20150042 Ver 1_Arlene Jackson (3)_20150516

Burdette, Jennifer a
From:
Arlene <alicearlene @yahoo.com>
Sent:
Saturday, May 16, 2015 1:03 PM
To:
Burdette, Jennifer a
Subject:
Favorites
Attachments:
ClosingThe Floodgates- Fina1.pdf
Dear DENR,
Please read this carefully. There are other ways to deal with coal ash instead of dumping it in the ground. It can be made safe and will
only cost power companies one percent of their profit and ratepayers could see as little as $7 -$8 dollars a year added to their bill.
Tell Duke Energy to figure out a way to implement these practices in our state in order to keep people safe.
Arlene Jackson
5057 Cox Mill Road
Sanford, NC. 27332
919- 258 -9393
http: / /action.sierraclub.org/ site /DocServer /ClosingTheFloodgates- Final.pdf
Sent from my iPad

dog.. w.,.a.rnox (�ERRiMNSiICf

TABLE OF CONTENTS
EXECUTIVE SUMMARY ....................... ............................... 1
PART ONE
YEARS OF NEGLECT AND A CHANCE FOR CHANGE ..........................3
Introduction....................................... ............................... 3
1. The Toxic Legacy of Coal Plant Water Pollution ...... ............................... U
How Coal Plant Water Pollution Affects Us ........ ............................... U
Why Is Coal Plant Water Pollution So Toxic? ....... ............................... a
A. EPA and States Fail to Control Toxic Discharges in the Absence of Federal Standards.. g
3. Coal Plants Can Clean Up Their Water Pollution .... ............................... 10
Time to Stop Settling for Unlined "Ponds" Instead of Genuine Treatment Systems... 10
Dry Ash Handling ................................ .............................10
Best Water Treatment Technologies for Scrubber Sludge and Leachate ............. 11
Available Technologies Can Solve a National Pollution Problem ..................... 11
U. Muddying the Waters: Political Interference Puts Protections at Risk .................12
PART TWO
LIVING DOWNSTREAM. COAL WATER POLLUTION ACROSS THE COUNTRY.... 14
1. Big Plants: Big Problems ............................ .............................14
Labadie: Leaks, Seeps, and Gushing Discharges into the Missouri ...................14
Monroe: Swimming in Coal Plant Waste ............. .............................15
A. Coal Rivers: Duke Energy's Toxic Legacy in North Carolina ..........................15
3. Rivers of Waste: Watersheds In Danger ............... .............................16
The Illinois River: Prairie Stream Under Pressure ..... .............................16
The Black Warrior River: Toxic Metals in Alabama's Waterways .....................18
U. Environmental Injustice: Coal Plant Water Pollution and Inequality ...................19
Waukegan: Industrial Pollution on the Lake .......... .............................19
North Omaha & River Rouge: Vulnerable Communities and Lax Permits .............19
a. Transferring Pollutants from Air to Water .......... ...............................
ae
o. Polluting Water in the Arid West .................. ...............................
as
g. TVA's Toxic Legacy: The Ash Pond Clean -Up Problem ..............................
23
u. Coal in the Water, Coast to Coast ................. ...............................
as
Conclusion......................................... .............................aa
Endnotes........................................... .............................ao
AppendixI ......................................... .............................30
AppendixII .......................................... .............................31
AppendixIII ...................................... ...............................
Ua

ABOUT THE SPONSORING ORGANIZATIONS
TIMIIEEi IF. EIN'V'IR011. IIIN'TIEEiQIf311T1f IFpIf30,YIfiC'lr (EIP) is a nonpartisan, nonprofit
organization dedicated to the enforcement of the nation's anti - pollution laws
and the prevention of political interference with those laws. The EIP provides
objective analysis of how the failure to enforce or implement environmental
laws increases pollution and harms public health, and helps local communities
obtain the protection of environmental laws.
TIMIIEEi SIIIPEEIf3If3A CII..UIE# is the nation's oldest and largest grassroots environmental
group, with 2.1 million members and supporters. The Sierra Club's Beyond Coal
Campaign works to address the pressing public health threat from coal -fired
power plants and toward clean energy.
CILJEEiAN WATIEEilf3 ACTION is a one - million member organization of diverse
people and groups joined together to protect our environment, health,
economic well - being, and community quality of life. Its goals include clean,
safe and affordable water, prevention of health threatening pollution, creation
ACKNOWLEDGMENT
This report was primarily composed and edited by EIP Managing Attorney
Jennifer Duggan and Sierra Club Staff Attorney Craig Segall. Others con£
tributing to this report include: EIP Research Analysts Tom Lyons and Troy
Sanders, Sierra Club Associate Attorney Casey Roberts, Sierra Club Analysts
and Fellows Sherri Tang, Toba Pearlman, Maggie Wendler, Stephanie Grebas,
DATA LIMITATIONS
The information contained in this report is based on company self - reported
data obtained through publicly accessible U.S. Environmental Protection
Agency webskes and Freedom of Information Act requests. Occasionally,
government data may contain errors, either because information is inaccu£
rately reported by the regulated entities or incorrectly transcribed by govern£
ment agencies. This report is based on data retrieved prior to July 2013, and
of environmentally safe jobs and businesses, and empowerment of people
to make democracy work. Clean Water Action organizes strong grassroots
groups and coalitions and campaigns to elect environmental candidates and
solve environmental and community problems.
IEEiARTIMIJUSTIICIEEi is a non - profit public interest law organization dedicated to
protecting the magnificent places, natural resources, and wildlife of this earth,
and to defending the right of all people to a healthy environment.
WATIEE RIKlEEiIEEiIFpIEEilf3 AIL. L.IIAINCIEEi was founded in 1999 by environmental attor£
ney and activist Robert F. Kennedy Jr., and several veteran Waterkeeper
Organizations. It is a global movement of on- the -water advocates who patrol
and protect more than 100,000 miles of rivers, streams, and coastlines in
North and South America, Europe, Australia, Asia, and Africa. Waterkeeper
Organizations combine firsthand knowledge of their waterways with an un£
wavering commitment to the rights of their communities and to the rule of law.
and Hina Gupta, Clean Water Action National Water Campaigns Coordinator
Jennifer Peters, Earthjustice Coal Program Director Abigail Dillen, Waterkeeper
Alliance Staff Attorney Peter Harrison and Waterkeeper Alliance Global Coal
Campaign Coordinator Donna Lisenby.
subsequent data retrievals may differ slightly as some companies correct prior
reports.
We are committed to ensuring that the data we present are as accurate as
possible. We will correct any errors that are verifiable.
QUESTIONS AND COMMENTS can be directed to Jennifer Duggan at
jduggan @environmentalintegrity.org

EXECUTIVE SUMMARY
Coal -fired power plants are the largest source of toxic
water pollution in the United States based on toxicity,
dumping billions of pounds of pollution into America's
rivers, lakes, and streams each year.' The waste from
coal plants, also known as coal combustion waste,
includes coal ash and sludge from pollution controls
called "scrubbers" that are notorious for contaminat£
ing ground and surface waters with toxic heavy metals
and other pollutants.2 These pollutants, including lead
and mercury, can be dangerous to humans and wreak
havoc in our watersheds even in very small amounts.
The toxic metals in this waste do not degrade over
time and many bio- accumulate, increasing in concen£
tration as they travel up the food chain, ultimately col£
lecting in our bodies, and the bodies of our children.
Existing national standards meant to control coal plant
water pollution are thirty -one years old and fail to set
any limits on many dangerous pollutants. Only now
has the U.S. Environmental Protection Agency (EPA)
proposed to update these outdated standards, in order
to curb discharges of arsenic, boron, cadmium, lead,
mercury, selenium, and other heavy metals from coal
plants. Although the Clean Water Act requires the EPA
and states to set pollution limits for power plants in the
absence of federal standard S,3 states have routinely al£
lowed unlimited discharges of this dangerous pollution.
Our review of 386 coal -fired power plants across the
country demonstrates that the Clean Water Act has
been almost universally ignored by power companies
and permitting agencies. Our survey is based on the
EPA's Enforcement and Compliance History Online
(ECHO) database and our review of discharge per£
mits for coal -fired power plants. For each plant, we
reviewed permit and monitoring requirements for arse£
nic, boron, cadmium, lead, mercury, and selenium; the
health of the receiving water; and the permit's expira£
tion date. Our analysis reveals that:
# Nearly 70 percent of the coal plants that discharge
coal ash and scrubber wastewater are allowed to
dump unlimited amounts of arsenic, boron, cad£
mium, mercury, and selenium into public waters, in
violation of the Clean Water Act.
Closing the Floodgates
�%i % ii
o.
/ /i / /,/ ,,,,, %//
Only about 63 percent of these coal plants are re£
quired to monitor and report discharges of arsenic,
boron, cadmium, mercury, and selenium.
Only about 17% of the permits for the 71 coal plants
discharging into waters impaired for arsenic, boron,
cadmium, lead, mercury, or selenium contained a
limit for the pollutant responsible for degrading
water quality.
Nearly half of the plants surveyed are discharging
toxic pollution with an expired Clean Water Act
permit. Fifty -three power plants are operating with
permits that expired five or more years ago.
In short, coal plants have used our rivers, lakes, and
streams as their own private waste dumps for decades.
These dangerous discharges have serious consequenc£
es for communities that live near coal -fired power
plants and their dumps across the United States.
Tens of thousands of miles of rivers are degraded by
this pollution .4 The EPA has identified more than 250
individual instances where coal plants have harmed
ground or surface waters.5 Because many coal power
plants sit on recreational lakes and reservoirs, or up£
stream of drinking water supplies, those thousands of
miles of poisoned waters have an impact on people
across the country. Coal water pollution raises cancer
risks, makes fish unsafe to eat, and can inflict lasting
brain damage on our children.6
Americans do not need to live with these dangerous
discharges. Wastewater treatment technologies that
drastically reduce, and even eliminate, discharges of
toxic pollution are widely available, and are already
in use at some power plants in the United States.'
According to the EPA, coal plants can eliminate coal
ash wastewater entirely by moving to dry ash handling
techniques.' Scrubber discharges can also be treated
with common sense technologies such as chemical
precipitation, biological treatment, and vapor com£
pression to reduce or eliminate millions of tons of toxic
pollution.'
The EPA's recent proposal to set long overdue stan£
cards contains multiple options, including strong

standards that would require the elimination of the
majority of coal plant water pollution using technolo£
gies that are available and cost - effective. The strongest
of these options, called "Option 5" in the proposal,
would eliminate almost all toxic discharges, reducing
pollution by more than 5 billion pounds a year, and
should be the option EPA selects for the final rule. The
next strongest option, called Option 4, would elimi£
nate ash - contaminated discharges, and apply rigorous
treatment requirements for scrubber sludge, however
it would only reduce pollution by 3.3 billion pounds a
year, 2 billion less than Option S. By eliminating or sig£
nificantly reducing toxic discharges from coal plants, a
strong final rule would create hundreds of millions of
dollars in benefits every year in the form of improved
health and recreational opportunities for all Americans,
in addition to the incalculable benefits of clean and
healthy watersheds.10 The EPA estimates that ending
toxic dumping from coal plants would cost less than
one percent of annual revenue for most coal plants
and at most about two pennies a day in expenses for
ordinary Americans if the utilities passed some of the
cleanup costs to consumers."
Unfortunately, the proposal also includes illegal and
weak options inserted by political operatives, rather
than EPA scientists. These options would preserve the
status quo or do little to control dangerous pollution
dumping. Weak options are a giveaway to polluters
and Americans deserve better. It is time for the EPA
to set strong, national standards to end decades of
toxic water pollution, and protect public health and our
waters.
2 Closing the Floodgates

PART ONE
IIE;;;;' A II IIF : : :' 114IIE;;;;' ° III,,,J11;;;;' "'I" A11411D
All across the United States, millions of gallons per
day of water pollution± laced with toxic pollutants
including arsenic, mercury, selenium, and lead± gush
from coal -fired power plants into our rivers, lakes, and
streams. Pollution flows from the aging, leaky "ponds"
that many plants use to store their toxic slurries of coal
ash and smokestack scrubber sludge. Toxic chemicals
also seep from unlined ponds and dry waste landfills
into ground and surface waters, leaving behind a per£
sistent lethal legacy. All in all, at least 5.5 billion pounds
of water pollution is released into the environment by
coal power plants every year, and a significant portion
of that pollution is made up of toxic chemicals.12
These power plants are the largest source of toxic
water pollution in the United States, dumping more
toxics into our waters than the other top nine polluting
industries combined.13 This harmful pollution, includ£
ing nearly 80,000 pounds per year of arsenic alone,14
makes its way into waterbodies across the country,
into fish and other aquatic life± and into our bodies,
though fish and water consumption, swimming, boat£
ing, and other activities.15 Thousands of miles of rivers
and streams are already harmed by this pollution, and
every year the problem gets worse.
This report, an independent review of hundreds of coal
plant wastewater permits, shows that nearly 70 per£
cent of power plant permits set no effluent limits on
how much arsenic, boron, cadmium, lead, mercury, and
selenium these plants can discharge.16 Indeed, many
permits do not even require monitoring, so regulators,
and the public, do not know for certain what poisons
are finding their way into the water. Our review focused
on these pollutants because they are almost always
found in coal ash and scrubber waste and are particu£
larly harmful to health or aquatic life.
The Clean Water Act, when it became law, established
a national goal of ending all water pollution by 1985.11
Nearly three decades later, the largest industrial source
of toxic water pollution continues to foul our waters
essentially unchecked because it is only regulated by
o. �%i % ii
minimal standards that were established in 1982. An
update is long overdue. Existing rules contain essen£
tially no limits on the amounts of toxic pollutants± in£
cluding arsenic, mercury, selenium, and lead± that coal
plants can dump into our water.18 The EPA itself admits
that these standards "do not adequately address the
toxic pollutants discharged from the electric power
industry.119
Based on toxicity, these power plants are the largest
source of toxic water pollution in the United States,
dumping more toxics into our waters than the other
top nine polluting industries combined. Many plants
have nothing more than rudimentary "settling" ponds,
which do almost nothing to remove the dissolved
heavy metals that make coal water pollution poisonous
and dangerous .20
Decades of unchecked pollution have put our wa£
terways, our environment, and our health at risk. But
now there is an opportunity to change all that. After
years of work by research scientists and engineers± as
well as determined advocacy by citizens across the
country± the EPA has finally proposed to update its
outdated standards. The EPA's proposal lays out a
menu of options that vary significantly in the amount
of pollution they would control. Some of those options
are inexcusably and illegally weak. But the strongest
options± Option 5, which sets "zero discharge" stan£
cards that would require plants to clean up almost
entirely and Option 4, which eliminates most dis£
charges and requires comprehensive treatment for the
remainder± would cost - effectively move the fleet of
coal power plants toward zero discharge of pollutants,
protecting our public health and our environment.
In addition to the incalculable benefits of thousands of
miles of cleaner rivers and streams that would result
from removing these discharges of toxic metals, the
rule would also create thousands of jobs and hundreds
of millions of dollars in monetary benefits every year in
the form of improved health and recreational oppor£
tunities across the United States .21 The coal industry,
which has long imposed the costs of its pollution on
all of us, can readily absorb the relatively modest cost
Closing the Floodgates 3

of cleaning up its pollution, rather than freely dumping
it into rivers. The common -sense treatments required
by the EPA's proposed rules are remarkably afford£
able, amounting to substantially less than one percent
of revenue for almost all coal plants, and no more than
two pennies a day in expenses for ordinary Americans,
if utilities passed costs onto consumers in their elec£
tricity bills.22 In exchange for two cents a day, we could
end most toxic water pollution in this country.
The EPA must finalize a zero discharge rule and put us
on a path to solving one of our most widespread and
harmful pollution problems. It is time to move forward
and protect public health and environment.
The 5.5 billion pounds of water pollution from coal
power plants every year include at least 1.79 billion
pounds of metals, including arsenic, selenium, cadmi£
um, chromium, and mercury.23 These toxics are hazard£
ous to humans or aquatic life in very small doses (mea£
sured in parts per billion) because they do not degrade
over time and bio- accumulate, meaning they increase
in concentration as they are passed up the food chain.
Much of the remaining pollution consists of "nutrients"
such as nitrogen and phosphorus, which contribute to
thick, soupy algal blooms that can choke watersheds,
such as the Chesapeake Bay.24
This dumping occurs in astonishing volumes. The EPA
estimates that, each year, up to 14.5 billion gallons of fly
ash transport water and up to 6.6 billion gallons of bot£
tom ash transport water may be produced at just one
power plant and dumped into ash pond S.21 Making wa£
ter pollution worse, many plants either have installed,
or will soon install, smokestack "scrubbers "± aka£
tems that can prevent toxic metals from going up the
smokestack into the air. The problem is that scrubbers
often concentrate the metals they remove into a wet,
toxic, sludge that generally does not undergo any
effective treatment.26 Thanks to stricter air pollution
rules, scrubber use has increased by 900 percent since
1982.21 Yet, there are no standards to ensure protective
wastewater treatment of the scrubber sludge, and so
this especially toxic new wastewater stream is ending
up in settling ponds where it then makes its way into
rivers, streams, and lakes.
And that's not all: Toxic pollution also occurs when
leachate systems for landfills and ash impoundments
discharge untreated or inadequately treated waste£
waters .211 In some cases, coal ash landfills or ponds
cover hundreds of acres, fill in local wetlands, and turn
streams into drainage ditches for waste that either leak
or discharge from these site S.29 Many of these waste
dumps or ponds have no liners to prevent pollution
from leaking out of them."
According to the EPA, tens of thousands of miles of
rivers are degraded by this pollution.31 The EPA has
already identified 132 separate cases where a power
plant contaminated surface waters and another 123
cases where groundwater was damaged. With respect
to arsenic, boron, cadmium, iron, lead, manganese,
nickel, selenium, and thallium, the 290 coal plants
surveyed by EPA put as much of a burden on the
environment as thousands of sewage plants.
In addition to those listed opposite, the EPA has identi£
fied many other dangerous substances in coal plant
wastewater, including chromium, molybdenum, and
thaIIium.64 In almost every instance, coal plants are
the largest source of each of these water pollutants
nationally.
The EPA calculates that the annual pollution from coal
power plants translates into more than eight million
TWPE or toxic weighted pound equivalents, indicat£
ing a huge toxic burden on the nation's waters.65 That
figure dwarfs the pollution from any other industrial
category in the United States and is more than the
other top nine polluting industries combined± more
than all the paper mills in the country, more than all the
refineries, more than all the chemical plants and fertil£
izer facilities and ore mills and incinerators.66 The waste
is also far more toxic than any discharge from a typical
publicly -owned treatment works, the sort of sewage
plant that serves cities and towns. Scrubber waste
alone contains 80 times more selenium than a typical
sewage plant's waste.61 With respect to toxic pollution,
the 290 coal plants surveyed by EPA put as much of
a burden on the environment as thousands of sewage
plants.6' With hundreds of coal power plants across
the country, it is no surprise that coal plant pollution
poses such a serious threat to our waterways.
IHOW COAII... IPII...AIN"ll" WA'11 "IEIR IP011...II...U11 "110IN AIFIFIEC"11"S U
Coal power plants can use millions of gallons of water
every day, so most power plants sit on or near a water
body. This means that coal plants discharge into hun£
dreds of rivers, lakes, and streams all across the United
States. These waters are often popular recreational
spots for boating, swimming, and fishing and are drink£
ing water sources for nearby communities. Fishing
provides an inexpensive, reliable, and healthy food
source, but when fish are contaminated, communities
that depend on fishing are far more vulnerable than
the general population.
There is no question that harm to fish and other
wildlife from coal waste discharges is widespread and
4 Closing the Floodgates

Although coal waste streams contain a varying mix£
ture of pollution, all of them are toxic. Below are sum£
maries of some of the most dangerous poisons they
contain.
ARSENIC
Arsenic is a potent poison. Power plants32 discharge
at least 79,200 pounds of arsenic every year -which
the EPA calculates to be 320,000 "toxic weighted
pound equivalents" (TWPE), the normalized unit that
EPA uses to compare the relative toxic effects of dif£
ferent pollutants.33 According to the EPA, arsenic is
"frequently observed at elevated concentrations" near
coal waste sites, where it has been found in ground£
water, and can also build up, or "bio- accumulate," in
ecosystems affected by these discharges .34 According
to the Agency for Toxic Substances Control and
Disease Registry (ATSDR), arsenic in drinking water
is linked to miscarriages, stillbirths, and infants with
low birth weights .35 Arsenic can also cause cancer,
including skin tumors and internal organ tumors '36 and
is also connected to heart problems, nervous system
disorders, and intense stomach pain .37
MERCURY
As the EPA explains, even though mercury concentra£
tions in coal plant waste can be relatively low, "mer£
cury is a highly toxic compound that represents an
environmental and human health risk even in small
concentrations," and the conditions at the bottom
of coal waste pools are particularly likely to convert
mercury into its most toxic form S.31 Mercury is a bio -
accumulating poison that impairs brain development
in children and causes nervous system and kidney
damage in adults.39 A fraction of a tea -spoon of mer£
cury can contaminate a 25 -acre lake '41 and coal plants
dump 2,820 pounds± or 330,000 TWPE± into our
water every year .41 Mercury also accumulates in fish,
making them unsafe to eat.42
SELENIUM
Coal power plants discharge 225,000 pounds of se£
lenium each year '43 resulting in severe environmental
harm .44 High levels of selenium can kill people, and
lower levels can cause nervous system problems, brit£
tle hair, and deformed naiIS.45 Selenium may take its
most serious toll in our rivers and streams, where it is
acutely poisonous to fish and other aquatic life in even
small doses. Concentrations below 3 micrograms per
liter can kill fish '46 and lower concentrations can leave
fish deformed or sterile .47 Selenium also bio- accumu£
lates and interferes with fish reproduction, meaning
that it can permanently destroy wildlife populations in
lakes and rivers as it works its way through the eco£
system over a period of years .41
LEAD
Lead is a highly toxic poison that can cause severe
brain damage, especially in children.49 Coal plants
dump 64,400 pounds of lead into the water each
year.50 Although the EPA reports that much of this
lead settles out fairly quickly, if it winds up passing
into river sediment, it will persist. Once lead enters the
river ecosystem, it can enter the food chain and bio -
accumulate, leading to serious harm to wildlife, as well
as threatening people.51
CADMIUM
Cadmium is yet another bio- accumulating heavy
meta 1.52 Power plants send 31,900 pounds each year
into our water, or 738,000 TWPE, due to cadmium's
high toxicity.53 ATSDR warns that drinking water with
elevated cadmium levels can cause kidney damage,
fragile bones, vomiting and diarrhea± and sometimes
death .54 Cadmium also likely causes cancer.55 Fish ex£
posed to excess cadmium become deformed.56
BORON
Boron is rare in unpolluted water, meaning that even
very small concentrations can be toxic to wildlife not
usually exposed to this pollutant.57 Coal plants dis£
charge more than 54 million pounds of boron annually,
converting a rare contaminant into a common -place
pollutant downstream of their discharge points.58
Boron's effect on people is unclear, but some studies
suggest that it can cause nausea, vomiting, and diar£
rhea, even at low concentrations.59
BROMIDES
Coal plant waste contains bromide salts, which are
very hard to remove short of evaporating wastewater
to crystallize out these pollutants.60 Bromides interact
with disinfectant processes in water treatment plants
to form disinfection byproducts, including a class of
chemicals called trihalomethanes, which are associ£
ated with bladder cancer.61
NITROGEN AND PHOSPHORUS
These nutrients are important in small quantities, but
can readily overpower ecosystems in larger quantities,
converting clear waters into algae- choked sumps.62
Because coal plants dump more than 30 million
pounds of nitrogen and 682,000 pounds of phos£
phorus annually, they are a substantial contributor to
harmful nutrient loadings in the Chesapeake Bay and
other watershed S.63

serious. Scientists have documented coal pollutants,
such as selenium and arsenic, building up to "very high
concentrations" in fish and wildlife exposed to coal
waste discharges, and that those accumulating toxics
can ultimately deform or kill animals.69
The more than 250 documented incidents of dam£
age to water resources from coal plant pollution have
resulted in lasting environmental harm.70 One survey
Even in large lakes, coal plant pollution persists and ac£
cumulates. Researchers have discovered that arsenic,
in particular, accumulates in the sediments on lake bot£
toms, and then erupts from sediments as water warms
and stratifies in the summer, emerging back into the
lake during the same summer days when many people
are likely to be out fishing and swimming.83
These are just some of the reported incidents of
focusing on reported fish and wildlife damage caused damage from coal plant pollution. As the EPA has
by coal waste discharges alone shows at least 22 such
incidents over the last few decades, causing damage
of more than $2.3 billion." Incredibly, 12 of the 22 cases
were caused by permitted discharges, further showing
the need for strong updated national standard S.72
The same alarming story repeats itself again and
again. In North Carolina, Belews Lake, a popular fishing
and recreation spot, was contaminated by just over
a decade of coal waste dumping. Just ten years of
discharges was enough to eliminate 18 of the 20 fish
species in the lake, and to leave dangerous levels of
contamination in fish and birds more than ten years
later .73 In Hyco Reservoir, also in North Carolina, coal
plant dumping led to an $864 million fish kill that left
selenium levels in blue gill 1,000 times greater than or£
dinary water concentrations.74 In Texas, at Martin Creek
Reservoir, a coal plant discharged wastewater for just
eight months; within two years, 90 percent of plank£
ton - eating fish in the lake had died, and largemouth
bass and bluegill could no longer reproduce .75 Even a
few years later, fish in the lake were riddled with dead
or dying tissue in their internal organs .71 Poisoned fish
turned up in the Welsh Reservoir in Texas, too, forc£
ing the state to warn against consuming fish from the
(tb f .77 Texas's Brandy Branch Reservoir was placed
under the same advisory once it started receiving ash
pond discharges .78
A recent survey of waters affected by nine power
plants, based on intensive water sampling in North
Carolina, found contamination all across the state .79
One sampling showed concentrations of arsenic in
discharges from two of the plants at levels four to nine
times greater than the EPA's drinking water stan£
cards. Discharges from other plants showed selenium
concentrations up to 17 times greater than the EPA's
recommended chronic exposure level for aquatic life.80
Discharges from these plants also exceeded human
and aquatic life standards for antimony, cadmium, and
thallium.81 The lakes and rivers receiving this waste,
predictably, showed elevated levels of toxics, includ£
ing arsenic and selenium, even though they are large
bodies of water. Fish in at least one of the lakes are
deformed in ways that indicate selenium poisoning .12
documented, the scope of this pollution is staggering.
According to the EPA, two - thirds of the waterways re£
ceiving coal plant waste have reduced water quality as
a direct result of that pollution .14 Nearly half of those
waterways (49 percent) have water quality worse
than the EPA's National Recommended Water Quality
Criteria, and a fifth of them violate standards for drink£
ing water.85 Standards for arsenic, selenium, cadmium,
and thallium are the most frequently violated. For
instance, 147 out of the 297 waterbodies receiving coal
waste exceed human health water quality standards
for arsenic.86 Seventy -eight power plants discharge
directly into a water body that has been formally listed
as having water quality impaired by a pollutant in coal
waste (with mercury being the most common pollut£
ant of concern) .17
The EPA estimates that 11,200 miles of rivers exceed
recommended water quality levels for human health
as a result of coal plant water pollution. Nearly 24,000
miles of river exceed recommended water quality
levels for recreation.88 In many of these waterways, fish
are not safe to eat. Mercury in fish poses a threat to
people fishing for food in nearly two - thirds of receiv£
ing waters, and 38 percent of those waters have formal
fish advisories.89
Drinking water is affected too. The EPA reports that
almost 40 percent of plants discharge within five miles
of a public water intake, and 85 percent of plants dis£
charge within five miles of a public well.90
Human health impacts from this pollution are serious.
The EPA estimates, for instance, that nearly 140,000
people per year experience increased cancer risk due
to arsenic in fish from coal plants; that nearly 13,000
children under the age of seven each year have re£
duced IQs because of lead in fish they eat, and that
almost 2,000 children are born with lower IQs because
of mercury in fish their mothers have eaten.91
This nationwide poisoning of our rivers is particularly
unjust for communities that depend heavily on fish for
food. According to the National Environmental Justice
Advisory Council, families in many communities of
color, including those of African - American and Native
6 Closing the Floodgates

peoples, rely on fishing to supply basic nutritional
need S.92 As the Council wrote, "[p]ut simply, communi£
ties of color, low- income communities, tribes, and other
indigenous peoples depend on healthy aquatic ecosys£
tems and the fish, aquatic plants, and wildlife that these
ecosystems support:193 Fishing provides an inexpen£
sive, reliable, and healthful food source, but when fish
are contaminated, reliance on fishing for food makes
communities far more vulnerable to water pollution and
contaminated fish than the general population.
Nutrient pollution is also a serious problem, contribut£
ing to algal blooms and other ecological imbalances
across the country. For example, power plants dis£
charge approximately 2.2 million pounds per year of
nitrogen to the Chesapeake Bay - 30% of the total
nitrogen load from NPDES permitted sources discharg-
ing industrial wastewaters in that struggling watershed,
which is among the most ecologically and economi£
cally important estuaries in the country. 94
In sum, from coast to coast, and in rivers, lakes, and
streams all across the country, coal plant water pollu£
tion accumulates, poisoning waters, fouling sediment,
and contributing to large -scale ecological disruption
across tens of thousands of miles of waterways± near£
ly three decades after the Clean Water Act's target
date to eliminate water pollution."
New national standards are urgently needed in large
part because EPA and the states have almost entirely
failed to control toxic metal pollution from coal power
plants. Where the EPA fails to set strong national
discharge standards for polluters (as is the case here),
state permitting agencies are required by the Clean
Water Act to set limits in discharge permits for indi£
vidual plants that reflect the best available treatment
technology and protect water quality.96 And technolo£
gies are available to significantly reduce and even
eliminate toxic discharges from power plants .97 Yet our
review of 386 coal -fired power plants indicates that
this law has been almost universally ignored by elec£
tric utilities and the permitting agencies that issue and
enforce Clean Water Act discharge permits.
Our survey is based on the EPA's Enforcement and
Compliance History Online (ECHO) database, which
includes permitting information for coal power plants
across the country, and our review of discharge per£
mits. For each plant surveyed, we recorded whether
the permit contained limits or monitoring requirements
for six representative toxic metals (arsenic, boron, cad£
mium, lead, mercury, and selenium); whether the plant
listed ash or scrubber waste among its discharges;
whether the plant discharges into a waterway impaired
for one or more of the six representative toxic metals;
and whether the plant's permit was expired.98 At least
274 of the 386 coal plants discharge coal ash and /or
scrubber wastewater. See Appendices 1 -III for the com£
plete results of our analysis. Our analysis shows that
EPA and states have routinely turned a blind eye to
these dangerous discharges while power plants have
used our nation's waters as their own private dumping
grounds.
The majority of the 274 coal plants (out of 386
reviewed) that report discharging coal ash or scrubs
ber wastewater are not required to limit toxic metal
discharges.99 Of the 274 power plants in this review
that discharge coal ash or scrubber wastewater, only
86 had at least one limit on arsenic, boron, cadmium,
lead, mercury, and selenium discharges.100 In other
words, the permits for 69 percent of the plants allowed
unlimited discharges of these pollutants in violation of
the Clean Water Act.
Sites without a limit for at least
188
one of the metals below
Arsenic
255
Boron
267
Cadmium
263
Lead
251
Mercury
235
Selenium
232
Moreover, permit limits vary by stringency and by com£
pleteness. Very few, if any, plants have protective limits
for all relevant metals; most have limits for only a sub£
set of these poisons. For example, far more plants have
limits for selenium than they do for arsenic, cadmium,
boron, or lead.
No state consistently issues comprehensive toxic
metals limits for all plants discharging ash or scrubs
ber waste in its jurisdiction. State permitting practices
are inconsistent, and do not afford citizens a predict£
able or complete level of protection for all dangerous
pollutants in coal waste water.
Approximately 63 percent of the power plants with
coal ash and scrubber discharges surveyed are
required to monitor and report discharge concena
trations of toxic pollution. Monitoring and reporting
requirements are critical because without monitoring
data, the EPA and state agencies and downstream
communities have no way of knowing the actual
Closing the Floodgates 7

