0002232.

2 LFs (one - in abandoned S&G pit, 

both now closed) and 3 ponds: 

Ash Basin, Secondary Basin, and 

Bypass/ Stormwater Basin. Also, a 

1,426 acres Powerton (cooling) 

Lake (closed-loop cooling system). 

Both dry- and wet-disposal 

implicated.

LFs: Poz-O-Pac (ash w/lime, 

with a tendency to crack 

upon shrinkage); 2 ash 

ponds (Ash Basin & 

Secondary Basin): Yes; 

stormwater retention basin: 

No.

Powerton Lake: 1971; Old 

LF: 1972; 'New' LF: 1978. 

SIs: apparently in the 

1970s.

2007 DC Ass #47 2 Primary SIs (slated for closing in 

2010), Recycle Pond, and an 1,800 

acre cooling pond.

Primary SIs: No; Recycle 

Pond: Clay.

1976, 1985, 1985.
2007 DC Ass #48 2 Primary SIs in a pre-existing 

gravel pit (both implicated; closed 

since 1996); an extinct (originally, 

a gravel pit) LF, overbuilt by a SI; 

several currently active (lined) SIs; 

and a recently completed, lined 

fly ash LF. 

2 Inactive SIs: No; Old LF: 

No; Active SIs: Composite. 

New LF: Synthetic.

SIs: 1952; 1958; 1997.

2007 DC Ass #49 3 multi-cell Primary SIs - one 

active, two closed in 1994. Impact 

associated w/one of the closed 

SIs.

Active SI: composite (clay & 

geomembrane); two other 

SIs: apparently No. 

Active SI (4 cells): 1990-

2003; Inactive SI (2 cells): 

1947; closed SI: 1977.

2007 DC Ass #52 3 multi-cell Primary SIs - one 

active, two closed (one in the mid1970s and the other converted, in 

1988, into a stormwater pond); 

and a cooling pond. Impact 

associated w/at least one of the 

two closed SIs.

2 SIs: No; 3rd SI: 

contradictory information.

Mid-1950s; mid-1970s; 

and 1988.

2007 DC Ass #53 Five Primary SIs, one of which 

(Pond D) is assoc. w/impact 

(closed in 2000, partially replaced 

by a LF).

3 SIs (A, B, C): 

geomembrane; bottom ash 

pond: probably No; Pond D: 

No. LF: unknown.

A: 1986; B and C: 2000; 

Bottom Ash: 1940; and D: 

1968.

References Waste Unit Type Liner Year Commissioned
2007 DC Ass #54 2 Primary ponds, one of which 

(West Pond - WAP - closed in 

2000) is assoc. w/impact. Original 

ponds redesigned, w/Bottom Ash 

handled in 2 ponds and, beginning 

in 1999, all fly ash has been 

managed by dry-handling. 

WAP: Originally No, but in 

1997, one cell received 

double clay liner w/leachate 

collection, and the EAP - a 

composite liner (45-mil 

HDPE/clay).

Precursor to both ponds: 

1952. Evolved into the 

West Ash Pond (WAP): 

1977 (and earlier) and the 

East Ash Pond (EAP): 

2006.

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #12)

2 SIs and a LF (Facility operates 

under IEPA Permit IL0002259).

SIs: Yes; LF: ? ?

2007 DC Ass #56 2 inactive LF cells (assoc. 

w/impact, closed between 1980-

1997); one active LF w/leachate + 

stormwater pond; and two recycle 

SIs (one for boiler slag and one for 

FGD gypsum). Also, a cooling lake.

LFs: No; Recycle Pond: No; 

FGD Pond: HDPE.

LF: 1977 or earlier; 

Recycle Pond: 1979; FGD 

Pond: 2009.

In Harm's Way #8 Primary Pond (defined as 'LF') in 

former quarry, assoc. w/impact; 2 

Primary SIs. 

No 1962

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #7)

3 active SIs (Facility operates 

under IEPA Permit IL0064254.)

Two: HDPE; One: 

geocomposite

?
EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #10)

Clay Yes 1968

In Harm's Way #9 1 LF; 11 SIs (most are Primary, for 

fly ash and FGD gypsum; two - for 

bottom ash/boiler slag and a 

connected Polishing Pond). SIs are 

implicated. Also, a cooling lake 

(Lake of Egypt).

LF: No; 6 SIs: No; 1 SI: Yes; 

remaining ponds: unknown.

SIs: 7 were commissioned 

in 1976, one – in 1988, 

one- in 1992, and 3 – in 

1996.

In Harm's Way #10 3 Primary SIs (implicated; stopped 

receiving CCR in 1977, but kept 

receiving process wastewater till 

2005), closed 2010. 

No 1950s

2007 DC Ass #43 2 historic, Primary SIs (assoc. 

w/impact; closed 2007); 

presently: 3 Primary SIs (two- for 

fly ash, one - for bottom ash) and 

3 polishing ponds: two 'secondary' 

ponds and one 'final settling' 

pond. Also, pre-1973 areas of 

unregulated structural fill.

All six SIs: No 1974

2007 DC Ass #44 Several unpermitted 'LFs' 

(discontinued 1979-1986) and 

several SIs: two Primary and 2 or 3 

Secondary (one closed 1979). 

Remaining ponds were retrofitted 

(1980-81). Apparently, all old WUs 

assoc. w/impact. Presently: 2 

Primary ponds, 2 Secondary 

ponds, one bottom ash pond, and 

All waste units were 

originally unlined. However, 

between 1979 and 1981, 

the SIs were dredged then 

‘composite’ lined (HDPE 

over clay).

1962-1970s
2007 DC Ass #55 3 Primary Ponds and 4 de-minimis 

ponds; one LF; and two former 

dry-staging areas (one for ash, the 

other - for FGD gypsum). Impact 

assoc. apparently with all old, 

unlined WUs.

LF Phases I and II: No; LF 

Phases III and IV: Composite 

liner w/leachate collection. 

SIs: No information (Dam 

Assm't Report withheld 

under CBI).

LF commissioned 1984. 

Ponds: 1976 (large, Final 

Settling basin); 1982 (3 

Primary and one deminimis pond); 1983 (FGD 

stormwater Pond); and 

1999 (Yard Drain 

Stormwater Pond). Two 

dry (retired) waste units: 

2007 DC Ass #57 One unlined LF assoc. w/impact; 

two unlined (bottom ash) SIs (not 

implicated).

LF: initially - No, Clay -in 

expansion; SIs: No.

LF: 1979 (expanded: 

1992); SIs: 1978 and 2003-

07.

2007 DC Ass #59 Site associated with old 

abandoned surface and 

underground coal mines. One 

unlined LF assoc. w/impact; 4 

unlined SIs (two active, two 

inactive, constructed between 

1964 and 1986) are not 

implicated.

LF: No (planned LF 

expansion will have a liner 

consisting of 1' of clay and 

2' of Poz-o-Tec); SIs: No

LF: 1976 (expanded: 1967, 

1969, 1977, 1986). SIs: 

1964-1986, modified: 

1999.

2007 DC Ass #60 One active (lined) and one closed 

(unlined) LF, associated with 

several auxiliary sedimentation-, 

wastewater treatment, and 

emergency basins, all lined. LF #1 

(unlined) impact GW, basins 

impact cooling reservoir. 

LF Area 1: No; Area 2A: Clay. 

Auxiliary basins: all lined 

(clay or synthetic).

LF: 1982; 1994.

Out of Control #7 Type III LF & 2 SIs (one is Primary, 

for Boiler slag, and the other was 

formerly Primary, for fly ash, but 

is currently used only for 

stormwater management.) An 

ulined Class III LF sited over the 

former fly ash SI (Overfill); in 

2009/10 it was redesigned as 

Class I LF for FGD and fly ash. 

LF and SIs: No SI: 1955; LF: 1992. Type I 

LF permitted in 2002 but 

subject to legal petitions 

for improved 

environmental controls. 
2007 DC Ass #35 3 unlined, Primary SIs and one LF 

(older cells - unlined). Both LF and 

SIs implicated.

3 SIs: No; LF: mostly NO, but 

2 recent cells have a 

composite geomembrane/ 

geosynthetic clay liner with 

leachate collection. 

LF: 1981; 3 SIs: 1980

In Harm's Way #11 3 LF phases (one of which is 

inactive; only one of the two 

active ones is lined); 1 Primary 

CCR SI and 4 FGD process ponds. 

WU culpability unresolved.

2 LFs: No; 1 LF: Composite; 

Ash SIs: No; FGD ponds: ?

1972

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #13)

Three ash disposal areas: 3 SIs (a 

scrubber sludge pond and a slag 

pond in an abandoned strip mine 

pit adjacent to the Green River; 

and Peabody Ash Pond next to 

Jacob’s Creek, S of the plant). FGD 

disposal area (LF?) SW of the 

plant.

No Scrubber Sludge pond: 

1985/86; Slag Pond: Mid 

1960's; Peabody Ash 

Pond: 1997. 

In Harm's way #12 2 unlined LFs & 2 SIs; one of the 

LFs is an overfill (built over a 

closed SI). Dry ash stacking area 

implicated.

LFs: No; SIs: No SIs: 1950s and 1971; LFs: 

1984 and 2007.

In Harm's Way #13 LF (unlined, since 1979; clay-lined 

expansion in 1996; LF implicated); 

and a Primary (Bottom Ash) SI.

LF (1996 expansion): 2' 

compressed clay; SI: Clay 

liner.

LF: 1979; SI: 1976
In Harm's Way #14 5 SIs: 2 Primary (one- fly ash, one - 

bottom ash), two wastewater 

treatment ('Primary' and 

'Secondary'), and a Surge Pond. 

Impact assoc. with Primary 

Treatment Pond, the Surge Pond, 

and the Bottom Ash pond. 

3 SIs: clay; 2 SIs: 'naturally 

occurring clay'.

1980

In Harm's Way #15 1 LF & 9 SIs: 3 bottom ash ponds, 

3 surge ponds (FGD and ash), a 

metal cleaning waste pond (fly 

ash), a plant discharge collection 

pond, and a limestone runoff 

pond. One Surge Pond and Metal 

Cleaning Pond (both contain ash) 

implicated.

LF: ?; 2 ash ponds: clay; 7 

SIs: ?; site underlain by low 

permeability clay.

1986

In Harm's Way #16 1 LF with a leachate collection 

pond; 7 SIs: two Primary (one- fly 

ash and one -bottom ash), 2 metal 

cleaning waste ponds, a coal 

sedimentation pond, and 

unpermitted clarifier sludge 

sedimentation pond. All WUs 

implicated.

LF: apparently No; 2 ash 

ponds: clay; 5 leach & 

wastewater ponds: 60-mil 

HDPE

LF: 1980s (overfill); SIs: 

1982; Leach ponds: 2009

2007 DC Ass #25 Unlined, offsite monofill in a 

former S&G Pit (actually, a 

structural fill). Use discontiued in 

2001, but closing might be still 

ongoing.

No 1976

Out of Control #8 LF, 4- leachate ponds (implicated), 

wastewater ponds.

LF: No – all but one pit 

(Composite liner since 

2007); Ponds: Yes

1970; 1971
MDE Notice of Intent to 

Sue Mirant , January 3, 

2011

1 LF (comprising one closed and 

one active phase); 2 settling/ 

leachate treatment ponds.

Pond 2: unlined; Pond 3: 

lined w/synthetic liner only 

in 2010, connected to active 

LF by an unlined ditch.

1959; 1962

Out of Control #9 2 Primary SIs (implicated), 

transformed into corresponding 

Class III (fly ash) LFs in 1986 and 

1992. Sluicing of fly ash stopped in 

2009. Bottom ash still handled in 

ponds.

No 1940s to 1970s.

EPA-HQ-RCRA-2009-0640-

6815, Attachment 5.

Sanitary Landfill Receiving Fly Ash No 1985

EPA-HQ-RCRA-2009-0640-

6815, Attachment 5.

Type III off-site Industrial Landfill Implicated LF: No; two later, 

non-implicated LFs: Yes, 

with leachate collection 

systems. 

1979

EPA-HQ-RCRA-2009-0640-

6815, Attachment 5.

Type III fly ash off-site monofill No 1980
EPA-HQ-RCRA-2009-0640-

6815, Attachment 5.

Type III industrial landfill No 1974

EPA-HQ-RCRA-2009-0640-

6815, Attachment 5.

Inactive SI (regulated as Type III 

industrial LF). Also, ten additional, 

active SIs.

Implicated pond: No 1970

EPA-HQ-RCRA-2009-0640-

6815, Attachment 5.

Inactive SI (regulated as Type III 

industrial LF). Also, four active 

ponds and seven active LF cells.

Implicated pond: No 1962

References Waste Unit Type Liner Year Commissioned

2007 DC Ass #41 4 Primary ponds w/overflow to a 

recycle/stoemwater basin (Ponds 

#1 and #2 are closed - they are 

assoc. w/impact); one LF and a 

leachate collection basin.

Ponds #1, #2, and Bottom 

Ash: Clay; Pond #3 and 

Recycle Basin: Composite; 

LF: Yes, w/leachate 

collection; Leachate 

collection pond: 

geomembrane.

Pond #1, Bottom Ash 

Pond and Recycle Pond: 

1975; Fly Ash/FGD Pond 

(#2): 1984; Fly Ash/FGD 

Ponds: 2004 (#3N) and 

2010 (#3S); LF and 

leachate collection pond: 

1986.
2007 DC Ass #34 2 Primary SIs: one closed (1973), 

converted into a lined LF 

('overfill'), the other (unlined, 4 

cells - 3 primary and one 

'polishing') is active.

2 SIs: No; LF: double liner 

w/leak detection system.

SIs: 1957; 1973; LF: 

2009/10

Out of Control #11 2 Primary SIs: one (unlined) closed 

(1985), the other (clay-lined ) 

active, both implicated; and a Secontaminated cooling lake.

1971: No; 1984: Clay; 

Cooling lake: No

1971, 1984; Cooling lake: 

1970s.

Out of Control #12 One Primary, active SI (prior to 

Plant's retirement - implicated), 4 

inactive (but not yet closed) 

ponds; and a cooling lake.

No Inactive: 1950s and 1960s 

(last closed 1980). Active: 

1980; cooling lake: 1961.

Out of Control #13 5 unlined SIs: one Primary (active 

until plant's retirement); two 

ponds for stormwater 

management; and 2 inactive 

ponds. Inadequate info to pin 

point down specific source term.

No 1956; 1963; 1970; 1978; 

1985

Out of Control #15 2 active, lined LFs and one unlined 

(inactive since 2007); one unlined 

SI, and a small chemical 

washdown pond. All WU 

implicated. Also, a 3,700-acre 

cooling lake.

One LF: geosynthetic with 

leach collection; FGD LF: 

Composite; SI: No; Chemical 

Washdown Pond: 

apparently No.

LFs: 1974, 2007, 2008; 

SI: 1974; Chemical 

Washdown Pond: 1972-

74; cooling lake: 1973.
Out of Control #16 2 Primary SIs: one active, and one 

inactive (part of it serves as a 

constructed wetland). Both 

implicated; also, a Chemical Metal 

Cleaning Treatment System, a 

FGDS wet scrubber wastewater 

treatment system, and a 320-acre 

cooling lake.

2 SIs: No (another source 

claims that the 1964 pond 

had a geonet installed 

there).

1964; 1982. Cooling lake: 

1963.

In Harm's Way #18 2 contiguous SIs (one Primary and 

one Scondary), both implicated; 

unlined LF (closed 2005), and a 

new, replacement LF thereafter.

SIs: No; Old LF: No; Post 

2005 LF: Unknown.

Old LF: 1949; New LF: 

2005 (?); SIs: 1956; raised 

in 1968/69 and 1976/77, 

reconfigured 1976/77.

2007 DC Ass #66 Unlined monofill 

(discontinued/closed 1989-90) - 

implicated; an active LF with a 

leachate evaporation pond. 

