May 4, 2023
Toxic Coal Ash Near the Great Lakes: Addressing Coal Plants’ Hazardous Legacy
For decades, utilities disposed of coal ash — the hazardous substance left after burning coal for energy — by dumping it in unlined ponds and landfills. There are 88 coal ash dumpsites within two miles of one of the Great Lakes.
Coal ash contains hazardous pollutants including arsenic, boron, cobalt, chromium, lead, lithium, mercury, molybdenum, radium, selenium, and other heavy metals, which have been linked to cancer, heart and thyroid disease, reproductive failure, and neurological harm. In 2023, the EPA acknowledged that coal ash is even more dangerous than previously thought, with levels of arsenic and radiation that pose cancer risks.
Industry’s own data indicate that across the country 91% of coal plants are currently polluting groundwater above federal health standards with toxic pollutants.
Coal ash remains one of our nation’s largest toxic industrial waste streams. U.S. coal plants continue to produce approximately 70 million tons every year.
Despite EPA’s 2015 Coal Ash Rule, which created the first-ever safeguards for coal ash disposal, many coal ash dumps remain unregulated due to sweeping exemptions for legacy coal ash ponds and inactive landfills.
The exempted coal ash dumps are sited disproportionately in low-income communities and communities of color. After years of litigation and grassroots activism, the EPA will extend clean up requirements to hundreds of old coal ash dumps across the country when it issues new regulations in the spring of 2024.
In 2023, the EPA acknowledged widespread noncompliance with existing coal ash regulations and ramped up enforcement after designating coal ash a national enforcement priority.
Action Needed
The magnitude of harm from recklessly dumped toxic coal ash requires decisive action from federal and state regulators.
- Utilities must be required to comply with the law and immediately clean up their pollution.
- EPA and states must act quickly to ensure that utilities leave communities with sites that benefit rather than harm their health, environment, and economic status.
- EPA must take action to prohibit the use of coal ash as construction fill and make polluters clean up areas where ash was used as fill.
34 Regulated Coal Ash Disposal Sites within Two Miles of Great Lakes
Utilities operating coal plants within two miles of a Great Lake operate 34 federally regulated coal ash ponds and landfills at 16 plants that contain more than 57 million cubic yards of toxic waste.
At all but two of these coal plants, industry monitoring data indicate coal ash has caused significant groundwater contamination at regulated dumpsites.
The utilities, however, have failed to initiate any plant-wide cleanups to restore water resources despite the legal requirement to do so.
| Waukegan | IL | Commonwealth Edison Co. | 2 unlined ponds | Sulfate (x1) |
| Bailly | IN | Northern Indiana Pub Serv Co | 4 unlined ponds | Arsenic (x8), Cadmium (x2), Lithium (x2), Molybdenum (x16), Thallium (x5) |
| Michigan City* | IN | Northern Indiana Public Service Company | 2 unlined ponds | Arsenic (x4), Boron (x2), Selenium (x1), Thallium (x2) |
| Dan E Karn | MI | Consumers Energy Co | 1 unlined pond | Arsenic (x45), Boron (x2), Lead (x2), Molybdenum (x1), Sulfate (x1) |
| J H Campbell | MI | Consumers Energy Co | 3 unlined ponds, 1 landfill | Antimony (x3), Arsenic (x29), Cobalt (x2), Lithium (x2), Molybdenum (x3), Selenium (x1), Thallium (x1) |
| J R Whiting | MI | Consumers Energy Co | 2 unlined ponds | Cobalt (x1), Lithium (x2), Thallium (x1) |
| Presque Isle | MI | We Energies | 1 landfill | No contaminants exceeding |