AL
9
5
5
0
0
0
1
0
AR
4
0
0
0
0
0
0
0
CO
3
2
0
0
1
1
0
2
DE
1
0
0
0
0
0
0
0
F L
7
7
3
0
2
5
4
4
GA
8
0
0
0
0
0
0
0
IA
15
1
0
0
0
1
0
0
IL
18
5
0
5
0
0
0
0
I14102
16
3
0
0
1
1
2
1
KS
5
0
0
0
0
0
0
0
KY
20
0
0
0
0
0
0
0
LA
4
3
0
0
0
3
0
0
MA
3
0
0
0
0
0
0
0
MID
6
0
0
0
0
0
0
0
MI
16
7
0
0
0
0
7
1
MIN
5
2
0
0
0
0
2
0
MO
15
1
0
0
0
0
0
1
M S
3
0
0
0
0
0
0
0
MT
2
0
0
0
0
0
0
0
INC
10
5
1
1
2
2
2
2
N D
6
0
0
0
0
0
0
0
NE
5
0
0
0
0
0
0
0
NH
1
0
0
0
0
0
0
0
NJ
2
0
0
0
0
0
0
0
NM
1
0
0
0
0
0
0
0
NY
3
3
2
0
2
3
3
2
OH
18
10
0
0
0
0
8
3
OK
4
0
0
0
0
0
0
0
PA
12
8
0
1
2
6
5
7
Sc
10
3
3
0
0
0
1
2
TIN
8
1
1
0
0
0
0
1
TX
13
12
1
0
1
1
1
12
VA
7
0
0
0
0
0
0
0
W I
7
3
0
0
0
0
3
0
W V
5
4
3
0
0
0
0
3
WY
3
1
0
0
0
0
0
1
Closing the Floodgates

amount of toxics discharged into a watershed. Yet only
172 of the 274 plants were required to monitor for at
least one of the metals analyzed in this report.
rt!• t
Arsenic
97
Boron
45
Cadmium
78
Lead
81
Mercury
126
Selenium
102
Monitoring requirements vary: Although some plants
are required to monitor for several toxic pollutants,
consistent and careful monitoring for all relevant pol£
lutants is a rarity. In other words, not only do many
permits lack limits on the quantity of toxic metals
being discharged, they fail even to require monitoring
of exactly what and how much is discharged into our
water, leaving communities in the dark.
Power plants discharge toxics into impaired waters
without limits. Under the Clean Water Act, states
must assess whether waters are "impaired" (U. not
meeting water quality standards) and create plans to
clean them up. The EPA estimates that 25 percent of
surface waters that receive power plant discharges
are impaired for a pollutant that is discharged by the
plan t.103 And "38 percent of surface waters are under
a fish advisory for a pollutant associated with [power
plant wastewater] :i104 Where discharges could cause or
contribute to an exceedance of water quality stan£
Cards in the receiving waters, states are required to set
pollution limits to prevent the exceedance.105 The EPA
has identified at least 78 plants discharging into waters
impaired by coal waste pollutants.106 Our review of 71
such power plants discharging to waters impaired for
arsenic, boron, cadmium, lead, mercury, or selenium
found that only twelve, or approximately 17 %, had
limits for at least one of the pollutants responsible for
causing the impairment. It is likely that even more wa£
ters are impaired by these discharges than this survey
reflects because most states do not regularly assess all
waters, and the EPA ECHO database did not always list
the cause of impairment.
The chart below identifies those plants discharging
into waters impaired by arsenic, boron, cadmium,
lead, or mercury that have at least one limit for the six
pollutants. In some cases, the plant's permit restricts
discharges of one pollutant, but allows unlimited dis£
charges of the pollutant damaging water quality. For
Closing the Floodgates
example, the permit for the Bay Shore plant in Ohio
limits discharges of mercury, but the receiving water is
impaired for arsenic.
71 POWER PLANTS
Limits for at least one of the metals below
18
Arsenic
3
Boron
2
Cadmium
3
Lead
5
Mercury
11
Selenium
8
Appendix III identifies power plants
discharging into
impaired waters.
Power plant permits are not regularly reviewed and
strengthened as required by law. The Clean Water Act
only allows discharge permits to be issued for a period
of five years.101 At the end of the five -year period, the
discharger must submit a new application and obtain
approval from the permitting agency. This requirement
is meant to ensure that effluent limits are regularly
reviewed to account for new advances in wastewater
treatment technologies. In addition, certain plants may
also need to meet more stringent limits if they are
polluting waters that are not meeting water quality
standards. However, the reality is that many discharge
permits for power plants are "administratively" ex£
tended, which means the plant continues to discharge
under the old permit for years and sometimes even
decades. Our review identified 187 (out of 382108) coal
plants operating with expired permits as of March 13,
2013.
Of the 187 plants with expired permits as of March 13,
2013, 144 are for permits that discharge coal ash and/
or scrubber wastewater. Only 41 of these plants have
at least one limit on arsenic, boron, cadmium, mercury,
or selenium discharges; 72 percent contain no limits on
these pollutants. Only 75 plants, or about 52 percent,
are required to monitor and report toxic discharges of
these pollutants.

Selenium 35 16
A significant number of coal plants are operating
with permits that expired five or more years ago.
Specifically, fifty -three permits expired on March 13,
2008 or earlier. Of these fifty -three plants, forty -three
discharge coal ash and /or scrubber wastewater. Only
six of these plants had a limit for one of the six metals;
86 percent had no limits on these pollutants. Thirteen
plants were required to monitor and report concentra£
tions of discharges of at least one of the metals.
The administrative extension of these expired permits
has serious consequences for public health and the
environment. The failure to timely renew permits for
power plants means that plants do not keep up with
advances in wastewater treatment technologies to
reduce toxic discharges. In addition, this practice effec£
tively prohibits the public from weighing in on permits
that affect their communities and watersheds± a right
that the Clean Water Act guarantees.
The bottom line is that, in the absence of a binding
federal backstop, EPA and the states are failing to
protect the public from the toxic threat posed by coal
plant water pollution; plants across the country have
been allowed to pollute without limit.
We do not have to live with dangerous pollutants in
our water. Coal plant operators have no excuse for
using rivers and streams as waste dumps when the
industry can readily afford to install modern pollution
controls that will keep our waterways clean. The stron£
gest regulatory options proposed by the EPA (Options
4 and 5 in its proposed rule) would compel this long
overdue cleanup, though only Option 5 would result in
"zero discharge" of toxic pollutants.
"II "111MIE 11 "0 g "II "01P SIE "II " "II "II...IIIING FOR UUINII...IIINIEID "POINIDS"
11INS "II "IEAD OF GIEINUIIINIE "II "IRIEA "II "IMIDN "II" Y "II "IEIM
Historically, power plants have pooled their wastewater
streams into massive, often unlined, pits called settling
ponds that provide only rudimentary "treatment." As
contaminated water is allowed to sit, some solids settle
to the bottom of the ponds, but dissolved heavy met£
als and other harmful pollutants remain in the pond
waters that are eventually discharged straight into
rivers and streams.109 Meanwhile, unlined ponds allow
pollutants to leach into the water table, contaminating
groundwater and the connected surface waters.110
Further, the structural instability of many ponds is
a major hazard, as a collapse in Tennessee made
tragically clear in December of 2008.111 When the 84-
acre surface impoundment at the Tennessee Valley
Authority's Kingston Plant burst, it dumped more than
a billion gallons of coal ash slurry into the Emory River,
destroying the watershed and covering more than 300
acres of surrounding land. This spill devastated an en£
tire community, and cleanup efforts costing more than
a billion dollars have yet to fully restore the watershed
in the Emory and Clinch rivers.
In its proposed rule, the EPA provides detailed analysis
confirming that coal plants can make a shift away from
settling ponds to better, safer, pollution controls. By
transitioning to dry ash management systems and em£
ploying superior wastewater treatment technologies
such as chemical precipitation, in combination with
biological treatment or vapor compression, it is pos£
sible to reduce pollution from coal plants by millions of
tons each year, even achieving zero liquid discharge .112
IDIRY A IH IHAINIDII...IIIING
Much coal water pollution comes from using water to
clean out bottom ash and fly ash from coal plant sys£
tems. But there is no need to use good, clean water to
move this hazardous waste. Instead, simple mechanical
systems can be used to move the ash. This "dry han£
cling" technology takes plant discharges of millions or
billions of gallons per year down to zero.
Dry handling of fly ash should be required to eliminate
one of the most polluted wastewater streams at coal
plants. In "wet" management systems, fly ash from coal
combustion is transported to ash ponds using water
as a sluicing agent, but it is also possible to convey
the ash pneumatically, without water, to silos, where it
can be loaded onto trucks or rail cars for transport to
a properly constructed, lined landfi11.113 Already, 66 per£
cent of coal and petroleum coke plants employ dry ash
handling methods that eliminate all discharges '114 and
there is no reason why all plants should not employ
the best dry handling methods exclusively. The convey£
Sion is readily achievable as evidenced by the fact that
"power companies have converted at least 115 units at
10 Closing the Floodgates

more than 45 plants to dry fly ash handling systems
since 2000.115
Coal plants should also be required to install dry ash
management systems for their bottom ash, as ap£
proximately 22 percent of U.S. power plants burning
coal, coke, and oil already are doing.116 Bottom ash is
the heavier ash that collects at the bottom the boiler
and generally drops by gravity to a hopper located
below the boiler. Most of the hoppers contain water for
quenching hot ash. In many wet management sys£
tems, ash exiting the hopper is sluiced into ash ponds.
In contrast, dry systems use a drag chain to remove
bottom ash out of the boiler, dewatering the ash as it
is pulled up an incline and draining the water back into
the boiler. The bottom ash is then ready for transport
to a landfill or commercial sale as a building material.117
IBIES "If" WA "FIEIR "FIRIEA "If "IMIEIN "If" "FIECIHIN011...0GIIIES IF0R
SCIRUIBIBIEIR SII...U, IDGIE AND II...IEACAIHA "FIE
The waste from scrubber sludge and the contami£
nated liquids leaching out from dry ash dumps also
pose significant pollution problems. Those problems,
too, can be solved with demonstrated controls. These
highly- contaminated waste streams are amenable to
treatment with chemical precipitation in combination
with biological treatment systems, which can achieve
extremely high rates of pollutant removal, or in com£
bination with vapor compression evaporation, which
can achieve zero liquid discharge. These technologies
are particularly important to use for scrubber sludge,
because, as discussed above, so many coal plants are
at last installing scrubbers to address long- standing air
pollution problems.1'
CHEMICAL PRECIPITATION: At least 40 U.S. power
plants already use chemical precipitation to achieve
significantly lower effluent concentrations of metals
compared to what settling ponds can achieve. In a
chemical precipitation system, chemicals are added to
the wastewater to facilitate the settling and removal
of solids.119 However, this technology cannot effec£
tively remove selenium, boron, or bromides, which
are typically present in coal plant wastewaters in high
concentrations .121 To remove these harmful pollutants
and enhance removal of mercury and other met£
als, additional treatment is necessary after chemical
precipitation± usually biologically treatment, except
for bromides, which can only be removed by vapor
compression evaporation..
BIOLOGICAL TREATMENT: In a biological wastewater
treatment system, microorganisms are used to con£
sume organic contaminants, most notably dissolved
forms of selenium.121 These systems can and should be
used after chemical treatment to remove remaining
dangerous metal pollution. In typical systems, the bio£
reactor alters the form of selenium, reducing selenate
and selenite to elemental selenium, which becomes
enmeshed in the biomass residuals, leaving discharged
wastewaters with very low concentrations of seleni£
A .122 The conditions in the bioreactor also can facili£
tate substantial removal of mercury, arsenic, and other
metals.123 The EPA estimates that at least six power
plants in the U.S. are successfully utilizing biological
treatmen t.124
VAPOR COMPRESSION EVAPORATION: Even com£
bined biological /chemical treatment leaves some dis£
charge behind, but it is possible to eliminate scrubber
discharges completely. Successful evaporation systems
have been installed at three coal -fired power plants in
the U.S. and at four plants in Italy.125 This type of system
uses a "brine concentrator" to reduce wastewater vol£
umes and produce a concentrated wastewater stream
that can be treated in a further evaporation process.
That process then yields a solid waste product that can
be landfilled and a pollutant -free distilled water that
can be reused within the plant or safely discharged to
surface waters .126 Using vapor compression evapora£
tion, power plants can stop discharging pollutants in
scrubber sludge altogether, including bromides, which
can form dangerous disinfection byproducts when they
interact with disinfectant processes in water treatment
plants. And vapor compression evaporation is just one
of many zero discharge options available and in use at
coal plants today.
AVAIIII...A113II...IE "If"IECAIHIN011...0GIIIES CAIN S011 VIE A
INA "IFIONA11... P011...II...UU11 "1101N PIR0113II...IEIM
To the EPA's great credit, it has recognized the avail£
ability of these technologies and the importance of
using them to cost - effectively reduce, and perhaps
completely eliminate, toxic water pollution from coal
plants.
The EPA's proposed update to the 1982 standards
contains several options, two of which would go a long
way toward solving the problem. These two strongest
options, labeled Options 4 and 5 in the proposed new
rule, work to address the most toxic waste streams,
including liquids contaminated by fly ash, bottom ash,
scrubber sludge, and leachate from waste dumps.
Importantly, only Option 5 meets the Clean Water
Act's mandate to achieve zero liquid discharge, and
because it appears that Option 5 is readily achiev£
able it should be selected. Option 5 would achieve
the greatest progress toward eliminating pollutant
discharges by requiring dry handling of fly ash and
bottom ash and requiring vapor compression evapo£
ration for scrubber wastewaters, along with chemical
treatment for leachate.127 Only Option 5 would require
Closing the Floodgates 11

power plants to use vapor compression evaporation to
control for bromides, which are known to form car£
cinogenic disinfection byproducts when exposed to
disinfectant processes in drinking water plants, result£
ing in increased exposure and health risk to those
drinking that water. Overall, Option 5 would eliminate
nearly 5.3 billion pounds of pollution per year.12' Option
4 would achieve lesser but still significant pollution re£
ductions± more than 3.3 billion pound S129± ay requir£
ing dry ash handling and a combination of chemical
precipitation and biological treatment for scrubber
wastewaters .130
Bote of thesi opteDns could be achieved without put£
tin¢ any significant burden on the coal industry. The
EPA has calculated that Option 4 controls would re£
moni pollution at a cost of about $70 per Ib.; Option 5
woAO cost about $111 per lb. of po (lt@Dn.131 Thesi Eosts
trG)LA'te into far leas than one percent of annual
revenAi s for thi vast majority of coal power plants and
Bower companies; a tiny additional expense that could
i ® e)ate a huge amount of pollution .132
Costs to ratepayers are equally small: the EPA esti£
mates that Option 4 would, at most, add $3.89 to the
average power bill peryear± iAat over a penny per day
to eliminate hundreds of thousands of pounds of toxic
water pollution from our water. 133 Option 5 would add
Y0.46 to the average annual bill± a bit less than two
cents per day.
The rules would also create jobs because skilled work£
ers are needed to install and manage water pollution
controls. The EPA expects that Option 4 would create
1,253 jobs, while Option 5, which requires more work,
would create 2,112 jobs .134
The bottom line is that there is no reason Americans
should have to cope with coal plant water pollution.
Installing controls will cost companies almost nothing,
and perhaps cost ordinary Americans a few pennies
a day. Yet, in the absence of strong leadership, coal
plants have skated by for years without installing these
basic protections.
Although Options 4 and 5 would eliminate most
toxic water pollution from coal plants, the proposed
rule does not designate them as "preferred" options.
Instead, the EPA's proposal includes so- called "pre£
ferred" options that would do next to nothing about
scrubber sludge discharges, and which would leave
other major waste streams unregulated- including
large amounts of toxic fly ash and bottom ash waste
The EPA has warned for years that the 1982 standards
are not adequate to protect the public, especially
because they fail to control toxic metals in scrubber
sludge .135 How could the EPA nonetheless favor such
weak options? The answer is that the EPA did not
come up with these options. The White House's Office
of Management and Budget (OMB) took the highly un£
usual and improper step of writing new weak options
into the draft rule prepared by the EPA's expert staff.
The rule that initially went to OMB basically reflected
the EPA's core priorities. The EPA was looking to sig£
nificantly tighten the 1982 standards because, as the
EPA has stressed since at least 2009, "[s]tudies have
shown that the pollutants present in discharges from
coal -fired power plants can affect aquatic organisms
and wildlife, resulting in lasting environmental impacts
on local habitats and ecosystems.i136 The EPA long
viewed regulatory updates as critical, admitting that
"[t]he current regulations, which were last updated in
1982, do not adequately address the pollutants being
discharged and have not kept pace with changes that
have occurred in the electric power industry over the
last three decades .1137
As a result, the EPA developed two "preferred" options
in its version of the proposal, which presented five op£
tions in all as part of its discussion .131 Under the first,
which the EPA called Option 3, scrubber sludge would
be treated with combined biological and chemical
treatment, and fly ash would have to be dry - handled,
eliminating the discharge. Bottom ash, meanwhile,
could still be handled in ponds, as could leachate from
ash landfills.139
The second option, called Option 4, which the EPA
described as the "more environmentally protective" of
its preferred options, would contain all the treatment
options of the first option and would also require dry
handling for bottom ash as well, and require chemical
treatment for leachate.140 Thus, as the EPA explained,
the two preferred options both addressed scrubber
sludge and fly ash thoroughly, and differed in their
handling of "bottom ash transport water and ... leach£
ate.1 141 (EPA, unjustifiably, proposed not to implement
the strongest possible proposed option, Option 5,
which would have required zero discharge standards
for scrubber sludge± though the EPA could still select
that option in the final rule).
The proposed rule that emerged from OMB looked
very different. OMB is meant to play a "traffic cop" role
in the Administration, and is charged with coordinating
administrative action, which includes reviewing agency
rulemakings. Because OMB is the last stop before rules
are proposed or finalized, powerful industry groups
have come to see OMB review as an opportunity to
12 Closing the Floodgates

delay, weaken, or block public health protections that
would impose costs on polluters .112 Here, the power
sector's lobbying was successful.
OMB review of the new coal plant water standards
began in winter 2013, and carried on until just before
the rule was signed by the EPA in April that same year.
During that time, the proposal was dramatically weak£
ened. A redline of the rule, showing the original EPA
version and OMB's version reveals the changes: OMB
refused to let the EPA choose more protective options
as "preferred" regulatory paths going forward, and
inserted weaker options instead .113
Visitor logs and other records show that indus£
try representatives met with OMB, with the White
House, and with other agencies. What is clear is that
OMB± whether on its own or, more likely, at the behest
of industry players± acted to weaken the proposed
rule. OMB would not let the EPA select Option 4, the
most protective of the EPA's preferred options, and
instead inserted new, weaker, options into the rule as
11 preferred :i144 Suddenly, the rule had four "preferred"
options± three of them the products of the OMB
process .141
To begin with, OMB added options "3a" and "31o",
which are both weaker than the EPA's original pre£
ferred option .146 Option 3a has no limits for the scrub£
ber sludge discharges that the EPA prepared the
rule to control. Instead, it leaves those limits to the
states± the same states that have failed to set permit
limits for decades± for determination on a case -by-
case basis.147 Option 3b is just as bad: It would require
sludge controls only for plants using scrubbers on
more than 2000 MW of capacity± a group consist£
ing of a very few enormous plants± leaving most
scrubbed plants totally uncontrolled .1411 OMB's pre£
ferred options are far weaker than the EPA's. While the
weaker of the EPA's original preferred options would
eliminate 1.623 billion pounds of pollution annually,
OMB's Option 3a would control just about 460 million
pounds of pollution per year, and Option 3b would
control just 914 million pound S.141
Options 3a and 3b are not independently analyzed in
the EPA's technical supporting documents because
they were not created by the EPA and are not sup£
ported by technical analysis: They are political options,
created to protect industry. "'
Having created new options that are contrary to the
EPA's view of what the best technology is, OMB went
on to rewrite the EPA's proposal, taking positions that
are directly opposed to the expert opinions formerly
expressed by EPA staff. For instance, the EPA had writ£
ten, correctly, that "surface impoundments "± settling
ponds± "do not represent the best available technol£
ogy for controlling pollutants in [scrubber sludge]" in
almost all circumstances.151 OMB deleted this sentence,
and instead announced that "EPA' was proposing op£
tions that would keep using "surface impoundments
for treatment of [scrubber sludge] "± exactly the op£
posite of what the EPA's scientists had proposed .112
OMB added other language endorsing pond S113 and
parroting industry concerns about the biological treat£
ment that the EPA had proposed in Option 4.154 OMB
added paragraph after paragraph of rationales for why
Option 4 was not preferred, inventing "concerns" that
warranted dropping that protective option.155 None of
this language was in the EPA's original proposal.
Apparently in response to this interference, the EPA
did manage to salvage some of Option 4 by creating
a new Option "4a," which resembles its original Option
4 in requiring bottom ash and leachate treatment, but
which is weakened by exempting plants smaller than
400 MW from the requirement to treat their bottom
ash waste.156 That exemption makes a big difference:
While Option 4 would control 3.3 billion pounds of pol£
lution annually, Option 4a would control only 2.6 billion
pounds, a 700 million pound difference .157
The result is that the EPA's original two preferred op£
tions± Option 3 and 4± turned into four preferred
options: Options 3a, 3b, 3, and 4a, three of them the
direct result of the OMB process. All of these rules are
weaker than Option 4, meaning that the proposal has
shifted away from the stringent controls that the EPA
has repeatedly recognized to be available and protec£
tive. If the EPA finalizes any of these lesser options (or
is forced to do so by OMB), it will fail to control billions
of pounds of pollution, possibly for decades to come.
The EPA can still choose to finalize the stronger stan£
cards contained in Options 4 and S. These options
would comply with the letter and spirit of the Clean
Water Act, and are well- supported by the EPA's techni£
cal and scientific analysis. The damage, however, has
still been done: OMB put weaker options on the table
as "preferred" courses of action, and big polluters will
no doubt try to persuade EPA to finalize those dan£
gerously lax proposals. But Americans deserve better.
After thirty -one years of delay, and billions upon bil£
lions of pounds of toxic pollution, the public deserves
strong, national standards that protect downstream
communities and are based on science± not a weak
rule based on politics.
Closing the Floodgates 13

PART TWO
III,,,, III V 1114 G ID 0 W 114 S "'I" III IIEEEEE' A II
1 WA "'I" IIEEEEE' IFZ IF) 0 III,,,, III,,,, "'1"110114 ACROSS
The hundreds of plants lacking permit limits are not
just numbers: Each one puts a waterway at risk. Most
Americans live, work, or play downstream from a coal -
fired power plant, which means we are all at risk from
the failure to control this toxic pollution, and we all can
benefit from finally cleaning it up. A journey to down£
stream communities across the United States reveals
poisoned rivers, imperiled communities, and a net£
work of toxic waste sites that may take years to fully
remed iate.
Not surprisingly, the largest coal plants are among the
worst polluters, and yet even these behemoths often
lack real pollution controls.
II...AIBAIDIIIE„ II...IEAIKS, SIDEPS, AINID GUSHING
IDIISCHAIRGIES IIIN11 "O'11 "IHIE IMIISSOUIRII
The huge, approximately 2400 MW, Labadie Power
Station, which sprawls across the Missouri River bot£
toms just upstream of St. Louis, is one of the worst
water polluters in the country.
The Labadie plant, the largest coal power plant in
Missouri, burns huge amounts of coal every day± so
much so that it is the fourth largest greenhouse gas
source in the entire country.15' The waste from all
that coal± more than half a million tons of it each
year159± is dumped in two ponds, including a 154 -acre
unlined coal ash pond in use since 1970.160 Fine alluvial
soil under the pond poses little barrier to contami£
nants, which can make their way into nearby wells.
But Ameren, the company that owns the plant, has
yet to conduct comprehensive groundwater testing,
and the state has not required it. The failure to con£
duct groundwater monitoring and testing is particu£
larly troublesome given Ameren's history of danger£
ous leaks from its ash ponds just across the border
in Illinois, where such testing is required. This means
danger and uncertainty for residents since the rural
communities around the plant depend on well water,
and the Missouri River itself is a drinking water source
for St. Louis residents.
%/%
Underground leaks are only the beginning of the prob£
lem, though. Amazingly, one of Labadie's ponds was
allowed to leak massive streams of waste for at least
nineteen years.161 The leak spilled up to 35 gallons per
minute± which works out to 50,000 gallons per day,
or about 350 million gallons over the years that it went
uncorrected .162 It took action by concerned citizens,
the Labadie Environmental Organization, and the
Washington University law clinic to compel the com£
pany and the state into finally addressing this river of
waste, at least superficially.
But even that egregious leak is not the biggest of
Labadie's waste problems. The plant dumps far more
waste into the river everyday than it leaks. The ash
pond is allowed to directly dump waste into a trench
leading to the Missouri River, and every day it dumps
25 million gallons or more, on average .163 The plant's
discharge permit was issued in 1994 and has no limits
for any toxic metal in this discharge. In fact, it does not
even require the Labadie plant to monitor for metals in
its ash pond waste .164
That failure doesn't sit well with citizens of the area. As
Christine Alt, the mother of two small children, and a
life -long resident of Labadie, says, "Our family is really
concerned that the leaking ash ponds and massive dis£
charges from the ash ponds are affecting the health of
family members. We have eaten fish from the Missouri
River and local streams that have likely been affected
by the lack of regulation.)
Despite these concerns, Missouri has failed to act. The
state has never updated Labadie's permit; it briefly
issued a draft permit in early 2013, but then withdrew
it.165 That wasn't much of a loss: the draft permit was
little better than the old one. The new permit also had
no limits on toxic metals in the ash pond waste stream,
instead requiring quarterly monitoring of boron and
molybdenum, but not of arsenic, mercury, or selenium,
among other toxics in coal ash.166 To make matters
worse, Ameren has proposed to build a new ash landfill
in the floodplain (an area with standing water for much
of the year).
14 Closing the Floodgates