Old LF: No; active LF: some 

cells - clay, others - 

composite.

1954

2007 DC Ass #23 Unlined Primary SI, closed since 

late 1980s.

No 1951

2007 DC Ass #24 2 Primary ponds, 4 ash-contact 

evaporation ponds (Zero 

discharge facility), a recycle pond, 

an extended basin for cooling 

water storage, a river water basin 

for storage of raw water; and 5 

special CCR landfills (storage for 

BU). Only Ponds are assoc. 

w/impact. 

2 Primary Ponds: originally 

lined with compacted soil, 

then - clay lined, finally - 

1979 to 1982 - composite 

lined + leachate collection. 

Auxiliary and watermanagement Units: 

Unknow. LF: Originally No 

liner; between 2005-2008, a 

2 Primary SIs: 1979; LF: 

First cell - 1989, other 

cells - later.
In Harm's Way #20 5 Primary SIs: three active bottom 

ash ponds and two closed fly ash 

ponds (ponds implicated). Since 

1994, plant switched from wet - 

to dry disposal of fly ash, which is 

minefilled.

SIs 1-3: No; SIs 4-5: Probably 

No; Mine LF: 2' Clay.

1966; 1975 (2); 1985; 5th 

pond - unspecified date.

In Harm's Way #21 1 LF (closed 1999; implicated) and 

several active LFs.

Closed LF: No (but rather 

natural clay substrate); 

active LFs: Clay liner

1989

2007 DC Ass #27 Offsite LF w/liner and leachate 

collection w/a 

leachate/sedimentation basin 

(closed since 2001). LF and 

Leachate Basin implicated in 

impact.

LF: 20 mil PVC/leach 

collection. Leachate 

collection basin: unknown.

1978-80

2007 DC Ass #28 Old LF (1959-63) implicated. 'New' 

LF has two combined leachate 

collection and stormwater basins.

Old LF: unlined; 'New' LF 

Phase I: Unknown; Phases II 

and III: double liner 

w/leachate collection 

system.

1959

2007 DC Ass #29 4 LFs inactive, unlined - implicated 

in impact - and one active LF; one 

Primary pond and five secondary 

ponds. 

4 Closed LFs: No; Phase II LF: 

Synthetic w/leachate 

collection. Primary Pond: 

No; two (of the 5) 

secondary ponds: No; two 

(of the 5) secondary ponds: 

asphalt; and one (of the 5) 

secondary pond: Clay. 

LF: Early 1970s; Ponds: 

Primary - prior to 1976; 

Secondary: 1977 (two) 

and 1984 (two).
2007 DC Ass #58 Offsite LF in a S&G Pit. Clay 1983

CCW DC Ass #82; EPA's 

2009 Dam Assessment 

Report. 

 2 LFs and 5 Ash Ponds. Also, 

wastewater and acid wash basin 

and stormwater basin.

LFs: ?; 4 of the 

impoundments have clay 

liner; one (the oldest): none.

LFs: ?; Ponds: 1975, 1977, 

1978, 1977/81, and 2001. 

2007 DC Ass #61 3 Primary (unlined) SIs, one of 

which is active.

No 1956, 1963, 1966.

In Harm's Way #23 2 Primary fly ash ponds: one 

closed and one active (both 

implicated); a 'pond complex' 

comprising 1 Primary Bottom Ash 

Pond, a Recirculation Pond, and 

polishing pond; and one FGD LF - 

an overfill.

LF: Synthetic; SIs: No SIs: 1973 & 1987; LF: Post2000

In Harm's Way #24 6 LFs (three closed and 3 active) 

and 3 small LF 

stormwater/leachate ponds; and 

2 Primary SIs (one active - for 

bottom ash, and one inactive - for 

fly ash). Also, 4 shallow storm 

water runoff collection ponds 

around the perimeter of the coal 

pile. Apparently, LF is implicated.

LFs: Composite (1.5' clay 

and 30-mil PVC); LF 

leachate/stormwater: 

Geosynthetic; 1 bottom ash 

and 1 fly ash SIs: No; 

shallow stormwater/coal 

pile - ?

SIs: 1974; LFs: 1994, 1996, 

1998
In Harm's way #26 4 Primary, ulined SIs - one is 

implicated.

No 1968

In Harm's Way #27 LF (unlined: implicated) and an 

unlined Primary (bottom ash) SI.

LF: No; SI: No LF: 1978; SI: 1979

Out of Control #19 Unlined LF; 2 Wastewater lagoons 

w/'soil liner'. Lagoons implicated, 

but ultimate source might be the 

up-gradient LF.

LF: No 2 wastewater 

lagoons: compacted 

soil/bottom ash

?

Out of Control #20 LF (FGD); 2 (unlined) wastewater 

treatment lagoons (implicated). 

All WUs closed (the ponds were 

clean-closed).

LF: No; Leachate collection; 

SIs: No

1969

Out of Control #21 2 unlined, unpermitted LFs 

(closed); Co-disposal coal ash/coal 

refuse pit (closed). Apparently, all 

WUs implicated.

No 1954
Out of Control #23 2 unlined SIs, operated until 

Plant's decommissioning (2010), 

implicated.

Only on inner slope of 

embankments, in situ clay

Early 1960s

Out of Control #24 LF in a quarry, lined above existing 

ash only in 1999 (implicated); 2 

Secondary Ponds: Stormwater 

sedimentation pond & leachate 

collection pond (NPDES-regulated 

outfalls)

LF: 60-mil LLDPE 

geomembrane over 6" fly 

ash sub base. Ponds: 

unknown.

Pre-1995

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #16)

LF and 3 SIs. ? ?

Out of Control #25 2 unlined SIs in formerly River 

S&G open pit mining (implicated); 

additional WUs (not-implicated): 

Class III FGD and ash LF; one coal 

pile runoff and LF leachate pond; 

and 2 small wastewater treatment 

ponds.

No 1970

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #15)

LF and 3 SIs. Bottom Ash 1: Clay (4" soilbentonite); Bottom Ash 2: 

Geosynthetic Clay; Gypsum 

Pond: Clay (4" soilbentonite); all 1x10-7 

cm/sec. 

Bottom Ash 1: 1983; 

Bottom Ash 2: 1995; 

Gypsum Pond: 1983.
Out of Control #27 2 Primary, unlined SIs, one of 

which had been converted (1977) 

into dry ash storage area prior to 

the recent retirement of the 

Plant. At least one of the SIs is 

implicated.

No 1966 & 1977

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #17)

6 Sis: Ash Pond A; Ash Pond B; 

South Ash Pond; West Ash Pond; 

Unit 3 & 4 Slurry Pond; and Unit 2 

Slurry Pond.

No. Two (A & B) in 1975; one 

(Unit 2 Slurry) in 1977; 

and three (South Ash, 

West Ash, and Unit 3 & 4) 

in 1980.

References Waste Unit Type Liner Year Commissioned

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #18)

2 Sis; Active East ash pond and 

inactive (since 1992) West ash 

pond. The inactive west pond 

implicated (OIG, 2011).

No West Pond: 1950's; East 

Pond: 1969.

2007 DC Ass #31 3 Primary SIs: bottom ash, fly ash, 

and gypsum (an overfill), several 

dry stacked areas, and a closed LF. 

Two of the 3 Primary ponds 

implicated.

No 1967
Out of Control #28 1 SI converted into dry stacking 

(implicated); 1 active Primary 

bottom ash SI. Auxiliary ponds 

include the Waste Stabilization 

Pond (WSP) and two Metal 

Cleaning Treatment Ponds 

(MCTPs). Runoff from the Dry Fly 

Ash Disposal area first drains to 

the sediment pond, then to a 

Originally - No; partial 

geocomposite liner 

w/leachate collection 

installed in 2008-09 over 

active LF.

1955; 1979

In Harm's Way #32 1 active SI, gypsum storage (both 

implicated), ash stack, and two 

former SIs that served as a basis 

for overfills. 

SIs: No; Gypsum sorage and 

ash stack: probably No.

1969

In Harm's Way #33 3 Primary SIs: two active (one 

each for bottom ash and fly ash) 

and one closed (- implicated), and 

3 stilling ponds.

No 1959

In Harm's Way #34 One active, Primary SI; also, 2 

closed Primary SIs (one of which 

was used before closure for dry 

stacking) & one closed LF. All 

unlined WUs implicated.

Active SI: No; 1 SI, later used 

for dry stacking: Clay; 1 

closed SI and 1 closed LF: 

No. 

1952

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #19)

2 SIs (“primary” and “secondary”) 

receive fly ash and bottom ash. 

One coal pile runoff pond; and 

one evaporation pond. Also, a 

“Dry Product Storage Area” of 130 

acres N of the ponds.

Compacted Clay “primary” and 

“secondary” SIs: 1980. 

Other 2 ponds: 1980? 
In Harm's Way #35 2 Primary SIs (at least one 

implicated), coal pile runoff pond, 

2,400-acre cooling lake, 1 CCR 

(FGD) LF and 1 Class II Sanitary LF.

2 SIs: Clay; coal pile runoff 

pond and cooling pond: 

Apparently No; LF: 

Unknown.

2 SIs: 1979 & 1988; FGD 

LF: 1988

EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #20)

LF (Bottom & Fly) and clay-lined 

FGD Emergency Pond

LF: ?; FGD pond: Clay. FGD pond: 1980/82

CCR Proposed Rule, 6/2010 Structural Fill No 2002-2007

2007 DC Ass #42 4 Primary ponds (discontinued in 

2000, but not yet closed).

No Unclear whether 1954 or 

1978.

2007 DC Ass #45 Five unlined SIs: 2 Primary (Slag 

and the twofold A) and 3 

Secondary (B, C, and F); a LF and a 

‘CCR landfill contact pond' 

(receiving sediments and storm 

runoff from the LF). Apparently, 

all implicated.

None lined. 1969 (2), 1977 (2), 1984 

(2)
2007 DC Ass #46 LF No 1971

2007 DC Ass #50 LF (closed 1986). No 1947

2007 DC Ass #51 One Primary SI, converted to LF in 

1995. The current, lined LF not 

implicated.

Original SI and LF Phases 1-

III: Clay; Current LF (IV): 

Geosynthetic w/leachate 

collection.

SI: 1983; converted to LF: 

1995 (Phase I); Phase IV: 

2007

2007 DC Ass #15 Coal ash pond (established 1959) 

and slag pond (established 1976), 

both permitted 1979 under 

RCRA). Old ash pond implicated in 

impact (closed 2001). 

No 1959, 1976.

In Harm's Way #39 3 LFs (two closed, one active), and 

a structural fill.

2 Inactive LFs: probably No; 

Active LF: Clay (Phase I); 

Composite w/leachate 

collection (Phase II); 

structural fill: No

1960s & 1974
2007 DC Ass #17 Unpermitted fill of a former S&G 

Pit and an abandoned limestone 

quarry.

No 1948

2007 DC Ass #62 Sand and Gravel Pit used as a 

‘Dual’, MSWLF and an Off-Site 

Industrial Waste LF. Located next 

to the Lemberger Transport Site 

(LTR), a licensed industrial LF 

which recieved primarily liquid 

waste, and was active between 

1970 and 1976.

No. Open dump from 1940 to 

1969. Lemberger Landfill, 

Inc. operated the site as a 

sanitary landfill under a 

license from WDNR from 

1969 to 1976. From 1976 

to 1977,received fly ash 

from Manitowoc Public 

Utilities to serve as daily 

cover. Located about 

2007 DC Ass #65 Three LFs (one active and two 

inactive), implicated in impact; 

also (non-implicated) eight ponds. 

A spill into the N. Platte River 

(1/2009) from a Secondary Pond.

3 LFs: No; 2 Primary SIs: 

Flexible Membrane, and 2 

others: composite liner; 4 

Secondary Ponds: No liner.

Ponds: 1959 and 1972. 

LFs: Unknown (but pre 

1985).

EPA-HQ-RCRA-2009-0640-

6416, Table 2

LF (License #2786) ? ?

EPA-HQ-RCRA-2009-0640-

6416, Table 2

LF (License #2801) ? ?
EPA-HQ-RCRA-2009-0640-

6416, Table 2

LF (License #3233) ? ?

EPA-HQ-RCRA-2009-0640-

6416, Table 2

LF (License #2879) ? ?

References Waste Unit Type Liner Year Commissioned
Year Damage 

Noted

Failure Mode COCs/GW COCs/SW

Early 1990s GW (SW: 1/2009 

gypsum pond spill 

killed fish; $9.2 

million in cleanup; 

declared FONSI).

MCL Action Level: Pb; 

SMCL or Health-Based 

Guidelines: Co, B, Fe, Mn, 

Al, Sf

1984 GW MCL: Cd, Sb, As, Cr, Pb, 

Nitrate; SMCL: Sf, Al, Fe, 

Mn; Health advisories: B, 

Mo, Co, Li. 

GW: 1994; SW: 

1996

GW & SW MCL: Se, Ag, (Ba, Cd, Pb - 

contested by utility); 

SMCL: Fe, Mn, Sf, pH, TDS

Only leachate (seepage) 

samples recorded.

Early 1990s GW MCL: (As, Cd, Pb - 

contested by ADEQ); 

SMCL: Fe, Mn, Sf, Cl, TDS, 

pH
Pre-1999 GW and ecological SMCL: Sf, Cl, F, TDS Elevated selenium in fish 

(?)

SW: Late 1960s GW & SW; Soil MCL: As, Be; SMCL: Mn, 

Fe, pH

State's 

industrial/commercial 

Direct Exposure Criteria 

(DEC): As, Be; State's 

Surface Water Protection 

Criteria (SWPC) and 

Pollutant Mobility Criteria 

(PMC) for Class GA 

designated areas: Cd, Pb, 

2005 GW, SW, Sediments, 

Ecologic (?), Fugitive 

Dust (?)

MCL: (As), Se, (Cr), Tl AWQS: (Al, Fe); State 

Uniform Risk-Based 

Standards (URS) in surface 

water and sediments: As, 

Al, Ba, Fe; Unknown 

standard: Cd, Cr, Cu, Pb, 

Hg, Ni, Zn (Sediments)

? GW MCL: As, Cd; HAL: Mn, 

Cr?; DWA: Na, Sf; SMCL: 

Al, Cl, Fe, pH, TDS 

N/A

Pre-1985 GW PDWS: Cd, Cr, F, Ra-226 

& 228; SDWS: Cl, Sf, Mn, 

Fe, Al, Na, TDS. Most 

constituents contested by 

utility as tracable to 

seawater or natural 

sources (local 

phosphates).
2003 GW & SW MCL: Gross Alpha, Ra226; State's 

Groundwater Clean-up 

Target Levels (CTLs): Al, 

Fe, Mn, V, Cl, Na, Sf, TDS, 

pH

State's Freshwater Cleanup Target levels: Al, Na, Cl, 

Sf, Gross Alpha; SMCL: Fe, 

Mn, TDS, pH

1999 GW & SW MCL: As, Pb; State's 

Groundwater Clean-up 

Target Levels 

(CTLs)/SMCL: B, Fe, Cl, Sf, 

TDS

FDEP benchmark': As; 

HAL: B; State's Class III 

fresh surface water 

Cleanup Target Levels 

(CTLs): Al; SMCL: Cl, Sf, Na, 

TDS

2000 GW & SW; 

Vegetation damage

MCL: As, Tl; State's 

Protection Groundwater 

Clean-up Target Levels 

(CTLs): Mn, Sf, Al, Mo, Cl, 

F, Na, Gross Alpha, TDS; 

HAL: B

State surface water 

standards guidance 

criteria: (B, Fe)

1997 GW MCL: As, Pb, Se, Cd, 

Nitrate; SMCL: Fe, Mn, V, 

Fe, Sf, TDS, pH

2002 GW MCL: As; SMCL: Fe, Sf, 

Mn; LHA: Mn
1995 GW MCL: Se; health-based 

guideline: Mn, Sf; SMCL: 

Mn, Sf, Fe.

