Read or download request here Eco-Justice Collaborative is one of many organizations and individuals who value the Middle Fork of the Vermilion River and the recreational and economic opportunities it brings to east-central Illinois. We remain committed to doing what we can to protect only Illinois’ National Scenic River from a catastrophic coal ash spill, and have continued our calls for relocation of the coal ash out of the river’s floodplain.While agencies work with Dynegy / Vistra to develop a closure plan for its three coal ash pits, the river continues to make its way west toward the coal ash storage facilities. That’s why we reached out to the Illinois Department of Natural Resources to ask them to:
- Conduct a slope stability analysis of riverbanks adjacent to the Old East and North Ash Pits.
- Require emergency, interim stabilization in areas determined most vulnerable to erosion.
- Require Dynegy to inspect and monitor riverbanks along all three ash pits; make inspection reports readily available to the public; and repair or install stabilization at targeted areas where needed.
The naturally-meandering Middle Fork has been moving toward the Old East and North Coal Ash Pits since 1966. Recognizing that the coal ash was at risk from the erosional forces of the river, Illinois Power installed gabion baskets along its two coal ash pits in 1981 as a means of protecting the ash from the river. These gabions were massive, and intended to last. (NOTE: The New East Ash Pit wasn’t constructed until 1989).
Over the years, the erosional forces of the Middle Fork have deteriorated and destroyed most of the gabion baskets installed along banks next to the Old East and North Ash Pits, leaving large swaths of riverbank unprotected. Photographs that show the impact the river and major storm events have had on riverbanks that separate the Middle Fork from the toes of the slope of adjacent dams of all three ash pits are included s in our request to the IDNR. In 2016, then-owner Dynegy received approval from applicable agencies to build stone toe protection along riverbanks next to the New East Ash Pit, because erosion was so severe. According to Dynegy’s field notes, just ten feet remained between the toe of the slope of the east dam and the crest of the riverbank.
Of particular concern is the area Stantec Consulting Engineers identified as most vulnerable in 2019. This area is along the Old East Ash Pit, downstream of one of the river’s bends. According to Stantec, six feet of unmitigated erosion could destabilize the Old East Ash Pit. To put this into perspective, in 2010, Dynegy realized that the riverbank along the north dam of the New East Ash Pit had eroded eight feet in just 12 months!
” These results show that the outer slope of the Vermilion CCR facility could be destabilized by the eroding riverbank. Six feet of unmitigated erosion would result in a slope that does not meet sign guidelines for the factor of safety and reliability. Protection of the riverbank is recommended to maintain satisfactory performance of the CCR facility slope.”
– Reliability Analysis for Slope Stability with Assumed Riverbank Erosion. Stantec Consulting Engineers, Inc. March 2019.
We are headed into another storm season. Dynegy is, we are told, watching the section of riverbank identified. But to our knowledge, Dynegy / Vistra has not protected this section of riverbank, as recommended by Stantec. EJC believes the decision to protect the Middle Fork from a potential catastrophic spill should not be left to a private landowner. The only agency that has the authority to act to determine the need for targeted, temporary, emergency stabilization is the Illinois Department of Natural Resources. That’s why we have reached out to them.
Meandering Rivers Always Move
Our formal request includes historical documentation and photos that show how the erosion has, over time, affected all three ash pits owned by Dynegy / Vistra. Links to reports, correspondence, and an analysis by Dr. Bruce Rhoads, fluvial geomorphologist at the University of Illinois, are provided to support our concerns and request to the IDNR to determine the need for immediate, interim stabilization at selected locations.
But as Dr. Rhoad’s presentation shows, there is nothing that can be done, long-term, to protect the coal ash pits from this meandering river. The river will continue to wind its way west towards the ash pits as it attempts to reclaim its floodplain. No amount of stabilization will be able to permanently protect the ash pits from the meandering river. The ONLY solution is to move the toxic ash out of the floodplain of this National Scenic River. We continue to make that position known to agencies who are working with Dynegy / Vistra.
Public Hearing on Closure Plan for Ash Pits
We are asking the Illinois EPA to hold public hearing on the final closure plan, consistent with requirements of the Coal Ash Pollution Prevention Act. While we don’t have a specific timeline, we think that the closure plan could be finalized this spring. Watch our website for information on that hearing as it is developed.