Patricia Schuba, the president of the Labadie
Environmental Organization, describes the threat to
her family, friends, and neighbors this way:
"Families surrounding the Labadie Power
Plant and ash dumps are afraid that decades
of exposure to unmonitored coal waste dump-
ing has increased their risks of cancer, asthma,
auto - immune diseases, cardiovascular dis-
ease, neurological impairment, and premature
death. Why are we dumping toxic waste in our
drinking water and floodplains? Floodplains
are for food production, flood protection, and,
most importantly, filtering our drinking water."
IMOINIROIE„ SWIIMIKIING IIIN COAII... PII...AIN"ll" WAS'1I "IE
The town of Monroe, south of Detroit, Michigan, on
Lake Erie, does not really have a waterfront. Instead,
DTE's Plant Monroe cuts the town off from the water,
sitting where the River Raisin flows into the lake. Plant
Monroe, at over 3200 MW, is the ninth worst green£
house gas polluter in the country, and produces coal
waste to match." The plant's vast ash ponds stretch
out around it, bordering the lake. Just across the river,
north of the plant, Sterling State Park hosts a popular
swimming beach. Many swimmers also congregate on
a sandbar at the head of the plant's discharge channel
itself, bathing in water flowing out of the ash ponds.
That could be a risky thing to do. Until 2010, Plant
Monroe had no limits on the six toxic metals discussed
in this report, meaning that those metals have flowed
into the lake and its underlying sediments unchecked
for decades.16' Although the plant makes some efforts
to treat its scrubber sludge, its permit requirements are
extremely lax, and ash waste winds up in ponds that
drain to the lake. Only in the last three years has the
state of Michigan added a single limit to the permit16'
for mercury, which is an annual rolling limit, rather
than a more stringent daily, or even monthly, limit. The
permit does not even require monitoring for other toxic
metals, including arsenic, selenium, and lead.1'
As a result, the plant is authorized to dump 57.5 million
gallons per day of wastewater contaminated by fly ash,
bottom ash, and scrubber sludge into Lake Erie. "' That
water flows by the swimmers on the sandbar, and into
the lake, where others play at the state park. Summer
fun, in Monroe, comes along with coal plant waste.
The largest plants are not the only serious water pol£
luters. The combined pollution of hundreds of plants
in many states also fouls our waters. North Carolina's
toxic burden± caused in significant part by decades
of pollution from Duke Energy power plants± demon£
strates how coal pollution can make its way into river
after river across the country.
Duke Energy operates ten coal- burning power plants
in North Carolina. Three of the state's signature riv£
ers, the Catawba River, the French Broad River and
the Cape Fear River, are seriously affected by pollu£
tion from these coal plants and the ash ponds in their
shadows. The damage extends beyond the waters in
which North Carolinians swim, paddle, and fish; recent
groundwater monitoring revealed that coal ash ponds
are leaking at every single one of these power plants.12
The Catawba River runs along the western edge of the
booming city of Charlotte, providing drinking water
for more than 1.5 million people, stunning recreational
opportunities, and habitat for abundant native spe£
cies, including bald eagles, osprey, and other raptors.
Unfortunately, at least three reservoirs on this river are
heavily polluted by coal ash and scrubber discharges
from Duke Energy power plants.
The trouble begins as the Catawba River flows from
the mountains of western North Carolina into the roll£
ing red clay hills of the piedmont. Lake Norman hosts a
state park, excellent swimming and fishing opportuni£
ties, and Duke Energy's Marshall coal- burning plant.
The four units at the nearly 2000 MW plant burn coal
mined at mountaintop removal sites in Appalachia,
and produce approximately eight million gallons per
day of scrubber sludge and ash water in the process .173
Duke Energy is allowed to dump this wastewater into
Lake Norman with no limits on arsenic or mercury.14
Lake Norman provides drinking water for many nearby
towns, including Davidson and Mooresville, and this
valuable resource is in jeopardy due to the ash pond at
the Marshall plant and the daily burden of unregulated
coal combustion wastewaters .175
Just a few miles down the Catawba River, another
drinking water reservoir was long used as a pollution
dumping ground for a Duke Energy coal plant. At the
Riverbend Station, which came offline in April of 2013
after years of pollution, coal ash was pumped into two
unlined ash ponds that are leaking toxic metals into
Mountain Island Lake, the sole drinking water source
for more than 800,000 people in the Charlotte area .171
Although Riverbend is no longer operating, its pollu£
tion remains. Large volumes of coal ash water can still
flow from these ponds into Mountain Island Lake with
no limits on arsenic, selenium, or mercury. Monitoring
for these metals, which might tell the public just how
dangerous these discharges are, is limited to a single
sample done four times a year."' The permit requires
testing for these metals in fish tissue concentrations,
but only once in the entire five -year permit term .1711 In
Closing the Floodgates 1s

May 2013, the state of North Carolina brought a Clean
Water Act enforcement action against Duke Energy for
contamination of Mountain Island Lake caused by the
seepages from its massive unlined ash pond S.179
Further down the Catawba River, another Duke Energy
coal- burning power plant, G.G. Allen, is authorized to
discharge an unlimited amount of coal ash wastewa£
ter into Lake Wylie.18' The massive Allen plant has five
boilers equipped with wet scrubber systems, creating
a large scrubber sludge waste stream. Although the
Allen plant has implemented a treatment system for
the scrubber waste, the permit contains no enforceable
limits on discharges of arsenic, mercury, or other coal
combustion waste metals, so it is impossible to know
whether this treatment system is working as intended.""
The Catawba River has taken enough chronic mistreat£
ment by Duke Energy. Sadly, it is not the only river in
North Carolina damaged by the coal industry.
The Cape Fear River is North Carolina's largest river
basin, with impressive ecological diversity encompass£
ing salt marshes where the river meets the Atlantic,
inland blackwater swamps, and ancient cypress trees.
Just a few miles upstream from the coastal estuar£
ies that provide rich habitat for shellfish, bird life, and
threatened species such as loggerhead and Atlantic
green sea turtles '1112 the Duke Energy L.V. Sutton power
plant dumps its ash waste into two unlined ponds on
the banks of Sutton Lake, an impoundment of a Cape
Fear tributary. Approximately 160,000 tons of coal
ash is generated each year and stored in these two
pond S.1113 This ash water receives no treatment other
than settling before it is discharged into Sutton Lake,
and the state - issued discharge permit for the Sutton
plant imposes no limits on the concentration of metals
that may be discharged .1114 According to the plant's
own discharge monitoring reports, it discharged 603
pounds of arsenic to the river, along with 526 pounds
of selenium in 2012 alone.
Fish in the Atlantic Ocean at the mouth of the Cape
Fear River contain dangerous levels of mercury, and res£
idents and tourists are warned not to consume them.185
The river below the Sutton Plant violates water quality
standards for nickel and copper, and is unsafe for har£
vesting aquatic life.186 Sutton Lake, and which is required
by the state to be managed as a public fishery, is a
very popular sportfishing lake, especially during winter
months when the water is kept warm by the plant's
cooling water discharges. Unfortunately, in recent years
the largemouth bass population in the lake has fluctu£
ated wildly, and the North Carolina Wildlife Resources
Commission has identified selenium contamination
from the coal ash ponds as a significant contributor to
that problem. Levels of selenium in fish tissue are three
to five times higher than levels known to result in fish
reproductive failure, and are extremely high in fish eggs
and lake sediments .1117 Duke Energy has gone so far as
to pump additional water into Sutton Lake from the
Cape Fear River to dilute additional discharges from the
ash ponds so that metals like selenium will be less likely
to accumulate in fish tissues.18'
Although Duke Energy is in the process of converting
the Sutton plant to run on natural gas rather than coal,
the risks posed by these coal ash ponds will persist
unless the ponds are properly closed and cleaned up.
Leaks from the ponds into groundwater have been thor£
oughly documented± the groundwater in the vicinity of
the plant and the riverbed is already contaminated with
arsenic, iron, boron, barium, manganese and other met£
als and salts.18' Moreover, the sediments at the bottom
of Sutton Lake are heavily contaminated with selenium
that will continue to taint the fish population for de£
cades to come. Simply capping the ponds and stop£
ping discharges to Lake Sutton is far from an adequate
solution. There is currently no plan for how this massive
source of coal ash pollution will be cleaned up.
In the meantime, Sutton Lake and Cape Fear River
bear the burden, along with nearby residents who
must live with the severe health risks associated with
the plant's toxic discharges. Seeking to address illegal
pollution at Sutton, citizen groups initiated enforce£
ment proceedings against Duke in June of 2013.190
From the Catawba to the Cape Fear, and from the
ocean to the mountains, North Carolinians bear the
burden of Duke Energy's waste. Their plight is not
unusual.
The rivers of North Carolina are not alone in carrying a
toxic burden. Across the country, citizens are in similar
straits. Many of the nation's watersheds are imperiled
by water pollution from coal power plants.
11" IAN IE 11 11 11.. II IN 0 1 S IR II V IE IR„
IPIRAIIIRIIIE S "ll "IRIEAIM UUINIDIEIR IPIRIESSUIRIE
The Illinois River, flowing southwest across farmland
and prairie from near Chicago to the Mississippi, was
once one of the healthiest rivers in the United States,
supporting migrating waterfowl, and huge populations
of fish and mussels.19' Today, at least 10 coal -fired pow£
er plants dump millions of gallons per day of contami£
nated waste into the river and its tributaries, and the
river is suffering. The state of Illinois has formally listed
the river as impaired by mercury pollution, and advises
its citizens to be wary of eating fish from the river. 192
16 Closing the Floodgates

Despite these warnings, Illinois has not required coal
plants to eliminate their toxic metal discharges, or
even to consistently monitor them. Of the 10 coal -fired
power plants on the Illinois and its tributaries, only
two of them have numeric limits for boron; none of
them have mercury limits, much less limits for arsenic,
selenium, cadmium, lead, or other toxic substances
found in coal ash and scrubber sludge .193 Indeed, not
all of these plants are even required to monitor their
discharges for mercury, and only one of them monitors
for arsenic. Most of these rogue plants are owned by
just two companies: Dynegy /Ameren194 and Midwest
Generation.
Dynegy /Ameren plants on the Illinois River or its tribu£
taries (including the Des Plaines River and the Chicago
Area Waterway System) include the E.D. Edwards and
Havana facilities. The Illinois River passes by Hennepin,
receives discharges from the E.D. Edwards facility at
Peoria, and then gets another dose of ash- contaminat£
ed water downstream at Havana. None of these plants
have limits for their discharges of mercury and other
ash contaminants.
Illinois has not put a ceiling on the volume of waste
these plants can discharge, or the concentration of
toxic metals in those wastes. At the upstream end, the
Hennepin plant reports that it may dump as much as
three million gallons of fly -ash and bottom -ash waste
into the river (though there is no upper limit on how
much it may discharge).195 There are no limits on what
toxic metals may be in the waste, and the company
doesn't have to test for most of them. At best the facil£
ity is to monitor for mercury in a single "grab" sample
from its millions of gallons of waste, once every three
months.196 The E.D. Edwards plant, next downstream,
has an 89 -acre, 32- foot -high unlined coal ash pond
located dangerously close to the Illinois River and just
upstream from recreation areas where families gather,
including Pekin Lake and fishing sites along both sides
of the river. That plant reports that it can discharge
more than 4 million gallons per day of ash pond waste£
water, containing a mixture of fly -ash and bottom ash -
contaminated waste.197 That plant was required to moni£
ter only for mercury on a monthly basis, and only had to
do that 12 times before stopping indefinitely.1911 Further
downstream, the Havana plant dumps at least another
A.8 million gallons per day of ash waste from its ash
ponds into the river even further downstream± once
again without even monitoring for most metals.199
Midwest Generation, meanwhile, owns four plants
dumping into the Illinois River and its tributaries:
Upstream of the Illinois River, Midwest Generation's
Joliet 9 facility reports it can discharge close to 7
million gallons per day of ash - contaminated water 200
and the Joliet 29 facility adds another 2.6 million gal£
Ions per day.201 The Will County Plant, located on the
Chicago Sanitary & Ship Canal, adds almost another
million gallons per day of ash - contaminated waste .202
Further downstream, Midwest Generation's Powerton
plant± near Pekin, just south of Peoria± can dump
7 million gallons per day or more of its ash- contam£
inated wastes into the Illinois River itseIf.203 There's
no telling exactly what is in that wastewater because
the company is not even required to monitor for toxic
metals, including arsenic and mercury, which are con£
twined in coal ash waste .204 Leaks from Powerton's ash
ponds add to the problem: Midwest Generation's own
monitoring at Powerton shows hundreds of test re£
ports documenting leaking toxics such as arsenic and
selenium that are contaminating groundwater at levels
exceeding federal and state standards. In 2012, the
Illinois EPA issued Notices of Violation for ground wa£
ter contamination after testing of wells showed numer£
ous exceedances of heavy metals including arsenic and
selenium. Several environmental organizations such as
the Sierra Club, Environmental Integrity Project, and
Prairie Rivers Network filed suit over many of the same
violations of groundwater standards and violations of
the state's "open dumping" Iaw205 Incredibly, the plant
sits just upstream of the Powerton Lake State Fish &
Wildlife Area,206 a state - managed reservoir that experi£
ences heavy fishing pressure from the public despite
its double use as a receptacle for cooling waters and
the power plant's wastewater.
All this pollution affects people up and down the river.
Joyce Blumenshine, for instance, lives near the Peoria
plants, and worries about what's happening to her
river.
"The tons of pollutants these power plants
are putting in our river every year have to be
stopped," she says. "Dumping pollution into
our river is antiquated. l live in Peoria and half
of our water supply is withdrawn from there.
The public and wildlife depend on the Illinois
River. There is scientific information now on
how small amounts of these heavy metals can
harm public health, especially for children.
We need to require that these power plants
stop using the Illinois River as a dump for their
pollution. "
Robin Garlish, who lives near the Powerton plant in the
community of Pekin, also wants to see the pollution
stop. She says
"My family moved here to the Peoria area
in 7986. It is a beautiful area with the bluffs,
trails, and the Illinois River. We own a campsite
along the river and have spent every summer
camping and boating along the water. I have
Closing the Floodgates 17

photographs of my son learning to waterski
in the river, with the ED. Edwards coal plant
looming in the background. l never knew the
millions of gallons of pollution that were be-
ing discharged into the river every single day.
Where were the warning signs ?"
Ms. Garlish has questions: "As spring and summer ap£
proach, I wonder if it will be safe for my family to enjoy
the outdoors? Will we be able to enjoy camping and
water sports on our boat without fear of pollution in
the water ?"
"II "IHIE IEII...ACIK WARRIOR RIMER :: "II "OXIIC IMIE "II "AIl...g II IN
AII...AIEAIMA!S A11 "IERWAY
Every year when the long, hot days of summer arrive
in Alabama, anglers come from miles around to fish
Bankhead Lake, a reservoir on the Black Warrior River
near Birmingham that is known for spotted and large£
mouth bass. These anglers may not know that nearby,
two massive Alabama Power Company power plants,
Plant Miller and Plant Gorgas, are constantly pumping
their coal ash refuse and scrubber sludge into huge
waste lagoons next to the lake. Further downstream in
Greene County, a third plant dumps even more pollu£
tion into the river. Alabama Power is allowed to dump
almost unlimited amounts of toxic wastewater from its
coal ash lagoons straight into Bankhead Lake, a public
drinking water source for the city of Birmingham and
surrounding areas. The largest of these Black Warrior
River power plants, the Miller Generating Station,
dumped more toxic ash into its ash pond than any
other plant in the country in 2010. Waste from the
Miller ash pond flows right into Bankhead Lake, con£
taminating the water downstream where people often
go boating and fishing.201
The two plants that dump their wastewater into
Bankhead Lake are both owned by a subsidiary of the
multi - billion dollar Southern Company, but Southern
has resisted any investment in cleaning up its ash
pollution at these two plants. In 2010, Alabama plants
dumped more dangerous heavy metals into their ash
ponds than any other plants in the country: more
than 14 million pounds of toxic waste .2011 The Miller
plant alone was responsible for more than five million
pounds of that waste, making it the biggest ash pol£
luter in the country that year .209 Plant Gorgas was the
15th worst out of hundreds of coal -fired power plants
nationwide .210
Despite this pollution, the state of Alabama does not
require these plants to monitor for numerous toxic
heavy metals typically discharged into the Black
Warrior, much less to control them. Miller ordinar£
ily discharges at least eight million gallons per day of
polluted water from its toxic ash pond into the Locust
Fork of the Black Warrior, though its discharges can be
much greater .211 Its permit does not require monitoring
or have discharge limitations for poisons like arsenic,
mercury, and lead .212 But even though Alabama doesn't
know exactly what is in the wastewater from Miller,
pollution from this power plant is having an impact.
Some of those impacts are easy to see: The rocks from
the water below the discharge are blanketed with a
hard white gunk that cements them together .211 Other
impacts, like the toxic metals that are likely building up
in the river system, are harder to see but no less real.
The same story is happening over on the Mulberry
Fork, where Plant Gorgas dumps its millions of gal£
Ions of waste into a huge pond euphemistically named
"Rattlesnake Lake .1214 The venom that lurks in that
"lake" flows into the river, at an average volume of 20
million gallons per day. That plant does have a monthly
(but not a stringent daily) limit on arsenic pollution,
but lacks any limits or monitoring for selenium, mercu£
ry, lead, thallium, cadmium, or many other toxic heavy
metals found in coal waste .215
The Black Warrior is not free from coal plant pollution
further downstream, either. After leaving Bankhead
Lake and passing by Tuscaloosa, the river winds
through small towns and farm country where, near the
town of Demopolis, Alabama Power's Greene County
plant sits. It, too, has been among the dirtiest plants in
the country based on its dumping of toxic coal ash in
some years '211 and it lacks limits on toxics other than a
lenient, monthly average arsenic Iimit.211
As we discuss elsewhere in this report, metals pollution
stays in rivers. It makes its way into the sediment, and
then into the fish and the other creatures using the
water± including the people. The Black Warrior is an
Alabama treasure, flowing from the sandstone gorges
of northern Alabama through the old fishing spots and
reservoirs around Birmingham and Tuscaloosa, and out
into the lowlands of the Gulf Coast. It's time to treat
the river like the treasure it is, and keep the millions of
gallons of coal ash - tainted wastewater from Alabama
Power's plants out of it.
Coal plants with water pollution problems are often
located in communities of color and communities with
lower- than - average incomes. Members of these com£
munities are often more dependent on fishing for food
than the national average, meaning that contaminated
18 Closing the Floodgates

water and fish are a particularly serious threat, ac£
cording to the EPA's National Environmental Justice
Advisory Council.21' Several plants across the country
illustrate this troubling national failure.
WAUIKIEGAIN:: IIINIDUS "II "IRIIAII... IP01I...II...UU11 "11011 OIN "II "IHIE II...AIKIE
The city of Waukegan, on the coast of Lake Michigan
north of Chicago, is a working class city with a proud
industrial heritage. With large Hispanic and African -
American communities, Waukegan has a diverse
population and an enviable location on Lake Michigan.
Unfortunately, its industrial history has left it with seri£
ous pollution problems that coal -fired power is making
worse.
That legacy of pollution includes a Superfund site in
Waukegan's harbor due to severe PCB contamina£
tion± the residue of a manufacturing business.21' That
PCB contamination alone makes fish from certain parts
of the city's lakefront unsafe to ea t,220 but it is not the
only water quality problem the city faces. Another
lurks just along the coast from downtown, at Midwest
Generation's Waukegan Generating Station, an aging
coal power plant whose first units began operating
in the 1920s and whose current boilers are more than
fifty years old .221
According to a recent NAACP report, the Waukegan
plant is one of the worst environmental justice of£
fenders in the nation .222 People of color comprise 72
percent of the population within three miles of the
plant, and the average income of that community is
just over $16,000 per year .221 Schools and a hospital
located near the plant must contend with its pollution,
which causes tens of millions of dollars' worth of public
health harm every year. 224
The Waukegan power plant's ash ponds sit just off the
shoreline of the lake, and are responsible for serious
groundwater contamination. According to the state,
"[g]roundwater flow" is "highly dependent on the wa£
ter level in the ash ponds," meaning that contaminants
from the ponds appear to be flowing into the ground£
water .221 In 2012, the Illinois Environmental Protection
Agency issued the plant a Notice of Violation for viola£
tions of arsenic, boron, manganese, iron, sulfate, chlo£
ride, total dissolved solids, pH, and antimony standards
in groundwater near the ponds, concluding that the
violations had been caused by waste leaking from the
ash pond S.226 Several environmental organizations such
as the Sierra Club, Environmental Integrity Project, and
Prairie Rivers Network filed suit over many of the same
violations of groundwater standards and violations of
the state's "open dumping" Iaw.227
Yet, even as the state of Illinois begins to address
leaks in the ash ponds, it continues to allow contami£
nated water in those ponds to flow directly into Lake
Michigan. Waukegan's discharge permit, which is more
than a decade old, sets only copper and iron limits for
the 3.2 million gallons per day of ash - contaminated
waste which Waukegan is authorized to discharge,
failing to set any limits for poisons like arsenic, mercu£
ry, and selenium.2211 A more recent draft permit, issued
for public comment in late 2013 repeats this mistake,
again setting no limits on the toxic heavy metals in
Waukegan's ash waste stream.229 Yet the plant is clear£
ly a large water pollution source: Waukegan reported
to the EPA that it discharged more than 1,000 pounds
of chemicals listed on the Toxic Release Inventory into
surface waters near the plant ever year between 2002
and 2010.230 Because Waukegan is not even required
to monitor toxic metal discharges, actual figures may
be higher.
This water pollution is only part of the plant's toxic
00(20; The plant emitted more than 11,000 tons per
year of asthma - causing sulfur dioxide (S02) between
2007 and 2010, and has yet to clean up its air pollu£
tion. Midwest Generation has said it will clean up this
pollution, but even that may not be good news for the
people of Waukegan. For one thing, the company will
likely use "Dry Sorbent Injection" to address S02 pol£
lution, a technology whose waste can greatly increase
the solubility and mobility of toxics in coal ash, includ£
ing arsenic and selenium.231 If that waste winds up in
Waukegan's ash, the plant's discharges will be all the
more potent.
INOIR "I1 "IH OIMAIHA & IRIIVIER IROUGIE„ VUII...INIEIRAIBII...IE
CA01MIMUIN1111 "IVES AINID 11 AX IPIEIRII 1111 "S
Other power plants on the NAACP's worst offenders
list follow this dangerous pattern of neglect, includ£
ing the North Omaha plant in Nebraska and the River
Rouge plant in Michigan. Although these plants may
opt to ship their ash elsewhere (where it may harm
other communities), their permits continue to allow di£
rect discharges into nearby waterways. There is no rea£
son these permits should allow unchecked dumping.
The North Omaha power plant, on the NAACP's list of
the worst environmental justice offenders '232 is located
in a predominantly African - American community with
an asthma rate of 20 percent. It is an old, poorly -regu£
fated facility, with some parts of the plant dating back
to the 1950s.233 The plant emits more than 300 pounds
of mercury each year. Of the 51 coal plants located in
cities the size of Omaha or bigger, the North Omaha
plant is the single biggest mercury emitter .234
Closing the Floodgates 19

The plant's legacy of air pollution, asthma, and mer£
cury poisoning is compounded by serious permitting
failures with regard to water pollution. Although the
plant's owner, the Omaha Public Power District, says
it now sends its ash off -site for dry storage, the state's
water permit for the plant allows it to send water from
its bottom ash and coal pile runoff ponds straight into
the Missouri River, not far from the city's water in£
takes .235 The plant is only required to monitor for toxic
substances, including mercury and arsenic, once a
year .231 There are no limits on how much of these toxic
metals it can discharge .237
Nebraska does not need more water pollution. Already,
73 waterbodies in Nebraska are already so con£
taminated with mercury that the state has warned
people about eating fish from them .231 The non - profit
Environmental Working Group has already rated
Omaha's drinking water as among the worst in the
country, based on its chemical content and safety.239
Any bottom ash waste from the North Omaha plant
will only add to these problems. There is no reason to
continue to allow the plant to dispose of any ash -con£
taminated wastewater in the Missouri River.
DTE's River Rouge Plant, on the Detroit River, also
has an unduly lax permit. The plant is one of many
huge industrial facilities± from oil refineries to steel
plants± that dot the banks in River Rouge near Detroit.
The cumulative pollution from all these facilities fouls
the air and water for many communities along the
river. The River Rouge Plant, though, stands out as a
particularly serious pollution source in its own right.
The smokestacks of the River Rouge plant rise directly
behind a playground, on the banks of the river. Two -
thirds of people living near the plant are minorities,
and their income is barely above half of the aver£
age income in Michigan .211 Over 1.6 million pounds of
hazardous chemicals are released in the River Rouge
community every year by the many heavy industrial
facilities there .241
Water pollution from the plant could add to this bur£
den, thanks to a weak permit. The River Rouge Plant is
authorized to discharge more than 654 million gallons
per day of wastewater into the river .242 The permit lists
"treated bottom ash transport water" and "treated
coal pile runoff" as constituents of this wastewater
flow± though it is not clear how much of this pollu£
tion is in the wastewater, and there are no limits and
no monitoring required for arsenic, selenium, mercury,
boron. or other constituents of ash waste .243
Although some large portion of the ash may be taken
offsite and dumped elsewhere, this permissive permit
is yet another danger for residents of the River Rouge.
Indeed, according to the Detroit Riverkeeper'244 at least
some of this bottom ash is not travelling far: It is being
dumped next to the river not far south of the River
Rouge at another DTE Energy plant, Trenton Channel.
Many citizens of the River Rouge community and
surrounding towns fish the Detroit River .245 People of
color go fishing more often, according to a University
of Michigan study, and they are more likely to take fish
home for food .246 Not all of these fish are safe to eat:
The state of Michigan warns against eating sturgeon
and freshwater drum because of mercury contamina£
tion, for instance, and has issued a blanket warning
against eating most other fish in the river .247
The bottom line is that coal waste has no place any£
where near the water people depend upon, and regu£
lators need to make sure that these power plants can
never release their waste into the public's waterways.
River Rouge's and North Omaha's dangerously lax
permits, and the ongoing pollution from the Waukegan
plant, are just one more injustice in communities al£
ready overburdened with environmental threats.
Without new water pollution protections, efforts to
clean the air will transfer air pollutants into the water
as scrubber sludge.
Nobody should be asked to make a tradeoff between
clean air and clean water. Technologies exist that en£
able coal plants to reduce the amount of metals in
their scrubber waste streams and eliminate all dis£
charges of this waste stream to surface water '2411 but
very few plants currently use these systems. Instead
they discharge scrubber wastewater to rivers and lakes
after the most minimal treatment. Scrubbed plants in
Pennsylvania and North Carolina illustrate the magni£
tude of the problem.
A prime example of the risks posed to the nation's wa£
ters by uncontrolled discharge of wet scrubber waste£
water is the Bruce Mansfield plant in Shippingport,
Pennsylvania. This massive 2740 MW plant, operated
by FirstEnergy, has three boilers equipped with wet
scrubbers to reduce sulfur dioxide air pollution, and
a wet handling system for bottom ash and fly ash.
For many years, FirstEnergy has sent all of the scrub£
ber wastewater and ash handling water through a
seven -mile pipeline to the Little Blue Run Coal Ash
Impoundment± the largest unlined ash pond in the
United States .249 In 2011, FirstEnergy dumped 79,500
pounds of arsenic and 26,190 pounds of selenium
into that impoundment.250 These pollutants and other
20 Closing the Floodgates

toxic metals such as boron and molybdenum are
then dumped into Little Blue Run Stream and Mill
Creek, ultimately making their way to the Ohio River.
Pennsylvania regulators have identified Little Blue Run,
Mill Creek and stretches of the Ohio River as water£
ways that are not safe for aquatic life due to siltation,
pH and metals.25' Pennsylvania officials have advised
community members to limit their consumption of fish
caught in the Ohio River, in part due to concerns about
heightened levels of mercury."'
The Bruce Mansfield plant operates under an expired
NPDES permit that imposes no discharge limits or
monitoring requirements for any of these metals where
water enters Little Blue Run Stream and Mill Creek .253
FirstEnergy's own monitoring reports reveal concentra£
tions of boron at the Little Blue Run Stream surface
water monitoring station location immediately down£
stream of the impoundment discharge (SW -3) higher
than the chronic Pennsylvania water quality criterion
for boron in all quarters between 2006 and 2012.254
During this same time period, concentrations of boron
even exceeded the acute Pennsylvania water quality
criterion for boron at SW -3 in 9 of 22 quarters .255 And
in the one quarter of available data for selenium from
SW -3 in the last five years, selenium exceeded the
chronic Pennsylvania water quality criterion .256 Notably,
FirstEnergy is not required to monitor for all coal
ash and scrubber sludge pollution at this monitoring
location.
Outraged by the water contamination at Little Blue
Run, the community organized to fight an expan£
sion of the disposal site and filed a lawsuit under the
Clean Water Act. In response, Pennsylvania regulators
have required closure of the leaking impoundment
by 2016 and some cleanup of seeps and ground£
water. FirstEnergy now plans to transport coal ash
and scrubber wastewater nearly 100 miles upriver
on thousands of uncovered barges per year to an£
other unlined, active coal ash dumpsite in LaBelle,
Pennsylvania.257 La Belle's groundwater and surface
water are already contaminated by leaks from this
coal ash dump, and because many of the working
class residents of that town hunt for food, they are
also exposed to bio- accumulating metals such as
selenium through what they eat .258
The incredible volume and toxicity of wastewater
generated by the scrubbers at the Bruce Mansfield
plant demands close scrutiny and careful handling, but
Pennsylvania permitting authorities have not imposed
any limits or required any kind of effective treatment
to protect the Ohio. Shifting the problem to a different
community upriver is no solution.
Another plant that already barges its coal ash waste
to LaBelle is the 50 -year old Mitchell Power Station
near New Eagle, Pennsylvania. In July 2013 FirstEnergy
announced plants to retire the Mitchell plant, but the
facility has been polluting local waterways for decades.
The Mitchell plant has a wet scrubber system and
discharges scrubber wastewater into the Monongahela
River several miles upstream from the intake for the
Pennsylvania- American Water Company. The "Mon,"
as it is affectionately known by thousands of residents
along its length, flows out of the mountains of West
Virginia and joins the Ohio River in Pittsburgh. This
river is the heart of southwestern Pennsylvania, the en£
gine of the region's economic growth for hundreds of
years, and the source of drinking water for more than
800,000 people. Sadly, a legacy of abandoned mines
and uncontrolled industrial discharges means that for
most of the river's length, water quality is not safe for
drinking and recreation .211
The Mitchell plant's water discharge permit expired in
1996± nearly 20 years ago. It is perhaps not surpris£
ing then, that this permit utterly fails to protect the
Monongahela from the toxic wastewater produced by
the Mitchell plant and its wet scrubber system. The
outfall that sends the plant's scrubber wastewater into
the Monongahela has no limits on metals commonly
found in coal combustion wastes, nor any monitoring
requirements .260 Another outfall at the Mitchell plant
dumps leachate from an ash landfill into Peters Creek,
a tributary of the Monongahela. While the Mitchell
plant's expired permit requires monitoring of boron
and aluminum discharges, the permit imposes no limit
on the amount of these metals that can be discharged
into Peters Creek .261 The EPA's proposed rule final£
ized in its strongest form would require the operator
to significantly reduce metals concentrations in this
discharge stream rather than merely monitor those
pollutants.
The approximately 400 MW Asheville plant, on North
Carolina's French Broad River, provides a test case for
how a wet scrubber system increases the toxicity of a
coal plant's wastewater discharges. In 2005 and 2006,
Duke Energy added wet scrubbers to the two units
at the Asheville plant for sulfur dioxide control. The
wastewater from the scrubbers is treated in an onsite
artificial wetland, and then sent to a holding pond
where it is mixed with fly ash and bottom ash handling
waters. The wastewater permit allows the Asheville
plant to dump from this holding pond into the French
Broad River with no limits on the metals commonly
found in scrubber sludge and coal ash wastewaters,
Closing the Floodgates 21