N/A

Pre-1987 GW MCL: (Se); SMCL: Sf

2001 GW (LF) MCL: (As); SMCL: Fe, Mn, 

Sf 

2000 GW MCL: (As); Up-gradient 

Control Limits (UCLs): Ba, 

Se, Zn; SMCL: Fe, Mn, Sf

2008 GW MCL: As; health-based 

guideline: B, Mn, Sf; 

SMCL: Fe, Mn, Sf.

N/A
2010 GW MCL: Pb; health-based 

guideline: Cr, Co, B, Mn, 

Sf; State GW standard: 

Pb, B, Fe, Mn, Sf; SMCL: 

TDS.

N/A

2010 GW MCL:As; health-based 

guideline:B, Mn, Cr?; 

State GW Standard: As, 

B, Mn; SMCL: Mn, Sf, 

TDS.

N/A

2010 GW MCL: As; health-based 

guideline: Cr, Na; State 

GW Standard: B, Mn, Fe; 

SMCL: Sf, TDS.

N/A

LF: Pre-1985; 

Ponds: 2010.

GW & SW LF: MCL: As, Se, Pb, Cr, 

Nitr; SMCL: Fe, Mn, Sf, 

TDS. Ponds: MCL: As, Pb; 

Health-based guideline: 

Cr, Mn; IL GW Standard: 

Pb, B, Mn; SMCL: Mn, Fe, 

TDS.

SDWS: Mn

1999 GW SMCL: Mn, Fe, Cl, Sf, TDS, 

B
1989 GW SMCL: (Fe, Mn), B, Sf, TDS

1997 GW SMCL: (Mn), B, Sf

Pre-2000 GW SMCL: B, Sf, TDS, Fe, Mn, 

Cl

Pre-2000 (as early 

as mid-1980s)

GW SMCL: (Mn), Sf, TDS; HAL: 

B

Year Damage 

Noted

Failure Mode COCs/GW COCs/SW
1989 GW SMCL: (Fe, Cl), B, Sf, TDS; 

Illinois Class I 

groundwater standard: 

(Mn) 

2010 GW MCL: As, Sb; healthbased guideline: B, Mn, 

Sf; IL GW Standard: As, 

Sb, B, Mn, Sf, TDS; SMCL: 

Mn, Fe, Sf, TDS.

N/A

GW: Pre-1993; 

SW: 1995

GW & sediment/ soil; 

Vegetation stress

MCL: Cd, Cr, Tl, Be; HAL: 

B; SMCL: Mn, Sf, Ni, TDS

Unspecified standards 

(Sediments/Soil): Cr, Ba, 

Mn, Fe, Ni, Zn, Al, Na

1994 GW MCL: As, (Se, Cd, Ba); 

Applicable Groundwater 

Quality Standards 

(AGQSs): (B), Sf, Mo, 

Ammon, TDS, pH; SMCL: 

Cu 

2010 GW MCL: Sb; health-based 

guideline exceedances: 

Mn, Sf; IL GW Standard: 

Sb, Mn, Sf, Cl, TDS; SMCL: 

Mn, Sf, Cl, TDS.

N/A
2010 GW MCL: As; EPA healthbased guideline:Cr, B, 

Mn, Sf; IL Groundwater 

Standard:Pb,B, Mn, Sf, Cl, 

Fe, TDS; SMCL: Mn, Cl, 

Fe, Sf, TDS.

N/A

1997 GW & SW Illinois Class I GW 

Standard/MCL: Cd; 

Illinois Class I GW 

Standard/SMCL: (Fe), Sf, 

B

AWQC: Al, TDS; EPA’s 

criteria for sensitive crop 

irrigation: B

1996 GW Illinois Class I GW 

standards/MCL: (As), Cd; 

Illinois Class I 

groundwater 

standards/SMCL: Fe, Mn, 

(B), TDS

Pre-1982 GW MCL: As, (Pb)

1976 GW and Soil MCL: Cd, As Boron-adversely impacts 

vegetation
Pre-1993 GW SMCL: Fe, Mn, Mo, Sf, Cl, 

Na; HAL: B

Pre-1987 GW MCL: As; SMCL: Sf, Na, Cl, 

TDS, pH; HAL: B

1997 GW SMCL: (Sf), TDS

1987; 1990 GW & SW; Fugitive 

Dust

MCL: Ba, Cr, Cd, Pb; 

SMCL: Sf, Na, Cl

Elevated Se in fish caused 

deformities and decline in 

fish population.

2002 GW HAL: B; SMCL: (Mn, Mg, 

Fe), Sf
1981 GW SMCL: Fe, Mn, Sf, Cl, TDS

1994 GW MCL: (As); SMCL: Sf, TDS, 

Cl

1980s; then 

(newly installed 

wells): 2011.

GW MCL: As; health-based 

guideline: B, Cr, Co, Mn.

N/A

1980s GW & SW MCL: As, Se, Be; HAL: B; 

SMCL: Co, Ni, Mo, V, Sf, 

Mn, TDS, pH 

Reddish Leachate

2005 GW MCL: (As); SMCL: Sf, TDS
1989 GW MCL: Se, Ba, As; SMCL: 

TDS

1992 GW MCL: As, Pb, Se; SMCL: 

Fe, Cl, Sf, TDS, pH 

1983 GW MCL: As, Pb; SMCL: Cl, 

TDS, pH, Sf

1998 GW MCL: Se, As(?)

GW: 2002; SW: 

2006

GW & SW; Fugitive 

Dust (?)

MCL: Cd; SMCL: Fe, Al, 

Mn, Sf, Cl, TDS

WQC: Cd, Pb, Se
2005 

(unauthorized 

discharges)

GW & SW MCL: As; SMCL: Cu, An, 

Al, Mn, Fe, Sf, Cl, TDS 

Maryland WQC: Se, As, Ba, 

Cr; Maryland Secondary 

WQC: Co, Cu, Fe, Zn, Sf, Cl, 

Hardness 

1982 GW MCL: (As); HAL: B; State's 

health-based standard: Li

Early 1990s GW State Health Based 

Standards: B, Li; Elevated 

Na

1989 GW State Health Based 

Standards: B, Li, Mo, Se, 

Na, and Sf.

Mid-1990s (?) GW State's health-based 

standards: B, Mn.
? GW & SW State's health-based 

standards: B, Li.

State's health-based 

standards: B, Li.

? GW State Health Standards: 

B, Li, Mn, Sf, Ammonia

? GW & SW/Potential 

for ecologic damage

State Health Based 

Standards: Se, B, Li, Sb; 

Unknown Federal & State 

Standards: pH, Cd, Cr, Fe, 

Pb, Va, Al, Ni, Tl, Mn, Zn. 

State Based Health 

Standards: Se, B, Li, Sb

Year Damage 

Noted

Failure Mode COCs/GW COCs/SW

1985 GW MCL: As, Se, Cd, Pb; 

SMCL: Sf, B
1985 GW SMCL or EPA Lifetime 

Health Advisory (LHA): 

Mn, Fe, Ni, nitrate, pH

2006 GW, SW, Ecologic MCL: As, Tl, Sb, Se, Pb; 

SMCL/HAL: Fe, Mn, B, Sf, 

TDS

Se in fish causing elevated 

morbidity and mortality

2007 GW MCL: (Pb, Cr), As; State's 

water quality standard 

(2L)/SMCL: B, Mn, Fe, pH

2007 GW MCL: (Pb, Cr), Se; State's 

water quality standard 

(2L)/SMCL: (Fe, Mn), B, Sf

2005 GW & SW MCL, State's water 

quality standard (2L): As, 

Se, Cr, (Pb); State's water 

quality standard (2L), 

SMCL: B, Sf, Nitrate,pH, 

(Fe, Mn) 

(Bromide)
2007 GW & SW MCL/State's water 

quality standards (2L): 

Cr, Tl, Se, Nitrate. SMCL: 

B, Fe, Mn, Cl, Sf, pH, TDS.

CCC: Se, Cd; MCL: As, Sb, 

Tl.

1993 GW MCL: {Pb), As; State's 

water quality standards 

(2L): Cr, Sb, (Ag); SMCL: 

Fe, Mn, Sf, B, TDS, pH.

1998 GW MCL: Cd, Se, nitrate; 

SMCL: B, Sf

1982 GW & SW; Sediments MCL: Cd, Pb, As, Cr; 

SMCL: Zn, Al,

Unspecified standard: As

1987 GW MCL: As, Se, Cr; SMCL: Fe, 

Sf, B, Na, Cl, TDS
1985 GW MCL: As, (Pb); SMCL: Sf, B 

1999 GW MCL: (Se); SMCL: (Sf)

1991 GW SMCL: Sf, Mn, Fe, Al, TDS, 

pH

? GW SMCL: Fe, Mg, Mn, Na, B, 

Sf, sulfide, TDS, pH

1987 GW & SW MCL: As, Cd, Ba, Pb; 

SMCL: Fe, Mn, Sf, TDS

Unspecifies standards (at 

discharge outfall): Fe, TSS
1994 GW SMCL: (Mn), Sf

Sometimes 

between 1973-

1986.

GW SMCL: TDS, Sf, Fe.

1985 GW MCL: Se; SMCL: Sf

1993 GW & SW MCL: As; HAL: B; EPA 

Lifetime Health Advisory 

(LHA): Mo

Unspecified standards (No 

limts in NPDES): As, Mo

1974 (ecologic); 

1994

GW & SW; Ecologic MCL: (As, Ba, Cd, Pb, 

Gross Alpha); SMCL: (Mn, 

Cl, TDS); EPA Lifetime 

Health Advisory (LHA): 

(Mo) 

NPDES permit criteria: B, 

Cu, Sf; Acute or Chronic 

exposure WQC: Al, Ni, Zn
2005 GW MCL: Ba, Gross Alpha; 

SMCL: Fe, Sf, (TDS)

2008 GW MCL: As, Ba, Cr, Pb, Se, Tl; 

SMCL: Sf, pH; State 

health-based standards: 

V 

1998 GW MCL: As; SMCL: B, Mo, 

Ni, Mn, Fe

SIs: Late 1980s; LF: 

mid-1990s

GW & SW MCL: As, F; SMCL: Al, Mn, 

Cl, TDS

CCC: As 

2004 GW & SW MCL: Sb, As, Cd, Cr, Pb, 

Se; SMCL: Al, Fe, Mn, Ni, 

Zn, Cl, Sf, TDS

WQC for fish and aquatic 

life (CCC): (Al, Ni, Zn); 

NPDES permit: Fe, Mn, pH
1999 GW MCL: As; SMCL: Fe, Mn

GW: 2001; SW: 

2006

GW & SW MCL: F; SMCL: Al, Fe, Mn, 

Sf, TDS 

Criteria Continuous 

Concentration (CCC): (Cr 

hex., Se, Cd, B)

2005 GW MCL: Cr, Pb (in turbid 

samples); health 

advisory: Cr, Sf; SMCL: Sf, 

Fe, TDS.

N/A

1997 GW & SW; Potential 

ecologic damage (As 

in fish)

State's Water 

Classifications and 

Standards for GB-class 

groundwater: As; MCL: 

Cr, Cd, Pb

MCL: As; SMCL: Fe

2009 GW MCL: As, Cd; healthbased guideline: Cr, Na, 

Sf, Fe; SMCL: Al, Cl, Fe, Sf, 

TDS.

N/A
1996 GW & SW MCL: As; SMCL: pH MCL: As 

2009 GW MCL: As; health-based 

guideline: Cr, Sf, Fe; 

SMCL: Sf, Cl, Fe.

N/A

Year Damage 

Noted

Failure Mode COCs/GW COCs/SW

2006 or earlier GW MCL: As; health-based 

guideline: Mn; SMCL: 

TDS.

N/A

1974 GW, SW MCL: As, Cd, (Co); SMCL: 

Sf, Al, Ca, Fe, B, Mn, Mo, 

Ni 

Fe
2006 GW & SW; Dam 

Failure (1973)

MCL: Cd; SMCL: Al, Sf; 

HAL: B, Sr; Regional 

Screening Level for tap 

water: Mn 

Chronic and Acute EPA 

Water Quality Criteria 

(WQC) levels for 

freshwater aquatic life: 

Cd; Chronic WQC: As, Se, 

Cr hex., Al, Mn

2008 GW & SW State's GWPS/MCL: As, 

Se; State's GWPS: V; HAL: 

B; SMCL: Al, Fe, Mn, Cl, 

Sf, TDS

WQC for Fish and Aquatic 

Life and DWS: Se 

2008 GW MCL/GWPS: As, Cd, Hg, 

(Be); HAL: B; State GWPS: 

Ni, V; SMCL: Co, Fe, Mn, 

Sf, TDS 

1986 GW MCL: As, Cd, Pb, Cr; HAL: 

B, Mo; SMCL: Al, Fe, Mn, 

Co, Sf, TDS

Pre-1985 (?); 2010 GW MCL: As, Pb; healthbased guideline: B, Co, 

Ni, V.

N/A
2005 GW State's Residential & 

Commercial Protective 

Contamination Levels 

(PCLs): Co; Residential 

PCL/HAL: Mo; MCL/PCL: 

Se; SMCL: Al, Mn, V, Sf, 

Cl, TDS

2009 GW MCL: As, Se, Ba; healthbased guideline: B, Cr, 

Co, Mn, Mo, Sf. 

N/A

2008 GW & SW MCL (onsite only): As, Cr, 

Pb; SMCL: V, Cu, (Mn, 

Fe); HAL: B (drinking 

water wells offsite)

Unspecified standards 

(Offsite): Al, Fe, Mn; 

Unspecified standards 

(Onsite): Tl, Cr, Pb, Al, Fe, 

Mn

1976-1977 GW State Enforcement 

Standard (ES = MCL): As, 

(Hg), Se; ES (= SMCL): B, 

Fe, Sf, TDS

1980s GW State ES HAL: B; State ES: 

Fe, Sf, TDS; State PAL: Cl; 

MCL: As, Se 
1986 or 1994 GW Enforceable Standard 

(ES): Sf, Mn; Preventative 

Action Level (PAL): Fe; 

SMCL: (B, Zn, Al, Cl, TDS, 

pH)

1975 GW State Enforcement 

Standard (ES): Mn, Sf

Pre-1993 GW State Enforcement 

Standard (ES): Mn, Sf, 

(Fe); State PAL: B; MCL: 

Se, (Cd)

Pre-1979 GW State PAL: As, Se, Cd (?); 

State ES: B, Sf, F, Mn 

2002 or earlier GW State Enforcement 

Standard (ES)/EPA's 

Lifetime Health Advisory 

(LHA): Mo; State PAL: As, 

F, Hg, B; State ES: Mn, Sf
1980 GW State PAL: Se; State ES: B, 

Sf

1980 GW & SW VOC and inorganic 

constituents. MCL: 

CVOCs, As, Ba, Cr, Cd, Pb.

Unknown standard(s): 

VOCs, Cd, Pb.

Pre-1985 GW & SW MCL: (Cd); SMCL: (Mn), 

Sf, B

Unknown

? GW ? B, Se, Hg, Sf

? GW ? As
? GW ? As, Pb, Mn

? GW ? As, Se, Pb, Mn

Year Damage 

Noted

Failure Mode COCs/GW COCs/SW
Regulatory Action Current Status

None. CO recommended (1993); No 

Administrative Action was taken by the 

State; no remediation was performed 

because contamination in an 'up-gradient' 

well was attributed to an off-site source.

Active 

In karst active area; sinkhole treated and 

capped.

Some Active, some 

not

ADEQ ordered assessment monitoring 

(2005) due to SSI in Se, sulfate and TDS. 

Notice of Deficiency (NOD) in 2008. 

Active

None. Since no primary MCL exceedances 

noted in the recent years, the State has not 

responded because it does not enforce 

SMCLs.

