Coal Ash and the Toxic Legacy of Fossil Capital

The Toxic Heritage of the Harding Street Station

For over a century, AES Indiana and its predecessors have prided themselves on providing cheap, efficient coal-generated energy to Hoosiers. But what did this cheap power truly cost? While coal pushed the United States into a new age of industrialization, the coal ash pits at the Harding Street Station power plant on the southwest side of Indianapolis have caused major issues for the local environment.


Sunshine Gardens

In 1925, developers started selling a dream in Sunshine Gardens. Families bought into that dream and now Sunshine Gardens is set in a little valley on the southwest side of Indianapolis near the Harding Street Station. Many families have lived in Sunshine Gardens since those few first homes in the 1920s. Recently, residents like Joyce Craven have discovered toxic levels of boron and other heavy metals in their drinking water. Keep reading to learn more about their experiences.


Coal and Capitalism in the Anthropocene

The Anthropocene is the current geological age in which humans are the primary influence on the environment and the climate. It coincides with the emergence of the Industrial Revolution in the 19 th  century, during which capitalism drove industry and coal rose to the forefront as the dominant energy source.

Coal mining, 1923. Credit: National Photo Company Collection, Library of Congress, Prints and Photographs Division.

Coal continues to dominate today’s energy industries and its environmental and human impacts permeate physical and cultural landscapes. Even as we begin to be more conscientious of our effects on the climate and strive to shift to cleaner, more renewable forms of energy, individuals, industries, and governments must deal with the lasting impacts of fossil capital.

Coal train transports the fuel of America. Credit: Carol M. Highsmith's America, Library of Congress, Prints and Photographs Division.

“These coal plant sites that operated for nearly a century in some cases buried toxic waste all over. As these sites are retired, and in order to make sure this isn’t a long toxic legacy, you have to deal with all the toxic sources” – Lisa Evans, senior attorney at Earthjustice, quoted in Courier Journal, January 5, 2022

What is Coal Ash?

Coal ash, also called Coal Combustion Residuals (CCR) or Coal Combustion Waste (CCW), is a number of byproducts resulting from burning coal, often to generate electricity. The waste is produced at many different stages in the process and includes things like boiler slag (molten ash in the form of pellets from coal-burning furnaces), fly ash (a fine, silica-based powder), and scrubber residues (wet residue resulting from emission treatment at coal power-plants). These and other waste products are often mixed with water to create a slurry-like substance which is then stored in landfills or unlined pits called coal ash ponds.

Toxins in Coal Ash

Coal ash contains numerous toxins that can, in certain concentrations or through certain routes of exposure (inhalation, ingestion, skin contact), be harmful and potentially fatal to human health.

These toxins, including arsenic, lead, and mercury, can leach into the water systems surrounding coal ash ponds if the ponds are unlined. By leaching into the groundwater, the coal ash contaminates drinking water and other public waters with its poisonous compounds and elements.

In the event of a flood, contents of uncovered coal ash pits also risk entering nearby waterways, such as rivers and creeks, thereby contaminating the waterways that serve as people's sources of drinking water, food, and recreation.

National Regulations of Coal Ash and Coal Ash Ponds

In 1976, the Resources Conservation and Recovery Act authorized the EPA to regulate coal combustion residuals, but it would be decades before any rules were implemented to do so. Two catastrophic coal ash spills, the Kingston Fossil Plant Spill in 2008 and the Dan River Coal Ash Spill in 2014 ushered in the 2015 Standards for the Disposal of Coal Combustion Residuals in Landfills and Surface Impoundments (Coal Ash Rule). The Coal Ash Rule, amended several times, includes stipulations for the safe disposal of coal ash; recordkeeping and reporting; public availability of facility information; and risks associated with the disposal of coal ash. Enforcement of adherence by utility companies was left to the states.