other than mercury.262 According to the plant's own
reporting, it discharged 324 pounds of arsenic and 564
pounds of selenium in 2012.263
The only way to understand how well the artificial
wetland treatment system is working is a monitoring
program of toxic metals where the ash pond dumps
into the French Broad± just a single sample taken
once a month .214 In fact, the water pollution problem at
Asheville has significantly worsened since the scrub£
bers were added. A study done by scientists at Duke
University compared pollutant load in the ash pond
discharge at Asheville before and after the wet scrub£
bers began operating, and found that the amount of
pollutants such as arsenic and selenium discharged to
the French Broad River dramatically increased after
the scrubbers were installed .211 The study reported
that samples collected during the summer of 2011 from
mingled scrubber and coal ash waste flowing to the
French Broad River contained arsenic at levels four
times higher than the EPA drinking water standard,
and selenium levels 17 times higher the agency's stan£
card for aquatic life. Cadmium, antimony, and thallium
were also detected in the wastewaters at levels above
human and aquatic life benchmarks .211
Clearly, more must be done to reduce pollution from
the Asheville scrubber system. The EPA has identi£
fied treatment methods that can eliminate or at least
achieve much lower levels of toxic metals from scrub£
ber waste streams, and must apply them to all coal -
burning plants with scrubber systems, including rela£
tively small plants like Asheville that have an outsized
impact on a treasured river.
These plants are just examples: All across the country,
scrubbers are going in and increased water pollu£
tion follows, without efforts to tighten permit limits.
Smokestack scrubbers are good news for the air,
and they can be good news for the water, too, if the
EPA puts strong controls in place for treatment of
this waste. No community should have its watershed
contaminated by the same pollution that it once was
forced to breathe.
The crisis of groundwater and surface water contami£
nation by uncontrolled discharges of toxic metals is
not limited to the wetter eastern half of our coun£
try. The waters of the western United States are also
burdened by these toxic discharges, which is all the
more troubling considering the scarcity of water in the
region and the rapidly growing population. Plants in
Colorado and Montana illustrate the problem of coal
water pollution in the West.
The Xcel Comanche plant in Pueblo, Colorado, has
three large coal- burning boilers. Two of these boilers
were built in the 1970s, and the third was built in 2010.
All of the boilers burn coal brought in from massive
strip mines in Wyoming, producing more than 300,000
tons of coal ash in a single year .211 The plant uses a wet
ash handling system to collect fly ash and bottom ash
and then moves this coal ash water through a series
of three settling pond S.2611 Despite evidence that ash
handling water contains significant amounts of toxic
metals and solids, there are no limits on any of these
metals in the wastewater discharged into the small St.
Charles River .269 The lack of limits on selenium dis£
charges is even more appalling considering that the St.
Charles is impaired for selenium, meaning that the river
is not meeting water quality standards for this pollut£
an t.270 Within a few miles of the Comanche plant, the
St. Charles flows into the Arkansas River, and that por£
tion of the Arkansas River is also failing to meet water
quality standards for selenium and sulfates .271
The water discharge permit for the Comanche plant
requires monitoring for some metals at the main ash
outfall, but imposes no limits on the concentrations
of those metals in the discharge .272 While monitor£
ing is an important first step, uncontrolled discharge
of these metals into an impaired stream is danger£
ous and contrary to the Clean Water Act. Once a
waterbody is designated as impaired, the state must
determine the "total maximum daily load" (TMDL) of
the particular pollutant that the waterbody is able to
absorb and still comply with water quality standards.
However, the state of Colorado has not yet developed
a TMDL for selenium in the St. Charles River or in the
Arkansas River downstream of the confluence with
the St. Charles, and is allowing the Comanche plant to
discharge coal ash wastewaters into this impaired river
with no limits at all on selenium.
The Arkansas River is a major fly- fishing destina£
tion in Colorado, and a source of tourism income and
recreation for area residents. Because high levels of
selenium severely impairs reproduction in fish, sele£
nium limits must be imposed on major sources like
Comanche so that the St. Charles and Arkansas Rivers
can continue to support abundant fish populations.
Moreover, water resources in this part of Colorado are
incredibly precious, especially considering the excep£
tional drought the area is now experiencing. These riv£
ers should be treated like the indispensable resources
they are.
Another prime fishing destination, the Yellowstone
River in Montana, is also threatened by coal ash
discharges. The Yellowstone runs for more than 500
22 Closing the Floodgates

miles through the heart of the state, providing drink£
ing water for its cities, irrigation for farms, and superior
fishing opportunities. As the river approaches Billings,
it flattens out, warms up, and provides excellent warm -
water angling for walleye, northern pike, and catfish.
Indeed, a large stretch of the river downstream of the
J.E. Corette plant is classified as a blue ribbon stream
for fishing. This stretch of the Yellowstone River brings
substantial tourism revenue to the region through
duck- and goose- hunting outfitters and trips to
Pompey's Pillar National Monument, a sandstone bluff
on the banks of the river bearing the engraved signa£
ture of Captain William Clark, of the Lewis and Clark
expedition.
Unfortunately, the Yellowstone is contaminated by
ash pond discharges from the Corette power plant,
operated by Pennsylvania Power & Light's Montana
subsidiary, PPL Montana. The Corette plant burns a rail
train car full of Wyoming coal every hour '273 produc£
ing approximately 32,000 tons of bottom ash each
year, containing 38 tons of heavy metals.274 The bot£
tom ash water is stored onsite in ponds before being
discharged to the Yellowstone without any limits on
any toxics or metals that may be contained in that
bottom ash water. The Montana Pollutant Discharge
Elimination System permit± which is eight years over£
due for renewal± imposes limits only on oil and grease
and total suspended solid S.271
The Montana Department of Environmental Quality has
assessed the Yellowstone River upstream and down£
stream of the Corette plant. This entire section of the
Yellowstone has been deemed not suitable for aquatic
life and primary contact recreation, such as swim£
ming.271 Below the Corette plant, the river does not
meet water quality standards for arsenic, rendering the
river unsuitable as a drinking water supply. Although
Montana DEQ attributes the arsenic impairment to
natural causes, the section of the river that is impaired
begins right around the Corette plan t,277 which is re£
leasing untreated bottom ash wastewater± known to
contain arsenic± directly into the river.
The Yellowstone River provides drinking water and
irrigation supply for millions of acres of farmland
downstream of Billings. Contamination of the river with
arsenic and other coal ash constituents increases treat£
ment costs for drinking water, and degrades one of
Montana's most treasured resources.
Hundreds of coal waste ponds, holding millions of
pounds of toxic ash and scrubber sludge, dot the
country, posing a real and present danger to public
health .2711 Over a hundred of these sites have been
shown to have damaged groundwater resources, and
this known damage is probably just the tip of the ice£
berg .279 The EPA's proposed coal water pollution rules
could, if finalized in their strongest form, stop compa£
Flies from dumping any more waste into these ponds.
But even if they do, the ponds themselves will remain
an ever - present threat to communities across America.
The EPA can and should begin to fix this problem by
stopping continuing use of the ponds, but waste rules,
focused on pond closure, will ultimately be needed to
solve it.
Nowhere is this pressing problem clearer than among
the plants of the Tennessee Valley Authority (TVA).
TVA has continued to use aging ponds throughout its
system despite causing the biggest coal ash spill in
U.S. history in December 2008, when a dredge cell at
its ash pond complex at TVA's Kingston, Tennessee,
plant failed, spilling roughly 5.4 million cubic yards of
ash into the Emory River and burying 26 homes .280
According to TVA's own Inspector General, TVA might
have been able to prevent the spill had it heeded de£
cades of warning about the pond's stability.281 A federal
court recently held TVA liable for its careless failure
to protect the publiC.2112 Recovery at Kingston slowly
continues, with formal cleanup activities recently
concluding, but the waters around the plant remain
contaminated, with ash remaining in sediment at the
river bottom.
One might think TVA and the state regulators watch£
ing over its plants would have learned from this experi£
ence. But change has been slow in coming. Incredibly,
the State of Tennessee continues to allow TVA to
discharge waste from Kingston to the river without
any permit limits for dangerous metals in the ash and
scrubber sludge at the site .283
This cavalier attitude toward coal ash is the rule, not
the exception. The TVA Inspector General reports
that TVA's internal culture was "resistant to treating
ash management as much more than taking out the
garbage," failing to treat it like the hazardous waste
that it really is.284 State regulators have been just as lax.
Although independent structural engineers have found
substantial seeps and leaks at the majority of TVA's
remaining ash pond S,211 TVA has not closed its ponds,
and state regulators continue to allow the ponds
Closing the Floodgates 23

to dump their wastes into rivers through permitted
discharges.
These plants include TVA's Colbert facility in north£
ern Alabama, where bright orange, toxic - filled, leaks
from the ash ponds are flowing into a tributary of the
Tennessee River, prompting concerned citizens to start
legal proceedings against TVA for its carelessness .2116
In addition to its unpermitted leaks, Colbert is actually
authorized by the state of Alabama to dump ash pond
waste through a pipe right into a stream, with no limits
on heavy metals.287 Another permitted wastewater out£
fall discharges into the Tennessee River within about
fifty feet of a county drinking water intake. (Although
TVA has recently indicated that it will remove Colbert
from service in 2016, those discharges may continue
for years afterwards, unless TVA properly closes the
plant's dangerous ash ponds.¶
Permitted dumping is going on throughout the TVA
system, including at TVA's Gallatin Plant, which is just
upriver of Nashville and discharges wastes from its
ponds into a popular reservoir, Old Hickory Lake .21111
TVA's Shawnee Plant sends nearly 20 million gallons
per day of ash - fouled water into the Ohio River near
Paducah, Kentucky, without limits on any toxic heavy
meta 1.289 The Allen Plant in Memphis disposes of some
ash offsite, but is still authorized to send its millions
of gallons of ash ponds waste into the Mississippi
River, again with no permit limits on toxic metals.29°
Discharge reports from many other TVA plants show
levels of mercury and selenium, among other poisons,
well above water quality standard S.291
These permitted discharges need to stop, and the
EPA's Clean Water Act rules can stop them. But even
if they do, TVA's ash ponds may remain behind± Oa)E
ing, seeping sources of continuing groundwater and
surface water pollution. Gallatin's ponds, for instance,
were constructed directly on top of a landscape dot£
ted with sinkholes. Although TVA has filled some of
them, a new sinkhole opened up as recently as 2010,
and the entire pond complex continues to sit on
fragile terrain and has developed stability problems
in its containment waIIS.292 In fact, TVA itself reported
that by the late 1980s, it had identified as many as 111
sinkholes beneath Gallatin's active ash ponds± a ter£
rain so filled with holes that it was hard to keep the
pond from draining into them .293 Several sinkholes have
also opened over the years at the Colbert facility, and
independent engineers have determined that some of
its containing walls should be repaired to prevent them
from collapsing .294
Many other TVA ash ponds sit on similarly danger£
ous ground. Some TVA facilities continue to leach and
leak even long after closure. At the Allen plant, TVA
acknowledges that leaks from its ash facilities have con£
taminated groundwater wells along the shore of nearby
Lake McKellar .211 That problem arises in part from a
long- closed, now mostly dry pond which TVA maintains
is still covered by a discharge permit± which means,
under Tennessee's interpretation of its waste laws, that
TVA need not ever show that the drying ash dump
complies with the state's landfill safety standards .211
The result is that both the "closed" pond and the active
ponds continue to contaminate water supplies, without
meaningful controls under either waste or rules.
Other TVA facilities are even more precarious: its
soon -to -close Johnsonville plant, for instance, dumps
its ash on an artificial "Ash Island" in the middle of the
Tennessee River, ringed by unstable dikes± a situation
so unacceptable that TVA has prioritized the site for
cleanup to avert a potential Kingston -like disaster .217
Even without a spill, contaminated ash water leaches
straight into the river from the ponds, and will keep
doing so even if the ponds are closed .2911 There, and
throughout the system, ash ponds raise serious public
safety concerns.
TVA has said that it intends to close its ponds some£
time in the next decade and is already working toward
that goal at some plants. But TVA officials said the
same thing more than twenty years ago and failed
to take action± leaving open the Kingston pond
that eventually collapsed and spilled into the Emory
River .299 Because there are not strong federal standards
for waste handling, and TVA's closure plans haven't
been submitted to the public for comment and review,
it's far from clear that pond closures will be safe and
secure, or that they will happen quickly, to protect
the public. The water pollution standards will help dry
these huge waste sites up, but there's more work to do
to clean them up permanently.
These stories of contaminated rivers and fouled
beaches, leaky waste sites and permitted poisonings,
are just a small sample of the national coal plant water
pollution problem that decades of state and federal
neglect and industry callousness have caused. No
community should have to worry about the safety of
its water or the health of its river. That is the guaran£
tee that Congress set out in the Clean Water Act, but
that promise has long been deferred. For the sake of
24 Closing the Floodgates

the hundreds of thousands of Americans who suffer
because of that indefensible delay, it is time, now, for
the EPA to at last clean up this toxic industry.
Clean water is a basic human right. We all deserve safe
water to drink, clean lakes and rivers to boat and play
in, flourishing watersheds, and healthy fish to eat. For
too long, the coal industry has polluted our precious
waters with impunity. For 31 years, state regulators and
the EPA have mostly looked the other way, allowing
toxic dumping to continue even though it could have
been cleaned up years ago. Decades of pollution and
thousands of miles of damaged waterways are the
result.
It's time to put this dark history behind us. There is no
reason to tolerate continued dumping, and the Clean
Water Act mandates cleanup. We can eliminate most,
if not all coal plant water pollution for pennies a day.
The strongest of the EPA's proposed options will get
us to that future. But it won't happen unless ordinary
people demand controls to clean up these dangerous
discharges from the president and the EPA. Industry
lobbyists seek to weaken the basic protections that
the EPA has proposed, and the industry lobby is well -
funded and well- connected. But industry's voice is not
louder than that of the millions of Americans who have
a right to clean water. It's time for all of us to stand up
and be heard.
Closing the Floodgates 25

I
it
12
13
14
15
16
1'7
1$
19
20
21
22
I
48
49
50
51
52
53
54
55
56
5'7
EPA, Environmental Assessment for the Proposed Effluent Limitation
Guidelines and Standards for the Steam Electric Power Generating
Point Source Category 3-13 (April 2013) [hereinafter, EA].
EA 3 -34, 3 -38.
33 U.S.C. § 1314(b), 40 C.F.R. §§ 122.44(a)(1), 123.25, 125.3.
78 Fed. Reg. at 34,512.
EA 3 -34, 3 -38.
See EA.
See, e.g., EPA, Technical Development Document for the Proposed
Effluent Limitations Guidelines and Standards for the Steam Electric
Power Generating Point Source Category (April 2013) [hereinafter,
TDD]
Id, at 7- 4 -7 -16.
Id, at 7-26-7-2917-36-7-38.
EPA, Benefit and Cost4nalysis for the Proposed Effluent Limitations
Guidelines and Standards for the Steam Electric Power Generating
Point Source Category 12-2 (April 2013) [hereinafter, BCA].
See 78 Fed. Reg. at 34, 501, table XI -9 (noting that the average annual
cost to ratepayers for the most stringent option Is $6.Uo ¶.
EA at 3 -13.
See id, at 3 -14 (total toxic - weighted pollution from steam electric
power plants Is 8.3 million TWPE; total pollution from remaining top ten
Industries Is 5.78 million TWPE).
Id.
See id, at 5 -7 - 5 -17.
See infra.
33 U.S.C. § 1251(a)(1).
See 78 Fed. Reg. 34,432, 34,435 (June 7, 2013).
Id,
EPA, Steam Electric Power Generating Point Source Category. Final
Detailed Study Report (2009) at 1 -2, 4 -26, 6 -11 ( "Coal combustion
wastewater Is commonly discharged directly to surface waters
following treatment In settling ponds ") [hereinafter "2009 Study "].
BCA at 12 -2.
78 Fed Reg. at 34,501, Table XI -9 (total average annual cost to
ratepayers for the most stringent option Is $6.06¶
See EA at 3 -13, Table 3 -2.
EA at 3 -13, Table 3 -2, 3 -20 - 3 -21.
Id, at 5 -6, 5 -7.
TDD at 6 -6, Table 6 -3.
See id, at 4 -33.
Id, at 6 -11.
Id, at 6 -8, 6 -11, see also 75 Fed. Reg. at 35,150.
See TDD at 7 -22 - 7 -41.
78 Fed. Reg. at 34,512.
EPA figure are for power plants generally, regardless of fuel, but coal
power plants are by far the principal source of the toxlcs we discuss.
EA at 3 -13.
2009 Study at 6 -5.
ATSDR, Toxicological Profile for,4rsenic, at 18.
Id,
Id. at 20 -22.
2009 Study at 6 -5.
See ATSDR, Public Health Statement. Mercury at §§ 1.5 -1.6.
Union of Concerned Scientists, Environmental Impacts ofCoal
Production. 4irPollution, available at: htt:p: / /www.ucsusa.org /clean
energy./coalvswind/c02c.html
EA at 3 -13.
See ATSDR, Public Health Statement. Mercury at § 1.a.
EA at 3 -13.
2009 Study at 6 -4.
See ATSDR, Public Health Statement. Selenium at § 1.a.
2009 Study at 6 -4.
See A. Dennis Lemly, Selenium Impacts on Fish, 4n Insidious Time
Bomb, 5 Human and Ecological Risk Assessment 1139 at 5 (1999).
See generally id.
Id.
Id, at 3 -13.
Id, at 3 -8.
EA at 3 -7.
Id, at 3 -13.
ATSDR, Public Health statement. Cadmium at 5.
Id.
EA at 3 -8.
Id, at 3 -8 - 3 -9.
58 See id at 3 -13.
59 See id
60 See 78 Fed. Reg. at 34,477.
61 Id. 34,505.
62 See EA at 3 -9 - 3 -10.
63 Id, at 3 -10.
64 Id.at 3 -13.
65 Id, at 3 -14.
66 Id,
67 Id, at 3 -15 - 3 -16.
68 See id3 -16 -3 -17.
69 See Christopher Rowe et al., Ecotoxicological implications of,4quatic
Disposal of Coal Combustion Residues in the United States, 4 Review,
80 Env. Monitoring and Assessment 207 (2002) at 215,231 -236.
70 EA at 3 -34 - 3 -40.
71 A. Dennis Lemly, Wildlife and the Coal Waste Policy Debate. Proposed
Rules for Coal Waste Disposal ignore Lessons from 48 Years of Wildlife
Poisoning, Env. Sci. Tech. (2012).
72 id.
73 Lemly, Selenium impacts on Fish at 4 -6, see also A. Dennis Lemly,
Symptoms and implications ofse/enium toxicity in fish, the Be/ews Lake
case examp /e, 57 Aquatic Toxicology 39 (2002).
74 Rowe et a/, at 231.
75 Lemly, Selenium Impacts on Fish at 6 -7.
76 Rowe et a/, at 241.
77 ATSDR, Health Consultation. Welsh Reservoir, Mount Pleasant Titus
County, Texas.
78 ATSDR, Health Consultation. Brandy Branch Reservoir, Marshall,
Harrison County, Texas.
79 Laura Ruhl,AvnerVengosh et al, The Impact ofCoal Combustion
Residue Effluent on Water Resources: 4 North Carolina Example (2012).
a Id.
81 Id,
82 Id.
83 Id.
84 EA at 5 -8,
85 Id, at 5 -9.
86 Id, at 5 -8.
$7 Id, at 6 -36.
00 EA at Table 6 -15.
0 EA at 6 -22, 78 Fed. Reg. at 34,505.
1 1 EA at 3 -33.
91 BCA at 3 -6 - 3 -14.
92 NEJAC, Fish Consumption and Environmental Justice (2002) at III - Iv.
93 Id, at 2.
94 See EA at 3 -20.
95 See 33 U.S.C. § 1241(a)(1)
96 33 U.S.C. § 1314(b), 40 C.F.R. §§ 122.44(a)(1), 123.25, 125.3.
97 See section 111, infra; 2009 Report at 4 -50.
10 We provide a more complete description of our methodology In
Appendix 1. Appendix 11 reports the main results themselves.
1 1 EPA states that "[t]here are 277 plants that generate and discharge
FGD wastewater, fly ash transport water, bottom ash transport water,
and /or combustion residual landfill leachate based on responses to
the Questionnaire for the Steam Electric Power Generating Effluent
Guidelines." RIA, at 3 -4 n. 39.
100 We have not determined whether the limits that do exist have been
set to reflect best available technology or to protect water quality In
Individual cases. However, because essentially all of the permits allow
continued discharge of effluent contaminated by ash or scrubber
waste, It Is clear that states are not setting the zero discharge limits
which the best technology allows.
101 Counts Include only permits listing ash or scrubber waste discharges.
102 Two additional Indiana plants have metals limits which take effect
In 2015. We have not Included those limits In this count of currently
applicably limits, but they demonstrate that states can and should set
such limits going forward.
103 78 Fed. Reg. at 34,505.
104 Id.
105 33 U.S.C. § 1312(a), 40 C.F.R. § 122.44(d)(1)(k.
106 EA at 6 -36.
107 33 U.S.C. § 1342(b)(1)(B).
108 Several plant Information summaries In the ECHO database did not
identify a permit expiration date.
109 78 Fed. Reg. at 34,459.
26 Closing the Floodgates

110 See, e.g., Environmental Integrity Project and Earthjustice, Out
of Control. Mounting Damages from Coal Ash Waste Sites htt:p: //
eart:hjustice.org /sites /defau It /files /library /report:s /ej -eipreportout:-of-
control final.pdf, Coal Combustion Waste Damage Case 4ssessments,
U.S. EPA, July 9, 2007, available at htt:p: / /eart:hjustice.org /sites /default./
f i les /E PA -Dam age -C ase-Assessment - 2007.p df.¶
111 78 Fed. Reg. at 34,441, see also id. at 34,516 (monetizing the annual
benefits of reduced Impoundment failures under Option 4 at $295.1
million).
112 This technology review Is by no means exclusive. Many other
technologies exist which can help reduce or eliminate coal plant
discharges.
113 78 Fed. Reg. at 34,439, TDD at 4- 19 -4 -23.
114 78 Fed. Reg. at 34,473, TDD at 4 -21, Table 4 -7.
115 Id. at 4 -22.
116 Id. at 4- 24 -25.
117 Id. at 4- 23 -4 -25.
118 78 Fed. Reg. at 34,439.
119 Id, at 34,459 -60.
120 Id, at 34,460.
121 TDD at 7 -9.
122 Id, at 7- 9 -7 -13, 78 Fed. Reg. at 34,460.
123 78 Fed. Reg. at 34,460.
124 Id.
125 Id.
126 TDD at 7 -13.
127 78 Fed. Reg. at 34,458 (Table VIII -1).
128 Id, at 34,485- 34,486 (Table IX -4).
129 Id.
130 78 Fed. Reg. at 34,458 (Table VIII -1).
131 Id, at 34,504 (Table XII -1).
132 See id. at 34,494 (Table IX -4).
133 Id, at 34,501 (Table XI -9).
134 Id, at 34,503 (Table XI -11).
135 See, e.g., Memorandum from James Hanlon, EPA, Director of the
Office of Wastewater Management to EPA Water Division Directors,
Regions 1 -10 & Attachment A: Technology Based Effluent Limits, Flue
Gas Desulfurizatlon (FGD) at Steam Electric Facilities (June 7, 2010)
(explaining that EPA Is conducting a rulemaking to "address" this
wastestream and that current controls are not adequate), 74 Fed. Reg.
55,837, 55,839 (Oct. 29, 2009).
136 74 Fed. Reg. at 55,839.
137 Id.
138 See Redline at 15.
139 78 Fed. Reg. at 34,458.
140 Id.
141 Redline at 186.
142 See, e.g., Lisa Helnzerling, Who Will Run the EP4?, 30 Yale Journal on
Regulation 39 (2013), available at: htt:p: / /jreg.commons.yale.edu /who£
will- run - the -epa /.
143 See generally EPA, Documentation of OMB Review Under Executive
Order 12866 (June 2013) [hereinafter `Redline "].
144 EPA, Summary of the Substantive Changes Made During Interagency
Review Under EO72866 (June 2013) [hereinafter "Summary Memo "].
145 See id,
146 See id,
147 78 Fed. Reg. at 34,458.
148 See id.
149 78 Fed. Reg. at 34,485, Table IX -4.
160 See, e.g., Redline at 338 -39.
151 Redline at 137.
152 See id.
153 Redline at 144.
154 Id, at 226 -27; see also Redline at 278 -80 (OMB drafted section Inviting
further criticisms of EPA's data from Industry).
166 Id, at 213 -14.
156 See Summary Memo, see also 78 Fed. Reg. at 34,458. In doing so, EPA
was forced to change Its conclusions on whether It was appropriate to
have different standards for different sizes of plants. EPA had originally
planned to have less stringent standards for plants smaller than 50 MW,
and had concluded that such standards were appropriate for "small
generating units" Redline at 79. When EPA was forced to expand Its
exemption to 400 MW, It also deleted Its conclusion about "small" units,
Instead endorsing different standards "based on size" generally. See id.
at 80.
167 See 78 Fed. Reg. at 34,485, Table IX -4.
158 EPA Greenhouse Gas Reporting Program Data for 2011, available at
htt:p://ghgdata.epa.gov.
169 Missouri Department of Natural Resources, Fact Sheet for the Purpose
ofRenewal ofMO- 0004812, Ameren Missouri- Labadie Energy Center
(Feb. 8, 2013) at 1.
160 Jeffrey Tomlch, St. Louis Post - Dispatch, Leaking Coal,4sh at Missouri
Plant Stirs Fear for Water Safety (Sept. 1, 2011).
161 See id.
162 Id,
163 Missouri Department of Natural Resources, Site Visit Memorandum
(Sept. 27, 2011) at 1.
164 Missouri Department of Natural Resources, Permit No. MO- 0004812
(Sept. 2,1994).
165 See Missouri Department of Natural Resources, Public Notice (Feb. 8,
2013).
166 See id, at 4.
1617 EPA Greenhouse Gas Reporting Program Data for 2011.
168 See Michigan Department of Natural Resources & Environment, Permit
No. M10001848 (Sept. 29, 2005) (permit contains no toxic metals
I I m I ts)
169 See Michigan Department of Natural Resources & Environment, Permit
No. M10001848 at 3.
170 See id.
171 See id, at 6 -7.
172 Bruce Henderson, Wilmington StarNews, Metals found in
groundwater at PIC, coal plants, Jan. 24, 2012, available at htt:p: / /www.
starnewsonline. com /,)rt:icle /20120124/AR FICI.. ES/120129 €8:32.
173 Ruhl, at al, The Impact ofCoal Combustion Residue Effluent on
Water Resources: A North Carolina Example, Environ. Sci. & Technol.
(accepted Sept. 30, 2012), at Table 1 (volume of ash discharge).
174 North Carolina Department of Environment and Natural Resources,
NPDES Permit No. NC0004987, at 6.
175 Catawba Rlverkeeper, Lake Norman Page, last viewed June 6, 2013),
at htt :p: / /www.catawbariverkeeper.org /our - work /covekeepers /lake-
norman page, U.S. EPA, Coal Combustion Residues (CCR) - Surface
Impoundments with High Hazard Potential Ratings (updated April
2012), available at http://www.epa.gov/osw/nonhaz /industrial/special/
fossil ccrs -fs
176 Southern Environmental Law Center, Press Release, North Carolina
Sues Duke Energy In Charlotte for Pollution of Mountain Island Lake,
May 28, 2013, available at htt :p: / /www.catawbariverkeeper.org /issues/
coal- ash -1 /state- files- second lawsuit against -duke- energy.
177 North Carolina Department of Environment and Natural Resources,
NPDES Permit No. NC0004961, at A(2).
178 NPDES Permit No. NC0004961, at A(14).
1'79 Id
180 Ruhl, at al, The Impact of Coal Combustion Residue Effluent on
WaterResources: A North Carolina Example, Environ. Sci. & Technol.
(accepted Sept. 30, 2012), at Table 1.
181 North Carolina Department of Environment and Natural Resources,
NPDES Permit No. NC0004979 at 2, 4.
182 North Carolina Coastal Reserve, Zeke's Island Reserve (2007), at htt:p: //
www.nccoastalreservenet/About: = Fhe- Reserve/National- Reserve - Sites
Zeke's- Is I a nd /60. aspx.
183 Gareth McGrath, Long after coal stops burning at Sutton, legacy
willlive on in toxic coal ash, StarNewsOnline, Aug. 7, 2010,
available at htt: p:// www.starnewsonline.com /art:icle /20100 €807/
AR FICI.. ES /100 €809762 ?p = =1 &tc =pg.
184 North Carolina Department of Environment and Natural Resources,
NPDES Permit No. NC0001422 at Table (A)(1).
185 North Carolina Water Quality Assessment Status for Reporting Year
2010, Atlantic Ocean Segment NC99 -(2).
186 North Carolina Water Quality Assessment Status for Reporting Year
2010, Segment NC18- (71)a.
1$7 North Carolina Wildlife Res. Comm'n, Bob Barwick, Fisheries Biologist,
An Update on Largemouth Bass Management at Sutton Lake (2008).
188 N.C. Wildlife Resources Commission, Division of Inland Fisheries, Sutton
Lake Sportfish Assessment (Winter 2010), at 2.
189 Bruce Henderson, Metals found in groundwater at N.C, coal plants,
Wilmington StarNews, Jan. 24, 2012, available at htt:p: / /www.
starnewsonline. com lart:icle12 0 1 2 01 24 /AR FICI.. ES/120129 €8.32.
190 See Southern Environmental Law Center, Press Release, Conservation
Groups Seek to Stop Progress Energy's Illegal Coal Ash Pollution of
Sutton Lake (June 2013), available at: htt :p: / /www.sout:hernenvironment.
org /newsroom /press releases /coal ash pollution sut:ton lake not 6-
19 -13 /.
191 Illinois Department of Natural Resources, The Illinois River Basin, its
Natural Resource Values, Conservation and Restoration, available at:
http://www.ifishillinois.org/profiles/rivers&creeks/lilinois/ii basin.htmi.
192 See Illinois Environmental Protection Agency Illinois Integrated Water
Qualify Report and Section ,50,5(d) List, Appendix A-1 at] (2012) ; see
also Illinois Department of Public Health, Statewide methylmercury
advisory (2013), available at: htt: p:// www.idph.state.il.us /cnvhealth/
fishadvisorylfishadvisory _ga.htm.
193 Based on data in EPA's ECHO database.
194 Ameren is selling many of its holdings to Dynegy.
Closing the Floodgates 27