| J B Sims | MI | Grand Haven Board of Light and Power | 2 unlined ponds | Arsenic (x12), Boron (x75), Cobalt (x1), Fluoride (x4), Lithium (x50), Sulfate (x2) |
| J C Weadock | MI | Grand Haven Board of Light and Power | 1 unlined pond, 1 landfill | Arsenic (x8), Beryllium (x3), Boron (x2), Cobalt (x2), Lithium (x6), Molybdenum (x3), Sulfate (x4), Thallium (x1) |
| Monroe | MI | DTE Electric Co. | 2 unlined ponds, 1 landfill | Boron (x1), Lithium (x3), Sulfate (x3) |
| Shiras | MI | Marquette Board of Light & Power | 1 unlined pond | Cobalt (x1), Lead (x2) |
| Taconite Harbor | MN | Minnesota Power | 1 landfill | No contaminants exceeding |
| AES Somerset LLC | NY | Somerset Operating Company, LLC | 1 unlined pond, 1 landfill | Antimony (x4), Arsenic (x1), Boron (x69), Cobalt (x4), Lithium (x6), Sulfate (x4) |
| Dunkirk Generating Plant | NY | NRG | 1 landfill | Antimony (x3), Thallium (x2) |
| Edgewater | WI | Wisconsin Power & Light Co. | 4 unlined ponds, 1 landfill | Arsenic (x2), Boron (x5), Cobalt (x1), Lithium (x1), Molybdenum (x55) |
| South Oak Creek | WI | We Energies | 1 landfill | Molybdenum (x1) |
* Michigan City Plant operates inactive coal ash ponds at the facility but has not reported the ponds on its CCR Rule Compliance Data and Information website nor has the owner complied with the CCR rule’s requirements that apply to these ponds, including groundwater monitoring, closure, and corrective action.
All data on groundwater contamination from coal ash derived from the utilities’ publicly accessible CCR Compliance Data and Information websites, and exceedances were calculated by Environmental Integrity Project.
For more information on regulated coal ash sites in Alabama and throughout the U.S., see Mapping the Coal Ash Contamination.
54 Unregulated Coal Ash Legacy Ponds and Inactive Landfills near Great Lakes (ash dumps exempted from the 2015 Coal Ash Rule)
March 2024 Update: The table below underestimates the legacy units that may be regulated by EPA’s upcoming CCR Legacy Pond Rule. Additional legacy units at specific plants may be found in the national map, above.
Utilities operating coal plants within two miles of a Great Lake operate host at least 54 unregulated inactive coal ash landfills and legacy ponds that escape federal regulation. The exact number remains unknown because utilities are not required to report these sites.
These dumps are almost certainly contaminating water and threatening health and the environment; however, monitoring data are not currently available for most unregulated sites.
As we anticipate EPA’s proposed rule on legacy ponds and unregulated landfills in May 2023, a concern remains that the agency will not address coal ash that was dumped off site or used as fill.
| Waukegan | IL | Commonwealth Edison Co. | 0 | 1 | Yes – EPA damage case |
| Bailly | IN | Northern Indiana Pub Serv Co | 0 | 2 | Yes – EPA damage case |
| Michigan City | IN | Northern Indiana Pub Serv Co | 0 | 1 | Yes – EPA damage case |
| Dean H Mitchell | IN | Northern Indiana Pub Serv Co | 8 | 0 | Unknown – no data |
| State Line Energy | IN | State Line Energy LLC | 1 | 0 | Unknown – no data |
| Dan E Karn | MI | Consumers Energy Co | 0 | 1 | Yes – Industry data |
| Harbor Beach | MI | Detroit Edison Co | 3 | 0 | Unknown – no data |
| J H Campbell | MI | Consumers Energy Co | 0 | 6 | Yes – EPA damage case |
| J R Whiting | MI | Consumers Energy Co | 0 | 2 | Yes – EPA damage case |
| Presque Isle | MI | We Energies | 0 | 2 | Yes – EPA damage case |
| Taconite Harbor Energy Center | MN | Minnesota Power | 0 | 4 | Unknown – no data |