Active
None Active

EPA's RCRA Corrective Action investigations 

at the site identified 14 Areas of Concern 

(AOCs). CTDEP and USEPA made final 

determination that migration of 

contaminated GW is under control (2001). 

The facility is working towards a RCRA Final 

Remedy. RCRA Closure/Post-Closure work 

continues on site. NRG has completed an 

Ecological Risk Assessment.

Inactive (Plant 

switched fuel to 

oil)

CO for RI and remediation of the Burton 

Island (SI) area; DNREC issued No Further 

Action remedy for off-site sediment and 

off-site surface water. The Final Remedial 

Plan for OU1 (construction of erosion 

controls) and for OU3 (No Further Action) 

was approved in 8/2008. A Final remedial 

Plan for OU2 (targeted soil cover with land 

use controls) was approved in 10/2013. 

Some Active, some 

not. Based on a 

Consemt Decree, 

and with the 

exception of 

Generation Unit 

#4, all generation 

units retired 

between 2011 and 

? Active

None; impact restricted to ZOD. Active
State required upgrades, additional 

monitoring of LF, determination of waste 

type, and bottom-liner systems for any 

future disposal units at the LF.

Active

State required Interim Remedial Action Plan 

(GW capture system and remedial 

monitoring). The groundwater monitoring is 

ongoing since 2004 with results reported 

quarterly to FDEP. 

Active

CO (2001) for repair/replacement of liner 

systems on waste management units; A 

Remedial Action Plan and GW monitoring 

plan approved 2007; closure of a SI 

impacting vegetation. 

Some Active, some 

not. Closed the 

unlined DA-2 

Disposal Area in 

2005.

FDEP issued a Consent Order (2001) 

because of impacts to GW and required 

additional on-site monitoring and ~ 

$180,000 in civil penalties.

Active

IDNR required (in 2009) that MW11 be 

evaluated to determine why it has been 

difficult to obtain GW samples and to 

replace it if it continues to remain dry. A 

replacement well (MW-11R) was installed in 

2010. Following the exceedances of As, Mn 

and Fe in MW-11R, IDNR required an 

assessment monitoring. IPL submitted a GW 

Assessment Workplan, including the 

installation of additional monitoring wells, 

and, for two rounds of assessment 

Active
? Active

Capping and seeding; GW 

monitoring/study. No further state 

remediation action.

Some Active, some 

not

MidAmerican Energy submitted a risk 

evaluation for arsenic to IDNR in 2006, and 

IDNR requested more data to support the 

study's conclusion attributing the high 

concentrations of arsenic to off-site sources 

or the submission of a plan to address the 

arsenic plume. Issue is still under 

consideration. A new composite lined cell 

constructed in 2009 and the older cells are 

Some Active, some 

not. Generating 

boilesr 1 & 2 to 

retire 4/2016 due 

to violations of 

CAA.

IDNR requested (2005) that future GW 

reports from MidAmerican discuss potential 

for GW mounding under LF, evaluate if 

listed wells are truly ”upgradient,” and 

discuss potential for migration and possible 

receptors. The Utility’s 2008 GW report did 

not address these questions.

Active

? LF inactive (1987); 

final cover in 1992.
A hydrogeologic assessment plan has been 

submitted and approved. IEPA met with 

Electric Energy to discuss elevated levels of 

contaminants at the site and appropriate 

remedial alternatives (IEPA, Oct. 2011).

Some active, some 

inactive

Hydrogeologic assessment plans approved 

and implemented, GW monitoring results 

received and under review (IEPA, Nov. 

2011).

Some active, some 

inactive

A hydrogeologic assessment received and is 

currently under review. CWLP met with the 

IEPA to discuss potential impact to the 

adjacent stream and the potential for offsite movement of contaminants. CWLP will 

be doing further investigation to better 

define GW impacts at the site (IEPA,Oct. 

2011).

Active

Waste units sited over highly permeable 

fluvioglacial deposits. The large, older LF 

has been closed after ceasing operation in 

1978 with 2' of soil cover. There is no 

information on whether the newer, smaller 

LF has been also closed since ceasing 

operation in 1982. 

Old LF 

closed/1978; 

Another LF 

closed/1982. 

Ponds: Active

Plant area underlain by fluvioglacial and 

aeolian deposits, and by mine spoil. Closure 

of unlined SIs, including dewatering; 

overhaul of monitoring well system. 

Switched to offsite dry disposal. Remedial 

action under development. 

Some Active, some 

not. Recycling 

pond cleanclosed/2011, as 

well as the two SIs. 

CCRs disposed in 

offsite LF.
Located on glaciofluvial deposits. CO by 

State. Old SI closed in 1996, replaced with a 

lined SI and LF.

Some Active, some 

not. In July 2013, 

Dynegy notified 

the EPA about its 

intent to close the 

Hennepin west ash 

pond system.

Located on glaciofluvial deposits. Consent 

Order; pond closing by State/2009.

Some Active, some 

not

Study; GW monitoring program, Plant 

retired in 12/2011.

Inactive

Two shallow aquifers separated by a 

confining layer. CO to close unlined SI and 

replace w/2 synthetically-lined SIs. GW 

program in effect. Ameren conducted a 

human health risk assessment and an 

ecological risk assessment in support of the 

closure of Pond D. 

Plant retired end 

of 2011. Closure of 

Pond D completed 

1/2013.

Regulatory Action Current Status
CO (in 1999, switched to dry handling; GW 

monitoring program). Approved GMZ.

Active/ modified

NOV W-2012-00056 (6/11/2012), violations 

in MW-1, MW-2, MW-3, MW-4, and MW-5. 

In the quarterly monitoring samplings 

between 10/2010 to 3/2012, exceedances 

of As, Sb, B, Fe, Mn, Sf, Cl, TDS, and pH. 

Compliance Commitment Agreement (CCA), 

10/24/2012. On 10/3/2012, the 

Environmental Law Policy Center (ELPC), 

along with other environmental 

organizations, filed a complaint against 

MWG before the IPCB, alleging that MWG 

caused or contributed to the contamination 

of GW via open dumping.

Active

IEPA acknowledged damage to vegetation 

by seeps and GW impact (1995-1996); 

Leaking cells capped; GW monitoring in 

effect. Area declared GMZ.

Culprit LF is 

Inactive.

In 1996 the LF became exempt from Illinois 

Class I GW Protection standards and IEPA 

applied relaxed standards (Applicable 

Groundwater Quality Standards, AGQSs) to 

a number of contaminants. IEPA issued a 

NOV (8/2009) for ”failure to operate a 

leachate collection and management 

system that assures the protection of Class I 

potable resource GW”, identifying 50 

Active

Hydrogeologic assessment plans approved, 

GW monitoring results received and under 

review (IEPA, Feb. 2010). Hydrogeologic 

assessment plans approved (27 parameters 

are reported quarterly). GW sampling 

results have been received indicating 

potential GW impacts. Additional sampling 

data is being collected to establish 

background water quality at the site (IEPA, 

Oct. 2011). NOV (6/11/2012); Compliance 

Commitment Agreement (CCA), 

Active
A hydrogeologic assessment plan has been 

submitted and approved. Preliminary GW 

sampling results received indicating 

potential GW impacts. Additional sampling 

data is being collected to establish 

background water quality at the site 

(IEPA,Oct. 2011).

Active

IEPA asked the Utility for and approved a 

“hydrogeologic assessment plan” to 

determine the source and extent of 

elevated Fe and Cd contamination at the 

site, including an upgrade and extension of 

the monitoring well system. 

Active

None, but proposed closure of the SIs 

through capping and a GMZ. The well 

inventory required by IEPA and completed 

by Ameren confirms that there is no use of 

groundwater for potable or industrial uses 

down-gradient of the impoundments. The 

contaminated GW will slowly discharge into 

the river by subsurface seepage at levels 

that are presumably protective of huma 

Inactive. Plant 

retired.

Two rows of steel slurry wall down-flow 

from the disposal site for protection from 

Lake storms and for improved structural 

stability. In 1999, Plant switched to drydisposal of fly ash. Impoundments capped 

in 2007. Fly ash from the Michigan City (and 

Bailly) Stations is transported for disposal 

offsite (Schafer Generating Station.) 

Active

RCRA EPA Corrective Action, monitoring 

wells, Baseline Ecologic Risk Assessment; 

NIPSCO required to investigate whether 

contamination from the site is affecting soil, 

GW or Lake Michigan.

LFs: Inactive 

(1976, 1986); SIs: 

Active
No Consent Order and/or other 

state/federal action. Original unlined cells 

capped; switched to dry handling; GW 

monitoring in effect.

Active/ modified

A slurry wall was installed in the NE corner 

of the original LF in late 1987; Leaking cells 

capped; GW monitoring in effect.

Some Active, some 

not

None Active

State: Corrective Action and GW monitor 

for GW impacts. Federal: Consent Decree 

for emission violations.

Some Active, some 

not

Citizen groups appealed the Type I 

Restricted waste landfill permit, requesting 

additional monitoring and installation of a 

liner during future construction. IKEC and 

IDEM rejected the requested changes, and 

the appeal has been subject to multiple 

judicial reviews since 2003. IDEM claims 

that the boron SMCL exceedances in downgradient GW monitoring wells do not 

Active
GW mounding is probable. A revised GW 

assessment plan that also included a risk 

assessment was submitted to the KPDES in 

12/2009.

Active

KY has discretion, under 401 KAR 45:160 

Sect.1, to require or not require a GW 

corrective action. The O/O is currently not 

required to perform a corrective action. 

Assessment monitoring for sulfate is 

currently required, and KDEP is currently 

evaluating the information on Cl 

exceedance.

Active

? Active

A GW assessment was performed at the site 

in the 1980s; no KDWM enforcement action 

since. KDWM permitted (2007) the 

expansion of the LFs without a liner (as 

“special waste landfills”), over old, unlined 

ash ponds.

Some Active, some 

not. Shawnee 

Units 1 and 4 

either will be 

converted to 

biomass-fuel, 

controlled by 

adding scrubbers 

and selective 

EKPC has been directed by the KDWM to 

conduct an assessment in MW-2A & MW3A, to determine the cause of the detection 

of arsenic in MW-3 at a concentration 

exceeding the permit limit . The 

Commonwealth of Kentucky did require a 

Remedial Action Plan (RAP) under its 

regulations; the plan has been approved 

and EKPC has implemented it. The RAP 

Active
LDEQ issued a Notice of Deficiency (NOD) 

during permit renewal regarding 

inadequacy of monitoring well system and 

required that 10 additional downgradient 

wells be installed. No other regulatory 

corrective action or administrative ruling. 

Resampling recommended to verify high 

levels of Ba and As detected in 2010.

Active

LDEQ required (Dec. 2008) on-site 

assessment monitoring, but in Feb. 2010, 

LDEQ allowed a return to detection 

monitoring.

Active

LDEQ required (2008) on-site assessment 

monitoring.

Active

CO, a partial cap. About 80% of the LF area 

has been capped. Most of the remaining 

20% of uncapped LF will be brought to 

grade with clean fill as part of the proposed 

Payne's Crossing development project.

Inactive 2001

In 4/2010, MDE filed suit in federal court 

maintaining that the disposal site was 

leaching pollutants in violation of the CWA 

and state law. A $1.9 million settlement was 

reached 1/2013.

Active. Plans for 

either switching 

from coal to oil at 

the Chalk Point 

Plant or having it 

retired in mid2017. This will 

significantly 

reduce the 
MDE filed notices of intent to sue Mirant 

Mid-Atlantic LLC in federal court (1/2011) 

for alleged water pollution violations. For 

additional lawsuits/settlemnt agreement, 

see under Comments.

Active. NRG, new 

owner, plans to 

switch the 

Dickerson Plant 

from coal to oil or 

have it retired in 

mid-2017.

Consent Decree requires slurry walls to be 

built to stop leakage, and monitoring of 

GW/surface water interface. While a slurry 

wall was constructed at the Weadock site, 

recently, the slurry wall proposition for the 

Karn site has been scrapped due to slope 

instability of the site. 

Active. Consumers 

Energy announced 

plans to demolish 

Weadock plant in 

April 2016 pending 

approval of the 

Michigan Public 

Service 

Commission and 

Feseability Study; Remedial Action Plan.

Inactive 1995

Consent Orders (1993 and 1995); Restrictive 

covenant in place to restrict installation of 

water supply wells; and groundwater 

monitoring (suspended in 2009). 

Inactive (capped) 

1993-1994. 

Feasibility Study and Remediation Action 

Plan (RAP) since 1998 required 

groundwater interceptor trench, rapid 

infiltration and treatment. 

Inactive 2001
Consent order (1993): remediation 

investigation suggested no active GW 

extraction. Ash redistribution and removal, 

grading, and capping w/synthetic 

membrane, surface water drainage, and 

remedial leachate collection. Supplemental 

Remedial Investigations (1995), amended 

Remedial Action Plan (1997), and a 30-year 

post-closure GW monitoring.

Inactive 1993

Consent Order, Remedial Investigation and 

Feasibility Study, followed by a Remedial 

Action Plan (RAP). Restriction on new 

drinking water wells. Construction of a 

bentonite slurry wall around the entire SI; 

FML cap covered by 30 inches of soil and 

topsoil; Closure (2008); and 30-year post 

closure monitoring.

Inactive 1982

Two Remedial Action Plans. Restrictive deed 

covenant. GW extraction (can be suspended 

if criteria are met), and mixing zone criteria 

for B, Li, and Se.

Inactive 1998

Regulatory Action Current Status

None(?); not clear whether Ponds' #1 and 

#2 capping/closing and active dewatering 

are in response to state requirements.

Some Active, some 

not.
Based on NC DENR directions, compliance 

monitoring wells were constructed at the 

Compliance Boundaries of the CCR SIs in 

12/2010. Due to Fe, Mn, and Ni 

exceedences between 2011-2013, NC 

DENR’s submitted a lawsuit against Duke 

Energy Progress (8/2013); DWR staff is 

working with the Defendant to determine if 

these exceedances are naturally occurring 

Some Active, some 

not

A NOV (1987) and request for corrective 

action; a CO (2004) was terminated by the 

company (2007) following a "Site 

Reassessment Report" by NCDENR which 

recommended the site be re-designated as 

"No Further Remedial Action Planned". 

However, multiple-constituent violations 

above 2L GW Standards have been 

measured in 8 compliance wells between 

Inactive: Plant 

closed 11/2013. 

Clean-closing of SI 

being considered.

NC DENR’s lawsuit against Duke Energy 

Progress alleges that based on GW 

monitoring data from 12/2010 through 

7/16/2013, there are GW exceedances of 

the 2L GW Standard at or beyond the 

compliance boundary of the Plant’s SIs. A 

consortium of citizens groups sued Duke 

(9/3/2014) alleging violation of the NPDES 

Permit and of the CWA. 

One Active, 3 

inactive (prior to 

Plant's retirement, 

9/2012).

Minor GW mounding next to the River. NC 

DENR’s lawsuit against Duke Energy 

Progress (8/2013) indicates that based on 

GW monitoring data since 9/2010, GW had 

exceedances of the 2L GW Standard at or 

beyond the compliance boundary of the 

Plant’s ash ponds. A consortium of citizens 

groups sued Duke (9/3/2014) alleging 

violation of the CWA. 

Some Active, some 

not (prior to 

Plant's retirement 

in 10/2012).

GW Corrective Action Plan and Closure of 

the Pine Hall Rd. LF, but not for the other 

two LFs. Pine Hall Road Landfill capped with 

a drainage geonet overlain by a 40 mil 

LLDPE geomembrane and 2' of soil cover. 

DWQ has sent a letter to Progress Energy, 

directing them to place wells at their 

Compliance Boundaries. New monitoring 

wells were installed (10/2010), per DNER 

Some Active, some 

not
Mounded GW around the active ash basin. 

