Toxic Coal Ash in Texas: 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. Texas has 79 coal ash dumpsites.

Texas is the nation’s top coal ash-generating state, ranking first in ash production in 2020. Texas also had the third highest number of operational coal plant units in 2022.

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.

A South Texas rancher looks out over his family’s land that has been contaminated by pollutants from the San Miguel Electric Plant, in the background.
A South Texas rancher looks out over his family’s land that has been contaminated by pollutants from the San Miguel Electric Plant, in the background. (Ari Phillips / EIP)

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.
Coal ash dump sites across the United States. Use this map to understand where coal ash might be stored near you and how a given site may be impacted by EPA's expansion of the federal Coal Ash Rule. (Caroline Weinberg / Earthjustice)

51 Federally Regulated Coal Ash Disposal Sites in Texas

Texas utilities operate 51 federally regulated coal ash ponds and landfills containing more than 156 million cubic yards of toxic waste at 17 coal plants.

Texas is home to the most contaminated coal ash site in the U.S.

Groundwater is contaminated above federal safe standards at all Texas plants where data are available.

Despite the serious and widespread water contamination, no Texas plant, to date, has selected a final plan to adequately clean up groundwater, as required by state law.

Big Brown Fairfield Luminant 2 unlined ponds, 1 landfill Boron (x2), Cobalt (x2), Selenium (x3)
Calaveras San Antonio CPS Energy 5 unlined ponds, 1 landfill Beryllium (x4), Boron (x3), Cadmium (x2), Cobalt (x24), Lead (x1), Lithium (x2), Radium 226+228 (x1), Selenium (x4), Thallium (x1)
Coleto Creek Fannin Luminant 2 unlined ponds Boron (x4), Molybdenum (x3)
Fayette Power Project* La Grange Lower Colorado River Authority 1 landfill Lithium (x3), Sulfate (x3)
Gibbons Creek Anderson Texas Municipal Power Agency 2 unlined ponds, 1 landfill Antimony (x3), Arsenic (x1), Beryllium (x29), Boron (x5), Cadmium (x18), Cobalt (x97), Lead (x2), Lithium (x19), Mercury (x1), Radium 226+228 (x2), Sulfate (x6), Thallium (x4)
HW Pirkey Hallsville AEP 2 unlined ponds, 2 landfills Arsenic (x1), Beryllium (x2), Boron (x1), Cadmium (x1), Cobalt (x47), Lithium (x4), Mercury (x4), Radium 226+228 (x2), Sulfate (x2)
J Robert Welsh Pittsburg AEP 2 unlined ponds, 1 landfill Arsenic (x2), Beryllium (x3), Boron (x1), Cobalt (x133), Lead (x1), Lithium (x49), Radium 226+228 (x3), Sulfate (x10)
Limestone Jewett NRG 1 unlined pond, 1 landfill Boron (x3), Sulfate (x2)
Martin Lake Tatum Luminant 4 unlined ponds, 1 landfill Arsenic (x1), Beryllium (x3), Boron (x11), Cobalt (x31), Lithium (x4), Mercury (x12), Sulfate (x4)
Monticello Mt Pleasant Luminant 3 unlined ponds Arsenic (x3), Beryllium (x8), Boron (x4), Cadmium (x4), Cobalt (x55), Lithium (x1), Selenium x2
Oak Grove Franklin Luminant 1 unlined pond, 2 lined ponds, 1 landfill Chromium (x2), Cobalt (x4), Lithium (x3)
Oklaunion Oklaunion Oklaunion Industrial Park 5 unlined ponds Not evaluated
San Miguel Christine San Miguel Electric Co 2 unlined ponds, 1 landfill Arsenic (x8), Beryllium (x127), Boron (x41), Cadmium (x114), Cobalt (x488), Fluoride (x2), Lithium (x90), Mercury (x3), Radium 226+228 (x6), Selenium (x8), Sulfate (x20), Thallium (x4)
Sandow Rockdale Luminant 1 landfill Chromium (x2), Lithium (x13)
Sandy Creek Reisel Sandy Crk Energy A 1 landfill Arsenic (x2), Cobalt (x2), Lead (x2), Lithium (x19), Selenium (x3), Sulfate (x6)
Twin Oaks Bremond Major Oak Power 1 landfill Unsafe levels of radium, cobalt, arsenic, sulfate, lithium and thallium
WA Parish Thompsons NRG 2 ponds, 1 landfill Antimony (x2), Arsenic (x3), Lithium (x2), Sulfate (x3), Thallium (x1)

* Fayette Power Project 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.

Twin Oaks Plant's groundwater contamination: Based on industry monitoring data. See Ashtracker.

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 Texas, see Mapping the Coal Ash Contamination.

28 Unregulated Coal Ash Legacy Ponds and Inactive Landfills in Texas (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.

In addition, Texas hosts at least 28 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.

Big Brown Fairfield Luminant 0 3 Yes – Industry data
Coleto Creek Fannin Coleto Creek Power LP 0 1 Yes – EPA damage case
Gibbons Creek Anderson Texas Municipal Power Agency 0 1 Yes – Industry data
Harrington Amarillo Southwestern Public Service Co 2 2 Unknown
JT Deely San Antonio City of San Antonio 0 1 Unknown
Martin Lake Martin Lake Luminant 0 5 Yes – EPA damage case
Monticello Mt Pleasant Luminant 0 3 Yes – Industry data
Oak Grove Franklin Luminant 0 2 Yes – Industry data
Oklaunion Oklaunion West Texas Utilities 0 1 Unknown
San Miguel Christine San Miguel Electric Coop 0 1 Yes – Industry data
Sandow No 4 Rockdale Luminant 0 5 Yes – Industry data
Tolk Muleshoe Southwestern Public Service Co 0 1 Unknown

“Industry data”: 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.

“EPA damage case” denotes a site where US EPA has found documented groundwater contamination from coal ash.

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.

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.