196 Illinois Environmental Protection Agency, NPDES Permit No. IL001554
(May 24, 2011).
196 Id,
197 Illinois Environmental Protection Agency, NPDES Permit No. IL0001970
(Jan. 11, 2006).
198 Id,
199 Illinois Environmental Protection Agency, NPDES Permit No. IL0001571
(Sept. 14, 2012).
200 Illinois Environmental Protection Agency, NPDES Permit No. IL0002216
(Feb. 4, 2000).
201 Illinois Environmental Protection Agency, NPDES Permit No. IL0064254
(Nov. 30, 2000).
202 Illinois Environmental Protection Agency, NPDES Permit No. IL000208
(May 31, 2005).
203 Illinois Environmental Protection Agency, NPDES Permit No. IL0002232
(Nov. 30, 2011).
204 See id.
206 Sierra Club et. Al. v. Midwest Generation, LLC. PCB 2013 -015. Filed
10/3/2012
206 See http: / /dnr. state. il. us /l..ands /landmgt. /parks /R1 /POWER FON.H FM.
207 Environmental Integrity Project Analysis from U.S Toxic Release
Inventory data, Disposal in Coal Ash Ponds Increases 9% in 2010 (Jan. 5,
2012), available at: htt: p:// www .environmentalintegrity.org /01. 05 2012.
chip.
208 See id.
209 See id.
210 Id.
211 See Alabama Power, NPDES Permit Application, Miller Steam Plant
(Aug. 2011) at 19.
212 Alabama Department of Environmental Management, NPDES Permit
No. AL0027146 (Jan. 25, 2007).
213 Images from Black Warrior Rlverkeeper (Feb. 26, 2013).
214 See generally PCR Engineers & Consultants, Final ReportCCW
Impoundments Inspection Report: Gorgas Steam Plant (Sept. 2009),
available at: htt:p: / /www.epa.gov /osw /nonhaz /industrial /special /fossil/
s u rveys2 /g o rg a s -f i n a I. p d f.
215 Alabama Department of Environmental Management, NPDES Permit
No. AL0002909 (Sept. 6, 2007).
216 See htt:p: / /www.southernstudies.org /2009 /01 /coals- ticking- timebomb-
could disaster -strip a coal ash -dump - near- youhtml.
217 Alabama Department of Environmental Management, NPDES Permit
No. AL0002917 (Oct. 9, 2007).
218 National Environmental Justice Advisory Council, Fish Consumption
and Environmental Justice (Nov. 2002).
219 International Joint commission, PCB con taminated Sedimen t
Remediation in Waukegan Harbor, available at: www.ijc.org /php/
publications /html /cases /waukegandwaukegan.htm1.
220 htt:p: / /www.idph. state .il.us /envhealth /f`ishadvisory/
wau keg annort.hharbor.htm.
221 See Midwest Generation Factsheet, htt:p: / /www.edison.com/
files /2005 factsheet waukegan.pdf.
222 NAACP, Coal Blooded Putting Profits Before People (2012), available
at: htt:p: / /www.naacp.org /pages /coal- bloodedl at 92.
223 Id.
224 Id.
225 IEPA, Illinois EPA's Ash Impoundment Strategy Progress Report
(October 2011), available at: htt:p: / /www.epa.state.il.us /water /ash-
impoundment /documents /ash -impoundment - progress- 102511.pdf
226 IEPA, Violation Notice Midwest Generation LLC, Violation Notice No.
W- 2012 -00056 (June 11, 2012).
227 Sierra Club et. al. v. Midwest Generation, LLC. PCB 2013 -015. Filed
10/3/2012.
228 Illinois Environmental Protection Agency, NPDES Permit No. IL0002259
(July 19, 2000).
229 Illinois Environmental Protection Agency, Draft NPDES Permit. No.
IL0002259 (Feb. 8, 2013)).
230 EPA ECHO database reporting for Waukegan, available at www.epa-
echo.gov/cgi- bin /getIcReport:.cgi ?t:ool::: :echo &IDNumber::::11..0002259.
231 Dr. Ranajit Sahu, Technical Report DrySorbent Injection (DSI) and ifs
Applicability to TV4's Shawnee Fossil Plant (SHF) (Apr. 2013) at 15 -16.
232 See generally NAACP, Coal Blooded. Putting Profits Before People at
App. I.
233 See Sierra Club factsheet, We Are the Owners ofthe Omaha Public
Power District (2013), Grist, Mary Anne Hitt, Fighting for Environmental
Justice in Omaha (Apr. 9, 2013).
234 Sierra Club factsheet, We Are the Owners ofthe Omaha Public Power
District (2013).
235 Nebraska Department of Environmental Quality NPDES Permit No.
NE0000621(Sept. 30, 2009).
236 See id, at 5.
23'7 Id,
28
238 See Nebraska Fish Advisories, available at: http: / /www.deq.state.ne.us/
Su rface W. nsf /Pages /F CA.
239 See http: / /www.ewg.org /t.apwater /images /EWG rated- utilities.pdf.
240 See generally NAACP, Coal Blooded Putting Profits Before People at
u q.
241 Sierra Club, State ofDetroits Environment (2013), available at: http: //
action. sierraclub .org /site /DocServer /State of Detroit s Environment.
pdf ?doclD.::12741.
242 Michigan Department of Environmental Quality, Permit No. M10001724
(Aug. 11, 2008).
243 Id, at 3.
244 Personal communication w/ Detroit Rlverkeeper Robert Burns (June 5,
2013).
245 Kalkirtz at al., University of Michigan Masters' Thesis, Environmental
Justice and Fish Consumption Advisories on the Detroit River Area of
Concern (May 2008).
246 Id, at 66.
247 See Michigan Fish Advisories, http: / /www.michigan.gov /documents/
FishAdvisory03 673547.pd_f.
248 Id, at 34,458 Table VIII -1.
249 Don Hopey, FirstEnergy to ship Little Blue Run coal wastes to Fayette
County, Pittsburgh Post - Gazette, Jan. 25, 2013, available at http: / /www.
post-gazette.com/stories/local/region/f`irstenergy-to -ship -little -blue -
run -coal wastes to fayette- county- 671916/.
260 See U.S. Envtl. Prot. Agency, TRI Explorer, htt:p: / /iaspub.epa.gov/
triexplorer /tri_ release.chemical.
251 See Pennsylvania Dep't of Environmental Protection, 2072Pennsylvania
Integrated Water Quality Monitoring and Assessment Report -
Streams, Category ,5 Waterbodies, Pollutants Requiring a TMDL,
at 680, 683, and 692. Report Is available at htt:p: / /files.dep.state.
pa. us/ Water / Drinking %20Water%20and%20FaciIity%20 Regulation/
Wa terQualityPortalFiles /2012'1201ntegrated'1201 ist /2012'`20
Streams %20Category %205.pdf.
252 See Ohio River Fish Consumption Advisories - Unit 1 Advisories 2012 at
htt:p //2.16.68. 102. 17€ 3 /comm /fishconsumption /unitl.asp
253 See Pennsylvania Dep't of Environmental Protection, NPDES Permit No.
0027481.
254 FirstEnergy, Form 14R: Residual Waste Landfills and Disposal
Impoundments, Quarterly and Annual Water Quality Analysis
(submitted to DEP) (2006 -2012) (quarters 1 and 3 for 2012 were
unavailable for review).
266 Id.
256 Id. (Quarter 3, 2012).
267 Don Hopey, FirstEnergy to ship Little Blue Run coal wastes to Fayette
County, Pittsburgh Post - Gazette, Jan. 25, 2013, available at htt:p: / /www.
post- gazett:e.com /stories /local /region /f`irstenergy -to -ship -little-blue-
run -coal wastesto fayett:e- county - 671916/.
258 Joanna Castle Miller, What's Killing Labelle, P4z, Nov. 3, 2010, available
at htt:p: / /t.hemarginalized.com/ 2010 /11 /03 /Wh,)ts- killing- labelle -pa/
269 See Pennsylvania Dep't of Environmental Protection, 2012
Pennsylvania Integrated Water Quality Monitoring and Assessment
Report - Streams, Category ,5 Waterbodies, Pollutants Requiring a
TMDL, at 594 -99. Report is available at htt:p: / /files.dep.state.pa.us/
Water /Drinking'`20Wa ter'` 20and '`20Facility'`20Regulation /
WaterQualityPortalFiles /2012 %201ntegrated %201 ist /2012%20
Streams %20Category %205.pdf.
260 PA Dep't of Envtl. Protection, NPDES Permit No. PA0002895.
261 Id, at page 2k.
262 North Carolina Department of Environment and Natural Resources,
Permit No. NC0000396, at A(2). The permit limits discharges of
mercury because the French Broad River Is not meeting water quality
standards for that metal. See U.S. Environmental Protection Agency,
French Broad Water Quality Status Assessment for 2010, available at
htt:p: / /iaspub.epa.gov /t.mdl waters10 /att:ains waterbody.control ?p_
list id FN06010105001 1000 &p cycle 2010 &p report type
263 Discharge Monitoring Reports filed by Duke Energy, as reported In
EPA's ECHO Database.
264 North Carolina Department of Environment and Natural Resources,
Permit No. NC0000396, Outfall 001.
265 Ruhl, at al, The Impact ofCoal Combustion Residue Effluent on
Water Resources: A North Carolina Example, Environ. Sci. & Technol.
(accepted Sept. 30, 2012), at C.
266 Id, at C.
267 U.S. DOE's Energy Information Administration, Form EIA -923, Electric
Power Data. 2011.
268 Colorado Dept. of Public Health and Environment, NPDES Permit No.
CO- 0000612.
269 Id, at Part 1, page 4.
270 See U.S. EPA Watershed Assessment, Tracking and Environmental
Results, 2010 Water Body Report for St. Charles River, Segment
COARM06_3400 (2010), available at htt:p: / /ofmpub.epa.gov/
tmdl waters10 /att:ains waterbody.control ?p list id &p au
id =COARMA06 3400 &pcyck =2010 &p state = =CO
271 See U.S. EPA Watershed Assessment, Tracking and Environmental
Results, 2010 Waterbody Report for Arkansas River - Fountain Creek to
near Avondale (Waterbody ID: COARLA01A_3400).
Closing the Floodgates

272 Colorado Discharge Permit No. CO- 0000612 (Issued Sept. 24, 2008), at
Ufa.
2'73
2'74
2'75
2'76
2'7'7
2'78
2'79
280
281
282
283
284
I
PPL Montana, J.E. Corette Plant profile, at htt:p: / /www.ppimontana.
com /producing +power /power +pl ants /`J.E. +Corett:e.htm
Natural Resources Defense Council analysis of data reported to Energy
Information Administration In 2005, Contaminated Coal Waste: Data
& Projections for Existing and Proposed U.S. Coal -Fired Power Plants,
available at www.nrdc.org /energy /coalwaste /M Fasp.
See MPDES Permit No. XYZ, Outfall 003.
See Montana DEC, Clean Water Act Information Center, 2012 Water
Quality Information for Water Body Segments MT43F001_011 and
MT43F001_010, available at ht t: p:l lcwaic .mt.gov /det_rep.aspx?segld:::
M C43F001 010 &gryld =101134 (section upriver Corette plant), htt:p: /1
cwaic.mt.govfdet rep.aspx ?segld =M 143F001 010_ &gryld= =101134
(section downriver of Corette plant).
See 2012 Water Quality Information for Water Body Segment
MT43F001_010, Impairment Information Table.
See generally, Jeff Stant at al., Out of Control: Mounting Damages
from Coal Ash Waste Sites (Feb. 24, 2010), available at: htt:p: / /www.
environmentalintegrity.org /news _reports/news 02 24 10.php
See id
TVA, Office of the Inspector General, Inspection Report: Review of the
Kingston Fossil Plant Ash Spill Root Cause Study and Observations
4bout4sh Management (July 23, 2009), available at: htt:p: / /oig.tva.
gov/PDF/09rpts/2.008-12283 -02.pdf.
Id. at4.
Bobby Allen, The Tennessean, TI4 Held Responsible forMassive Coal
Ash Spill (Aug. 23, 2012), available at: h tt:p: / /usatoday30.usatoday.com/
newslna tionlstoryl2012- 0 €3- 231tva coal - ash- spill/57246824/1.
Tennessee Department of Environment and Conservation, NPDES
Permit No. TN0005452.
See TVA, Office of the Inspector General, Inspection Report: Review of
the Kingston Fossil Plant Ash Spill Root Cause Study and Observations
About Ash Management at 31.
See generally Stantec Engineering Reports, posted at htt:p: / /www.tva.
comlpowerlstantec2lindex.htm.
Southern Environmental Law Center, 60-Day Notice of Violations and
Intent to File Citizen Suit re. Colbert Plant (Feb. 13, 2013).
Alabama Department of Environmental Management, NPDES Permit
No. AL0003867 (Jan. 7, 2008).
See Tennessee Department of Environment and Conservation, Permit
No. TN0005428 (June 26, 2012).
289 Kentucky Department for Environmental Protection, Pollutant
Discharge Elimination System Permit No. KY0004219 (July 13, 2005).
290 Tennessee Department of Environment and Conservation, Permit
No.TN0005355 (Aug. 4, 2005).
291 See, e.g., Environmental Integrity Project Comments on Discharge
permits for the Cumberland (Mar. 24, 2010), Johnsonville (Mar. 16,
2010), and Bull Run (Apr. 9, 2010) discharge permits (documenting
these dangerous pollution levels).
292 See Sta ntec, Report of Geotechnical Exploration and S lope Stability
Evaluation. 4sh Pond /Stilling Pond Complex" Gallatin Fossil Plant
Gallatin, Tennessee (May 27, 2010), available at: htt:p: / /www.tva.com/
power /stantec2 ./GAF /GAF- GE- 100527'`20(rpt_001 17555901 €3).pdf.
293 TVA, 4n Evaluation of the Impacts of the Gallatin Fly 4sh Pond to
Groundwater Resources (Aug. 1989).
294 See Sta ntec, Report of Geotechnical Exploration and Slope Stability
Evaluation. Ash Pond" Colbert Fossil Plant Tuscumbia, Alabama (Jan.
22, 2010), available at: htt:p: / /www.tva.com /power /stantec2 ./COF/
bottom ash pond.pdf.
295 TVA, Groundwater Monitoring Report - Allen Fossil Plant - February
2008, at 2 (Aug. 22, 2008).
296 See, e.g., Letter from Robert J. Martineau, Jr., TDEC Commissioner, to
Joshua Galperin, Southern Alliance for Clean Energy (Apr. 23, 2012)
( "Industrial and municipal wastewater treatment plants, such as TVA
ash ponds, are not subject to solid waste permitting process...When
the ash pond Is converted from a wastewater treatment unit to a solid
waste management unit, oversight will be transferred to Solid Waste
Management f¶
297 Ben Hall, NewsChanne15, TV4 Focuses on Johnsonville Ash Pond (Dec.
21, 2009), available at: http://www.newschannel5.com/stor.y/11712450/
tva - focuses- on Johnsonville-ash -pond.
298 Charles Norris, Geo- Hydro, Inc., Keporton TI4'EJohnsonville 14sh Island
Placement Area and Closure Plan (Dec. 12, 2011).
299 TVA, Office of the Inspector General, Inspection Report: Review of the
Kingston Fossil Plant Ash Spill Root Cause Study and Observations
4bout4sh Management at Appendix C, 15.
Closing the Floodgates 29

We identified 386 operating coal -fired power plants
using the EPA's Clean Air Markets Program database.
Using EPA's Enforcement and Compliance History
Online (ECHO) database, we reviewed effluent lim£
its and monitoring requirements for arsenic, boron,
cadmium, lead, mercury, and selenium and expiration
dates for each of the coal -fired power plants. Our
review focused on these pollutants because they are
almost always found in coal ash and scrubber waste
and are particularly harmful to health or aquatic life. In
addition, we reviewed whether each power plant dis£
charged into impaired waters and included the cause
of impairment if it was identified in the ECHO data£
aQi=ai . Our review focused on these pollutants because
they are almost always fund in coal ash and scrubber
waste and are particularly harmful to health or aquatic
(N. Where available, we reviewed individual permits
for coal -fired power plants to identify waste streams
discharged at the plant and any effluent limits and
monitoring requirements for arsenic, boron, cadmium,
lead, mercury, and selenium. Where data related to ef£
fluent limits and monitoring requirements in the ECHO
database conflicted with the plant's current permit, the
data in the plant's permit was used in the analysis. We
did not have access to permits for all 386 plants.
In some cases, multiple power plants are regulated un£
der a single permit. For example, the HMP &L Station 2,
R.D. Green, and Robert Reid power plants in Kentucky
are regulated under one discharge permit. These
power plants are identified as three separate plants in
our analysis (as opposed to one plant).
DATA LIMITATIONS: The information contained in this
report is based on company self- reported data ob£
twined through publicly accessible U.S. Environmental
Protection Agency websites and Freedom of
Information Act requests. Occasionally, government
data may contain errors, either because information
is inaccurately reported by the regulated entities or
incorrectly transcribed by government agencies. This
report is based on data retrieved in March of 2013, and
subsequent data retrievals may differ slightly as some
companies correct prior reports.
30 Closing the Floodgates

Closing the Floodgates
mu
nry
un mu
nry
Cm (eB
BM
Npcjrb
Cbss
Alabama Power
1770.7
AL0002879
10/31/2013
Arsenic,
Arsenic,
Bti
j
Dpn gboz
Nfsdvs
Nfsdvs
BM
X bti johrpo
Charles R
PowerSouth Energy
538
AL0003671
2/28/2010
Mbe
Opof
Ash &
Tombigee River
ivpx n bo
Cooperative, Inc
Tdsiccfs
BM
Dpmf su
Dpmf su
Tennessee Valley
1350
AL0003867
5/31/2010
Arsenic, Lead
Cpof
Bti
Bvu psjrz
BM
Ti f raz
E C Gaston
Alabama Power
2012.8
AL0003140
6/30/2012
Bstf ojd
Bstf ojd,
Bti
Don gboz
BM
Frpx bi
Hbetefo
Alabama Power
138
AL0002887
1/31/2008
Bstf ojd
Bstf ojd
Bti
- Coosa River Ph; Phosphorus
Dpn gboz
(Neely Henry
BM
X brhf s
Hpshbt
Alabama Power
1416.7
AL0002909
9/5/2012
Bstf ojd
Bstf ojd,
Ash
Don gboz
BM
Hsffof
Greene
Alabama Power
568.4
AL0002917
9/30/2012
Bstf ojd
Bstf ojd
Bti
j Dpvouz j
Dpn gboz
BM
Jefferson
James H
Alabama Power
2822
AL0027146
1/31/2012
Opof
Opof
Bti
Miller Jr
Don gboz
BM
IbdI tpo
Widows Creek
Tennessee Valley
1968.6
AL0003875
3/31/2010
Bstf ojd
Cpof
Bti
Bvu psjrz
BS
Cforoo
Flint Creek
Southwestern
558
ARROOB277
6/30/2014
Opof
Opof
Bti
Swepco Lake Ph Phosphorus Total
Power Plant
Electric Power
Suspended Solids
Don gboz
BS
.befgfoefocf
.befgfoef odf
Entergy
1700
AR0037451
6/30/2017
Arsenic,
Cpof
Ash&
j
Dps4psbgpo
Cadmium,
TcLwccfs
Mercury, Lead,
'...
Tfrhojvn
BS,,,,,,
Njttjttjggj
Plum Point
Plum Point Energy
720
AR0049557
1/31/2012
Tfrhojvn
Opof
Bti
Energy
Associates, Inc
Trbgoo
BS
Jefferson
White Bluff
Entergy
1700
AR0036331
6/30/2017
Cpof
Cpof
Bti
Dpsgpsbgpo
B[
Dpd jtf
Apache
Arizona Electric
408
AZ0023795
2/21/2005
Arsenic,
Opof
'...
....
Trbgpo
Power Cooperative
Tfrhojvn
,...
.....
,... ... ...
B[
Obvblp
Di PA
..Arizona Public
1128.8
AZ0023311
8/10/2003
Cpof
Cpof
,B[,,,,,,,
,
Service Company
,
Cgn b,,,,,,,,
Irvington
Tucson Electric
173.3
Opof
Opof
Generating
Power Company
Trbgoo
B[
Dpc¢ojop
Navajo
Salt River Project
2409.3
AZ0000010
Cpof
Cpof
Cpof
Generating
Trbgpo
DP
Ef m4
Bsbgbi of
Public Service
1525
CO0001091
12/31/2012
Mercury Lead
Tfrhojvn
Bti
South Platte
Company of
Tfrhojvn
Sjvkf s
Dprpsbep
DP
Bebnt
Di fspl f
Public Service
676.3
CO0001104
4/30/2014
Boron,
Cadmium
Bti
- South Platte Dbenjvn
Company of
Cadmium,
Lead,
SjWS
Dprpsbep
Mercury, Lead,
Tfrhojvn
Tfrhojvn
DP
(Dvfcrp
Don bod f
Public Service
1635.3
CO0000612
10/31/2013
Opof
Opof
St. Charles Tfrhojvn
Company of
Sjvkfs
Dprpsbep
DP
Moffat
Dsbjh
Tri -State Generation
1427.6
COR900399
6/30/2017
Cpof
Cpof
Unnamed
& Transmission
tributary
- Johnson Gulch
DP
Spvw
I bzef o
Public Service
438.6
COR900429
6/30/2017
Opof
Opof
Marshall
Company of
Roberts Ditch
Dprpsbep
-Yampa River
DP
Cspx fst
Abn bs
Lamar Utilities
43.5
COR900436
6/30/2017
Cpof
Cpof
Arkansas River
Cpbse
DP
El Paso
Martin Drake
Colorado Springs
257
CO0000850
10/31/2010
Lead Arsenic
Opof
Fountain Creek
Vgrjajf t
Tfrhojvn
DP
NpouEptf
O✓drb
Tri -State Generation
113.8
CO0000540
10/31/2011
Mercury,
Cpof
San Miguel
& Transmission
Lead, Boron,
SjW S
''.....
Arsenic
''.....
DP
Mon f s
Rawhide
Platte River Power
293.6
COR900559
6/30/2017
Opof
Opof
Boxelder Creek
Energy
Bvu psjrz
South Platte
Trbgoo
Sjtif s
DP
El Paso
Ray D Nixon
Colorado Springs
207
COR900550
6/30/2017
Cpof
Cpof
Unnamed
Vgrjajft
Tributary - Little
Fountain Creek '..
DP
Cpvrefs
Nbm you
Public Service
191.7
CO0001112
10/31/2017
Cadmium,
Opof
Bti
Tributaries to Tfrhojvn
Company of
Boron,
St. Vrain Creek
Dprpsbep
Mercury,
Bstf ojd
Closing the Floodgates

32 Closing the Floodgates
mu
nry
un mu
nry
mia
�
Cm (eB
DU
Fairfield
Bridgeport
PSEG Power
400
CT0030180
12/29/2010
Mbe
Cpof
- Cedar Creek/ CvLifoLL
Harbor Station
Connecticut, LLC
Long Island '...
Sound; '...
Brideport '...
I bs: ps
EF
Tvttfy
Indian River
Indian River Power,
782.4
DE0050580
12/31/2016
Opof
Opof
Bti
K&D
EF
Lfou
NRG Energy
NRG Energy, Inc
18
- DE0050466
8/31/2013
Cpof
Cpof
Center Dover
'...
CM
I fntcpspvhi
Big Bend
Tampa Electric
1822.5
FL0000817
12/29/2016
Arsenic
Nfsdvs
Tdsiccfs
Big Bend Bayou
Don qboz
Mercury, Lead,
Tfrhojvn
0A
Ciorh
C D McIntosh
City of Lakeland
363.8
FL0026301
12/5/2015
Cpof
Cpof
Jr Power
Lakeland Electric
Crhou
'......
CM
Evvbm
Cedar Bay
Cedar Bay
291.6
FL0061204
11/4/2015
Opof
Opof
Broward River
Generating
Operating Services
Co. LP
K&D
0A
Ftdbn cjb
Crist Electric
Gulf Power
11351
FL0002275
1/27/2016
Arsenic,
Arsenic,
Bti
Generating
j Dpn qboz
Cadmium,
Cadmium,
Crhou
Mercury, Lead,
Mercury, Lead,'...
Tfrhojvn
Tfrhojvn
CM
DJwit
Crystal River
Florida Power
2442.7
FL0000159
3/11/2017
Arsenic
Arsenic
Dpslpsbypo
Cadmium,
Cadmium,
Mercury, Lead,
Mercury, Lead
Tfrhojvn
Tfrhojvn
0A
Psbohf
Curtis H
Orlando Utilities
929
FL0681661
6/23/2016
Cpof
Cpof
Stanton
j Dpn njttjpo
Energy Center
C3vl
Brbd vb
Ef f s bnf o
Gainesville Regional
250.7
FLROSB392
2/2/2016
Cpof
Opof
Vglxft
0A
Nbajo
Indiantown
Indiantown
3954
FLROSB625
4/28/2015
Cpof
Cpof
Cogeneration,
j Cogeneration
NO
Limited Partnership
'...
CM
Cbz
Lansing Smith
Gulf Power
340
FL0002267
12/1/2014
Arsenic
Mbe
Bti
Alligator Bayou
Generating
Don qboz
Cadmium,
Qbou
Mercury, Lead,
Selenium,
Cpspo
0A
Evvbm
CpsJ tjef
I1FB
595
FL0001031
5/8/2017
Arsenic,
Arsenic,
Cadmium,
Mercury, Lead,
j
Mercury, Lead,
j Tfrhojvn
Tfrhojvn
CM
Cprh
Cprh
Tampa Electric
3263
FL0043869
3/30/2014
Arsenic,
Arsenic,
Bti
'...
Don qboz
Cadmium,
Cadmium,
Lead,
Lead,
Tfrhojvn
Tfrhojvn
0A
fbdI tpo
Scholz Electric
Gulf Power
98
i FL0002283
9/22/2015
Cadmium,
Mbe
Bti
Apalachicola
Generating
j Dpn qboz
Mbe
j Sjwfs
Crhou
'......
CM
CUwbn
Tfnfoprh
Seminole Electric
14292
FL0036498
8/28/2017
Arsenic
Selenium
Tdsiccfs
Rice Creek Cadmium Iron Lead
Cooperative, Inc
'...
'....
Cadmium,
Lead, Mercury
Nickel; Silver
Lead, Mercury
0A
Evvbm
St. Johns
I1FB
1358
FL0037869
2/9/2011
Arsenic,
Arsenic,
Bti
'...
River Power
Mercury, Lead
Mercury,
Tfrhojvn
HB
Cbspx
Cpxfo
Georgia Power
34986
GA0001449
6/30/2012
Opof
Opof
Tdsiccfs
Etowah River
Don qboz
HB
....Grpze
I bn npoe
Georgia Power
953
GA0001457
6/30/2012
Cpof
Cpof
Ash&
Coosa River
j Dpn qboz
tcLwccfs
HB
CUwbn
Harllee Branch
Georgia Power
1746.2
GA0026051
2/28/2010
Opof
Opof
Bti
Don qboz
HB
Di bid bn
Lsbgj
Georgia Power
207.9
- GA0003816
5/31/2004
Arsenic, Lead,
Cpof
Bti
j Dpn qboz
Mercury,
Selenium,
'...
Dbenjvn
HB
Effingham
McIntosh
Georgia Power
177.6
GA0003883
5/31/2004
Arsenic, Lead,
Opof
Bti
(6124)
Don qboz
Mercury,
Selenium,
Dbenjvn
HB
Epvhi fsuz
Nj ui frm
Georgia Power
163.2
GA0001465
2/28/2015
Cpof
Cpof
Bti
j Dpn qboz
,
HB
Npospf
Tdi f sf s,,,,,,,,
Georgia Power
3564
GA0035564
11 /30/2006
Cpof,,,,,,,,,
Opof
Bti
Don qboz
HB
I fbse
X botrF¢
Georgia Power
1904
GA0026778
8/31/2011
Cpof
Cpof
Dpn qboz
HB
Dpx f Lb
Zbuf tGeorgia
Power
14873
GA0001473
8/31/2011
Cpof,,,,,,,,,,,
Opof
Ash &,,,,,,
Chattahoochee
Don qboz
Tdsiccfs
River
J3
Trps
Bn ft
City of Ames
1088
IA0033235
7/22/2006
Cpof
Cpof
Bti
South Skunk
j SjWs
Des Moines
CUs)mhrpo
Interstate Power&
212
IA0001783
9/4/2011
Cpof,,,,,,,,,,,
Opof
Bti
Light Company
32 Closing the Floodgates