Indiana Regulations of Coal Ash and Coal Ash Ponds

Indiana has the most active coal ash pits of any state in the country and has among the worst record of coal ash spills in the nation. In Indiana, the Indiana Department of Environmental Management (IDEM) enforces the federal Coal Ash Rule. The Indiana Senate Bill 271, passed in 2021, authorizes IDEM to develop a permit program for the Coal Ash Rule under the Water Infrastructure Improvements for the Nation Act (2016). HR 1332 and SB 412, two pieces of Indiana legislation requiring the safe disposal of coal ash as part of state law, were killed in committee.

“Indiana has more coal ash ponds than any other state, and yet at least a handful of other states have managed to excavate their coal ash. We know it can be done and be done cost effectively and successfully” – Susan Thomas, northwest Indiana resident, 2021, quoted in Indianapolis Star, February 14, 2021

In 2022, Earthjustice, a nonprofit legal organization, filed a lawsuit against the EPA on behalf of several plaintiffs, including the Hoosier Environmental Council for the EPA’s failure to regulate some coal ash landfills, such as those located at the Harding Street Generating Station. Residents near these plants and environmental groups are worried about the coal ash contaminating the waterways.

“The overall conclusion of this preliminary analysis is that toxic concentrations of coal ash contaminants have been migrating in all directions from the ponds since the 1980s and probably much longer” -J. Russell Boulding, Hoosier Environmental Council consulting geologist, March 2014, quoted in Our Waters at Risk, 2014


The Harding Street Generating Station

Site: AES Indiana's Harding Street Station (HSS), 3700 S Harding St., Indianapolis, Indiana 46217

Situation: HSS's coal ash ponds are adjacent to White River and Lick Creek.

 Map credit: Matthew Mers  

They are within the West Fork White River floodplain and the Dollar Hide Creek-White River Watershed.

The ponds sit above the White River Outwash Aquifer System (pink), a shallow sand and gravel aquifer from which drinking water is sourced.

The ponds are near the city's drinking water wells, including the private wells used by Sunshine Gardens residents, 1.5 miles downstream from Harding Street Station.

More than 35,000 people live within three miles of the power plant.

The blue circle represents the three-mile radius. Click on the map to view demographic data. Zoom in to see the coal ash ponds and Sunshine Gardens.

 Map credit: Matthew Mers 

"It's not only going to affect our little neighborhood, but (it has) the potential to affect a lot of people if it gets into that aquifer"

- Stella Harper, Sunshine Gardens resident, quoted in NUVO, March 16, 2016.

Homeowners concerned about drinking water safety, WRTV Indianapolis, May 16, 2016

Sunshine Gardens: In the Shadow of a Coal-Powered Plant

Sunshine Gardens is located 1.5 miles downstream of the Harding Street Station.

The subdivision was there in the 1920s before the plant was constructed. It is a small, working-class neighborhood, with about 200 homes.

Advertisment for Sunshine Gardens. Source: Indianapolis News, September 26, 1925, newspapers.com

It was promoted as a place to move away from the dirt, noise, and smoke of the city. Sunshine Gardens was advertised as a great place to raise children.

But today, it is a place where residents are worried about their health and safety.

Their drinking water is at risk of contamination from the Harding Street Station coal ash ponds and other toxic industrial sites in the area.

The water already shows elevated levels of boron, though these levels are currently within "safe" drinking water levels. Groundwater contamination from unlined coal ash ponds can occur within approximately one mile of the ponds, by some estimates, if not farther.

“None of us knew about the coal ash ponds; we didn’t even know they existed. We didn’t give a thought about the plant being there and the problems it could cause other than the air pollution.” – Stella Harper, lifetime Sunshine Gardens resident, 2017, quoted in Indianapolis Star September 24, 2017

Sunshine Gardens residents test their water for toxins. Source: The Indianapolis Star, March 28, 2018

Sunshine Gardens was built in the 1920s before the Harding Street Station was constructed. However, for most of its existence, Sunshine Gardens residents have had to deal with the Harding Street Station's air, water, and ground pollution, from the time of the powerplant's construction to its growth throughout the decades.