DWQ has sent a letter to PE, directing them 

to place wells at their Compliance 

Boundaries. Monitoring wells placed in 

2010 & 2011. Since 2006, Progress Energy 

took several actions to maintain and 

upgrade the SIs and associated components 

of its wastewater treatment system at the 

Asheville Plant. Following a contamination 

Active

Until 2013, State stated it will not require 

action until contamination is outside the 

”compliance boundary.” On August 16, 

2013 NC DWQ filed a lawsuit against Duke 

Energy. The lawsuit indicates that based on 

GW monitoring data from 1/2011 through 

7/2013, GW exceedances from the 2L GW 

Standard, at or beyond the compliance 

boundary of the Plant’s ash ponds, include 

Inactive. Plant 

retired on April 1, 

2012.

State required corrective action: Old LF site 

capped and closed; GW monitoring in 

effect.

Some active, some 

Inactive

State issued a special use disposal permit to 

allow disposal to continue, but required 

continued monitoring and site closure. A 

preliminary assessment (PA) in 1990 and a 

Site Inspection (SI) in 1995, both under 

CERCLA. According to the 1999 RTC, "Site 

closed and capped and pending NFRAP (“No 

Further Remedial Action Planned”). The GW 

monitoring wells were approved for 

Inactive (closed) 

1989/90.

State required relining of SIs in 1990; GW 

monitoring in effect. 

Active
None. Some Active, some 

not (Pond 4 and 

Pond 5 were 

decommissioned 

and capped 

between 1992 and 

1996).

NDEQ required the Utility to install 

additional wells and extended post-closure 

GW monitoring period from 10 to 15 years 

due to evidence of contamination.

Some Active, some 

not

CO (1999). Site Investigation, closing and 

capping, and GW monitoring. Closure 

completed 2001, and GW monitoring 

system in operation.

Inactive (2001)

Corrective Measure Assmt. As of 2010, 

Phase I of the LF (1987-1994) was closed 

and fully capped; Phase II (1992-2005) was 

closed and 70% capped, and Phase III has 

operated since 2006 till Plant's retirement.

Active (current 

permit to expire 

8/2018).

As of June 2011, seven CWA violations have 

been recorded, including a State 

Administrative Penalty Order (oil leak, July 

2006), incurring a penalty of $500.

Some Active, some 

not (current 

operational permit 

to expire 1/2023).
Closed and capped (1996); GW monitoring 

is no longer required.

Inactive

Unknown Active (?)

GW investigation and remediation 

performed, monitoring wells in effect. A 

sinkhole Investigation and Repair Plan letter 

was followed by sinkhole repair (1999).

Active/ modified

AEP asserts that GW contamination was 

due to previous mining. The OH EPA placed 

(2004) 4- GW monitoring wells under 

“assessment monitoring” due to evidence 

of CCR contamination. In 2009, AEP 

submitted a 2nd Assessment Monitoring 

Report to OH EPA based on the results of 

the expanded GW monitoring program, 

which included wells Groundwater 

Some Active, some 

not

OH EPA required assessment monitoring 

onsite to determine extent and rate of 

contamination and to address the 

contamination. OHEPA claims that several 

coal mines and oil/gas wells that are either 

within the LF’s footprint or adjacent to the 

LF’s and SIs’ footprints are the culprits: in 

fact, the fly ash SI serves to collect and treat 

the surrounding acid mine drainage prior to 

Some Active, some 

not
OH EPA mandated AEP (2004) to implement 

a GW monitoring plan and install 15 GW 

monitoring wells, 4 GW elevation 

monitoring wells, and 5 piezometers. 

However, OH EPA does not support the 

conclusion that the PP has demonstrated an 

indication of an impact on GW quality.

Active. Generation 

Units 1-4 to retire 

by Dec. 31, 2014, 

while Unit 5 might 

be then switched 

to natural gas.

ODEQ required AEP (9/2007) to establish a 

GW monitoring program at the LF (26 

wells). Concerned about the karstic milieu 

and the proximity to the Verdigris River, 

ODEQ required further investigation and 

possible remedial action.

Active. One of the 

two generation 

units to retire by 

2017.

None (State law does not require state 

response for onsite exceedances of 

secondary MCLs); (NOV for fugitive dust)

Inactive. The Plant 

was deactivated at 

the end of 2013.

Consent Order and Agreement (COA) was 

signed in 1990 providing several options to 

remediate contamination source; included 

$50,000 penalty for discharge violations.

Inactive; early and 

late-1990s. Plant 

decommissioned 

2002, demolished 

2011/2012.

CO (1982) for closing of unpermitted pits 

and $308,000 fine for violating SWM Act. 

COA (2000); several COAs to cease 

discharge from coal ash/coal refuse pit. In 

May 2010, four environmental groups 

announced that they intend to sue 

Seward’s owners for about 12,000 

violations of the federal CWA, the 

Pennsylvania Clean Streams Law, and the 

Inactive
PADEP ordered GW assessment (2008) to 

delineate source and extent of 

contamination. As of early in 2010, PADEP 

was assessing monitoring data for well 

network adequacy to determine the scope 

of abatement necessary under closure.

Inactive. As of 

5/22/2010, the 

Hunlock PP is no 

longer operative, 

including all 

associated 

disposal activities.

None. PADEP claims that State law does not 

require state response for onsite 

exceedances of SMCLs; surface discharges 

are regulated through a NPDES permit, and 

Reliant has not been in violation of their 

permit. 

Active. Plant 

slated to close in 

January 2015.

? Active

CO (2001) in response to monitoring well 

violations of As seeping from the SIs. It 

established a GW Mixing Zone, with waivers 

for As (3,000 ppb), sulfate, Pb, Cr and Cd. 

According to a Settlement filed 8/17/2012 

(U.S. District Court for the District of SC) 

with Catawba Riverkeeper Foundation, 

SCE&G will decommission the Wateree’s 

Station CCR storage ponds by removing 

One SI is inactive; 

all other WUs - 

Active

? Active
SC DHEC required a proposal (2009) for 

stabilizing Arsenic exceedances in 3 

monitoring wells or a corrective action plan. 

DHEC also indicated that no remediation of 

the SIs is being conducted, and no 

violations or orders have been issued to the 

site owner.

Inactive: the Plant 

shut down 

operation in May 

2012.

? Active

Regulatory Action Current Status

? Active

None, assuming dilution by the Clinch River. 

Phase III, then Phase II GW Assessment 

Monitoring. In May 2012, citizens’ groups 

petitioned the Tennessee Water Quality 

Control Board, contending that the State of 

Tennessee NPDES Permit, which authorizes 

BRF to discharge 19 million gl/d of CCR 

effluents from its settling pond directly into 

Melton Hill Reservoir on the Clinch River, 

Active
None. Apparently, state law does not 

require a response to onsite exceedances. 

The Plant has been under Phase II Ground 

Water Assessment Monitoring since April 

2007. Between 1998 and recently, TVA 

installed a leachate collection system ~ 

2,500 feet in length adjacent to the Holston 

River, and during 2008-2009, TVA installed a 

geocomposite liner system and leachate 

Inactive. Plant 

retired from 

service December 

31, 2012.

None. Apparently, state law does not 

require a response to onsite exceedances. 

Groundwater Assessment Plan required by 

TDEC.

Some Active, some 

not

GW Assessment Plan in place since 4/2011. 

A coalition of environmental groups filed 

with the Tennessee Water Quality Control 

Board an appeal of a pollution permit 

issued for Gallatin (July 2012).

Two ponds active, 

one closed (1998)

Both New Johnsonville and the City of 

Camden intake their municipal water 

supplies from the Tennessee River near the 

PP’s outfalls. Despite evidence of surface 

water quality impacts from the PP’s CCR 

disposal, the State has not required the PP 

to limit its discharge, monitor CCR disposal 

areas more frequently, or take any 

corrective action. The PP stopped 

Some Active, some 

not. Six of the 

Plant's 10 

generating units to 

close no later than 

by end of 2015, 

and the four other 

generation units - 

no later than by 

? Active
TCEQ required (2005) a Se assessment at 

one of the SIs as the likely source of Se; 

investigations remain underway. 

Assessment monitoring, capping/closure of 

leaking SI, and notification of residents in 

adjacent properties.

Pond closed; LF 

Active

? Active

Among the CoC (arsenic, boron, chromium, 

copper, lead, and vanadium) in GW from onsite monitoring wells, only boron has been 

detected in about 25 residential drinking 

water wells. In response to the City of 

Chesapeake’s requested, EPA conduct site 

inspection under CERCLA. Dominion Power 

undertook installing public water to the two 

closest communities. Several lawsuits by 

Inactive

Biennial GW Reports. Inactive 

(decommissioned: 

2000)

State required upgrade of GW monitoring, 

studies, and remediation. WDNR required a 

series of investigations from 1988 to 1997. 

The investigations found that cessation of 

ash sluicing and capping of the LF had 

effectively controlled the contamination of 

GW and no additional remedial actions 

were required. The ‘LF contact pond’ closed 

with clay cap in 1986 after construction of a 

Some active (new 

LF and SIs); Old LF 

w/contact pond - 

Inactive. One 

generation unit 

slated for closure 

by the end of 

2015, and a 

second, possibly to 
The LF was closed and capped in 1986. In 

1994, WDNR required investigation of GW 

contamination and upgrade of monitoring 

network to reflect concentrations outside 

the screened ash zone intervals. 

Inactive 1986

AOC; requirement for additional monitoring 

wells; ultimately-site closure. Now, under 

post-closure monitoring.

Inactive 1986. 

Three of the 

Plant's 5 

generating boilers 

closed end of 

2011, and the 

remaining two - to 

be retired early in 

2015.

Analysis of LF performance, better liner and 

mitigation study. Phase II final cap was 

placed in 2000 and Phase I/III final cap - in 

2007.

Some Active, some 

not

The State required an investigation of GW 

contamination, capping and closing of old 

ash pond (permitted as LF).

Some Active, some 

not. Plant to retire 

by the end of 

2015.

WDNER has been investigating (as of 

6/2010) to better establish local 

background and gradients to determine if 

CCRs are source of exceedances. Strong 

indication for past extensive, unregulated 

CCR dumping might explain Mo upgradient 

from designated LFs. WE has been 

purchasing impacted properties. 

Some Active, some 

not
Investigation Report (1994) and Remedial 

Report (2007). The property with the quarry 

and impacted private well that had preremediation boron and sulfate exceedances 

was purchased by the utility and retired. 

Engineered cap (2007/08) and partial 

removal of the fly ash to form a 1-acre 

wetland.

Inactive 1971. Coalfueled generation 

unit closed 2004.

Designated as an NPL site in 1986 due to 

GW contamination. RI/FS performed in 

1991. PRPs entered into a consent decree 

with U.S.EPA in 1992 to perform design and 

remedy implementation activities. 

Remediation, completed 9/1996, included 

waste relocation; landfill capping; slurry 

wall construction; leachate collection and 

GW treatment system installations; and 

implementing GW monitoring and use 

Inactive: Both LL 

and LTR, the 

adjacent industrial 

waste LF, stopped 

operating in 1976 

(1977?). Wate 

relocated in 1996.

No Reg. action on GW impact. A Jan. 2009 

release of 14,400 gallons of coal ash from 

the Blowdown Canal. Corrective action 

addressed the spill.

Some Active, some 

not

? Closed (in ?); now 

being mined.

? Active
? Active

? Closed (in ?); 

another cell active 

(License #3067)

Regulatory Action Current Status
Comments NOV CO/Admin 

Order

Study

Plant situated on a karst terrain. Groundwater mounding inferred from 

radial flow pattern. A January 2009 gypsum pond spill incident was 

resolved as Finding of No Significant Impact (FONSI). The removal of the 

gypsum from the triangle area was completed June 2009.

Y (EA to 

document the 

spill emergency 

response 

actions)

Groundwater mounding. Y

Plant's area designated (2007) as an “Important Bird Area” (IBA). An 

intermediate liner (i.e., over existing CCR fill) and leachate collection 

system would be placed over the ash currently in the landfill to minimize 

infiltration into the lower ash body.

Y

Mounding beneath the Surge Pond. 
Baseline GW quality was worse than that of the contaminant plume. 

‘Zero discharge facility’, high evaporation rates result in high Na and Cl 

levels in the ash ponds, as well as in salty seeps.

The Thames River close to the PP is saline, classified as unsuitable for 

shellfish harvesting, or as a fish/ shellfish habitat. Due to its high base 

flow, it is highly unlikely that GW contaminated in excess of SWPC would 

adversely impact the River

Y

RI studies for OUs 1, 2, and 3 determined that GW contamination 

pathways to residential wells are impeded by the prevalence of brackish 

water, and that fugitive dust dispersion complies with NAAQS. The RI of 

OU2 determined that if landfill erosion is controlled, there is no 

ecological hazard from exposure to sediment through food web 

interactions; and there is possible, but not probable potential for adverse 

effects on benthic invertebrates due to arsenic and barium in sediment. 

Citizens claim that Indian River arsenic data in fish and shellfish for 1998-

08 exceed 1x10-5 human health risk estimate.

Y Y

The plant is located in quaternary alluvium of the Escambia River. GW 

appears to have a naturally low pH. GW mounding in the area of the ash 

LF. GW monitoring data from 5 sampling events from 5/2008 to 11/2010 

show that contamination from a coal ash LF and gypsum storage areas at 

the Plant have caused multiple exceedances of MCLs for As and Cd in a 

compliance monitoring well. An expanded monitoring program that 

began in 2010 added testing for Tl. The first round of monitoring found 

levels that are 85% of the Tl MCL in a detection monitoring well. Other 

health-based guidelines were also exceeded. Data for 5 GW sampling 

? ? ?

According to the Utility, GW impacts are reported to occur within the 

approved FDEP ZOD, so they are in compliance with FDEP GW 

regulations.
A Zero Discharge facility. State claims that the problem is completely 

contained on-site.

Y

A Zero Discharge facility. LF - stabilized FGD. State claims impact within 

Zone of Discharge (ZOD). Utility claims that surface water samples were 

taken from ditches adjacent to the FGD LF, where surface water quality 

standards are not applicable because they are part of an NPDES MultiSector General Permit treatment system.

Y

A Zero Discharge facility. The unlined Gypsum Management Area is one 

of the sources of contaminants. State claims impact limited to Zone of 

Discharge (ZOD). Thallium primary EPA MCL exceedance on a property 

offsite, which was subsequently purchased by TECO. Plant is co-located 

with The Tampa Bay Seawater Desalination Plant, from which it receives 

its cooling water. 

Y

Built on top of abandoned phosphate mine, which likely has some 

influence on GW flow under the site. Impacts confined to the Zone of 

Discharge. Lakeland has prepared and implemented a Best Management 

Plan (BMP), a permanent Waste Management Plan (WMP), and a 

modified groundwater Monitoring Plan (GWMP) for the power plant. 

Y

The Lansing PP was constructed in 1948, with generation units added in 

1957 and 1976. “The flow of the regional aquifer is N-NW toward the 

Mississippi River. However, the potentiometric map of the area does not 

appear to take into account the localized, more westerly flow in shallow 

GW in the alluvium of the valley in which the CCR LF and impoundments 

are located. The alluvium, which is generally more permeable than the 

fine-grained sandstones of the bedrock aquifer, probably represent a 

near-surface GW system that creates a preferential flow path for 

contaminants to the W-NW. The presence of contaminants in MW11 is 

consistent with this interpretation." Originally rejected as a damage case 

(ICF, 10/2010, Appendix C, #7, p. 14 ) due to Inadequate Information: 
Monofill located on alluvial sand, silts and clays adjacent to the flood 

plain of Pine Creek, which enters the Mississippi River 0.5 mile SW of the 

monofill. Over most of the site shale is found at depths of 15' below the 

original ground surface or less. GW monitoring data from 1995 to 2008 

indicate that the monofill has contaminated underlying GW. The LF has 1 

downgradient well where the average level of Se since 1995 has 

exceeded the MCL (max. 713 ppb, 14 times the MCL) and the average 

since 1995 has been 71.3 ppb (1.4 times the MCL). Health-based 

guidelines have been exceeded in 5 downgradient wells.