Closing the Floodgates 33
mu
nry
un mu
nry
Cm (eB
J3 ......_.
Drhz .........
Earl Wisdom
Corn Belt Power
33
IA0004570
3/26/2007 ,..
Cpof .........
Cpof
.... ..
......._
DppgfsbgW
J3
Nvtdbyof
Fair Station
Central Iowa Power
62.5
IA0001562
10/20/2014
Opof
Opof
Bti
DppqfsbqW
J3
X ppecvs
George Neal
MidAmerican
1046
IA0004103
11/30/2016
Cpof
Cpof
Bti
Missouri River
Mercury (Fish
j CpsJ
Energy Company
Consumption Advisory)
J3
X ppecvs
George Neal
MidAmerican
640
IA0061859
3/30/2014
Opof
Opof
Bti
Missouri River
Mercury (Fish
Tpv ti
Energy Company
Consumption Advisory)
J3
Brthn bl f
Abotjoh
Interstate Power&
312
IA0003735
10/1/2003
Nf be
Mbe
Bti
,foWvftb
Light Company
,
,Opof
,Opof
foWvftb
MidAmerican
8119
IA0063282
3/31/2017
Bti,,,,,,,,
Energy Company
J3
DooLpo
Milton L Kapp
Interstate Power &
218.5
IA0001759
7/15/2004
Cpof
Cpof
Bti
Light Company
J3
Nvtdbyof
Nvtdbgof
Muscatine Power
293.5
IA0001082
5/22/2008
Opof
Opof
Bti
'...
and Water
J3
X bqf rip
Puvn x b
Interstate Power &
725.9
IA0060909
3/4/2008
Cpof
Cpof
Bti
'...
Light Company
,
,38,,,,,,,,,,,,
,
,Opof,,,,,,,,,,,,
'...
N14 po,,,,,,,,
Cfnh
City of Pella,,,,,,,,
IA0032701
12/19/ 2009
Opof
Bti,,,,,,,,
J3
fyoo
Prairie Creek
Interstate Power&
213.4
IA0000540
7/31/2015
Cpof
Cpof
Bti
Light Company
,
,12/31/
,
,Bti
Tdpw
Sjvkfstjef
MidAmerican
141
IA0003611„
2016
Opof
Opof
Energy Company
J3
Black Hawk
Streeter
Cedar Falls
51.5
IA0002534
8/31/2017
Cpof
Cpof
'..
Tibypo
Municipal Electric
Nbsti brm
Tvu fshoe
Interstate Power&
1191
IA0000108
11/12/2011
Opof
Opof,,,,,,,,
Bti,,,,,,,,
Light Company
J3
Cpubc bubn ff
Walter Scott
MidAmerican
1778.9
IA0004308
2/26/2008
Cpof
Cpof
Bti
'...
Jr. Energy
Energy Company
Of ods
JS
Sboeprgi
Baldwin
Dynegy Midwest
18941IL0000043
4/30/2010
Opof
Opof
Ash
Energy
Generation Inc
Don grhy
dv1
Npoihpn fs
Coffeen
Ameren Energy
1005.4
IL0000108
1/31/2013
Boron,
Cpof
Bti
Coffeen Lake
Phosphorus; Total
Generating
Nfsdvs
Suspended Solids Total '...
Dpn gboz
Dissolved Solids Ph
Jvl
Tbohbn po
Ebnn bo
City of Springfield
667.7
IL0024767
12/31/2006
Cpspo
Cpspo
Ash &
Illinois River
Mercury Silver Nitorgen
Jvl
Tdsiccfs
Phosphorus; Total
Suspended Solids Fish
Consumption Advisory
dv1
&rtpo
Duck Creek
Ameren Energy
441
IL00SS620
2/28/2013
Boron,
Cpspo
Bti
Illinois River
Silver, Boron, Iron
'....
Resources
Nf sdvs
Nf sdvs
Generating
'...
Dpn gboz
Jvl
Cf psjb
E D Edwards
Ameren Energy
780.3
IL0001970
1/31/2011
Opof
Opof
Ash
South Branch
Fish Consumption
Resources
of the Chicago
Bevgtps
Generating
Sjtifs
Don gboz
dv1
Nbtpo
I bnbob
Dynegy Midwest
488
IL0001571
9/30/2017
Nfsdvs
Cpof
Ash &
Illinois River
Mercury; Silver; Nitorgen
Generation Inc
TcLwccfs
Phosphorus; Total
'...
Suspended Solids Fish '...
Consumption Advisory
Jvl
QvLDbn
Hennepin
Dynegy Midwest
306.3
IL0001554
4/30/2016
Nfsdvs
Opof
Bti
Illinois River
Mercury (Fish
'...
Power Station
Generation Inc
'...
'....
'.... Consumption Advisory)
dv1
X jrm
Joliet 29
Midwest Generation
1320
IL0064254
11/30/2000
Cpof
Cpof
Bti
Des Plaines
Mercury (Fish
EME, LLC
j
SjWS
Consumption Advisory)
Jvl
X frm
Joliet 9
Midwest Generation
360.4
IL0002216
3/31/2001
Opof
Opof
Ash
Des Plaines
Fish Consumption
EME, LLC
Sjtifs
Bevgt ps
dv1
Nbttbd
Joppa Steam
Electric Energy Inc
1099.8
IL0004171
7/31/2014
Boron,
Cpof
Bti
Ohio River
'......
N f sdvs
'......
Jvl
Dtgtgbo
Kincaid
Dominion Energy
1319
IL0002241
4/30/2005
Opof
Opof
Ash
Lake Sangchris
aLofod
Tibypo
Services Company
dv1
X jn)bn tpo
Nb4po
Southern Illinois
272
IL0004316
2/29/2012
Boron,
Cpspo
Ash &
'...
Power Cooperative
Nf sdvs
TcLwccf s
'...
Jvl
iVgfs
Of tpo
Ameren Energy
12348
IL0049191
1/31/2012
Boron
Cpspo
Ash &
Newton Lake
aLofott
Generating
Nfsdvs
Tdsiccfs
Don gboz
dv1
lb(fx frm
Cpx fstoo
Midwest Generation
1785.6
IL0002232
10/31/2010
Cpof
Cpof
Bti
EME, LLC
Jvl
X bti johtpo
Prairie State
Prairie State
245
IL0076996
11/30/2010
Arsenic,
Opof
Ash
Illinois River
Nfsdvs
Generating
Generating
Cadmium,
Don qboz
Don gboz
Mercury, Lead
Tf rhojvn
dv1
Abl f
X bvI f hbo
Midwest Generation
681.7
IL0002259
7/31/2005
Cpof
Cpof
Ash
tvfvD
Jvl
X frm
Will County
Midwest Generation
897.6
IL0002208
5/31/2010
Opof
Opof
Ash
Chicago
Iron Oil Nitrogen
EME, LLC
Sanitary & Ship
Phosphorus; Fish
Dbobm
Consumption Advisory
Closing the Floodgates 33

34
mu
nry
im
un mu
mn
m
a
nry
im
Cm (eB
Jv1
Nbejt po
Wood River
Dynegy Midwest
500.1
IL0000701
12/31/2014
Arsenic,
Cpspo
Bti
Wood River
Copper; Manganese
Power Station
Generation Inc.
Dbenjvn
Total Dissolved Solids
Phosphorus; Total
Suspended Solids; Ph '...
JD
Cot fz
A B Brown
Southern Indiana
530.4
IN0052191
9/30/2016
Arsenic,
Opof
Bti
Ohio River -
Mercury (fish tissue)
Generating
Gas and Electric
Boron,
'...
Evansville to
Tibypo
Don gboz
Cadmium,
VojpoLpx o
Mercury,
Tfrhojvn
JD
X bsldl
Alcoa
Alcoa Allowance
777.6
IN00SSO51
3/31/1991
Cpof
Cpof
Ash &
Ohio River -
Mercury (fish tissue)
Allowance
Management, Inc
TcLwccfs
Cannelton to
'...
Management
Cfx cvshi
.bd
JD
CPsfs
Bailly
Northern Indiana
603.5
IN0000132
7/31/2017
Arsenic
Opof
Bti
Lake Michigan
Nfsdvs
'...
Generating
Public Service
'...
Boron,
'...
Shoreline -
'...
Tibypo
Don gboz
Cadmium,
Evoft
Mercury, Lead,
Tfrhojvn
JD
Nb4po
C. C. Perry K
Citizens Thermal
23.4
IN0004677
12/31/2016
Nfsdvs
Cpof
Steam Plant
JD
V®sn jn)po
Dbzvhb
Duke Energy
1062
IN0002763
7/31/2012
Arsenic
Nfsdvs
Bti
Wabash River
Mercury (fish tissue)
Dpslpsbypo
Cadmium,
Selenium,
N f sdvs
JD
Jefferson
Clifty Creek
Indiana Kentucky
13038
IN0001759
1/31/2017
Arsenic,
Cpof
Bti
Electric Corp
Boron,
Cadmium,
'...
Mercury,
Selenium,
'...
M be
JD
X bqdl
F B Culley
Southern Indiana
368.9
IN0002259
11/30/2016
Arsenic
Cadmium
Bti
Generating
Gas and Electric
Boron,
Nfsdvs
Tibypo
Don gboz
Cadmium,
Mercury,
Tfrhojvn
JD
Gjl f
Frank ERatts
Hoosier Energy
233.2
IN0004391
9/30/2017
Arsenic,
Cpof
Bti
White River
Mercury (fish tissue)
REC, Inc.
Mercury,
'...
Tfrhojvn
JD
Npsh so
IPL Eagle
Indianapolis Power
301.6
IN0004693
9/30/2017
Arsenic
Opof
Bti
White River
Mercury (fish tissue)
Valley
& Light Company
Cadmium,
Generating
Lead, Mercury,
Trbypo
Selenium,
Boron
JD
Nb4po
IPL - Harding
Indianapolis Power
698
IN0004685
9/30/2017
Arsenic,
Cadmium,
Ash&
White River
Mercury (fish tissue)
Street Station
& Light Company
Boron,
Lead, Mercury
j TcLwccfs
j (EW Stout)
Cadmium,
(effective I
'...
Mercury, Lead,
Aug. 28, 2015)
Tfrhojvn
JD
ql f
IPL
Indianapolis Power
2146.7
IN0002887
9/30/2017
Arsenic
Boron
Ash &
White River
Mercury (fish tissue)
'...
Petersburg
& Light Company
'...
'...
Boron,
Cadmium,
Tdsiccfs '...
Generating
Cadmium,
Lead, Mercury
Trbypo
Mercury, Lead,
Selenium
Tfrhojvn
(effective
Sept. 28,
2015)
JD
Tvnywbo
Nfspn
Hoosier Energy
1080
IN0050296
12/31/2015
Arsenic,
Cpof
TcLwccfs
REC, Inc.
Cadmium,
'...
Mercury, Lead,
Tfrhojvn
JD
iv)gDsf
Michigan City
Northern Indiana
540
IN0000116
2/29/2016
Cadmium,
Opof
Bti
Lake Michigan
Mercury (Fish
Generating
Public Service
Mercury, Lead
Ti psfrjmf.
Consumption Advisory)
Trbypo
Don gboz
Evoft
JD
Gpze
R Gallagher
Duke Energy
600
IN0002798
8/31/2015
Arsenic,
Cpof
Ash
j Dps4psbypo
Cadmium,
Tfrhojvn
JD
IV qfs
R M Schahfer
Northern Indiana
1943.4
IN0053201
4/30/2015
Arsenic
Opof
Generating
Public Service
Cadmium,
Trbypo
Don gboz
Mercury, Lead,
Tfrhojvn
JD
Tqf odfs
Spol qpsu
Indiana Michigan
2600
IN0051845
11/30/2015
Boron,
Lead,
Ash&
Ohio River -
Mercury (fish tissue)
Power Company
Mercury, Lead,
j Tfrhojvn
TcLwccfs
Cannelton to
Tfrhojvn
Cf x cvshi
JD
Ef bsc pso
Tanners Creek
Indiana Michigan
1100.1
IN0002160
5/31/2015
Arsenic,
Opof
Bti
Ohio River and
Mercury in fish tissue
Power Company
Cadmium,
Tanners Creek
N f sdvs
JD
Vyhp
Wabash River
Duke Energy
860.2 -
IN0063134
10/31/2013
Arsenic,
Cpof
Bti
Wabash River
Mercury (Fish
Gen Station
j Dps4psbypo
Nfsdvs
- Wabash Gen
Consumption Advisory)
Sta to Lost
Dsf f I
''.....
JD
X bzof
Whitewater
City of Richmond
93.9
IN0063151
11/30/2013
Opof
Opof
Short Creek and
V&6Q
other Tribs
LT
Gjoofz
I prcpnc
Sunflower Electric
348.7
KS0080063
12/31/2011
Arsenic,
Cpof
Power Corporation
Cadmium,
'...
Lead,
Tfrhojvn
LT
Cpubc brpnff
Jeffrey Energy
Westar Energy Inc
2160
KS0080632
5/31/2013
Arsenic
Nfsdvs
Deep Creek
C ptgi psit
Dfoufs
Cadmium,
Mercury, Lead,
Tfrhojvn
Closing the Floodgates

Closing the Floodgates 35
mu
nry
im
un mu
mn
m
a
nry
im
Cm (eB
LT
fyoo
La Cygne :Kansas
City Power
1578
KS0080071
10/31/2009
Cpof
Cpof
Ash &
&
Light Company
TcLwccfs
'...
LT
Epvhrht
Lawrence Westar
Energy Inc
566
KS0079821
3/31/2013
Arsenic
Cpof
Ash &
Energy Center
Cadmium,
Tdsiccfs
Mercury, Lead
Tf rhojvn
LT
Xzboepuf
Nearman Kansas
City Board
261
KS0119075
12/31/2008
Cpof
Cpof
Bti
'..
DsffI of
Public Utilities
LT
X zboepuf
Rvjoebsp Kansas
City Board
239.1
KS0080942
12/31/2008
Opof
Opof
of
Public Utilities
LT
Di fsPlff
SJW sroo Empire
District
87.5
KS0079812
12/31/2013
Mbe
Cpof
Bti
Spring River
Electric
Company
'...
LT
Ti bx off
Tecumseh Westar
Energy Inc
232
KS0079731
7/31/2017
Opof
Opof
Bti
Kansas River
Mbe
Energy Center
LZ
hbx sf odf
Big Sandy Kentucky
Power
1096.8
KY0000221
3/31/2006
Cpof
Cpof
Bti
Big Sandy River Jpo
j Dpn
gboz
LZ
Jefferson
Cane Run LGE
and KU Energy
644.6
KY0002062
10/31/2007
Coof,,,,,,,,,,,
Coof,,,,,,,,,
Bti
N&D
LZ
I bodpol
Dprhnbo Big
Rivers Electric
602
KY0001937
2/28/2005
Cpof
Cpof
Bti
Ohio River
Mercury in fish tissue
Dpslpsbypo
LZ
Pi jp
D B Wilson Big
Rivers Electric
566.1
KY0054836
10/31/2004
Opof
Opof
Tdsiccfs
'...
Dpslpsbypo
LZ
Nfsdfs
E W Brown LGE
and KU Energy
757.1
KY0002020
2/28/2015
Cpof
Cpof
Bti
Herrington Lake
Methylmercury(Fish
MvD
Consumption Advisory)
'....
Ph; Total Suspended '...
Tprjet
LZ
Cppof
East Bend Duke
Energy
669.3
KY0040444
7/31/2007
Opof
Opof
Ash &
Dpslpsbypo
Tdsiccfs
LZ
Ebv4ftt
ElmerSmith Owensboro
445.3
KY0001295
3/31/2005
Cpof
Cpof
Ash&
Ohio River
Mercury (Fish
'....
Municipal
Utilities
TcLwccfs
j (Cannelton to
Consumption Advisory) '...
Cfx cvshi
LZ
DbWrm
Hifou Kentucky
Utilities
22259
KY0002038
6/30/2007
Opof
Opof
Bti
Don
gboz
LZ
Nvi rhocfsh
Green River Kentucky
Utilities
188.6
KY0002011
10/31/2004
Cpof
Cpof
Bti
j Dpn
gboz
LZ
Nbtpo
H L Spurlock East
Kentucky
16085
KY0022250
4/30/2004
Opof
Opof
Bti,,,,,,,,
Power
Cooperative
LZ
Ifoefstpo
HMP &L Big
Rivers Electric
405
KY0001929
11/30/2009
Cpof
Cpof
Bti
Station 2 Dpslpsbypo
LZ
avrhtlj
John S East
Kentucky
344
KY0003611
10/31/2013
Opof
Opof
Ash &
Lake
Nf u zm fsdds
Dppgfs Power
Cooperative
Tdsiccfs
Dvn cfsrboe
LZ
Jefferson
Mill Creek LGE
and KU Energy
1717.2
KY0003221
10/31/2007
Cpof
Cpof
Ash &
Ohio River /Mill
MvD
TcLwccfs
Creek /Pond
Dsf f I
LZ
Nvi rtrocfsh
Cbsbejtf Tennessee
Valley
2558.2
KY0004201
10/31/2009
Opof
Opof
Bti
Bvu
psjrz
LZ
X fctrfs
R D Green Big
Rivers Electric
586
KY0001929
11/30/2009
Cpof
Cpof
Bti
Dpslpsbypo
LZ
X fctufs
Robert Reid Big
Rivers Electric
96
KY0001929
11/30/2009
Opof
Opof
Bti
Dpslpsbypo
LZ
NcEsbdl f
Ti bx of f Tennessee
Valley
1750
KY0004219
8/31/2010
Cpof
Cpof
Ash &
Bvu
psjrz
TcLwccfs
LZ
U'gn crh
Trimble LGE
and KU Energy
14001,,,,,,,,
KY0041971
4/30/2015
Opof
Opof,,,,,,,,,,,,
Tdsiccfs
Dpvouz MvD
LZ
X ppeg)se
1pspof Kentucky
Utilities
75
KY0001899
1/31/2007
Cpof
Cpof
Bti
Kentucky River
Methylmercury(Fish
j Dpn
gboz
53.2 to 66.95
Consumption Advisory)
LZ
Drcd
William C East
Kentucky
216
KY0002194
11/30/2006
Opof
Opof
Bti
Kentucky River
Methylmercury (Fish
'...
Ebrh '.. Power
Cooperative
'.. '...
121.1 to 138.5
Consumption Advisory)
M8
Pointe
Big Cajun 2 Louisiana
1871
LA0054135
4/30/2014
Cpof
Cpof
Bti
j Dpvqff
Generating,
LLC
M3
Sbgjeft
Brame Energy Cleco
Power LLC
558
LA0008036
3/31/2011
Mbe
Mbe
Bti
Of oafs
M8
De Soto
Dolet Hills Cleco
Power LLC
720.7
LA0062600
10/28/2017
Mbe
Mbe
Ash &
'..
! Power Station !
TcLwccfs
M3
Dbrdbtjfv
RS Nelson Entergy
6146
LA0005843
9/30/2014
Mbe
Mbe
Bti
Houston River
Dpslpsbypo
From Bear Head
Creek to West
Fork Calcasieu
NB
Cot rpm
Brayton Point Dominion
Energy
1124.6
MA0003654
5/31/2017
Cadmium,
Cpof
Bti
Mount Hope
Nutrients; Unknown
Brayton
Point LLC
Mbe
Cbz j
Lbyjdjrz
NB
I Ion gefo
Mount Tom FirstLight
Power
136
MA0005339
9/17/1997
Opof
Opof
Bti
Connecticut
Mercury (Fish
Sftpvsdit
Sjvkfs
Consumption Advisory)
NB
Fttfy
Salem Harbor Footprint
Power
329.6
MA0005096
10/29/1999
Arsenic,
Cpof
Bti
Trbypo Salem
Harbor
Cadmium,
'...
Operations
LLC
Lead, Mercury
Tf rhojvn
Closing the Floodgates 35

36 Closing the Floodgates
Inu
iia
ruin mu
. e
iia
Cm (eB
NE
Bnhhboz
AES Warrior
AES Corporation
229
MD0066079
12/31/2017
Cpof
OR&
Lower North
Cadmium; Nickel; Ph
Svo
Branch
Q ptqi psit
Potomac River
'..
NE
Anne
Brandon
Raven Power Fort
1370
MD0001503
4/30/2014
Arsenic
Opof
Tdsiccfs
Bwoefm
Ti psft
Smallwood LLC
Cadmium,
Mercury, Lead,
Tfrhojvn
NE
Cbrgn psf
C P Crane
C.P. Crane LLC
399.8
MD0001511
6/30/2015
OR&
OR&
Bti
Middle River -
Browns Creek
)gebrfi
NE
Prince
Chalk Point
GenOn Chalk Point
728
MD0002658
6/30/2014
Opof
Opof
Tdsiccfs
Hf pshf St
AMU
NE
Nporhpn fs
Ejdl f stpo
GenOn Mid-
588 -
MD0002640
10/31/2014
Arsenic,
OR&
Ash &
Atlantic, LLC
Cadmium,
Tdsiccfs
'...
Mercury, Lead,
Tfrhojvn
,
NEAnne
Herbert A
Raven Power Fort
495,,,,,,,,,,,,
MD0001503
4/30/2014
Opof
Opof,,,,,,,,,,,
Bti
Bwoefm
Xbhofs
Smallwood LLC
NE
Di bsfit
Npshborpx o
GenOn Mid-
1252
MD0002674
10/31/2014
Arsenic,
OR&
Ash &
Atlantic, LLC
Cadmium,
Scrubber
'...
Mercury, Lead,
'...
Tfrhojvn
NJ
NvtI f hpo
B C Cobb
Consumers Energy
312.6
M10001520
10/1/2013
Nfsdvs
Opof
Bti
Rivers/
Mercury (Fish
Don gboz
Streams in HUC
Consumption Advisory)
040601021004
NJ
Saint Clair
Belle River
Detroit Edison
1395
M10038172
10/1/2013
Arsenic,
Mercury,
Bti
Rivers/
Fish Consumption '...
j Dpn gboz
Mercury,
Tfrhojvn
Streams in HUC
Advisory
Tfrhojvn
040900010407
NJ
Cbz
'... Dan E Kam
Consumers Energy
544 '...
M10001678
'... 10/1/2011
'... Nfsdvs
Nfsdvs
Bti
Rivers/
Fish Consumption '...
Don gboz
Streams in HUC
Bevyt ps
040801030101
NJ
Jbhi bn
Eckert Station
Lansing Board of
375
M10004464
10/1/2012
Nfsdvs
OR&
Rivers/
Mercury (Fish
Water and Light
Streams in HUC
Consumption Advisory)
040500040703
NJ
I jntebrh
Endicott
Michigan South
55
M10039608
10/1/2016
Arsenic,
Boron,
Hfofsbgoh
Central Power
Boron,
Tfrhojvn
Bhfodz
Cadmium,
Mercury,
Tfrhojvn
NJ
Fbrpo
Flog tpo
Lansing Board of
154.7 -
M10005428
10/1/2012
Tfrhojvn
OR&
Rivers/
Mercury (Fish
Water and Light
Streams in HUC
Consumption Advisory) '...
040500040704
NJ
I vERo
Harbor Beach
Detroit Edison
121
M10001856
10/1/2014
Mercury
Opof
Bti
Don gboz
Tfrhojvn
NJ
Pubs b
J B Sims
Grand Haven Board
80
M10000728
10/1/2015
Mercury,
OR&
Ash &
Grand River
Mercury; Mercury in fish
of Light and Power
Tfrhojvn
TcLwccfs
gttvf
NJ
Cbz
J C Weadock
Consumers Energy
312.6
M10001678
10/1/2011
Nfsdvs
Nfsdvs
Bti
Rivers/
Fish Consumption
Don gboz
Streams in HUC
Bevyt ps
040801030101
NJ
Pubs b
J H Campbell
Consumers Energy
1585.9
M10001422
10/1/2011
Nfsdvs
OR&
Bti
Dpn qboz
NJ
Npospf
J R Whiting
Consumers Energy
345.4
M10001864
10/1/2012
Mercury, Lead,
Nfsdvs
Bti
Don gboz
Tfrhojvn
NJ
Pubs b
James De
City of Holland
62.8
M10001473
10/1/2011
OR&
OR&
Bti
Rivers/
j Zpvoh
Streams in HUC
040500020408
NJ
Npospf
Npospf
Detroit Edison
32796
M10001848
10/1/2014
Nfsdvs
Nfsdvs
Ash&
Rivers/
Mercury (Fish
'......
Dpn gboz
'......
'......
'......
'......
Tdsiccfs
Streams in HUC
Consumption Advisory)
041000020410
NJ
Nbsvfuf
Presque Isle
Wisconsin Electric
450
M10006106
10/1/2012
OR&
OR&
Bti
Power Company
NJ
X bzof
River Rouge
Detroit Edison
650.6
M10001724
10/1/2012
Boron
Opof
Bti
Rivers/
Mercury (Fish
Don gboz
Mercury,
Streams in HUC
Consumption Advisory)
Tfrhojvn
040900040407
NJ
Nbsvf of
Ti jsbt
Marquette Board of
77.5
M10006076
10/1/2012
Arsenic,
OR&
Bti
Light and Power
Mercury,
Tfrhojvn
NJ
'... Saint Clair
'... St. Clair
Detroit Edison
'... 1547 '...
M10001686
'... 10/1/2013
'... Nfsdvs
'... Nfsdvs
'... Bti
'... '....
'....
Don gboz
NJ
Nbojtrff
TES Filer City
CMS Enterprises
70
OR&
OR&
OR&
Opof
Trbgpo
Co.
NJ
Xbzof
Trenton
Detroit Edison
775.5
M10001791
10/1/2012
Nfsdvs
Opof
Bti,,,,,,,,
Di boof m
Don gboz
NJ
Xbzof
Xzboepuf
Wyandotte
73
M10038105
10/1/2012
Cadmium,
Nfsdvs
Bti
Municipal Services
Mercury,
Tfrhojvn
NO
X bti fohLpo
Allen S King
Northern States
598.4
MN0000825
1/31/2010
Opof
Opof
Bti
Power (Xcel
Fof shz*
36 Closing the Floodgates

Closing the Floodgates 37
mu
nry
im
un mu
mn
m nry
a im
Cm (eB
NO
Ebl prb
Black Dog
Northern States
293.1
MN0000876
2/28/2013
Nfsdvs
OR&
Bti
Power (Xcel
Fof shz*
NO
,lbt olo
Boswell
Minnesota Power,
1072.5
MN0001007
2/29/2012
Lead Mercury
Nfsdvs
Ash & Cibdl x bufs
Energy Center
Inc.
Tdsiccfs
NO
Otter Tail
Hoot Lake
Otter Tail Power
129.4
MN0002011
11/30/2012
Nfsdvs
Opof
Dpn gboz
'... NO
Saint Louis
Laskin Energy '...
Minnesota Power,
'... 116
'... MN0000990
3/31/2010
Boron,
'... Nfsdvs
Ash &
Dfoufs
Inc.
Mercury,
Scrubber
Tfrhojvn
NO
Ti fscvsof
Sherburne
Northern States
2430.6
MN0002186
7/31/2014
OR&
Opof
j Dpvoue
Power(Xcel
'......
Fof shz*
'......
NO
Pm tufe
Silver Lake
Rochester Public
,,,,,,,,,,,
,99 MN0001139
2/28/2013
,,,,,,,,,,,
Opof
,,,,,,,,
Opof
Vglxft
NO
Dppl
Taconite
Minnesota Power,
252
MN0002208
11/30/2010
Nfsdvs
Opof
'....
Harbor Energy
j Inc.
'...
Of orf s
NP
iVgfs
Btcvs
Empire District
231.5
MO0095362
12/1/2010
Opof
Opof
Bti
Electric Company
NP
Wodl tpo
Blue Valley
Independence
115
MO0115924
5/5/2016
OR&
OR&
Bti
Power and Light
NP
Ptbhf
Chamois
Associated Electric
59
MO0004766
5/15/2008
Opof
Opof
Bti
Power Plant
Cooperative, Inc
NP
Cppof
Dpmn cfb
City of Columbia
38.5
MO0004979
7/5/2017
Arsenic,
OR&
Bti
Cadmium,
'...
- Mercury, Lead,
'...
Tfrhojvn
NP
Nbdl t po,
I bx u pso
Kansas City Power
594.3
MO0004855
7/27/2005
Opof
Opof
....
& Light Company
,.Kansas
,...
..... ..... .....
NP
Olnif
.bLbo....
City Power
1640
MO0082996
2/5/2009
OR&
Opof
'...
& Light Company
NP
Hsffof
James River
City of Springfield
253
MOR109Z51
3/7/2012
Arsenic
Opof
Bti Lake Springfield
NP
Boron,
Cadmium,
Lead, Mercury
Tfrhojvn
NP
Hsf fof
John Twitty
City of Springfield
494
MO0089940
8/12/2015
Tfrhojvn
Tfrhojvn
Bti
'..
Energy Center
NP
'...
NP
Cool 10
ivbc beff
Union Electric
2389.4
MO0004812
3/17/1999
Opof
Opof
Bti
Don gboz
NP
Cvd bobo
Lake Road
KCP &L Greater
90
MO0004898
6/12/2008
Cpof
OR&
Bti
Missouri Operations
Dpn gboz
NP
Saint Louis
Nfsfon fd
Union Electric
923
MO0000361
5/18/2005
Opof
Opof
Bti Mississippi River Manganese Fish
Don gboz
Consumption Advisory
NP
I fos
NpoLEptf
Kansas City Power
564
MO0101117
3/26/2014
Cpspo
OR&
Bti
'...
& Light Company
'...
NP
New Madrid
New Madrid
Associated Electric
1200
MO0001171
4/21/2016
Opof
Opof
Bti
Power Plant
Cooperative, Inc
NP
Jefferson
Rush Island
Union Electric
1242
MO0000043
9/30/2009
OR&
OR&
Bti
Dpn gboz
NP
Nbdl t po
Tjcrhz,
KCP &L Greater
524,
MO0004871
11/2/2005
Opof
Opof
Ash &
Missouri Operations
Tdsiccfs
Don gboz
NP
Tc¢w
Tjl ftrpo
Sikeston Ed. of
261
MO0095575
2/12/2014
OR&
Opof
Municipal Utilities
NP
Saint Charles
Tfpvy
Union Electric
10994
MO0000353
4/15/2009
Opof
Opof
Bti
Don gboz
NP
Sboeprgi
Thomas Hill
Associated Electric
1135
MO0097675
12/23/2008
Cpof
OR&
Ash &
'...
Energy Center
Cooperative, Inc
TcLwccfs
NT
Nbdl tpo
Daniel Electric
Mississippi Power
1096.6
MS0024511
12/31/2013
Opof
Opof
Bti
Generating
Don gboz
Ohou
NT
fvbn bs
R D Morrow
South Mississippi
400
MS0028258
12/31/2010
Cpof
OR&
Ash &
Senior
Elec. Power Assoc
TcLwccfs
Generating
Crhou
NT
Di pclu c
Red Hills
Tracte be Power,
513.7
MS0053881
12/31/2016
Tfrhojvn
Tfrhojvn
Generation
Inc.
NT
I bsgtpo
Watson
Mississippi Power
877.2
MS0002925
11/30/2013
OR&
OR&
Bti
Electric
j Dpn gboz
'...
Generating
Crhou
NU
Big Horn
Hardin
Colorado Energy
115.7
MTR000457
9/30/2011
Opof
Opof
Generating
Management, LLC
Trbypo
Closing the Floodgates 37