"Superpower Station of the Company": Timeline of Harding Street Station

1931

Construction of HSS is completed by Indianapolis Power & Light (IPL), making it the fourth power plant in Indianapolis at the time. It was to be the “superpower station of the company” and was built to address “the growth of [IPL’s] business and the expectation of large industrial development in the city” (Indianapolis Star 1929). It cost $16,000,000 to build and would have a 240,000-kilowatt capacity, “putting it among the largest power producers of the country in cities comparable to Indianapolis” (Indianapolis Star 1929).

Drawing of HSS. Credit: The Indianaplis Star, November 23, 1931, via Newspapers.com

1947

The plant's 4th generating unit begins operation.

1958

The first of eight coal ash ponds is commissioned, and the plant name changes to Elmer W. Stout plant, for a long-term serving board member of IPL. The 5th generating unit for the plant is also constructed.

1961

The plant's 6th generating unit begins operation.

1973

The plant's 7th generating unit begins operation.

News clipping announcing new generating unit, the Indianapolis News, July 18, 1973.

1983

Final coal ash pond is commissioned.

1986

IPL installs 13 groundwater monitoring wells adjacent to the coal ash ponds, though testing was not conducted consistently nor continuously.

2001

IPL is acquired by Applied Energy Service Corporation (AES) and HSS is no longer referred to as the Elmer W. Stout Station. $60 million is spend between 2000 and 2002 to increase HSS's capacity.

2010

Assessment of HSS coal ash ponds is conducted by CDM on behalf of the Environmental Protection Agency (EPA), finding that many of the ponds were in poor condition and presented high or significant risks.

2013

IPL wins approval for funds ($500 million) to upgrade HSS and Petersburg plants in order to continue to burn coal while still adhering to EPA standards and regulations.

2015

The EPA's Coal Ash Rule goes into effect, and thus HSS is required to deal with its problematic coal ash pits.

2016

IPL stops burning coal at HSS and converts plant to 100% natural gas in order to comply with EPA regulations at the lowest cost to customers (and the company) as possible.

IPL, now AES Indiana, announces it will convert its Harding Street Generating Station to natural gas, complying with new EPA rules and regulations for emissions. Image Source: The Indianapolis Star, May 31, 2015, newspapers.com.

As the city grew and the needs of the residents, businesses, and industries also grew, IPL constantly increased HSS’s generating capacity throughout the years At the same time, IPL was creating more waste, necessitating the construction of more coal ash ponds.

Industrialization and the growth of populations ushered in a greater need for energy, and IPL, now AES Indiana, helped provide cheap, efficient power to the masses through its coal-powered plants. It fueled the growth of the city and provided jobs, in turn necessitating greater growth of the power plant. As it did this, it also harmed the environment through air, ground, and water pollution, negatively impacting the communities within its shadow.  

Advertisement from the Northern Indiana Public Service Company and the other Electric Companies of Indiana, including Indianapolis Power & Light. Source: The Wolcott Beacon, November 16, 1950, Hoosier State Chronicles.

The switch from coal power to natural gas in 2016 at the Harding Street Station was not a choice based on environmental concerns and human health protection, but rather one that was based on cost-efficiency, in order to still comply with the EPA’s regulations.

Sluiced Sludge: Harding Street's Eight Coal Ash Ponds

Location of Harding Street Generating Station's coal ash ponds in 1956 before the commissioning of the first pond in 1958 versus location of Harding Street Generating Station's coal ash ponds in 2021. Source: MapIndy.

1

Coal Ash Pond 1

Hazard Potential Classification - Significant

Regulated under Federal Coal Ash Rule? Yes

1958 - commissioned

1995 - levees elevated to 684 feet

1998 - levees widened

Breach of Pond 1 could...

"have an environmental impact on Lick Creek and the White River"

"damage/washout plant access and haul roads"

"cause failure of adjacent lower ponds with discharge into Lick Creek"

-CDM 2010, 4-2

Significant Hazard Potential Classification - classification assigned to a "diked surface impoundment where failure or mis-operation results in no probable loss of human life, but can cause economic loss, environmental damage, disruption of lifeline facilities, or impact other concerns” (Sargent & Lundy 2021a, 1).