| AES Somerset LLC | NY | Somerset Operating Company, LLC | 0 | 2 | Yes – Industry data |
| Avon Lake | OH | GenOn Power Midwest LP | 2 | 1 | Unknown – no data |
| FirstEnergy Ashtabula | OH | FirstEnergy Generation Corp | 1 | 0 | Unknown – no data |
| FirstEnergy Bay Shore | OH | FirstEnergy Generation Corp | 1 | 1 | Unknown – no data |
| FirstEnergy Eastlake | OH | FirstEnergy Generation Corp | 1 | 1 | Unknown – no data |
| FirstEnergy Lake Shore | OH | FirstEnergy Generation Corp | 1 | 0 | Unknown – no data |
| Bay Front | WI | Northern States Power Co - Minnesota | 0 | 2 | Yes – EPA damage case |
| Port Washington Generating Station | WI | Wisconsin Electric Power Co. | 0 | 1 | Yes – EPA damage case |
| Pulliam | WI | Wisconsin Public Service Corp | 1 | 1 | Yes – EPA damage case |
| Valley | WI | Wisconsin Electric Power Co | 0 | 4 | Yes – EPA damage case |
| Edgewater | WI | Wisconsin Power & Light Co. | 0 | 1 | Yes – EPA damage case |
| South Oak Creek | WI | We Energies | 0 | 2 | Yes – EPA damage case |
These data were developed by using EPA datasets relied upon in their 2007 and 2014 CCR risk assessments (Human and Ecological Risk Assessment of Coal Combustion Residuals) and comparing those datasets to the universe of regulated units.
“Industry data”: Historical industry monitoring data is the basis of the finding of contamination. See Ashtracker.
“EPA damage case” denotes a site where US EPA has found documented groundwater contamination from coal ash.
For More Information
Christine Santillana, Legislative Counsel, Earthjustice, csantillana@earthjustice.org
Lisa Evans, Senior Counsel, Earthjustice, levans@earthjustice.org.
More on Coal Ash Near the Great Lakes
- EPA Moves to Reject Six Coal Plants’ Applications to Keep Toxic Coal Ash Dumps Open (January 25, 2023)
- Poisonous Coverup: The Widespread Failure of the Power Industry to Clean Up Coal Ash Dumps (November 3, 2022)
- Cleaning Up Coal Ash For Good: Resources and Recommendations (July 8, 2021)
- Court Victories Signal Hope for Communities Threatened by Coal Ash (August 10, 2021)
- Illinois Coal Ash Rule Will Clean Up Coal’s Dirty Legacy (April 16, 2021)
- What Schoolhouse Rock Didn’t Tell You About Lawmaking (April 16, 2021)
- Other states are making utilities dig up toxic coal ash. Indiana is letting it sit there. (February 10, 2021)
- Milestone Bill to Clean Up Coal Ash Pollution in Illinois Becomes Law (July 30, 2019)
- Secrets in the Ash (December 14, 2018)
- Cap and Run: Toxic Coal Ash Left Behind by Big Polluters Threatens Illinois Water (November 27, 2018)
- New Tests Reveal 15 out of 15 of Indiana’s Coal Ash Sites Are Leaking (August 17, 2018)
- Federal Lawsuit Filed to Force Dynegy to Clean Up Toxic Pollution of Vermilion River (May 30, 2018)
- Groups to Sue to Compel Duke Energy to Stop Withholding Required Toxic Waste Spill Safety Information (September 20, 2017)
- Duke Energy Violates National Coal Ash Rule by Hiding Critical Dam Safety Information (September 20, 2017)
- Dumping Toxic Coal Ash Threatens the Great Lakes (July 20, 2015)
- "Pure Michigan" Might Not be So Pure (December 5, 2013)
- Messed Up in Michigan (March 8, 2013)
- Tr-Ash Talk: Rebellion Against Coal Ash in Illinois (August 31, 2011)
Coal Ash in States, Territories, Regions
Puerto Rico (En Español)
Earthjustice fights in the courts for a long-term solution to the toxic menace of coal ash. And we act on behalf of dozens of clients and over 100 coalition partners to defeat legislative attempts to subvert federally enforceable safeguards of coal ash.
Earthjustice’s Clean Energy Program uses the power of the law and the strength of partnership to accelerate the transition to 100% clean energy.