38 Closing the Floodgates
mu
nry
im
un mu
mn
m
a
nry
im
Cm (eB
NU
Zf npx trpof
J E Corette
P P & L Montana
172.8
MT0000396
3/1/2005
Opof
Opof
Bti - Yellowstone Arsenic; Nutrients
AMU
j SjW s
NU
Sjdi rboe
Lewis & Clark
Montana Dakota
50
MT0000302
11/30/2005
Opof
Opof
Bti Yellowstone Chromium, Copper Lead
Utilities Company
Sjvfs
CID
Cuoc¢n cf
Bti fvgrFb
Carolina Power &
413.6
NC0000396
12/31/2010
Arsenic,
Nfsdvs
Ash &
Light Company
Cadmium,
TcLwccfs
Mercury, Lead,
'...
Tfrhojvn
OD
Trpl f t
Belews Creek
Duke Energy
2160.2
NC0024406
2/28/2017
Arsenic,
Opof
Ash &
Dpslpsbypo
Mercury,
Tdsiccfs
Tfrhojvn
CID
Spx bo
Cvd
Duke Energy
250
NC0004774
8/31/2016
Arsenic,
Opof
Bti
Carolinas, LLC
Selenium,
'...
N f sdvs
''....
CID
DdW rboe
Cliffside
Duke Energy
570.9
NC0005088
7/31/2015
Arsenic
Opof
Ash &
Dpslpsbypo
Selenium,
Scrubber
Cadmium,
N f sdvs
CID
Fehfc¢n cf
Edgecombe
Edgecombe Genco
114.8
NC0077437
10/31/2014
Opof
Opof
Genco, LLC
AMU
W,,,,,,,
Hbt rpo,,,,,,,,
G G Allen
Duke Energy
1155
NC0004979
5/31/2015
Arsenic
Opof
Ash &
Dpslpsbypo
Cadmium,
Scrubber
Mercury,
Tfrhojvn
CID
- New Hanover
L V Sutton
Carolina Power &
671.6
- NC0001422
12/31/2016
Arsenic,
Arsenic,
Bti '...
Light Company
Mercury,
Tfrhojvn
Tfrhojvn
OD
Spcftpo
Lumberton
Lumberton Energy,
347
NC0058301
7/31/2014
Nfsdvs
Opof
Cox f s
AMU
CID
Nbsti brm
Nbsti brm
Tennessee Valley
1996
NC0004987
4/30/2015
Arsenic, Boron,
Tfrhojvn
Ash &
Bvu psjrz
Tfrhojvn
TcLwccfs
OD
Of St Po
Nbzp
Carolina Power&
735.8
NC0038377
3/31/2012
Arsenic,
Cadmium
Ash& '...
'...
'.... '....
Light Company
'...
Cadmium,Lead,
'... Lead, Mercury
Scrubber
Selenium,
Cpspo
Mercury, Boron
OD
- Hbt rpo
SjW scf oe
Duke Energy
466
- NC0004961
2/28/2015
Arsenic,
Opof
Bti
Dpslpsbypo
Mercury,
Tfrhojvn
OD
Of St Po
Spyc psp
Carolina Power&
25582
NC0065081
5/31/2012
Cadmium, Lead
Cadmium
Ash&
Light Company
Af be
Tdsiccfs
OD
- 1 bgMy
Westmoreland
Westmoreland
182.3
NCS000229
6/30/2012
Opof
Opof
Partners
Partners LLC
Roanoke
'...
Valley I
OD
I bgMy
Westmoreland
Westmoreland
57.8
NCS000229
6/30/2012
Opof
Opof
'... '...
Partners
Partners LLC
Roanoke
Valley 11
OE
- Nfsdfs
Antelope
Basin Electric
869.8
ND0024945
6/30/2013
Opof
Opof
Bti
vbntE
Power Cooperative
'...
OE
Nfsdfs
Dpzpuf
Otter Tail Power
450
ND0024996
3/31/2013
Opof
Opof
Bti '... '....
Don gboz
OE
Nfsdfs
Leland Olds
Basin Electric
656
ND0025232
12/31/2016
Arsenic,
Opof
Bti
Power Cooperative
Cadmium,
Mercury, Lead,
'...
Tfrhojvn
OE
Ppmfs
Milton R,,,,,,,,
Minnkota Power
734
ND0000370
6/30/2015
Cpspo
Opof
Ash&
Zpvoh
Cooperative, Inc
Tdsiccfs
OE
Npsrpo
R M Heskett
Montana Dakota
115
ND0000264
3/31/2013
Opof
Opof
Bti
Utilities Company
OE
Nfsdfs
Trborpo
Great River Energy
190.2
ND0000299
12/31/2016
Arsenic,
Opof
Bti
Cadmium,
Mercury, Lead,
Tfrhojvn
OF
Agodpro
Gerald
Nebraska Public
1362.6
NE0111546
9/30/2016
Opof
Opof
Gentleman
Power District
'..
Trbypo
OF
Bebn t
Gerald Whelan
Nebraska Municipal
324.3
NE0113506
9/30/2017
Cadmium
Opof
Ash &
Energy Center
Energy Agency
Mercury, Lead,
Tdsiccfs
Tfrhojvn
OF
Epehf
Lon D Wright
City of Fremont
130
NE0001252
6/30/2015
Cadmium,
Opof
Power Plant
Mercury, Lead
'...
OF
P rpf
Nebraska City
Omaha Public
1389.6
NE0111635
6/30/2013
Arsenic
Opof
Bti
Trbypo
Power District
Cadmium,
Mercury, Lead,
Tfrhojvn
OF
Epvhrkt
North Omaha
Omaha Public
644.7
NE0000621
9/30/2013
Arsenic,
Opof
Bti
Trbypo
Power District
Cadmium,
, ,
,NE0113646
,
Mercury, Lead
,Opof
,
OF
brm
Crbuuf
Grand Island
9/30/2017
Opof,,,,,,,,,,
Bti,,,,,,,,
Utilities Dept.
38 Closing the Floodgates

Closing the Floodgates 39
Inu iia
ruin mu
. e iia
Cm (eB
OF
Abodbt ifs
Ti frepo
Nebraska Public
228.7
NE0111490
9/30/2016
Cadmium, Lead
Opof
Bti
'..
Power District
'..
•
Nfsqn bdl
Nfsqn bdl
Public Service of
459.2
NH0001465
7/31/1997
Cadmium Lead
Opof
Ash &
Merrimack River
New Hampshire
Tdsiccfs
•
Spo9 johi bn
Tci jrft
Public Service of
100
NH0001473
9/30/1995
Arsenic,
Opof
Lower
'....
New Hampshire
Cadmium,
Piscataqua
'...
Mercury, Lead,
SjWS
Tf rfiojvn
OK
I vetpo
Hudson
CTFH
659.7
NJ0000647
9/30/2016
Mercury, Lead,
Opof
Bti
'... '....
Generating
Bstf ojd
Trbypo
OK
Hrpvditrfs
Logan
Logan Generating
242.3
NJ0076872
9/30/2011
Bstf ojd
Bstf ojd
'....
Generating
Co. LP
'...
Crbou
OK
, Mercer
C TFH
652.8
, NJ0004995
,10 /31/2011 „
Arsenic,
,Bti
Generating
Cadmium,
Trbypo
Mercury,
Selenium, Lead
ON
NdLjorhz
Escalante
Tri -State Generation
257
NMROSA996
10/29/2005
Opof
Opof
& Transmission
'..
ON
San Juan
Four Corners
Arizona Public
22696
NN0000019
4/6/2006
Opof
Opof,,,,,,,,,,,,
Bti
Steam Elec
Service Company
Trbypo
ON
San Juan
San Juan
Public Service
1848
NM0028606
3/31/2016
Boron,
Cpof
Company of New
Tfrhojvn
Nfyjc4D
OZ
Jefferson
Black River
Black River
55.5
NY0206938
7/31/2017
Arsenic
Arsenic Lead
Generation
Generation, LLC
Mercury, Lead
Nfsdvs
N&D
CZ
Lon ql jot
Cayuga
Cayuga Operating
322.5
NY0001333
12/31/2014
Arsenic, Boron
Arsenic
Ash &
'...
Operating
Company, LLC
Cadmium,
Cadmium,
TcLwccfs
'...
Company
Mercury, Lead,
Mercury Lead,'...
'..
KW
i Tfrhojvn i
Tfrhojvn
OZ
Psbohf
Dynegy
Dynegy Power
386.5
NY0006262
5/31/2011
Arsenic
Arsenic
Bti
Hudson River
Cadmium PCBS
EbotI Ion n fs
Dpsgpsbypo
Cadmium,
Cadmium
Mercury, Lead,
Mercury Lead
Tfrhojvn
Tfrhojvn
CZ
Fqf
Huntley Power
Huntley Power LLC
436
NY0001023
6/1/2008
Arsenic,
Nf be
'..
Cadmium,
'...
'...
Mercury, Lead,
'...
'.....
Tfrhojvn
OZ
Dt bvrbvrvb
NRG Dunkirk
NRG Energy Inc
627.2
NY0002321
4/30/2015
Arsenic
Mercury Lead
Bti
Cox f
Cadmium,
Mercury, Lead,
Tfrhojvn
CZ
Cgbhbsb
Somerset
Somerset Operating
655.1
NY0104213
12/31/2013
Arsenic, Boron
Nfsdvs
'...
Operating
Company, LLC
Nfsdvs
'...
Company
)Ljoyhi ,
OZ,,,,.
Popoebhb
Syracuse
SUEZ Energy
1011
NY0213586
4/30/2015
VbeOpof
Energy
Generation NA
Dpslpsbgpo
PI
Bti rbcvrb
Bti rbcvrb
FirstEnergy
256
OH0001121
1/31/2013
Nfsdvs
Nfsdvs
Ash &
Lake Erie
Ph; Total Suspended '...
'..
Generation
TcLwccfs
Central Basin
Solids '..
Dpslpsbypo
Ti psf rjmf
PI
Wsbjo
Avon Lake
GenOn Power
766
OH0001112
7/31/2015
Mercury
Nfsdvs
Bti
Lake Erie
Ph Total Suspended
Power Plant
Operating Services
Tfrhojvn
Central Basin
Solids
Midwest, Inc.
Ti psfrjmf
PI
Kkdbt
Bay Shore
FirstEnergy
498.8
OH0002925
7/31/2015
Arsenic, Boron
Nfsdvs
Bti
Lake Erie
Arsenic; Total Suspended
'...
Generation
Cadmium,
Tributaries (East
Solids; Oil & Grease '...
j Dpsgpsbypo
Mercury, Lead,
of Maumee
Tfrhojvn
River to West of
Toussant River)
PI
Jefferson
Dbsejobm
Cardinal Operating
1880.4
OH0012581
7/31/2012
Arsenic Boron
Opof
Ash &
Ohio River
Jpo
Dpn gboz
Mercury, Lead,
Tdsiccfs
(Upper South)
Tfrhojvn
PI
Dpti pdrpo
Dpoftvgrrfi
Ohio Power
1890.8
OH0005371
7/31/2012
Boron,
Mercury
Ash &
j Dpn gboz
Cadmium,
Tfrhojvn
TcLwccfs
Mercury, Lead,
Tfrhojvn
PI
fall f
Flat ubl f
FirstEnergy
1257
OH0001139
1/31/2013
Nfsdvs
Opof
Bti
Lake Erie
Ph Total Suspended
Generation
Central Basin
Solids
Dpslpsbypo
Ti psfrjmf
PI
Hbn)b
Gen J M Gavin
Ohio Power
2600
OH0028762
7/31/2013
Boron,
Nfsdvs
Ash &
Ohio River
Arsenic; Boron; Cadmium:
j Dpn gboz
Cadmium,
TcLwccfs
Tributaries
Chromium; Cobalt;
'....
Mercury,
(Downstream
Copper; Iron; Lead;
Tfrhojvn
Leading Creek
Mercury; Zinc; Ph; Nickel
'...
- to Upstream
Kanawha River)
PI
CV ufrs
Hamilton
City of Hamilton
75.6
OH0010413
7/31/2014
Nfsdvs
Opof
Great
Fish Consumption
Municipal
Miami River
Bevnjt ps
Power Plant
(Downstream
Fourmile Creek
to Mouth)
Closing the Floodgates 39

40 Closing the Floodgates
Inu
iia
ruin mu
. e iia
mom
No
PI
Bebn t
J M Stuart
Dayton Power and
2440.8
OH0004316
6/30/2007
Cadmium
Opof
Ash&
Light Company
Mercury
TcLwccfs
'...
Lead Boron
Bstf odd
PI
Bebn t
Killen Station
Dayton Power and
660.6
OH0060046
1/31/2013
Arsenic
Opof
Ash &
Light Company
Boron
Tdsiccfs
Cadmium
Mercury Lead
Tfrhojvn
PI
Hbn)b
Kyger Creek
Ohio Valley Electric
1086.5
OH0005282
7/31/2013
Arsenic
- Nfsdvs
Ash &
Ohio River
Arsenic; Boron; Cadmium
j Dps4psbypo
Boron
TcLwccfs
Tributaries
Chromium; Copper
Cadmium
j (Downstream
Iron; Lead; Manganese '...
Mercury Lead
-
Leading Creek
Mercury; Molybdeum
Tfrhojvn
to Upstream
Nickel; Selenium; Silver
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Zinc; Ph '...
PI
Dvzbj phb
Lake Shore
FirstEnergy
256
OH0001147
7/31/2016
Nfsdvs
Nfsdvs
Bti
Lake Erie
Ph Total Suspended
Generation
Central Basin
Solids
Dpslpsbypo
Ti psfrjmf
PI
I bn jrrpo
Miami Fort
Duke Energy Ohio
1278
OH0009873
7/31/2013
Arsenic
Cpof
Ash&
Generating
Inc.
Boron
TcLwccfs
Trbypo
Cadmium
Mercury Lead
Tfrhojvn
PI
X bti fohrpo
Muskingum
Ohio Power
15294
OH0006149
7/31/2011
Arsenic
Opof,,,,,,,,,
Bti
Sjv�fs
Dongboz
Nfsdvs
PI
Nporhpn fs
O H Hutchings
Dayton Power and
414
OH0009261
7/31/2014
Mercury
Tfrhojvn
Bti
Light Company
Tfrhojvn
PI,,,,,,,
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qcx bz,,,,,,,
Ohio Power
1062
OH0005398
6/30/2017
Opof
Opof
Bti,,,,,,,,,
Big Walnut
Don gboz
Dsffl
PI
Jefferson
WHSammis
FirstEnergy
24556
OH0011525
7/31/2012
Mercury
Cpof
Ash &
Ohio River
Jpo
Generation
Selenium
TcLwccfs
j (Upper North)
'...
Dpsgpsbypo
Boron
Cadmium
'...
M be
PI
Drhsn you
WHZimmer
Duke Energy Ohio
14256
OH0048836
1/31/2015
Arsenic
Nfsdvs
Tdsiccfs
Generating
Inc.
Boron
Trbypo
Cadmium
Mercury Lead
Tfrhojvn
PI
Drim you
Walter C
Duke Energy Ohio
12213
OH0009865
7/31/2013
Arsenic
- Tfrhojvn
Bti
Ohio River
Beckjord
Inc.
Boron
Tributaries
'...
Generating
Cadmium
j (Upstream Big
Trbypo
Mercury Lead
-
Indian Run to
Tfrhojvn
Upstream Little
Miami River
PL
,Le Flore
AES Shady
350
, OK0040169
2/29/2016
Opof,,,,,,,,,
,Opof,,,,,,,,
Point LLC
PL
Nbzft
Grand River
Grand River Dam
1134
OK0035149
12/31/2014
Cpof
Cpof
Grand Neosho
Dam Authority
j Bvu psjrz
j SjWS
PL
Di pdu x
I vhp
Western
446
OK0035327
5/31/2013
Opof
Opof
Bti
Washita River
Lead; Turbidity
Farmers Electric
Cooperative, Inc
PL
Nvtlphff
Nvtlphff
Oklahoma Gas&
1716
OK0034657
3/31/2016
Cpof
Cpof
Bti
Electric Company
,
PL
Sphfst
Opsu f bt u so,,,,
Public Service
946
OK0034380
12/14/2011
Arsenic
Opof,,,,,,,,,,,
Bti
Company of
Nf sdvs
PI ibi pnb
PL
Cperh
Tppofs
Oklahoma Gas&
1138
OK0035068
4/30/2011
Cpof
Cpof
Bti
Electric Company
CB
'.... Cf bvd s
AES Beaver
AES Corporation
114
PA0218936
5/24/2007
Opof
Opof
Wexford Run
aLof Od
Valley LLC
CEI
Cf bvfs
Bruce
FirstEnergy
27411
PA0027481
11/30/2011
Cpof
Cpof
Ash&
Hayden Run
Cvuof Ou
Mansfield
Generation
Scrubber
Creek/ Wexford
'...
j Dps4psbypo
Svo
CB
Zpg
Brunner Island
PPL Generation,
1558.7
PA0008281
9/30/2011
Arsenic
Lead,
Bti
N&D
Boron
Tfrhojvn
Cadmium
Mercury Lead
Tfrhojvn
CEI
Dbn c1lb
Cambria
Cambria CoGen
98
PA0204153
9/30/2012
Cpof
Cpof
j Dphf o
j Dpn gboz
CB
Bnbhi foz
Dt ftx fdl
GenOn Power
637
PA0001627
8/31/2012
Arsenic
Cadmium
Ash &
Little Deer
Aluminum Arsenic
Midwest, LP
Boron
Mercury, Lead
Scrubber
Dsffl
Cadmium; Chronium
Cadmium
Tfrhojvn
Copper; Lead; Iron;
Mercury Lead
Manganese; Mercury
Tfrhojvn
Molybdeum; Selenium
Silver; Thallium; Zinc
CEI
Dbn c1lb
Colver Power
A/C Power - Colver
118
PA0204269
9/19/2000
Cpof
Cpof
Elk Creek
Arsenic; Cadmium;
j Qsplf du
Pgfsbypot
Chronium; Copper; Iron
Mercury; Zinc; Lead '...
CB
,bejbob
Dpof n by hi
GenOn Northeast
1872
PA0005011
12/27/2006
Arsenic
Mercury, Lead
Ash &
Management
Boron
Tfrhojvn
Tdsiccfs
Don gboz
Cadmium
Mercury Lead
Tfrhojvn
40 Closing the Floodgates

Closing the Floodgates
mu
nry
im
un mu
mn
m nry
a im
Cm (eB
CEI
Dbn csjb
Ebensburg
Power Systems
57.6
PA0098612
7/31/2011
Opof
Opof
'....
Power
Operations, Inc
Dpn gboz
CB
X bti fohrpo
Frffin b,,,,,,,
GenOn Power
510,,,,,,,,,,,,
PA0001571
9/20/2001
Opof
Opof
Bti
Midwest, LP
CEI
Tdi vzrhgrm
Gilberton
Broad Mountain
88.4
PA0061697
9/1/2014
Cpof
Cpof
Mill Creek Arsenic; Cadmium
Power
Cbsnfs
Chromium; Copper Iron;'...
j Dpn gboz
Lead; Mercury; Zinc
CB
Hsffof
Hatfield's
Allegheny Energy
1728
PA0002941
12/31/2008
Arsenic
Mercury Lead
Tdsiccfs
Ferry Power
Boron,
Tfrhojvn
Trbypo
Cadmium,
Mercury Lead,
Tfrhojvn
CEI
.bejbob
Homer City
NRG Homer City
2012
PA0005037
7/31/2012
Arsenic,
Lead,
Ash &
Services LLC
Boron,
Tfrhojvn
TcLwccfs
'...
Cadmium,
'...
Mercury, Lead,
'...
Tfrhojvn
CB
Bsn tuEpoh
Lfztrpof
GenOn Northeast
1872
PA0002062
3/31/2013
Arsenic
Mercury Lead
Ash &
Management
Boron,
Tfrhojvn
Scrubber
Don gboz
Cadmium,
Mercury Lead,
Tfrhojvn
CEI
X bti johrpo
Mitchell Power
Allegheny Energy
299.2
PA0002895
9/30/1996
Cpspo
Cpspo
Ash &
Trbypo
Scrubber
CB
Nporpvs
Nporpvs
PPL Generation
1641.7
PA0008443
1/31/2013
Arsenic,
Cadmium
Tdsiccfs
K&D
Boron,
Mercury
Cadmium,
Tfrhojvn
Mercury Lead,
Tfrhojvn
CEI
%,bx sf odf
New Castle
GenOn Power
348
PA0005061
4/6/2010
Cpof
Cpof
Bti
'....
Midwest, LP
'...
CB
Cpsi Ion grpo
Northampton
NAES Corporation
114.1
PAR702213
6/2/2015
Opof
Opof
Generating
Qbou
CEI
Tdivzrhgrm
Northeastern
Nepco Services
59
PA0061417
1/31/2014
Cpof
Cpof
Power
Dpn gboz
,
Dpn gboz
C$
ZOg
P H Glatfelter
P H Glatfelter
70.4
PA0008869
6/30/2012
Cpspo
Opof
Don qboz
Don gboz
CEI
Drhspo
Piney Creek
Piney Creek Limited
36.2
PA0005029
10/31/2017
Cpof
Cpof
Power Plant
Cbsnf st i jq
CB
Cpsi Ion grpo
Cps.rboe
GenOn REMA LLC
427
PA0012475
7/15/2007
Opof
Opof
'...... '...... '.....
CEI
Vlobohp
Scrubgrass
Scrubgrass
94.7
PA0103713
12/31/2017
Cpof
Cpof
- Alleghany River Nfs3vs
Generating
Generating
'...
'.....
Clbou
Dpn gboz
CB
,bejbob
Tfx lose
GenOn Wholesale
585
PA0002054
7/18/2015
Arsenic,
Opof
Conemaugh Aluminum; Arsenic
Generation, LP
Mercury Lead
SjVkfs Cadmium; Chromium
Cobalt; Copper; Iron
Manganese; Mercury
Nickel; Zinc; Ph
CEI
Clearfield
Ti bx vgnb
GenOn REMA LLC
626
PA0010031
8/31/2015
Cpof
Cpof
- West Branch Alumium; Arsenic
'...
- Susquehanna Cadmium; Chromium
j SjWS Copper; Iron; Lead
'...
Manganese; Mercury
'..
Nickel; Zinc '...
CB
Tozefs
Tvocvs
Sunbury
437.9
PA0008451
3/31/2012
Arsenic
Opof
Bti,,,,,,,,
Generation, LP
Cadmium,
Mercury Lead,
.....
......
Tfrhojvn
,...
.....
... ,... .....
CEI
Cfg t
Ljwt
.GenOn REMA LLC
225
PA0010782
9/30/2015
Cpof
Cpof
CB
Tdi vzMtyn
Wheelabrator
Wheelabrator
48
PA0061263
9/30/2016
Opof
Opof
Mill Creek Arsenic; Cadmium
- Frackville
Frackville Energy
Chronium; Copper Iron
Company Inc
Lead; Mercury; Zinc
CEI
Tdi vzrhgrm
WPS
Olympus Power,
36
PA0061344
4/30/2017
Cpof
Cpof
- Lower Rausch Arsenic; Cadmium
Westwood
UVD
Dsffl Chromium; Copper Iron;'...
'...
- Generation
Lead; Mercury; Zinc
UVD
TO
Dprrtrpo
Canadys
South Carolina
489.6
SC0002020
6/30/2009
Arsenic,
Arsenic,
Bti
Tuf Ion
Electric &Gas
Nfsdvs
Nfsdvs
Don gboz
TO
Psbohfcvsh
Cope Station
South Carolina
417.3
SC0045772
9/30/2014
Nfs3vs
Cpof
Ash &
'..
Electric & Gas
TcLwccfs
'..
Dpn gboz
TO
Cf sl f rfE
Dsptt,
Santee Cooper
2390.1
SC0037401
8/31/2010
Nf sdvs
Opof
Bti
TO
I ps3z
Dolphus M
Santee Cooper
163.2
SC0001104
9/30/2006
Arsenic
Cpof
Bti
Waccamaw
Hsbjohfs
j SjWS
TO
Cfsl fifE
Jefferies
Santee Cooper
345.6
SC0001091
2/29/2008
Bstf ofd,,,,,,,
Opof,,,,,,,,,,,,
Bti,,,,,,,,
TO
Nfyjohrpo
NdNffIjo
South Carolina
293.6
SC0002046
4/30/2009
Bstfojd
Cpof
'..
Electric & Gas
'..
Dpn gboz
Closing the Floodgates

42 Closing the Floodgates
Inu
iia
ruin mu
. e
iia
Cm (eB
TO
Bjl fo
Vsvi b9i
South Carolina
100
SC0000574
9/30/2008
Nfs3ys
Cpof
Bti
Electric &Gas
Dpn qboz
TO
Boef st po
WS Lee
Duke Energy
355
SC0002291
6/30/2013
Arsenic
Opof
Bti
Dpsgpsbypo
Cadmium
Mercury Lead
TO
Sjci rboe
X brfsff
South Carolina
771.8
SC0002038
12/31/2012
Arsenic
Cpof
Bti
Electric & Gas
Nf sdvs
j
Dpn gboz
TO
Cfsl fifE
X jn)bn t
South Carolina
632.7
SC0003883
5/31/2014
Arsenic
Arsenic
Ash &
Generating
Cadmium
Tfrhojvn
Tdsiccfs
Don gboz
Mercury
Tfrhojvn
TO
Hf pshf rpxo
Xjozbi
Santee Cooper
1260
SC0022471
7/31/2011
Arsenic
Arsenic,
Bti
Tfrhojvn
Tfrhojvn
UO
Ti fraz
Bnim
Tennessee Valley
990
TN0005355
8/3/2010
Opof
Opof
Bti McKellar Lake Mercury Nickel Ph Total
Bvu psjrz
Suspended Solids
UO
Boefst po
Bull Run
Tennessee Valley
950
TN0005410
11/1/2013
Arsenic
Cpof
Ash &
Bvu psjrz
Cadmium
TcLwccfs
Mercury Lead,-
'...
Tfrhojvn
UO
Tufx bsu
Dvn cfsrboe
Tennessee Valley
2600
TN0005789
5/31/2010
Cadmium
Opof
Ash &
Bvu psjrz
Mercury Lead
Tdsiccfs
Tfrhojvn
UO
Tvn ofs
Hbrrtrjo
Tennessee Valley
12552
TN0005428
5/31/2017
Arsenic
Cpof
Bti
Bvu psjrz
Cadmium
Mercury Lead
Tfrhojvn
UO
I bx I jot
John Sevier
Tennessee Valley
800
TN0005436
6/30/2014
Arsenic
Arsenic
Bti Cherokee Mercury
Bvu psjrz
Cadmium
Tfrhojvn
Sftfwjs
Mercury Lead
Tfrhojvn
UO
....I vn qi sfzt
Kpi otpovgrFb
Tennessee Valley
1485.2
TN0005444
11/29/2013
Arsenic
Cpof
Bti
Bvu psjrz
Cadmium
Mercury Lead
Tfrhojvn
UO
Spbof
Ljohtrpo
Tennessee Valley
1700
TN0005452
8/31/2008
Opof
Opof
Tdsiccfs Clinch River Nfsdvs
Bvu psjrz
Arm of Watts
Bar Reservoir
UO
,Spring City
Watts Bar
Tennessee Valley
240
TN0005461
8/31/2016
Arsenic
Cpof
Bti
j Gpttjm
Bvu psjrz
Cadmium
Mercury Lead
Tfrhojvn
UY
Clfftrpof
Big Brown
Luminant
11868
TX0030180
2/1/2012
Tfrhojvn
Tfrhojvn
Bti '...
Generation
Company LLC
UY
Hprjbe
Coleto Creek
Coleto Creek
622.4
TX0070068
2/1/2010
Cpof
Cpof
Bti
Power, LP
UY
Hqn ft
Gibbons Creek
Texas Municipal
453.5
TX0074438
5/1/2011
Tfrhojvn
Tfrhojvn
Steam Electric
Power Agency
Typo
UY
I bssjtpo
H W Pirkey
Southwestern
721
TX0087726
4/1/2011
Tfrhojvn
Tfrhojvn
Ash &
Power Plant
Electric Power
TcLwccfs
j
Dpn gboz
UY
Coufs,,,,,,,,
Harrington
Southwestern
1080
TX0124575
10/1/2015
Cpspo
Opof,,,,,,,,
Trbypo
Public Service
Don gboz
UY
Cfybs
J K Spruce
City of San Antonio
1444
TX0063681
3/1/2015
Tfrhojvn
Tfrhojvn
Ash &
TcLwccfs
UY
Cfybs
J T Deely
City of San Antonio
932
TX0063681
3/1/2015
Tfrhojvn
Tfrhojvn
Ash &
Tdsiccfs
UY
Mn ftrpof
Mn ftrpof
NRG Energy, Inc
1867.2
TX0082651
12/1/2013
Tfrhojvn
Tfrhojvn
Bti
UY
Svtl
Martin Lake
Luminant
23796
TX0054500
4/1/2012
Tfrhojvn
Tfrhojvn
Ash &
Generation
Tdsiccfs
Company LLC
UY
Ljwt
Npoydfnp
Luminant
1980
TX0000086
2/1/2010
Tfrhojvn
Tfrhojvn
Ash &
Generation
TcLwccfs '..
Company LLC
UY
Spcf st Po
Oak Grove
Oak Grove
17954
TX0068021
5/1/2014
Tfrhojvn
Tfrhojvn
Ash&
Management
Tdsiccfs
Company LLC
UY
Xjmbshfs
Oklaunion
West Texas Utilities
720
TX0087815
12/1/2015
Arsenic
Arsenic,
Bti
Power Station
Company
Cadmium
Cadmium,
Mercury Lead
Mercury, Lead,-
'...
Tfrhojvn
Tfrhojvn
UY
Spcf sl Po
Optim Energy
Optim Energy Twin
3492
TX0101168
12/1/2013
Tfrhojvn
Tfrhojvn
Twin Oaks
Oaks LP
UY
G'ozf of
Sam Seymour
Lower Colorado
1690
TX0073121
12/1/2014
Tfrhojvn
Tfrhojvn
Bti
River Authority
UY
Brbtdptb
San Miguel
San Miguel Electric
410
TX0090611
5/1/2015
Opof
Opof
Cooperative, Inc
42 Closing the Floodgates