2

Coal Ash Pond 2

Recommended Hazard Rating (CDM 2010) - High

Regulated under Federal Coal Ash Rule? No, exempt (has geosynthetic liner)

1968 - commissioned

1980 - wing leveee constructed

1992 - Perry K ash disposal facility constructed

1995 - levees raised to elevation of 684 feet

1998 - levees widened

2001 - levee elevation raised 17 feet

2006 - levee elevation raised 20 feet

Breach of Pond 2 could...

"adversely affect adjacent stone quarry operation, and possibly result in worker's loss of life, due to the close proximity of the quarry to the south embankment"

"have an environmental impact on Lick Creek and White River and possible property damage and loss of life downstream"

"cause failure of adjacent lower ponds with discharge into Lick Creek"

-CDM 2010, 4-2

High Hazard Potential Classification - classification assigned to a "diked surface impoundment where failure or mis-operation will probably cause loss of human life" (Sargent & Lundy 2021a, 1).

3

Coal Ash Pond 3

Hazard Potential Classification - Significant

Regulated under Federal Coal Ash Rule? Yes

Coal Ash Pond 3 discharges directly into Lick Creek

1977 - commissioned

1995 - levees raised to elevation of 684 feet

1998 - levees widened

Breach of Pond 3 could...

"have an environmental impact on Lick Creek and White River and cause possible property damage"

-CDM 2010, 4-2

Significant Hazard Potential Classification - classification assigned to a "diked surface impoundment where failure or mis-operation results in no probable loss of human life, but can cause economic loss, environmental damage, disruption of lifeline facilities, or impact other concerns” (Sargent & Lundy 2021a, 1).

4

Coal Ash Pond 4

Recommended Hazard Rating (CDM 2010) - High

Regulated under Federal Coal Ash Rule? No, exempt

Former gravel borrow pit -- coal ash may have been dumped directly into the deposits of the White River Outwash Aquifer

1983 - commissioned

1995 - levees raised to elevation of 684 feet

1998 - levees widened

Breach of Pond 4 could...

"cause property damage at an adjacent stone quarry and possibly result in quarry worker's loss of life due to the close proximity of the quarry to Ash Pond 4"

"cause failure of adjacent lower ponds with discharge into Lick Creek"

-CDM 2010, 4-2

High Hazard Potential Classification - classification assigned to a "diked surface impoundment where failure or mis-operation will probably cause loss of human life" (Sargent & Lundy 2021a, 1).

5

Coal Ash Pond 2A

Hazard Potential Classification - Low

Regulated under Federal Coal Ash Rule? Yes

1992 - commissioned

Breach of Pond 2A could...

"damage plant haul roads"

-CDM 2010, 4-2

Low Hazard Potential Classification - classification assigned to a “diked surface impoundment where failure or mis-operation results in no probable loss of human life and low economic and/or environmental losses. Losses are principally limited to the surface impoundment owner’s property” (Sargent & Lundy 2021a, 1)

6

Coal Ash Pond 2B

Hazard Potential Classification - Low

Regulated under Federal Coal Ash Rule? Yes

1992 - commissioned

Breach of Pond 2B could...

"damage plant haul roads and slurry lines which discharge into Pond 2A"

-CDM 2010, 4-2

Low Hazard Potential Classification - classification assigned to a “diked surface impoundment where failure or mis-operation results in no probable loss of human life and low economic and/or environmental losses. Losses are principally limited to the surface impoundment owner’s property” (Sargent & Lundy 2021a, 1).

7

Coal Ash Pond 4A

Recommended Hazard Rating (CDM 2010) - Low

Regulated under Federal Coal Ash Rule? No, exempt

1983 - commissioned

1995 - levees raised to elevation of 684 feet

1998 - levees widened

Breach of Pond 4a could...

"impact hail roads and drainage ditches"

-CDM 2010, 4-2

Low Hazard Potential Classification - classification assigned to a “diked surface impoundment where failure or mis-operation results in no probable loss of human life and low economic and/or environmental losses. Losses are principally limited to the surface impoundment owner’s property” (Sargent & Lundy 2021a, 1).