? ? ?

Not certain that the active LF is co-located with the closed (1973) LF. 

Limited-size LF and plume with no down-gradient recipients. An 1987 

scientific article concluded that “the pollution potential for this small 

upland LF appears limited to a small area, and is unlikely to adversely 

affect any water supplies utilized by humans in the near future.”

Y

Mounded GW underneath the monofill. The Utility suggested that the upgradient As contamination was due to up-gradient sources and is not CCRrelated. In Harm’s Way counters that some of the up-gradient wells are 

improperly classified because GW does flow from the monofill towards 

these wells due to mounding. 

Y

There are indications that the only “up-gradient” monitoring point 

(MW4) has been affected by CCR constituents as a result of GW 

mounding within the LF.

(Y)

The shallow GW flow system includes shallow bedrock in the S part of the 

site, the saturated portion of the fill, and shallow unconsolidated 

deposits near a creek at the N edge of the LF. 18 monitoring wells, not all 

active. GW monitoring data (1994 - 2009) show As levels in 2 

downgradient wells steadily increasing, exceeding the MCL in 2008 and 

2009 (max.: 18.3 & 28.9 ppb). The Iowa GW standard of 1.0 ppm for B 

has been exceeded in 10 wells (Max. 37.1 ppm). Sulfate, in 10 

downgradient wells (max. 5,300 ppm) and other SMCLs also exceeded.

? ? ?
One of more than a dozen plants in Illinois with coal ash ponds where 

GW monitoring was not required by IEPA prior to the TVA Kingston ash 

spill in TN. The first round of GW sampling of monitoring wells at 2 ash 

ponds was in 2010. The Pb MCL was exceeded in 2 wells (Max. 27.4 ppb, 

1.8 times the MCL). As levels may be above the MCL, but this cannot be 

confirmed as the detection limit for arsenic was 2.5 times higher than the 

MCL . In response to IEPA’s new monitoring program, 7 wells (G101, 

G111, G112b, G113, G151, G152 and G153) were sampled on 8/17/2010. 

Whereas a well location map was not available for review, none of the 

? ? ?

One of more than a dozen plants in Illinois with coal ash ponds where 

GW monitoring was not required by IEPA prior to the TVA Kingston ash 

spill in TN. The first round of GW sampling of 5 downgradient wells 

occurred in 2010. Arsenic exceeded the MCL in 2 wells (Max. 148 ppb, 

14.8 times the MCL). EPA health-based guidelines were also exceeded. In 

response to this program 5 wells (APW1 to APW5) were sampled on 

12/13/2010. A well location map was not available for review. Although 

no exceedances were found in APW1 and APW5, the presence of B at 

0.117 ppm and 0.118 ppm in these 2 wells suggests that all wells have 

been impacted by ash ponds.

? ? ?

One of more than a dozen plants in Illinois with coal ash ponds where 

GW monitoring was not required by Illinois EPA prior to the TVA Kingston 

ash spill in TN. The first round of GW sampling, of 5 downgradient wells 

at the ash pond and 3 downgradient wells at the FGD pond in 2010 (May 

or June sampling), showed exceedances of the As MCL at 3 ash pond 

wells (Max. 93.6 ppb, 9.4 times the MCL) and 1 FGD well (14.8 ppb). In 

response to IEPA’s new monitoring program, 4 temporary piezometers 

were installed at the periphery of the ash pond area (AP1 to AP4, GW ~ 4-

6’ below ground surface) and another well, AW3, at a further distance 

downgradient from the ash pond. There are also 3 FGD monitoring wells 

? ? ?

On 6/11/2012, IEPA issued a NOV for GW contamination after testing of 

wells showed numerous exceedances of heavy metals including As and 

Se. On 10/24/2012, a Compliance Commitment Agreement (CCA) signed 

between Midwest Generation (MWG) and IEPA. In 10/2012 citizen 

groups filed a complaint with Illinois Pollution Control Board, calling 

MWG to stop disposing ash in the ponds, start hauling the ash to a LF in a 

closed system and remediate the site to remove all contaminants. 

Y Y

On 2/4/2013, Illinois Attorney General filed a complaint with the Illinois 

Pollution Control Board alleging that Ameren Energy Resources 

Generating Co. illegally disposed of 180,000 tons of coal ash (from 

another PP) at the Duck Creek power plant for use as fill material for a 

railroad embankment (no impact reported).

Y
Groundwater mounding under each of the two impoundments (east & 

west) while they were active. An approved GMZ (1997). 

Y

Groundwater monitoring Zone (GMZ). Citzens' group appeal to the 

Illinois Pollution Control Board to revise the Plant's upcoming NPDES 

permit remains pending.

Y

Utility claims contamination related to coal mining.

CIPS petitioned the Illinois Pollution Control Board (IPCB) in the mid1980s to establish site-specific water-quality standards for GW at the site; 

petition rejected by the IPCB, and rejection upheld by the Illinois 

Supreme Court. Ultimately, although contamination migrated offsite, 

such a special designation was approved by the IPCB towards the closure 

of Pond-D.

Y Y

Comments NOV CO/Admin 

Order

Study
In 1997-1998, ash was excavated from two unlined cells and lined cells 

were constructed in those areas. 

Y

Satellite images indicate that the waste units are located on shore 

sediments of Lake Michigan. According to IEPA's Oct. 2011 report, GW 

flow appears to be highly dependent on the water level in the ash ponds. 

Due to the potential for off-site movement, Midwest Generation has 

been instructed to complete some additional investigations to more fully 

evaluate contaminant movement. Illinois EPA’s Ash Impoundment 

Strategy, developed in response to the TVA Kingston ash spill, identified 

the ash ponds at Waukegan as a Priority 2 site for hydrogeologic 

assessment (IEPA, 2010). 5 wells (MW1 to MW5) were sampled on 

10/25/2010. A well location map was not available for review. MW5 is 

identified as an upgradient well, but very high levels of B (28 ppm), Sf, 

and TDS, in addition to As and Se detections, indicate that it is in fact 

contaminated by coal ash.

Y Y Y

In a 2011 draft NPDES permit, IEPA proposed changes to some of the 

outfalls and the addition of metals as constituents to be monitored.

GW flow shifts caused by quarrying activities to the LF's southeast 

necessitated additional monitoring wells. After encountering Boron 

exceedances in 8 of the 18 drinking water wells sampled south of the 

quarry, MG offered to either buy out the properties or drill new, deeper 

wells for the affected residences. MG contends that Boron was merely 

used as a 'fingerprint' tracer isotope in the study and that no residential 

wells were impacted by the LF. IEPA approved two Ground Water 

Management Zones (GMZs) designation for the LF area (with a potential 

for allowing off-site contamination of GW within the GMZs).

Y

Illinois EPA’s Ash Impoundment Strategy, developed in response to the 

TVA Kingston ash spill, identified the ash ponds at Joliet 29 as a Priority 1 

site for hydrogeologic assessment (IEPA, 2010). 11 wells (MW1 to MW11) 

were sampled on December, 6-7, 2010. Based on ash constituents being 

detected in all wells, all sampled wells are presumed to be downgradient. 

Sb MCL was exceeded in one well (12 ppb, twice the MCL). 5 parameters 

exceeded Illinois Class I GW Standards, including Sb (1 well), Cl (4 wells), 

Mn (3 wells), Sf (1 well), and TDS (2 wells). EPA health-based guidelines 

were also exceeded for Mn (2 wells, up to 3.7 times the LHA) and Sf (1 

well, 3.2 times DWA).

Y Y ?
Illinois EPA’s Ash Impoundment Strategy, developed in response to the 

TVA Kingston ash spill, identified the ash pond at Pearl Station as a 

Priority 1 site for hydrogeologic assessment (IEPA, 2010). 12 wells (MW1 

to MW12) were sampled on 5/27/2010. Based on ash constituents 

detected in all wells, all wells are presumed to be downgradient. As MCL 

was exceeded in 5 wells (Max. 48 ppb, 4.8 times the MCL). EPA healthbased guidelines were exceeded for B in 7 wells (Max. 16 pm, 5.3 times 

the CHA), Mn in all wells (Max. 18 ppm, 60 times LHA), and Sf in 5 wells 

(Max. 1,400 ppm, 2.8 times DWA). 7 parameters exceeded Illinois Class I 

? ? ?

SIPC obtained a boron-adjusted water quality standard in the 1990s from 

the Illinois Pollution Control Board (IPCB) for a long segment of the 

receiving stream. Still, SIPC apparently does not meet the boron permit 

limits dictated by the adjusted standard every month. Further 

assessment of GW impacts is underway.

Y

Reversals in direction of GW flow with river's flood stage. A storm water 

and wastewater treatment system built in 2005: as a result, all discharges 

into the ash pond system were eliminated, the ash pond system has been 

completely isolated, and the water table beneath the ponds and the 

amount of saturated ash has dropped considerably since that time. As 

part of the plan for final closure of the SIs, AmerenUE proposed (3/2010) 

final capping and a “Groundwater Management Zone” to contain 

contaminant plumes within the property. 

Y

While no wells were placed off-site, Dames & Moore concluded that a 

steel slurry wall downflow from the disposal site, in addition to natural 

attenuation, mitigated and limited the contaminant plume. Because Pb 

exceeding the PDWS was detected also in several up-gradient wells, it is 

not clear whether it is related to the CCR. 

Seepage from the pre-1981, ulined settling ponds, estimated to be at 

least 2 million gallons per day, resulted in GW mounding. Near the 

Indiana National Lakeshore on Lake Michigan. In 1978, the SIs were 

dredged then lined with a composite liner (HDPE over clay). Fly ash from 

the BGS (and Michigan City) Stations is transported offsite for disposal 

(Schahfer Generating Station.) 

Y Y
Phase III & IV have composite liner w/leachate collection.

FGD solids LF; Compacted clay liner in expanded LF area.

IDEM accepted Utility's claim that impacts are due/inseparable from 

those caused by coal mining activities.

5' clay liner (1x10-6 hydraulic conductivity). Also: “Poz-O-Tec” (processed 

ash and FGD waste). 

Y

State and Utility claim that the GW flow discharges to the Ohio River and 

does not risk any drinking water resources
In 1999 the state required the facility to: (1) expand its list of semi-annual 

monitoring parameters, (2) prepare a GW assessment plan to address 

GW degradation, and (3) establish the rate and direction of migration of 

contaminants in GW. 

Y

The Utility claims there is no significant potential for adverse impacts on 

local water supplies: GW flow for the location is in the direction of the 

Ohio River and there are no residential wells (or non-company owned 

properties) between the plant and the river. All local households are 

connected to public water supplies.

Y

The area around the Paradise plant has been severely disturbed by strip 

mining. A Lisman Fm. aquifer 6 to 22' beneath the surface has been 

substantially removed by mining, and where it remains it is in direct 

contact with ash disposal areas. Of great concern is the long-term impact 

on GW and possible ecological impacts to local surface water (TVA, 1989: 

“Any impacts to GW will be localized, with increased fluxes to the Green 

River and/or Jacob’s Creek.”). Monitoring in the 1980s, reported in a 

1989 Draft EA for development of a dredged coal ash disposal area, 

revealed contamination at this site that included Be, Cd, and Pb above 

? ? ?

Geohydrologic mounding underneath the dry stack area. GW has been 

assessed onsite; however, no offsite GW data are available. Metal 

monitoring started only in 9/2008.

The Kentucky Division of Waste Management is unable to determine the 

location of any well or the direction and rate of GW flow at the site 

because it does not require that a potentiometric surface map be 

submitted with GW reports. In its comment to the docket, KDEP states 

that there only appears to be one residential well down-gradient from 

the LF within the 2-mile radius. This well needs to be investigated for its 

actual use, as it appears it may be on plant property. Remedial Action 

Plan prepared for the LF.
The higher GW elevations in pond area wells suggest GW mounding 

beneath the ponds due to leakage, causing localized reversal of GW flow 

to the west, away from the Mississippi River.

Y

Rodemacher Station submitted a request for a major permit modification 

of the coal ash management area to construct a Type I LF, which included 

a request for a 60' height increase in the existing CCR disposal unit, use of 

coal ash as protective cover, and use of an alternate liner.

In early 2001, MADEP issued a consent order, requiring modifications to 

the site’s GW monitoring program and surface water sampling, and 

evaluation of GW discharge to the adjacent Assonet Bay. In 2008, 

designated for development as a shopping mall (Payne's Crossing).

Y

Under the proposed consent decree filed in Jan. 2013 in the U.S. District 

Court for the District of Maryland, GenOn MD Ash Management would 

cap and seal all closed cells in the landfill and install liner systems in all 

leachate and stormwater collection ponds; perform a study to 

characterize the levels of contamination at the Site; and develop and 

implement a plan to control fugitive coal dust, which can be released 

from the ponds.

Y (Y)
Bioreactor wastewater system installed in 2009/10 but failed. 1/2011: 

MDE filed Intent to Sue in Federal court. 12/2012: settlement between 

MDE/coalition citizen groups with the Utility: penalty ($1.9 m); properly 

cap & seal all closed LF cells; install liner systems in all leachate/ 

stormwater ponds; study to characterize levels of onsite contamination; 

and control fugitive dust. 1/2013: coalition of citizens groups has filed an 

Intent to Sue for wastewater discharge violations. 6/2013: MDE filed a 

water pollution lawsuit to address unpermitted wastewater release into 

the Potomac River. A settment is under negotiations.

(Y)

Geohydrologic mounding. In 2004, MDEQ developed tighter leachate and 

GW venting standards for surface waters at the GW/Surface Water 

Interface (GSI). Evaluations of data are complicated by the natural 

background concentrations of parameters such as As and Hg and likely 

low-level contamination coming from (non-CCR) dredge spoils piles. 

MDEQ recently claimed that under the revised “mixing zone” standards, 

and State revisions for B and As standards ‘based on new science’, these 

LFs' discharge levels comply with criteria. MDEQ concedes that whereas 

as of late in 2009 there were no known violations, there was also a lack 

Y Y Y

Restrictive covenant blocking new water wells or use of drinking water 

within aquifer or any aquifer within 0.5 miles of the site; landfill closed 

and covered in 1993-95. Post-closure monitoring was required for ten 

years.

Y

Plant slated for decommissioning in 2/2014 but was compelled by 

regulator to keep operating due to impact to power reliability.

Y Y

BC Cobb plant, the LF's customer, slated for decommissioning by April 

2016. The LF was closed and capped as part of a settlement to a class 

action suit brought by neighbors. Under post-closure monitoring. 

Y
Wet municipal solid waste underneath the ash. Y Y

Originally closed by the state in 1984 with the standard earthen final 

cover required at the time, but closure later brought to par with stricter 

Type III closure requirements. Plant due for retirement by 4/2016.

Y Y

Selenium concentrations in fish from the lower Pigeon River and Pigeon 

Lake, in the vicinity of the fly ash disposal ponds, were significantly 

greater than Se concentrations at the up-stream Pigeon River site and 

were greater than published background Se concentrations in fish in the 

Great Lakes region. Se concentration in some species of fish from the 

lower Pigeon River and Pigeon Lake exceed dietary lowest observable 

adverse effect concentrations (LOAECs) associated with toxic effects in 

wildlife and laboratory animals.

Comments NOV CO/Admin 

Order

Study

Hydrologic mounding is plausible. According to the Utility, As, Ba, Cl-, Cu, 

F

-

, Pb, Sulfate, and Zn were only detected in samples collected from wells 

screened in the CCP pond.
Past study showed high levels of Fe and Mn in background soils, as well 

as exceedences of SMCLs for Fe and Mn in background GW and the 

river/lake up-gradient and upstream of the site, at levels similar to those 

seen in the wells immediately adjacent to the ash ponds. 