Closing the Floodgates 43
mu
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mn
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Cm (eB
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Sandy Creek .Sandy
Creek
900
TX0127256
12/1/2014
Cpof
Cpof
Energy
Energy Associates,
'...
Trbypo
NO
Uy
Fort Bend
W A Parish
NRG Energy, Inc
2736.8
TX0006394
7/1/2014
Tfrhojvn
Tfrhojvn
Bti
Uy
Ljwt
Welsh Power
Southwestern
1674
TX0063215
2/1/2016
Tfrhojvn
Tfrhojvn
Bti
'..
Crbou
Electric Power
'..
Dpn gboz
VU
Vjorbl
Cpobo {b
Deseret Generation
499.5
UTU000120
Opof
Opof
Opof
'...
'...
& Transmission
VU
Dbspo
Dbspo
Pacificorp Energy
188.6
UT0000094
2/29/2012
Cpof
Cpof
Hfofsbypo
VU
Fn f s
I vouf s
Pacificorp Energy
1472.2
UTR000446
12/31/2012
Opof
Opof
Hf of sbypo
VU
Fn f s
I voyohrpo
Pacificorp Energy
996
UT0023604
11/30/2012
Cpof
Cpof
- Huntington
Salinity /Total Dissolved
Hfofsbypo
Creek -2
Solids /Chlorides
NB
Dbn qcf mm
Altavista
Dominion
711
VA0083402
9/25/2010
Opof
Opof
Tdsiccfs Roanoke
Mercury (Fish
Power Station
Hfofsbypo
(Staunton)
Consumption Advisory)
Sjvkf s
VB
King George
Birchwood
General Electric
258.3
VA0087645
12/7/2014
zero discharge
zero discharge
Power Facility j
Dpn gboz
of coal ash
of coal ash
NB
(3mvboob
Bremo Power
Dominion
2542
VA0004138
7/31/2015
Opof
Opof
Bti James River
Trbypo
Hfofsbypo
VB
Chesapeake
Chesapeake
Dominion
649.5
VA0004081
3/19/2017
Bstf ojd
Cpof
Bti Elizabeth River
j )Djrz*
Energy Center
Hfofsbypo
NB
Chesterfield
Chesterfield
Dominion
1352.9
VA0004146
12/9/2009
Opof
Opof
Bti Almond Creek
C3
Power Station
Hfofsbypo
VB
Svttfrm
Clinch River
Appalachian Power
712.5
VA0001015
9/14/2015
Cpof
Cpof
Bti
j
Dpn gboz
NB
I bigy
Clover Power
Dominion
848
VA0083097
1/12/2016
Opof
Opof
Ash & Roanoke
Mercury (Fish
Trbypo
Hfofsbypo
Tdsiccfs (Staunton)
Consumption Advisory)
Sjvkf s
VB
Hopewell
Dphf ougy.
James River
114.8
VA0073300
9/30/2017
Cpof
Cpof
j )Djrz*
I pgfx frm
Cogeneration
Dpn gboz
NB
Portsmouth
Dphf ou4y.
Cogentrix
1148
VA0074781
9/3/2014
Opof
Opof
Unsegmented
Fish Consumption
)Dj LE*
Gpsln pvu
Virginia Leasing
estuaries in
Advisory
Dpslpsbypo
Hampton Roads
I b9c Ps
VB
Hjrht
Glen Lyn
Appalachian Power
337.5
VA0000370
7/10/2014
Cpof
Cpof
New River
j
Dpn gboz
NB
Hopewell
Hopewell
Dominion
71.1
VA0082783
7/10/2010
Opof
Opof
'...
)Dj LE*
Power Station
Hfofsbypo
VB
Nfdlrhocvsh
Mecklenburg
Dominion
139.8
VA0084069
12/20/2016
Cpof
Cpof
,NB
,Tpvu
Power Station
Hfofsbypo
,Opof,,,,,,,,
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Southampton
71.1
VA0082767
2/22/2016
Opof,,,,,,,,,
Power Station
Hfofsbypo
VB
Richmond
Spruance
Spruance Genco
229.6
VA0085499
5/23/2011
Cpof
Cpof
j )Djrz*
Genco, LLC
UvD
NB
Zpg
Yorktown
Dominion
375
VA0004103
11/13/2017
Bstf ojd
Opof
Bti York River
Power Station
Hfofsbypo
X
Nfxjt ....
Df oubo
lffiotBmb
1459.8
.... WAR001818
12/31/2014
Cpof
Cpof -...
..... .....
..... .....
X J
Buffalo
Bm b
Dairyland Power
181
W10040223
12/31/2010
Nfsdvs
Opof
Mississippi River
Mercury Mercury (FCA)
Dppgfsbyv5
- Chippewa
River to Lock
and Dam 6
X J
Bti rboe
Bay Front
Northern States
27.2
W10002887
12/31/2007
Nfsdvs
Cpof
Power(Xcel
Fof shz*
X J
Cppof
Dpmn cfb
City of Columbia
1023
W10002780
9/30/2011
Nfsdvs
Opof
Bti
x
Ti fcpzhbo
Fehfxbrfs
Wisconsin Power&
770
W10001589
9/30/2008
Arsenic,
Cpof
- Lake Michigan
Mercury (Fish
'....
Light Company
Nfsdvs
Consumption Advisory)
x
Njm bvlff
Elm Road
Wisconsin Electric
1316.3
W10000914
3/29/2010
Nfsdvs
Opof
Lake Michigan
Mercury(FCA)
Generating
Power Company
Trbypo
x
V1 sopo
Hfopb
Dairyland Power
345.6
W10003239
6/30/2013
Nfsdvs
Nfsdvs
Mississippi River
Mercury (Fish
j
Dppgf sbymf
- Root River
Consumption Advisory)
to Wisconsin
'..
j Sj%f s
X J
Buffalo
J P Madgett
Dairyland Power
387
W10040223
12/31/2010
Nfsdvs
Opof
Bti Mississippi River
Mercury(FCA)
Dppgfsbyv5
- Chippewa
River to Lock
and Dam 6
x
Hsbou
Nelson Dewey
Wisconsin Power&
200
W10002381
12/31/2015
Cpof
Cpof
Ash Mississippi River
Mercury (Fish
'....
Light Company
- Wisconsin
Consumption Advisory) '...
'..
River to Lock
'..
and Dam 11
Closing the Floodgates 43

44 Closing the Floodgates
Inu
iia
ruin mu
. e
iiWo
Cm (eB
X J
Lfopti b
Pleasant
Wisconsin Electric
1233
W10043583
6/30/2009
Arsenic,
Nfsdvs
Ash&
Lake Michigan Mercury (Fish
Csbjsjf
Power Company
Nfsdvs
TcLwccfs
Consumption Advisory)
X J
Cspx o
Qva)bn
Wisconsin Public
350.2
W10000965
6/30/2011
Nfsdvs
Opof
Lake Michigan Mercury (Fish
Service Corporation
Consumption Advisory)
X J
Njmbvl ff
South Oak
Wisconsin Electric
11916
W10000914
3/29/2010
Nfsdvs
Cpof
Bti
Lake Michigan Mercury (FCA)
DsffI
Power Company
'...
x
Njm bvlff
Valley
Wisconsin Electric
272
W10000931
12/31/1991
Nfsdvs
Nfsdvs
Bti
)X FCDP'
Power Company
x
Nbsbu po
Xftrpo
Wisconsin Public
10871
W10042765
3/31/2015
Nfsdvs
Nfsdvs
Bti
Wisconsin River Mercury (Fish
Service Corporation
- Merril Dam to Consumption Advisory) '...
Prairie Du Sac '..
Ebn
X W
Npopohbgb
Fort Martin
Monongahela
1152
WV0004731
6/30/2014
Arsenic,
Opof
Power Station
Power Company
Mercury, Lead,
Tf rhojvn
X W
Nbtpo
Grant Town
Edison Mission
95.7
- WV0079235
1/29/2014
Arsenic,
Cpof
Power Plant
Operation &
Mercury,
Nbjod obodf
Tfrfiojvn
X W
I bssjtpo
Harrison
Allegheny Energy
2052
WV0005339
6/30/2015
Arsenic,
Opof
West Fork River Iron; Zinc
Power Station
Mercury, Lead,
Tf rhojvn
X W
CVrnbn
John EAmos
Appalachian Power
2932.6
WV0001074
6/6/2012
Arsenic,
Arsenic,
Ash&
Kanawha River Nfsdvs
j Dpngboz
Mercury, Lead,
Tfrfiojvn
TcLwccfs
j )WXfe
Tfrfiojvn
X W
Nbsti brm
Lbn n f s
Ohio Power
712.5
WV0005291
6/30/2015
Opof
Opof
Ohio River Jpo
Don gboz
(Upper South)
X W
Lbomc i b
Kanawha
Appalachian Power
439.2
WV0001066
11/17/2010
Cpof
Cpof
Bti
j SjWS
j Dpngboz
X W
Npopohbgb
Longview
Longview Power,
807.5
WV0116238
12/29/2016
Opof
Opof
Cox f s
N&D
X W
Nbst i btm
Nj ui frm
Ohio Power
1632.6
WV0005304
6/30/2015
Arsenic,
Tfrfiojvn
Bti
Fish Creek / Mercury; Iron
j Dpn gboz
Cadmium,
Ohio River
Selenium,
(Upper South)
Cpspo
X W
Npopohbgb
Morgantown
Morgantown
68.9
WV0078425
5/28/2014
Arsenic,
Arsenic,
Energy
Energy Associates
Mercury,
tfftjvn
G4*
Tfrhojvn
X W
Hsbou
Mount Storm
Dominion
1662.4
- WV0005525
4/13/2013
Mercury,
Cpof
Power Station
HfofsIBypo
Tfrfiojvn
X W
Nbtpo
Npvorbfoffs
Appalachian Power
1300
WV0048500
6/30/2013
Arsenic
Bstf ofd
Ash &
Don gboz
Nf sdvs
Tdsiccf s
X W
Hsbou
North Branch
Dominion
80
WV0115321
5/23/2017
Arsenic,
Cpof
Power Station
HfofsIBypo
Tfrfiojvn
x
Nbtpo
Phil Sporn
Appalachian Power
11055
WV0001058
6/30/2013
Arsenic,
Arsenic,
Bti
Dongboz
Mercury,
Tfrhojvn
Tf rhojvn
X W
Qfibt bod
Pleasants
Allegheny Energy
1368
WV0023248
12/13/2012
Arsenic,
Tfrfiojvn
Ohio River Jpo
Power Station
Mercury,
(Middle North) '...
Tfrfiojvn
x
DpoW stf
Dave Johnston
Pacificorp Energy
8167
WY0003115
11/30/2014
Cadmium
Tfrhofvn
Ash&
Hfofsbypo
Lead, Mercury,
Tdsiccfs
Tf rhojvn
X Z
Tx f f uc bds
Jim Bridger
Pacificorp Energy
2317.7
WYG650015
10/19/2012
Cpof
Cpof
Hf of sIBypo
X Z
fyodpro
Obvhi rpo
Pacificorp Energy
707.2
WY0020311
7/31/2013
Tf rhofvn
Opof
Bti
Hf of sbypo
X Z
Dbn qcf rm ...
X zpebl
Pacificorp Energy
362
WY0001384
9/30/2015
Tfrfiojvn
Cpof
Ash&
Hf of sIBypo
TcLwccfs
44 Closing the Floodgates

45
Inu iia
SEEM
Cm (eB
DP
Bebnt
Di fSPl f
Public Service
676.3
CO0001104
4/30/14
Boron,
Cadmium
Bti
South Platte
Dben jvn
Company of
Cadmium,
Lead,
SjWS
Dprpsbep
Mercury, Lead
Tfrhojvn
Tfrhojvn
DP
GUfcrp
Don boos f
Public Service
1635.3
CO0000612
10/31/13
Opof
Opof
St. Charles
Tfrhojvn
Company of
Sjvkfs
Dprpsbep
DP
Cpvrefs
Vbm you
Public Service
191.7
CO0001112
10/31/17
Cadmium,
OR&
Bti
Tributaries to
Tfrhojvn
'....
Company of
Boron,
St. Vrain Creek
Dprpsbep
Mercury,
Bstf ojd
Ov
GUwbn
Tfnjoprh
Seminole Electric
1429.2
FL0036498
8/28/17
Arsenic,
Selenium
Tdsiccfs
Rice Creek
Cadmium; Iron; Lead
'...
'....
Cooperative, Inc
Cadmium, '...
Lead, Mercury
Nickel; Silver
Lead, Mercury
J3
X ppecvs
George Neal
MidAmerican
1046
IA0004103
11/30/16
OR&
OR&
Bti
Missouri River
Mercury (Fish
j CpsJ
Energy Company
Consumption Advisory)
J3
X ppecvs
George Neal
MidAmerican
640
IA0061859
3/30/14
Opof
Opof
Bti
Missouri River
Mercury (Fish
Tpv Li
Energy Company
Consumption Advisory)
dv1
Tbohbn po
Ebrmbo
City of Springfield
667.7
IL0024767
12/31/06
Cpspo
Cpspo
Ash &
Illinois River
Mercury; Silver; Nitorgen
Jv1
TcLwccfs
Phosphorus; Total '...
'...
- Suspended Solids Fish
Consumption Advisory '..
Jvl
Cirtpo
Duck Creek
Ameren Energy
441
IL00SS620
2/28/13
Boron
Cpspo
Bti
Illinois River
Silver Boron Iron
Resources
Nf sdvs
Nf sdvs
Generating
Don gboz
dv1
Nbtpo
I bnbob
Dynegy Midwest
488
IL0001571
9/30/17
Nfsdvs
OR&
Ash &
Illinois River
Mercury; Silver; Nitorgen
Generation Inc.
TcLwccfs
Phosphorus; Total '...
'...
Suspended Solids Fish
Consumption Advisory
Jvl
CUwbn
Hennepin
Dynegy Midwest
306.3
IL0001554
4/30/16
Nfsdvs
Opof
Bti
Illinois River
Mercury (Fish
Power Station
Generation Inc
Consumption Advisory)
dv1
X jrm
Joliet 29
Midwest Generation
1320
IL0064254
11/30/00
OR&
OR&
Bti
Des Plaines
Mercury (Fish
EME, LLC
j SjWS
Consumption Advisory)
Jvl
X bti johrpo
Prairie State
Prairie State
245
IL0076996
11/30/10
Arsenic
Opof
Ash
Illinois River
Nfsdvs
Generating
Generating
Cadmium,
Don qboz
Don gboz
Mercury, Lead
Tfrhojvn
JD
Cptfz
A B Brown
Southern Indiana
530.4
IN0052191
9/30/16
Arsenic,
OR&
Bti
Ohio River
Mercury (fish tissue)
'...
Generating
Gas and Electric
Boron,
Evansville to
Trbypo j
Dpn gboz
Cadmium,
Vojoorpx o
Mercury,
'....
Tfrhojvn
,D
X bspol
Alcoa
Alcoa Allowance
777.6
IN00SSO51
3/31/91
Opof
Opof
Ash &
Ohio River
Mercury (fish tissue)
'......
'......
'.... Allowance '......
Management, Inc
'......
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'...... '......
'...... Tdsiccfs
Cannelton to
'...... '......
Management
Ofx cvshi
,bd
JD
Cpsls
Bailly
Northern Indiana
603.5
IN0000132
7/31/17
Arsenic,
OR&
Bti
Lake Michigan
Nfsdvs
'....
Generating
Public Service
Boron,
Shoreline -
'...
Trbypo j
Dpn gboz
Cadmium,
Evoft
'...
Mercury, Lead
'...
'....
Tfrhojvn
,D
VV sn jrI
Dbzvhb
Duke Energy
1062
IN0002763
7/31/12
Arsenic
Nfsdvs
Bti
Wabash River
Mercury (fish tissue)
Dpslpsbypo
Cadmium,
Selenium,
N f sdvs
JD
ql f
Frank E Ratts
Hoosier Energy
233.2
IN0004391
9/30/17
Arsenic,
OR&
Bti
White River
Mercury (fish tissue)
REC, Inc.
Mercury,
Tfrhojvn
,D
Npsh so
IPL Eagle
Indianapolis Power
3016
IN0004693
9/30/17
Arsenic
Opof
Bti
White River
Mercury (fish tissue)
Valley
& Light Company
Cadmium,
Generating
Lead, Mercury
Trbypo
Selenium,
Boron
JD
Nb4po
IPL - Harding
Indianapolis Power
698
IN0004685
9/30/17
Arsenic,
Cadmium
Ash &
White River
Mercury (fish tissue)
'...
Street Station
& Light Company
Boron,
Lead, Mercury
j TcLwccfs
'...
(EW Stout)
Cadmium,
(effective Aug
j
'...
Mercury, Lead
28, 2015)
Tfrhojvn
,D
C,)I f
IPL -
Indianapolis Power
2146.7
IN0002887
9/30/17
Arsenic
Boron
Ash &
White River
Mercury (fish tissue)
Petersburg
& Light Company
Boron,
Cadmium
Tdsiccfs
Generating
Cadmium,
Lead, Mercury
Trbypo
Mercury, Lead
Selenium
Tfrhojvn
(effective
Sept. 28
2015)
JD
M)gDsLf
Michigan City
Northern Indiana
540
IN0000116
2/29/16
Cadmium,
OR&
Bti
Lake Michigan
Mercury (Fish
Generating
Public Service
Mercury, Lead
Ti psfrjmf.
Consumption Advisory)
Trbypo j
Dpn gboz
Evoft
,D
Tgfodfs
Spol qpsu
Indiana Michigan
2600
IN0051845
11/30/15
Boron,
Lead,
Ash &
Ohio River
Mercury (fish tissue)
'...
Power Company
Mercury, Lead
Tfrhojvn
Tdsiccfs
Cannelton to
Tfrhojvn
Of x cvshi
JD
Dearborn
Tanners
Indiana Michigan
1100.1
INOOO216O
5/31/15
Arsenic,
None
Ash
Ohio River
Mercury in fish tissue
'...
Creek
Power Company
j
Cadmium,
and Tanners
'...
Mercury
Creek
,D
Vigo
Wabash
Duke Energy
'... 860.2
INOO63134
10/31/13
Arsenic, '...
None
Ash
Wabash River
Mercury (Fish
'...
'.. River Gen
Corporation
'... '....
'.... Mercury
'...
- Wabash Gen
Consumption '...
Station
Sta to Lost
Advisory)
Creek
Closing
the Floodgates
45

46 Closing the Floodgates
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mu
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uu
mu
Cm (eB
LT
Shawnee
Tecumseh
Westar Energy,
232
KS0079731
7/31/17
None
None
Ash
Kansas River
Lead
Energy
Inc.
Center
LZ
Hancock
Coleman
Big Rivers '...
602
'... KY0001937
'... 2/28/05
'... None
None
Ash
Ohio River
Mercury in fish tissue '...
Electric
Corporation
LZ
Mercer
E W Brown
LGE and KU
7571
KY0002020
2/28/15
None
None
Ash
Herrington Lake
Methylmercury
Energy LLC
(Fish Consumption
Advisory); Ph; Total '...
Suspended Solids
LZ
Daviess
'... Elmer Smith
Owensboro
445.3
KY0001295
3/31/05
None
'... None
Ash &
Ohio River
Mercury (Fish
Municipal '...
'... Scrubber '...
(Cannelton to
'... Consumption '...
Utilities
Newburgh)
Advisory)
LZ
:Pulaski
John S.
East Kentucky
344
KY0003611
10/31/13
None
None
Ash &
Lake
Methylmercury
Cooper
Power
Scrubber
Cumberland
'...
Cooperative
LZ
'... Woodford
'... Tyrone
Kentucky Utilities
75
KY0001899
1/31/07
None
None
Ash
Kentucky River,
Methylmercury
Company
53.2 to 66.95
(Fish Consumption
Advisory)
LZ
-Clark
William C
East Kentucky
216
KY0002194
11/30/06
None
None
Ash
Kentucky River,
Methylmercury
Dale
Power
121.1 to 138.5
(Fish Consumption '...
Cooperative
Advisory)
NS
Hampden
Mount Tom
First Light Power '...
136
MA0005339
9/17/97
'... None
None
Ash
Connecticut
Mercury (Fish '...
Resources
River
Consumption
Advisory)
NE
Allegany
AES Warrior
AES Corporation
229
MD0066079
12/31/17
None
None
Lower North
Cadmium; Nickel, Ph, '...
Run
Branch Potomac
Phosphorus
River
NJ
Muskegon
B C Cobb
Consumers
3126
M10001520
10/1/13
Mercury
None
Ash
Rivers/
Mercury (Fish
Energy Company
Streams in HUC
Consumption
040601021004
Advisory)
NJ
Ingham
Eckert
Lansing Board of
375
M10004464
10/1/12
Mercury
None
Rivers/
Mercury (Fish '...
Station
Water and Light
Streams in HUC
Consumption
040500040703
Advisory)
NJ
Eaton
Erickson
Lansing Board of
154.7
M10005428
10/1/12
Selenium
None
Rivers/
Mercury (Fish
Water and Light
Streams in HUC
Consumption
040500040704
Advisory)
NJ
Ottawa
J B Sims
Grand Haven
80
M10000728
10/1/15
Mercury,
None
Ash &
Grand River
Mercury; Mercury in '...
Board of Light
Selenium
Scrubber
fish tissue
and Power
'..
NJ
Monroe
Monroe
Detroit Edison
32796
M10001848
10/1/14
Mercury
Mercury
Ash &
Rivers/
Mercury (Fish
Company
Scrubber
Streams in HUC
Consumption
041000020410
Advisory)
NJ
Wayne
River Rouge
Detroit Edison
6506
M10001724
10/1/12
Boron,
None
Ash
Rivers/
Mercury (Fish '...
Company
Mercury,
Streams in HUC
Consumption
Selenium
040900040407
Advisory) '..
NU
Yellowstone
J E Corette
P P & L Montana,
172.8
MT0000396
3/1/05
None
None
Ash
Yellowstone
Arsenic, Nutrients
LLC
River
NU
- Richland
Lewis &
Montana
50
MT0000302
11/30/05
None
None
Ash
Yellowstone
Chromium, Copper, '...
Clark
Dakota Utilities
River
Lead '..
Company
'..
OZ
Orange
Dynegy
Dynegy Power
3865
NY0006262
5/31/11
Arsenic,
Arsenic,
Ash
Hudson River
Cadmium, PCBS
Danskammer
Corporation
Cadmium,
Cadmium,
Mercury,
Mercury,
Lead,
Lead,
Selenium
Selenium
PI
Lucas
Bay Shore
FirstEnergy
4988
OH0002925
7/31/15
Arsenic,
Mercury
Ash
Lake Erie
Arsenic; Total '...
Generation
Boron,
Tributaries (East
Suspended Solids, Oil
Corporation
Cadmium,
of Maumee
& Grease '...
Mercury,
River to West of
Lead,
Toussaint River)
'...
Selenium
'..
PI
Gallia
Gen J M
Ohio Power
2600
OH0028762
7/31/13
Boron,
Mercury
Ash &
Ohio River
Arsenic, Boron,
Gavin '...
Company
Cadmium,
Scrubber
Tributaries
Cadmium: Chromium, '...
Mercury,
(Downstream
Cobalt; Copper, Iron,
Selenium
Leading Creek
Lead; Mercury; Zinc,
to Upstream
Ph; Nickel
Kanawha River)
PI
:Gallia
Kyger Creek
Ohio Valley
10865
OH0005282
7/31/13
Arsenic,
Mercury
Ash &
Ohio River
Arsenic; Boron, '...
Electric
Boron,
Scrubber
Tributaries
Cadmium: Chromium, '...
Corporation
Cadmium,
(Downstream
Copper; Iron; Lead, '...
Mercury,
Leading Creek
Manganese; Mercury,
Lead,
to Upstream
Molybdeum; Nickel, '...
Selenium
Kanawha River)
Selenium; Silver '...
Zinc; Ph
PL
Choctaw
Hugo
Western
446
OK0035327
5/31/13
None
None
Ash
Washita River
Lead, Turbidity
Farmers Electric
Cooperative, Inc
CB
Allegheny
Cheswick
GenOn Power
637
PA0001627
8/31/12
Arsenic,
Cadmium,
Ash &
Little Deer Creek
Aluminum; Arsenic, '...
Midwest, LP
Boron,
Mercury,
Scrubber
Cadmium; Chronium,
j Cadmium,
i Lead,
i Copper; Lead; Iron, 1
Mercury,
Selenium
Manganese; Mercury,
Lead,
Molybdeum; Selenium, '...
Selenium
Silver; Thallium, Zinc '..
CB
Cambria
Colver Power
A/C Power
118
PA0204269
9/19/00
'... None
'... None
Elk Creek
Arsenic; Cadmium,
Project
- Colver
Chronium; Copper,
Operations
Iron; Mercury; Zinc,
Lead
46 Closing the Floodgates

Closing the Floodgates 47
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Cm (eB
CB
Schuylkill
Gilberton
Broad Mountain
884
PA0061697
9/1/14
None
None
Mill Creek
Arsenic; Cadmium;
Power
Partners
Chromium; Copper;
'....
Company
Iron; Lead; Mercury; '...
Zinc
CB
Venango
Scrubgrass
Scrubgrass
94.7
PA0103713
12/31/17
None
None
Alleghany River
Mercury
Generating
Generating
Plant
Company
CB
Indiana
Seward
GenOn
585
PA0002054
7/18/15
Arsenic,
None
- Conemaugh
Aluminum; Arsenic; '...
'....
Wholesale
Mercury,
River
Cadmium; Chromium;
Generation, LP
Lead
Cobalt; Copper; Iron; '...
'....
Manganese; Mercury;
'..
Nickel; Zinc; Ph '..
CB
Clearfield
Shawville
GenOn REMA
626
PA0010031
8/31/15
None
None
West Branch
Alumium, Arsenic, '...
LLC
Susquehanna
Cadmium; Chromium;
River
Copper; Iron; Lead;
Manganese; Mercury;
Nickel; Zinc
CB
Schuylkill
Wheelabrator
Wheelabrator
48
PA0061263
9/30/16
None
None
-Mill Creek
Arsenic; Cadmium;
'...
- Frackville
Frackville Energy j
Chronium; Copper;
Company, Inc
Iron; Lead; Mercury; '...
Zinc
CB
Schuylkill
WPS
Olympus Power,
36
'... PA0061344
4/30/17
None
'... None
'... '.. Lower Rausch
Arsenic; Cadmium; '...
Westwood
LLC
Creek
Chromium; Copper;
Generation,
Iron; Lead; Mercury;
LLC
Zinc
UO
Shelby
Allen
Tennessee Valley
990
TN0005355
8/3/10
None
None
Ash McKellar Lake
Mercury; Nickel; Ph;
'....
Authority
Total Suspended '...
'..
Solids '..
UO
Hawkins
John Sevier
Tennessee Valley
800
TN0005436
6/30/14
Arsenic,
Arsenic,
Ash Cherokee
Mercury
Authority
Cadmium,
Selenium
Reservoir
Mercury,
Lead,
Selenium
UO
Roane
Kingston
Tennessee Valley
1700
TN0005452
8/31/08
None
None
Scrubber Clinch River Arm
Mercury '...
Authority
of Watts Bar
Reservoir
N8
Campbell
Altavista
Dominion
711
'... VA0083402
'... 9/25/10
'... None
None
'... Scrubber Roanoke
Mercury (Fish '...
Power
Generation
(Staunton) River
Consumption
Station
Advisory)
VB
Halifax
Clover Power
Dominion
848
VA0083097
42381
None
None
Ash & Roanoke
Mercury (Fish '...
'...
Station
Generation
Scrubber (Staunton) River
Consumption
Advisory)
X J
Buffalo
Alma
Dairyland Power
181
W10040223
40543
Mercury
None
Mississippi River
Mercury, Mercury
Cooperative
- Chippewa River
(FCA)
to Lock and
Dam 6
X
Sheboygan
Edgewater
Wisconsin Power
770
W10001589
39721
Arsenic,
None
Lake Michigan
Mercury (Fish '...
& Light Company j
Mercury
Consumption
Advisory) '..
X J
Milwaukee
Elm Road
Wisconsin
1316.3
W10000914
40266
Mercury
None
Lake Michigan
Mercury (FCA)
Generating
Electric Power
Station
Company
X J
Vernon
Genoa
Dairyland Power
345.6
W10003239
41455
Mercury
Mercury
Mississippi River
Mercury (Fish '...
Cooperative
- Root River to
Consumption
'..
Wisconsin River
Advisory) '..
X J
Buffalo
J P Madgett
Dairyland Power
387
W10040223
40543
Mercury
None
Ash Mississippi River
Mercury (FCA) '...
Cooperative
- Chippewa River
to Lock and
Dam 6
X
Grant
Nelson
Wisconsin
200
W10002381
42369
None
None
Ash - Mississippi River
Mercury (Fish '...
Dewey
& Light Company j
- Wisconsin River
Consumption
'...
to Lock and
Advisory) '...
Dam 11
'... xi
Kenosha
Pleasant
Wisconsin
1233
'... W10043583
'... 39994
Arsenic,
'... Mercury
Ash & '... Lake Michigan
Mercury (Fish
'...
Prairie
Electric Power '...
'... Mercury
Scrubber
'... Consumption '...
Company
Advisory)
X J
Brown
Pulliam
Wisconsin
3502
W10000965
40724
Mercury
None
Lake Michigan
Mercury (Fish '...
'...
Public Service
Consumption
Corporation
Advisory)
X J
Milwaukee
South Oak
Wisconsin
1191.6
'... W10000914
'... 40266
Mercury
None
'... Ash '... Lake Michigan
Mercury (FCA)
Creek
Electric Power
Company
X
Marathon
Weston
Wisconsin
10871
W10042765
42094
Mercury
Mercury
Ash Wisconsin River
Mercury (Fish
'...
Public Service
- Merril Dam to
Consumption '...
Corporation
Prairie Du Sac
Advisory)
Dam
X W
Putnam
John E Amos
Appalachian
2932.6
WV0001074
41066
Arsenic,
Arsenic,
Ash & Kanawha River
Mercury
Power Company
Mercury,
Selenium
Scrubber (Lower)
Lead,
Selenium
X W
Marshall
Mitchell
Ohio Power
1632.6
WV0005304
42185
Arsenic,
Selenium
Ash Fish Creek/
Mercury; Iron '...
Company
Cadmium,
Ohio River
'...
Selenium,
j (Upper South)
'...
Boron
Closing the Floodgates 47