Dive Brief:

• Environmental advocates in Illinois say they have identified two Dynegy coal ash reservoirs that could pose a threat to those living nearby, and they say many facilities have failed to post compliance and safety reports, Midwest Energy News reports. 
• The citizen watchdog group Prairie Rivers Network posted reports on their website that said coal ash storage locations at Dynegy's Joppa and E.D. Edwards power plants have safety ratings which are barely above minimum scores. Those reports also predict a probable "loss of human life" if safety measures failed. 
• Prairie Rivers Network is working to ensure generators are complying with rules finalized by the U.S. Environmental Protection Agency. The group says a formal oversight mechanism is needed to supplement work being done by citizen-led watchdog groups. 

Dive Insight:

One of the big questions surrounding the EPA's coal ash rule has been enforcement, or lack thereof.  The 2014 rule set requirements and standards for the management of coal combustion residuals, but included no formal oversight. Unless states took further action, the onus fell to ordinary citizens to comb through reports that generators are supposed to provide.

Prairie Rivers Network  is one such group that tracks missing documents. While some have been updated or added, the group had found dozens of missing reports as of November. 

"This may be the real story," the group said of its analysis. "The 168 documents that we have collected do not represent the entirety of what was supposed to be released. For example, in some locations, entire impoundments are completely undocumented." 

For the Dynegy sites, the East pond at the Joppa Power Station has a seismic safety score of 1.01, just barely above the minimum 1.00 required.  An assessment of the Edwards Power Station ash pond concludes there is a "high hazard potential," and, should dikes fail, they would “probably cause loss of human life.”

EPA chose to make the rules "self-implementing" in part because of its determination that coal ash was a solid waste, but not necessarily "hazardous." If states implement legislation or permitting regulations covering the rules, they would be enforceable under state law, but otherwise the responsibility fell to citizens.