The site has been the subject of several EPA investigations under 

Superfund (CERCLIS # NCD000830646). In 2008, NC DENR issued NOV and 

requested corrective action. Progress Energy is performing corrective 

action work voluntarily. Monitoring wells were installed at several phases 

(2004, 2006, 2008, 2010), with exceedances triggering a site assessment 

study (2008), a complaint in Wake County Superior Court, filed by SELC 

(1/2013) on behalf of several conservation groups, then sued Duke 

Energy, requiring cleanup of GW contamination around the Plant's 

unlined coal ash ponds; a federal judge decided (6/2014) that the lawsuit 

Y Y Y

Originally, the State had no plans of taking regulatory action until GW 

contamination reaches the compliance boundary. This posture has 

changed once newly sited monitoring detected impact outside the ponds' 

compliance zone. Unpermitted dicharge is also alleged.

Originally, the State had no plans of taking regulatory action until GW 

contamination reaches the compliance boundary. This posture has 

changed once newly sited monitoring wells detected impact outside the 

ponds' compliance zone. Unpermitted dicharge is also alleged.

State and industry claim that Fe and Mn are due to background levels, 

and no remediation was required for any of the contaminants because 

exceedances are located inside the state’s Compliance Boundary. This 

very PP was associated with the Belews Lake ecologic DC. In 2014, Duke 

Energy agreed to assist Madison and Eden financially to upgrade their 

water-treatment systems, to make them capable of scrubbing water 

clean of bromide without producing unsafe levels of trihalomethane (The 

Plant's bromide discharges into the Dan River are unbridled by state or 

federal regulations: bromide, when interacting with chlorine in drinking 
Originally, the State has no plans of taking regulatory action until GW 

contamination reaches the compliance boundary. In 2012, Duke Energy 

Progress retained SynTerra Corp. to evaluate GW data and prepare a site 

conceptual model. In 5/2013, NC DENR filed a complaint amending its 

March 2013 filing against Duke Energy over leaks and contamination at 

its Asheville Plant. Duke Energy and NC DENR have tentatively reached a 

settlement, a proposed consent order has been filed in two state 

superior courts and public comments are being sought. Following the 

February 2, 2014 spill into the Dan River, NC DENR rescinded the 

(Y) Y

The LF has been capped and is inactive since 2005; the PP was retired 

4/2012. 

Y

The site was operated without any control of surface waters from the SI. 

A tributary to the marsh and a nearby creek formerly flowed through the 

ash disposal areas. As late as 1989, surface water ran directly off the site 

from the SI dike into the marsh. Facility decommissioned in 1985. Unclear 

whether an impacted drinking water well was located on-site or off-site 

(if the latter, this Potential DC. should be redesignated as a Proven DC)

Y

All ponds were relined with composite geosynthetic/clay liners. This site 

is a possible candidate for redesignation as a Proven DC. 

Y
Groundwater has been evaluated onsite; however, no offsite assessment 

or monitoring has been required. State claims it was instrumental in LOS' 

conversion to dry handling of fly ash in 1996.

NDEQ argues that Se and sulfate exist as naturally occurring minerals 

throughout the region. In evaluation of the site, the natural occurrence 

of both substances is being considered, as well as the possibility of a 

localized discharge of cooling tower water used for fire suppression or 

similar PP activity. 

Y Y

Owned by Dynegy’s Northeast Generation Inc. Following extensive 

damage during Hurricane Sandy, auctioned (12/2012) for demolition. In 

April 2014, petition to NY Public Service Commission to restore the 

facility as a peak power generator plant.

Y

Phase II LF not implicated Y Y
Property is utilized as a model airplane flying field.

Originally Rejected (EPA 2007 DC Ass. Report) due to inadequate 

information : "This site is categorized as a case without documented 

evidence of proven or potential damage to human health or the 

environment." No subsequent new information. However, reinstated as a 

potential DC based on Ohio EPA's comment to the Oct. 2011 NODA, EPAHQ-RCRA-2011-0392-0163: “JM Stuart Station, Adams County, Ohio. At 

this time, there is evidence indicating the quality of GW beneath the J.M. 

Stewart Station has been impacted. Samples collected at the J.M. Stewart 

(sic) Station, well #2, between 1973 and 1986 by Ohio EPA staff indicates 

a rising level of total dissolved solids, sulfate, calcium, iron and 

magnesium. Ohio EPA continues to monitor GW to determine if this 

trend continues and rises to a level where a full assessment is 

warranted.” 

Issue w/sinkholes. Ash sluicing ceased in 1985. An interceptor well was 

installed in 1993 to prohibit a sulfate plume from reaching off-site public 

water supply wells. NOVs (EPA) for emission/PM violations in the late 

1990s.

 The Tidd-Dale Subdivision, ~ 2000’ from the FAR 2 dam, relies on private 

drinking water wells (at least 9 private wells). The latest potentiometric 

map of the PP suggests that this Subdivision is in the direct path of GW 

flow from FAR 2. OH EPA has not required any sampling of these wells.

OH EPA increased the plant’s allowable daily max. concentration for B in 

2009 so it no longer exceeds NPDES requirements; it has also set water 

quality criteria for Kyger Creek for several metals that are all much higher 

than for the Ohio River; this results in significant mortality rate of the 

fathead minnow next to the outfalls’ mixing zone. In 1994, AEP switched 

to a dry ash handling system, reducing Se inputs to Stingy Run and Kyger 

Creek. 
Probable groundwater mounding. Local aquifer has high 'baseline' TDS.

Groundwater mounding. AEP has submitted a proposal to construct a 

slurry wall and grout curtain barrier along the length of the LF facing the 

Verdigris River; a proposal to ensure rainwater infiltration into the LF 

proper is minimized/ eliminated; and AEP is designing an intermediate 

liner and leachate collection system for the LF, to be submitted for 

ODEQ’s approval.

Presumably, groundwater mounding. State claims that elevated levels of 

Fe and Mn and sporadic low levels of As and B are attributed to AMD 

created by past mining of the Pittsburgh Coal Seam upgradient of the 

site. USWAG claims that the data should be more appropriately 

compared to Pennsylvania Statewide Health Standards of medium 

specific concentrations (MSCs) for non-residential, non-use aquifers 

rather than drinking water MCLs. The Pennsylvania MSCs for nonresidential, non-use aquifers have not been exceeded. EPA identifies As 

as released from the plant's WUs.

PADEP claims that the decommissioning of the SIs was due to closing of 

the PP and not required by legal action. 

Y Y

PADEP and the PP claim that is the legacy of the original Seward Power 

Station that has been demolished; and the neutrailzation of old coal 

refuse with FBC ash used for the foundation of the newly constructed CoGen plant.

Y
Groundwater mounding under the central and western portions of the 

site. Clean closure is either underway or has been completed.

RRI claims that there are no permit limits stipulated for discharges of B, 

Cd and Se into Brushy Meadow Creek from Outfall 002. As to 

unpermitted discharges of B, Cd, Crvi, and Se into Brushy Meadow Creek 

from Outfall 001, RRI claims that the CCC is not an 'end of the pipe' 

standard, but rather a standard used in modeling of allowable 

downstream levels of a pollutant.

The current GW monitoring program was established in 2005 and was 

supposed to have 7 monitoring wells in the vicinity of the ash LF, south of 

the Saluda River (MW3B, MW13, MW14, MW15R, MW16R, MW17, and 

MW18), and 3 monitoring wells north of the Saluda River (MW30, MW31 

and MW32). Between 2005 and 2010, MW13, MW14 and MW15 were 

only sampled in May, 2005, and no data were found for MW15R and 

MW18. Monitoring programs omit some CCR signature parameters: Sb, 

Be, Pb, Hg, Se, and Tl. Interpretation of Cr in GW sampling results is 

complicated by the fact that pH shows considerable variation in the same 

? ? ?

The site is upstream of the Congaree National Park, one of the largest 

contiguous sections of floodplain forest in N. America. Fish living in the 

Wateree River in close proximity to the plant were found to have 

elevated tissue levels of arsenic in comparison to upstream and 

downstream populations. Neighboring landowners' lawsuits (2009) to 

stop contamination from reaching their properties has been overturned 

based on DHEC's 2001 arsenic waiver. Based on a settlement with SELC, 

SCE&G is now removing the 2.4 million tons of coal ash from its two SIs to 

an offsite LF, with full removal expected by 2021. The agreement also 

Y

GW elevation indicates flow from the ash pond to the NE toward Lake 

Moultrie, about 0.5 mile away. One apparent upgradient well (PM1), and 

17 downgradient monitoring wells (CAP1 to 14, PM2, PM4, and PM6), 

were sampled in Jan. and July of 2009 and 2010. Well PM1 does not 

appear to be affected by ash and provides a good basis for comparison. 

The only coal ash constituent that appears to be naturally high in PM1 is 

Fe (16 ppm). PM1 had non-detects for heavy metals and the following 

concentrations for other parameters: Al <0.05 ppm, Cl 15.8 ppm, Na 5.99 

ppm, Sf 6.86 ppm, and TDS 270 ppm. The following CCR signature MCL 

? ? ?
Nov. 2013 Consent Agreement requires semi-annual GW monitoring to 

continue up to 2 years past the full removal of ash, a clean closure plan, 

and reporting any discharge and dike breach to DHEC and citizen groups. 

Santee Cooper sued by citizen groups in federal & State courts; lawsuits 

withdrawn following a Nov. 2013 Consent agreement for clean closure by 

Dec. 2023.

(Y)

GW monitoring data go back to 1995. The monitoring programs omits 

many CCR signature several MCL parameters (Sb, Be, Hg, and Tl) and 

many health-based standard parameters. Pb added as a parameter in the 

most recent sampling event: it was detected in 6 wells at 2.98 to 10.2 

ppb. GW monitoring data from 2009 and 2010 show As above the MCL (3 

wells, Max. 180 ppb, 18 times the MCL). Health-based guidelines were 

exceeded for Sf (4 wells, Max. 1,163 ppm) and Fe (2 wells, Max. 88.7 

ppm, 3.4 times the tapwater RSL). Total chromium was detected in 1 well 

at pH levels where all or most is likely to be Cr (+6). Data for 12 

? ? ?

Comments NOV CO/Admin 

Order

Study

The aquifer beneath Allen Station interacts with adjacent Lake McKellar, 

causing flow reversals which render upgradient/downgradient well 

locations questionable. Also, there is mounding beneath the ponds. TDEC 

was not aware of the As exceedances at the ash ponds prior to a 2011 

TVA Office of Inspector General (OIG) Report (TVA, 2011). Having no 

permitted LFs, TDEC does not require GW monitoring of the Plant’s ash 

disposal sites, but voluntary monitoring took place from 2004 to 2008.

? ? ?

Switched to dry handling of fly ash (mid-1980s). Toxicity study indicated 

potential for ecologic damage to introduced species; no data, however, 

to indicate impacts to native species.

Y
On May 27, 2011, a consortium of citizens groups submitted a petition 

for statutory appeal to the Tennessee Water Quality Control Board 

concerning the intent of TDEC’s Division of Water Pollution Control to 

renew TVA JSF’s NPDES Permit TN 0005436. A modified permit was 

issued in Dec. 2012.

The construction of 2 CCR storage-disposal areas on top of earlier SIs and 

on top of a former creek channel, have created conditions conducive to 

GW contamination. Groundwater mounding, with one node each 

underneath the ash pond and underneath the gypsum stack. In 2/1997, 

bypass of Outfall 001 occurred when during about ten minutes, between 

1/2 to 1 million gallons of gypsum wastewater spilled from the Gypsum 

Disposal Area into Wells Creek (oversurge due to heavy rainfall). 

Adjacent to the Cumberland River, in Karstic terrain, with a history of 

active sinkholes. Closed pond subject to post-closure, quarterly 

monitoring sampling campaigns.

One of the PP’s disposal units - an 87-acre unlined CCR SI - is located on 

an island in the Tennessee River. In May 2011, JOF developed 

Preliminary Closure Plan for the Active Ash Pond. This Plan is deemed 

lacking by citizens groups and their professional consultant.

According to the TCEQ, “multiple aquifer levels are accessed in the 

region,” and “numerous private water wells are located around and 

adjacent to the facility with reported uses such as irrigation, household, 

and private drinking water.” (TCEQ, 2009). There are 19 drinking water 

wells within a mile of the Plant and its ash ponds (Aecom, 2009). TCEQ 

claims, however, that these wells are either upgradient or isolated from 

the Plant’s GW by Coleto Creek Reservoir, the Plant’s cooling water 

supply, which flanks the south and east boundaries of the site (Aecom, 

2010). The response to the FOIA request for data from Coleto Creek 

? ? ?
The PP is located on Lake Fayette, serving as a cooling reservoir, and is 

also a popular recreational lake for fishing and boating. Half of the CCR SI 

was closed down in 1988; the remaining part to be closed by 2012 and 

convert to dry handling. 

Y

Fishing is prohibited in the 2,140 acre Smithers Lake, immediately north 

of the Plant, which is owned and operated by NRG as a cooling water lake 

for the plant. The response to the FOIA request for data from Parish 

Station was received too late to develop a detailed description of 

contamination at this site. 27 wells sampled in 2009 and 2010 (two 

sampling events each year, four total). As was measured in 10 wells 

above the MCL (Max. 125 ppb); Ba, in 1 well above the MCL (2.15 ppm), 

and Se, in 2 wells above the MCL (Max. 242 ppb). 

? ? ?

Course filled w/1.5 million yd3 of fly ash, amended with 1.7% to 2.3% 

cement kiln dust. Virginia’s Administrative Code allowed the use of fly 

ash as fill material w/o a liner as long as the fly ash was placed at least 2’ 

above GW and covered by an 18” soil cap.

Y

Plant switched to natural gas in 2000. Closure of impoundments possibly 

underway.

Y

Groundwater mounding. Ongoing monitoring at the site (including 

monitoring of the private wells) includes boron, sulfate, and arsenic. 

Previous monitoring included selenium, iron, fluoride, and chloride.

Y
Groundwater mounding. Ongoing monitoring at the site includes 

indicator parameters plus boron, selenium, manganese, and iron.

Y

Site is in the Mississippi floodplain and ash fill may have been placed 

below the water table/surface water elevation. Transient GW flow 

gradient reversals under high-river stage. Ongoing monitoring at the site 

includes indicator parameters plus manganese and boron.

Y

Y

Site is in the Mississippi floodplain and due to GW mounding, ash fill has 

been placed close to the water table. A drinking water well was 

impacted by SMCL exceedances.

Y Y

12 offsite private wells found exceedances of Mo and B. A consultant to 

WE determined that Mo in the private wells was not coming from CCR in 

the LFs. WE started supplying (as of 8/2009) bottled water to several 

dozen residents in the area w/o claiming responsibility for the 

contamination; however, shortly after WDNR relaxed the State’s 

molybdenum GW quality enforcement standard from 40 ppb (the federal 

HAL) to 90 ppb (in August 2013), WE stopped supplying water to affected 

residents (end of 2013). 

Y
Operated from 1948-1971. A well located ~ 250’ south of the old quarry 

was contaminated by very high levels of boron (the State did not have a 

health-based standard for B at the time of the exceedances).

Y

Most of the residential wells found to be affected by the LL 

contamination in 1985 were screened near the top of the dolomite rock 

and were replaced with wells screened starting at about 250 feet below 

ground surface. Following citizens’ complaints about drinking water in 

1985, WDNR sampled nearby residential wells, and replaced seven wells 

with much deeper wells. Twenty three private wells are sampled as part 

of continuing site activities. None of the metals exceeded MCLs in private 

well samples; one well had a VOC concentration exceeding an MCL.

Y Y

The testing documented in the 1988 RTC suggests uncertainty as to the 

cause of the impacts to downgradient GW because Cd, Mn, and sulfate 

were also found in upgradient wells. The utility reports that a follow-up 

investigation found that the Cd and Mn were naturally-occurring.