8

Coal Ash Pond 4B

Recommended Hazard Rating (CDM 2010) - Low

Regulated under Federal Coal Ash Rule? No, exempt

1983 - commissioned

1995 - levees raised to elevation of 684 feet

1998 - levees widened

Breach of Pond 4B could...

"impact haul roads and drainage ditches"

-CDM 2010, 4-2

Low Hazard Potential Classification - classification assigned to a “diked surface impoundment where failure or mis-operation results in no probable loss of human life and low economic and/or environmental losses. Losses are principally limited to the surface impoundment owner’s property” (Sargent & Lundy 2021a, 1).

As cities grew and people needed more power, these ponds filled with the waste of the power plant. They are a part of our history, a history of growth, but also of one that marginalized "lower-class" communities, the environment, and the health of wildlife. It is our heritage. We must deal with it. We must reflect on where we have been, where we are, and how to move forward sustainably as we deal with this toxic heritage.

A Lick (Creek) and a Promise: Closure in Place and Toxic Waters

Approved coal ash closure plans “are in compliance with all state and federal regulations, and are protective of human health and the environment.”Indiana Department of Environmental Management, 2021, quoted in Indianapolis Star, February 14, 2021

AES Indiana intends to close the EPA-regulated coal ash ponds in place. However, following the law is not always enough. The EPA has been deferring the push to deal with the nation's coal ash pits and has made numerous exceptions to the law for energy companies. As a result, numerous environmental groups are suing the EPA.

The state of Indiana has fallen behind its fellow states in supporting and passing environmental protection regulations. It has resisted, killed, and rolled back numerous environmental regulations.

Closure in place, allowed by the EPA Coal Ash Rule, is the preferred method of utility companies for closing coal ash pits. This process involves covering the coal combustion residuals where they are, in unlined pits. Because the pits are unlined, they can still leach into the groundwater and cause contamination.

Closure in place is the cheapest, easiest method that adheres to the regulations. However, leaving coal ash in place means that toxins can continue to leach into waterways and groundwater, contaminating nearby neighborhoods, and risking catastrophic environmental disasters if the White River floods.

Chart showing the number of wells subject to runoff (down gradient wells) in Indiana tested for toxins and those that showed at least one chemical above health-based limits. Harding Street Station’s wells are highlighted. Source: Hoosier Environmental Council, Our Waters at Risk, Part 2, 2020.

“Based on initial [nature and extent] sampling results, IPL has determined that groundwater concentrations above applicable groundwater protections standards underlie the Hanson Aggregates property, located at 4200 S Harding St, Indianapolis, Indiana” - Mark Holbrook, Plant Manager, IPL Harding Street in February 10, 2020 letter to Randy Jones, Plant Manager Hanson Aggregates (quarry adjacent to HSS)

Toxins found in coal ash have already begun infiltrating our groundwater systems. We need to prevent further contamination and work to rectify the harm that has already been done.

A flood could also present risk, collapsing the levees or flooding above them, thus causing the toxins from yet-uncovered ponds to enter the flood waters, contaminating the surrounding land and waterways.

Elevated levels of toxin above safe levels at power plants in Indiana, including Harding Street. Source: Hoosier Environmental Council, Our Waters At Risk Part 2, 2020

The monitoring wells at the Harding Street Station show elevated levels of toxins. Many of these levels are above what is considered safe for drinking water.


What Now?

How can we make a difference, and ensure that we move beyond what is the bare minimum these companies and government entities can do within the language of the law, to ensure they do what is right for the people being directly affected by this poisonous legacy of harm?

“If they would have done it right in the first place and had these pits with liners, like they require it now because they know it’s bad, then we wouldn’t be here. But this is proof positive [testing results], and something they will have to take seriously now…hopefully” -Joyce Cravens, Sunshine Gardens resident, 2018, quoted in Indianapolis Star March 22, 2018

Get Involved

"I just want to know, what is the next step?" -Joyce Cravens, Sunshine Gardens resident, 2018, quoted in Indianapolis Star March 28, 2018

Indiana is behind many other states in its transition to renewable energy sources and in cleaning up the pollution and waste left by nonrenewable energy. It has repeatedly resisted legislation that would promote environmental protections and cleanup. What can we do to help and encourage addressing this toxic heritage?

