TVA is one of the biggest Aquifer users, buying 5 million gallons per day from MLGW to cool their gas power plant. POA was founded to protect our drinking water from overuse and contamination at their South Memphis plant.
The Tennessee Valley Authority (TVA) generates power at their Allen Plant in South Memphis, just five miles south of downtown. MLGW built the plant, beginning construction in 1955. By 1959, the power plant was fully operational. In 1964, MLGW began leasing Allen Plant to TVA. Twenty years later, they sold it outright to TVA in 1984.
The Allen Facility is a coal-fueled power plant, burning coal to create steam in order to generate electricity. The plant operated from 1959 until 2018, burning 7,200 tons of coal each day. This created tons of coal ash, the toxic waste byproduct.
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Coal ash contains contaminants like mercury, cadmium and arsenic. It can cause cancer, heart disease, reproductive failure, stroke, and can inflict lasting brain damage on children. During power production, the dangerous, powdery ash was mixed with water and dumped into ponds onsite. These coal ash ponds were unlined - meaning there was nothing to prevent the toxins from seeping into the shallow aquifer below.
In 2011, after years of Clean Air Act violations, the Environmental Protection Agency (EPA) demanded that TVA reduce their toxic emissions at the coal plant by 2018. TVA decided, in 2014, to replace the coal power plant with a new $975 million natural gas power plant across the street. That facility, the Allen Combined Cycle Plant, would demand 2 to 7 million gallons per day of cooling water. TVA’s initial plan was to use treated wastewater from the nearby Maxson Wastewater Treatment Facility to cool the plant.
In January 2016, with no public notice, TVA changed its cooling water plans, citing the high cost of cleaning treated wastewater for use. Instead, they would drill 5 deep production wells into the Memphis Sand Aquifer for their 2 to 7 million gallons of cooling water from the Aquifer each day. In July, the Sierra Club learned that their new plan had been approved with no public notice. They mobilized, holding public meetings and advocating at Memphis City Council, who voted unanimously to oppose the plan.
In September 2016, a group of water advocates involved in this fight decided to start meeting regularly. That group would later become Protect Our Aquifer! Alongside the Sierra Club, we filed an appeal with the Shelby County Groundwater Control Board to stop the well permits. While we argued that a threat of arsenic contamination existed at TVA’s coal ash ponds across the street, the board agreed with TVA’s lawyers and allowed the wells to move forward. In February 2017, we filed suit in Chancery Court to stop the wells. By August, the Court dismissed the suit for procedural reasons. We were losing.
Meanwhile, TVA reported to TDEC that they found arsenic at 300 times the legal limit in groundwater at the coal ash ponds. In July 2017, TDEC ordered TVA to conduct a Remedial Investigation, looking into the extent of the contamination and temporarily halting use of the wells.
By March 2018, TVA released their findings: yes, the coal ash ponds have polluted the shallow aquifer with arsenic, lead, and other toxins. They also administered a “pump test,” turning on the new wells for 24 hours to monitor the movement of water levels. Within hours, that test revealed a “hydraulic connection” between the contaminated shallow aquifer and the Memphis Sands.
This meant that there was a nearby breach in our Aquifer's protective clay layer, connecting the contaminated shallow aquifer to our drinking water source below. If TVA used their wells - pumping water constantly right next to the coal ash pits - they would create a "drawdown effect." This would pull the arsenic and other contaminants in the coal ash ponds down into our drinking water supply.
With the science in hand, TDEC made it official: TVA can never turn on those 5 production wells again.
In July 2018, TVA announced that it would buy water from MLGW for cooling and build two 2.5 million gallon water tanks onsite in case of emergency. While this decision eliminated the immediate threat that their wells would have created, it still depends on aquifer water. Pumping up to 5 million gallons of water a day puts a strain on the MLGW wellfield in Southwest Memphis, where we know that legacy pollution is heavily concentrated. Continued overpumping could create the same “drawdown effect” that we saw at TVA, but across Southwest Memphis. Today, we urge TVA to return to their original plan, and make the investment in recycling wastewater to cool the plant. TVA must stop overpumping our aquifer and diversify their industrial water sources. It’s not just an investment in sustainability – it’s an investment in our shared water future.
Check out our folder of resources for more information about our fight to reduce TVA's overuse of our drinking water.
This Environmental Assessment, released by TVA in 2014 outlines their original plans for the new Gas Power Plant, including use of recycled wastewater from Maxson Wastewater Treatment Plant. Their Supplemental Environmental Assessment goes into detail on their plans.
Read the letter submitted by SELC in 2018, outlining the threats to our aquifer and our demands to TVA. Or, read the letters SELC sent to TDEC, and the Shelby County Health Department. This SELC Press Release also offers a great summary!
And - for a really scientific deep dive - check out the 2019 Groundwater Modeling Report, in multiple parts (because there's just so much science!).
Note: TVA's handling of coal ash at the retired Allen Plant is a whole other issue of environmental injustice. Learn more on our Fact Sheet.
