A Tennessee power plant walked its dike daily for decades and measured nothing.

•  An ash pond dike at a Tennessee power plant.

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•  Permitted as a landfill, never measured as a dam.

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•  Twenty-one years of memoranda asking the same question.

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•  The cell was rebuilt on site and capped.

The Kingston Fossil Plant stands on the Emory River in Roane County, Tennessee, and it had been putting its ash in ponds on the site since the 1950s. At full output it made 1,000 tons of fly ash a day, and the site record shows where it went.

The ash left the boilers mixed with water, settled in a pond, was dredged, and was pumped into storage cells beside it. Those cells were held in by perimeter dikes, and the dikes were stacked on top of each other and on top of the wet ash already there.

By 2008 the stack stood about seventy feet above the original ground. Plant staff walked it every day, the state inspected it every quarter, and TVA engineers went over it once a year.

It was permitted as a Class II solid waste landfill. Every structure is judged by the rulebook attached to its name, and names are handed out early, while the thing is still small.

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The table below comes from one document: the inspector general report of 23 July 2009, which went back through twenty-one years of internal memoranda and set out what the structure was called at each point, and by whom. It is a review of somebody else’s root cause study, which is why it carries the paperwork the study left out.

Every row is a name somebody gave the same dike. The row that matters is the fourth. In 1996 the Manager of Fossil Engineering wrote that it would be in TVA’s best interest to go on treating the waste area dikes as pollution control facilities rather than as dams. Nothing about the dike changed that day. The word did, and the word set which inspections it got.

The inspector general set the record beside the structure. Four things did not line up.

•  The name. A dam draws stability analysis, instrumentation, documented flooding criteria and inspection at intervals no greater than two and a half years. A landfill draws a walk round. The dike drew the walk round.

•  The foundation. The perimeter dikes were raised on previously sluiced ash, not on ground anyone had tested as a foundation. The structure stood on the material it was built to hold, and each new stage was placed on the stage below it.

•  The answer. In 1989 the Vice President of Power Engineering and Construction wrote that he could see no advantage to TVA in reassigning management control to the Dam Safety Program.

•  The count. The Dam Safety manager had written in 1988 that as many as 17 ash ponds in the TVA system might meet or exceed the technical definition in the guidelines. None were reassigned.

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Shortly before one in the morning on 22 December 2008 the north and central parts of the site gave way. 5,400,000 cubic yards of ash moved out in a sequence of flow slides over one to two hours and spread across about 300 acres.

The report counts what it reached: 26 homes damaged, electrical power down, a railway and a road under ash, and the slide running 3,200 feet beyond the old pond. It counts no people. The last walk round had been the previous afternoon and noted nothing.

Clearing it ran six years. 3,500,000 cubic yards came out of the Emory River by rail and the rest went into a rebuilt cell on site, capped. By 2015 the fish, the sediment and the tree swallows were back to baseline.

•  The name is the rulebook. Find out which category a structure was filed under, and in what year. The category sets what gets measured and how often.

•  Ask who answered. Each of these questions went to the office that would have carried the extra work. The answer came back no, four times across nine years.

•  A daily look is not a measurement. The dike was walked every day for decades. Walking past a thing records that it is still standing and nothing else.

•  Built on its own output. The dikes rested on the ash they existed to hold. Anything standing on what it produces has borrowed its foundation from itself.

I sat in a Chicago back office in 1994 where a book was still called small because it had been small when somebody named it, four years earlier.

Gold is settled by weight and fineness in every market that handles it, which is the test to put to anything else: find out what it is measured against, and how often.

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