Indiana legislation passed in 2021, giving the Indiana Department of Environmental Management the authority to develop a permit program for the CCR rule under the WIIN Act. In 2022, pieces of legislation introduced in the Indiana House of Representatives (HR 1335) and the Indiana Senate (SB 412) to require the safe disposal of coal ash as part of state law were killed in committee and thus were not passed. The Sunshine Gardens community has been pushing for changes, and local non-profit organizations, such as  Hoosier Environmental Council , provide resources for Indiana residents to learn more about the issue of coal ash, and how they can help

Water Testing

Private wells are not currently regualted by the state of Indiana. Testing your water will not only protect your household, it will hold companies accountable.

You can also keep an eye on the toxin levels at the HSS monitoring wells here:

The Environmental Protection Agency also has an application that allows people to view the conditions of the waterways near their home:

EPA How's My Waterway near Harding Street Generating Station, showing Sunshine Gardens.

Legislation

Supporting government officials who promote environmental issues and protecting people from the harm of coal ash ponds and other toxic heritage is an effective and achievable action you can take. Contact your legislatures in order to express your support for stricter regulation enforcement here:

Supporting Environmental Groups

In 2018 Jodi Perras of the Sierra Club Beyond Coal Campaign collected 450 signatures petitioning IPL to close its coal ash ponds by relocating the coal ash into a dry, covered, lined landfill. Supporting groups and campaigns such as these, with your time or money, can encourage change.

Addressing the toxic legacy of coal ash can seem daunting. It is just one of many hazardous materials affecting our waterways. But strengthening and enforcing legislation and testing our waters are important first steps to achieving a more sustainable and healthful heritage.

“The natural inclination when you first start something like this is to point fingers and to assign blame, but we are beyond that right now, and the bottom line is need we [sic] to work together on this. We can’t deny it anymore, so we just need to figure out a solution”  -Joyce Cravens, Sunshine Gardens resident, 2018, quoted in Indianapolis Star March 22, 2018


Madeline Griem, with contributions from Angela Campbell, Micaela Knox, and Katelynn Sinclair, December 2022 Revised by Benjamin Clark, October 2023

Coal mining, 1923. Credit: National Photo Company Collection, Library of Congress, Prints and Photographs Division.

Coal train transports the fuel of America. Credit: Carol M. Highsmith's America, Library of Congress, Prints and Photographs Division.

Advertisment for Sunshine Gardens. Source: Indianapolis News, September 26, 1925, newspapers.com

Sunshine Gardens residents test their water for toxins. Source: The Indianapolis Star, March 28, 2018

Drawing of HSS. Credit: The Indianaplis Star, November 23, 1931, via Newspapers.com

News clipping announcing new generating unit, the Indianapolis News, July 18, 1973.

IPL, now AES Indiana, announces it will convert its Harding Street Generating Station to natural gas, complying with new EPA rules and regulations for emissions. Image Source: The Indianapolis Star, May 31, 2015, newspapers.com.

Advertisement from the Northern Indiana Public Service Company and the other Electric Companies of Indiana, including Indianapolis Power & Light. Source: The Wolcott Beacon, November 16, 1950, Hoosier State Chronicles.

Location of Harding Street Generating Station's coal ash ponds in 1956 before the commissioning of the first pond in 1958 versus location of Harding Street Generating Station's coal ash ponds in 2021. Source: MapIndy.

Chart showing the number of wells subject to runoff (down gradient wells) in Indiana tested for toxins and those that showed at least one chemical above health-based limits. Harding Street Station’s wells are highlighted. Source: Hoosier Environmental Council, Our Waters at Risk, Part 2, 2020.

Elevated levels of toxin above safe levels at power plants in Indiana, including Harding Street. Source: Hoosier Environmental Council, Our Waters At Risk Part 2, 2020

EPA How's My Waterway near Harding Street Generating Station, showing Sunshine Gardens.