Y
Comments NOV CO/Admin 

Order

Study
Extended or 

Assmt 

Monitoring

Remedial 

Action

Lawsuit/ 

Petition/ 

Complaint

Fish Advisory/ 

Fishing Ban

Provide 

Drinking 

Water

Other (Closure, 

switch to drydisposal)

Y (spill 

cleanup)

Y Generation units 1-

6 and 8, to retire by 

2015.

Y Y

Y Y
Y Y (Y)

Y Y

? ? ? ? ? ?
YY

Y

YYY

YY
? ? ? ? ? ?

Y

Y

? ? ? ? ? ?
Y ? ? ? ? ?

Y ? ? ? ? ?

Y ? ? ? ? ?

Y Y Y Y

Y Y
Y Y

Y Y

Y (Y) Y

Y Y Y

Extended or 

Assmt 

Monitoring

Remedial 

Action

Law 

suit/Petition

Fish 

Advisory/fishi

ng ban

Provide 

drinking 

water

Other (Closure, 

switch to drydisposal)
Y Y Y

Y Y Y ? ? ?

Y Y

Y (Y)

Y Y Y ? ? ?
Y ? ? ? ? ?

Y Y Y

Y

Y Y Y
Y Y Y

Y Y Y

Y Y

Y Y
Y

? ? ? ? ? ?

Y

Y (Y)
Y

Y

Y

Y Y

(Y) Y
Y

Y

YY

YY

YY

YYYY
Y Y Y

Y Y Y

Y Y

Extended or 

Assmt 

Monitoring

Remedial 

Action

Law 

suit/Petition

Fish 

Advisory/fishi

ng ban

Provide 

drinking 

water

Other (Closure, 

switch to drydisposal)

Y Y 
Y Y

Y Y Y Y

Y

Y Y Y

Y Y Y* Y
Y Y Y Y Y: Progress Energy 

purchased (on 

12/10/2010) 

neighboring 

property, which 

relocated the 

Compliance 

Boundary such that 

well CB-3 (Tl 

Y (Y) Y Y

Y Y Y

Y Y

Y Y
Y

Y

YY
Y

YY

YY

YY
Y

Y (Y)

Y Y

Y Y
Y Y

? ? ? ? ? ?

(Y) Y Y

? ? ? ? ? ?
(Y) (Y) Y (Y)

? ? ? ? ? ?

Extended or 

Assmt 

Monitoring

Remedial 

Action

Law 

suit/Petition

Fish 

Advisory/fishi

ng ban

Provide 

drinking 

water

Other (Closure, 

switch to drydisposal)

? ? ? ? ? ?

Y Y
Y Y (Y)

Y

Y Y Y

(Y)

? ? ? ? ? ?
Y Y Pond Closure

? ? ? ? ? ?

Y Y Y

Y (Y)

Y Y
Y

Y

YY

YY

YY

Y
Y

YY

YYY
Extended or 

Assmt 

Monitoring

Remedial 

Action

Law 

suit/Petition

Fish 

Advisory/fishi

ng ban

Provide 

drinking 

water

Other (Closure, 

switch to drydisposal)



































No. Crosswalk Facility Location State References/Pre-Existing 

Designation

1 PR08 JR Whiting Generating 

Plant, CMS/Consumers 

Energy 

Erie MI CCW DC Ass #76; 'rejected'

2 PR32 Clinch River Cleveland VA CCW DC Ass #71; 'rejected'

3 PTa21 Copicut Road Monofill Freetown MA CCW DC Ass #72; 'rejected'

4 PTb39 Cardinal PFBC Monofill Brilliant OH CCW DC Ass #69; 'rejected'

5 PTb39 Cardinal Fly Ash Reservoir 

II Impoundment

Brilliant OH CCW DC Ass #70; 'rejected'

6 PTb40 Gavin Impoundments Cheshire OH CCW DC Ass #74; 'rejected'

7 PTb41 Muskingum River Power 

Plant Impoundments

Beverly OH CCW DC Ass #77; 'rejected'

8 None Stuart Station 

Impoundments - Dayton 

Power & Light 

Adams Co. OH CCW DC Ass #82; EPA's 2009 

Dam Assessment Report. 

9 R1 Florida Power & Light P.L. 

Bartow Plant

St. Petersburg, 

Pinellas Co.

FL CCW DC Ass #39; 'potential'

10 R2 Florida Power & Light 

Plant

Port Everglades FL CCW DC Ass #37; 'potential'

11 R3 Florida Power & Light 

Plant

Port Riviera FL CCW DC Ass #38; 'potential'
12 R4 Rocky Acres Coal 

Combustion By-Product 

Disposal Site – Bunge 

North America Corp., 

(Also: Grays Siding) 

Oakwood, 

Vermillion 

County

IL Out of Control #5

13 R5 New England Power Brayton Point MA CCW DC Assmt #26; 'potential'

14 R6 Salem Acres Site Salem MA CCW DC Ass #1; 'proven' - ICF 

(10/2010), Appendix A, P. 1 

15 R7 Vitale Fly Ash Pit Beverly MA CCW DC Ass #2; 'proven' - ICF 

(10/2010), Appendix A, P. 2 

16 R8 Four Corners Power Plant Fruitland NM Out of Control # 17; 'proven' - 

ICF (10/2010), Appendix B, 

#17, p. 33

17 R9 Antelope Valley Station - 

Basin Electric Power 

Cooperative 

Beulah, Mercer 

County

ND In Harm's Way #19

18 R10 Industrial Excess Landfill 

Superfund Site

Uniontown OH In Harm's Way #25; ICF 

(10/2010), Appendix C, #25, p. 

52 

19 R11 Boardman Plant – 

Portland General Electric

uniontown OR In Harm's Way #28; ICF 

(10/2010), Appendix C, #28, p. 

58 

Crosswalk Facility Location State References/Pre-Existing 

Designation
20 R12 Big Stone Power Plant – 

Otter Tail Power

Big Stone City SD In Harm's Way #31; ICF 

(10/2010), Appendix C, #31, p. 

64

21 R13 Reliant Energy Elrama 

Plant

Union Township, 

Washington Co.

PA CCW DC Assmt #30; 'potential'

22 R14 VEPCO Possum Point VA CCW DC Ass #4; 'proven'. ICF 

(10/2010), Appendix A, P. 4 

23 R15 Mitchell Generating 

Station

Moundsville WV CCW DC Ass #31; 'potential'. 

ICF (10/2010), Appendix B, 

#31, p. 62

24 None Turris Coal Company 

Elkhart Mine

Elkhart IL CCW DC Ass #84; 'rejected'

25 None Dixie Caverns County 

Landfill

Roanoke Co. VA CCW DC Ass #73; 'rejected'

26 None Former CSX Rail Corridor Bloomington IN EPA-HQ-RCRA-2011-0392-0259 

(Risky Business #5)

27 None Georgia Power (Southern 

Company) Yates 

Generating Plant, FGD 

Landfill

Newnan GA EPA-HQ-RCRA-2011-0392-0259 

(Risky Business #2)

28 None NV Energy and Idaho 

Power North Valmy 

Generating Station Ash 

Ponds

Valmy NV EPA-HQ-RCRA-2011-0392-0259 

(Risky Business #14)

29 None Star Coal Company #6 

Landfill

Monroe Co. IA CCW DC Ass #80; 'rejected'

30 None Star Coal Company #14 

Landfill

Monroe Co. IA CCW DC Ass #81; 'rejected'
31 None Thompson Landfill Thompson MI CCW DC Ass #83; 'rejected'

32 None Ohio Valley Electric Corp. 

Kyger Creek Power Plant 

Impoundments

Gallipolis OH CCW DC Ass #75; 'rejected'

33 None Muskogee Environmental 

Conservation Company 

Fly Ash Disposal Site 

Muskogee OK CCW DC Ass #78; 'rejected'. 

EPA-HQ-RCRA-2003-0796-0019

34 None Public Service Co Fly Ash 

Disposal Site 

(Northeastern Station?)

Oologah (?) OK CCW DC Ass #79; 'rejected'. 

EPA-HQ-RCRA-2003-0796-0019

35 None Western Farmers 

Electrical Fly Ash Site

Chactaw Co. OK CCW DC Ass #85; 'rejected'

36 None American Coal 

Corporation #5 Landfill

Marion County IA CCW DC Ass #68; 'rejected'

Crosswalk Facility Location State References/Pre-Existing 

Designation
Current 

Designation/Rationale

Comments

Re-designated as a 

proven damage case

In CCW DC Ass, case is referred to as 'Lake Erie, Ohio'. Superseded by In 

Harm's Way Case #17, JR Whiting Generating Plant - CMS/ Consumers 

Energy .

Re-designated as a 

proven damage case

Superseded by In Harm's Way #36: Clinch River Plant, American Electric 

Power d/b/a Appalachian Power – Cleveland, VA 

Re-designated as a 

potential damage case

Double counted': Superseded by CCW DC Ass Case #25, K. R. Rezendes 

South Main Street Coal Ash Landfill (a Potential DC).

Re-designated as a 

potential damage case

Superseded by In Harm's Way #23: Cardinal Plant, American Electric 

Power – Brilliant, OH 

Re-designated as a 

potential damage case

Superseded by In Harm's Way #23: Cardinal Plant, American Electric 

Power – Brilliant, OH 

Re-designated as a 

potential damage case

Superseded by In Harm's Way #24: Gavin Power Plant, American Electric 

Power d/b/a Ohio Power Company – Cheshire, OH

Re-designated as a 

potential damage case

Superseded by In Harm's Way #26: Muskingum River Plant, American 

Electric Power d/b/a Ohio Power Company – Beverly, OH 

Re-designated as a 

potential damage case

Originally Rejected (EPA 2007 DC Ass. Report) due to inadequate 

information : "This site is categorized as a case without documented 

evidence of proven or potential damage to human health or the 

environment." No subsequent new information. However, reinstated as a 

potential DC based on Ohio EPA's comment to the Oct. 2011 NODA, EPAHQ-RCRA-2011-0392-0163: “At this time, there is evidence indicating the 

quality of GW beneath the J.M. Stewart Station has been impacted. 

Samples collected at the J.M. Stewart (sic) Station, well #2, between 1973 

and 1986 by Ohio EPA staff indicates a rising level of total dissolved solids, 

sulfate, calcium, iron and magnesium. Ohio EPA continues to monitor GW 

to determine if this trend continues and rises to a level where a full 

assessment is warranted.” 

Rejected: Out of Scope One of nine sites managing oil combustion wastes that have groundwater 

contamination identified for the 1999 RTC. 

Rejected: Out of Scope One of nine sites managing oil combustion wastes that have groundwater 

contamination identified for the 1999 RTC. 

Rejected: Out of Scope One of nine sites managing oil combustion wastes that have groundwater 

contamination identified for the 1999 RTC. 
Rejected: Out of 

Scope/Non-Utility coalfired boiler

CCR is from a non-utility coal-fired boiler (dry corn mill operation)

Rejected: Out of Scope One of nine sites managing oil combustion wastes that are associated with 

largest coal- and oil-powered generating station in New England. 

Rejected: CCRs 

commingled with other 

waste

"Contribution of FFC wastes to damage not separable from other wastes.” 

"“The co-managed wastes contributed metal contamination 

indistinguishable from CCRs."

Rejected: CCRs 

commingled with other 

waste

“Non-CCR wastes primarily USTs were focus of MADEP remediation." 

Rejected: CCRs 

commingled with other 

(coal mining) waste

”CCR is managed alongside mining wastes on the site, and the studies 

presented do not specifically implicate CCRs as a cause for contamination. 

The onsite water sample from a “well” in the CCR disposal area which had 

arsenic above the primary EPA MCL and boron above the EPA Child Health 

Advisory is arguably not a groundwater sample, but more representative of 

an ash pore water sample.”

Rejected: Out of 

Scope/Minefilling

Landfill located in a mined out lignite pit.

Rejected: CCRs 

commingled with other 

waste; also, CCR from 

industrial boilers.

”Although there are numerous exceedances of primary and secondary EPA 

MCLs in both onsite and offsite groundwater, high incidences of cancer in 

the surrounding neighborhoods, and several regulatory actions, there are 

no explicit indications that CCRs are solely responsible for the damages. 

Large quantities of other non-CCR wastes have been co-managed at the 

landfill since the 1960s. In addition, the source of the coal ash was from 

industrial boilers in the Akron/Canton area.

Rejected: Inadequate 

information

Inadequate Information to uphold it as a damage case: ”Groundwater 

exceedances of primary and secondary EPA MCLs have been found onsite 

but at distance and upgradient from CCR materials. There is inadequate 

information to determine whether exceedances are site- related, from 

offsite sources, or from on-site but non-CCR sources. There has not been 

any assessment of groundwater or surface water offsite and there are no 

other impact or damage claims.” 

Current 

Designation/Rationale

Comments
Rejected: CCRs 

commingled with other 

waste

”Although there are exceedances of primary EPA MCLs, EPA Lifetime 

Health Advisories, and EPA SMCLs in onsite groundwater, the exceedances 

generally occur near the brine ponds and are possibly related to the water 

softening and treatment process: CCRs cannot be directly implicated as a 

source of the contamination.” 

Rejected: CCRs 

commingled with other 

(coal mining) waste

Landfill in an abandoned coal mine.

Rejected: CCRs 

commingled with other 

waste

“Co-Managed CCR wastes without clear implication of CCR wastes in 

damages.”

Rejected: CCRs 

commingled with other 

(coal mining) waste

”The site is reported to co-manage CCR and unspecified “coal mining 

wastes”; therefore the claim does not specifically implicate CCRs as a cause 

of damage to human health or the environment.” 

Rejected: Out of 

Scope/Minefilling

"An underground mine that disposes of coal processing waste and coal 

combustion waste in a diked surface lagoon...insufficient information to 

identify the extent of the contamination or confirm the source of the 

contamination."

Rejected: Out of Scope "The fly ash disposed at the site is emission control dust from an electric 

arc furnace, not fossil fuel combustion waste." No subsequent new 

information.

Rejected: Out of Scope CCR commingled with non-CCRs; from a non-utility source. A rail-to-trail 

project, railroad right-of-way soils ('Beneficial Use'). Coal ash and clinkers 

from train engine boilers used for ballast for railroad tracks bed. 

Rejected: Inadequate 

information to 

determine source of 

metal contaminants 

"well screens are within soils derived from weathering of the Waresville 

Schist which contains abundant nickel, chromium and cobalt." Georgia 

Power challenges allegations because: (i) "TCLP leaching concentrations 

from gypsum are lower than those in GW"; (ii) The settling pond and 

gypsum stacks are lined; and (iii) "Naturally occurring soils are one possible 

source of the metals. 

Rejected: Inadequate 

information to 

determine source of 

metal contaminants

The Utility claims that the high As, Fl, and Mn levels are naturally occurring 

due to the unique geology of the area; the author of the report states that 

upgradient or background monitoring would be required to confirm this 

possibility.

Rejected: Inadequate 

information

"No information available."

Rejected: Inadequate 

information

"No information available."
Rejected: Inadequate 

information

"There is insufficient information available to identify the extent of ground 

water contamination, or to positively identify the source of the 

contamination."

Rejected: Inadequate 

information; lack of 

verification by state 

regulator

"Ohio EPA staff are unaware of any issues related to this pond." No 

subsequent new information.

Rejected: Inadequate 

information

"There is insufficient information available to identify the extent and 

nature of damages present and attribute them to fossil fuel combustion 

wastes."

Rejected: Inadequate 

information

"There is insufficient information available to identify the extent and 

nature of damages present and attribute them to fossil fuel combustion 

wastes."

Rejected: Inadequate 

information

"There is insufficient information available to identify the extent and 

nature of damages present and attribute them to fossil fuel combustion 

wastes." No new information.

Rejected: No 

Information

No Information.

Current 

Designation/Rationale

Comments