In 2015, the U.S. Environmental Protection Agency (EPA) issued a new rule addressing the handling, storage and disposal of coal combustion residuals (CCRs). CCRs are the materials that remain after coal is burned.
Three Amos Plant ash storage sites are included in the CCR monitoring program:
- The bottom ash pond,
- The FGD landfill and
- The fly ash pond.
The bottom ash pond and landfill currently are in active use. Amos Plant is making plans to close the bottom ash pond and move the material to a lined landfill. Amos Plant uses dry fly ash handling and no longer requires use of the fly ash pond. This pond has been capped and was closed at the end of 2017.
In 2017, Amos Plant provided 23,844 tons of bottom ash and 73,091 tons of fly ash for beneficial reuse.
- Coal Combustion Residuals Monitoring & Reporting
Appalachian Power (APCO) has completed the first steps in the new groundwater monitoring program under this rule.
APCO took a series of groundwater samples at the boundaries of the ash storage sites. We took some samples before the groundwater passed beneath the ash storage sites. (The reports refer to this as up-gradient.) We took other samples after it passed beneath the sites (down-gradient). We used the data to establish baseline levels for 21 different substances in the groundwater. It is important to remember that variations in the level of these substances in groundwater are natural and occur for many reasons.
Moving forward, we will use these baselines to help determine if our ash storage sites are impacting the groundwater. We will watch to see whether there are changes in the amount of these substances before and after the groundwater flows beneath the ash storage sites. We also will watch whether levels of these substances vary from the baselines we observed.
The initial data at Amos Plant show potential groundwater impacts very close to our storage sites. Using appropriate sampling and analysis methods, we found differences in the amounts of boron, calcium, chloride, fluoride, sulfate and total dissolved solids in certain wells before and after the groundwater passed beneath the storage sites. The rule calls these indicator substances. They are used to determine whether additional analysis is needed.
Baseline sampling in some wells showed one or more results for arsenic and radium above primary drinking water standards. One or more samples showing a higher concentration of a substance, even above a standard, does not mean that local drinking water is unsafe or that there is any impact from the ash storage site.
We are working to understand what the numbers mean. We will do additional monitoring and analysis to determine if there are groundwater impacts from our storage sites farther from the immediate area.
We are proactively reaching out and meeting with plant neighbors and community leaders to answer questions about the data collected so far and to discuss next steps.
Here’s how APCO conducted the monitoring:
- The bottom ash pond - 10 wells, and
- The FGD landfill - nine wells.
The fly ash pond falls under the CCR rule, but has a different monitoring and compliance schedule. That is because it was added to the program at a later date. APCO has installed monitoring wells and is conducting baseline sampling at the fly ash pond.
- Alternate Source Reviews
Independent third parties completed Alternate Source Reviews for the FGD landfill and bottom ash pond sites at Amos Plant. The reviews consider other factors that could impact sampling results as the groundwater passes the CCR storage sites.
This review process found alternate sources for groundwater impacts at Amos Plant’s landfill site. The plant will continue sampling groundwater at the landfill to determine any future need for additional monitoring.
An alternate source for groundwater impacts was not found for the bottom ash pond. This work has not yet been completed for the fly ash pond because it was brought into the program at a later date and is on a different monitoring and compliance schedule.
- Location Restrictions - New
The CCR rule established location restrictions for coal ash storage sites. It requires that storage site locations be evaluated regarding proximity to
- Groundwater aquifers,
- Fault areas,
- Seismic zones and
- Unstable areas (example: presence of quicksand).
AEP and Appalachian Power recently completed the required review of location restrictions for Amos Plant’s CCR storage sites. This review found:
- The Amos bottom ash pond is separated from the uppermost aquifer by less than the five feet specified by the rule. It does meet the other four restrictions.
- The Amos FGD landfill meets all location restrictions.
- The Amos fly ash pond is on a different compliance schedule and will be evaluated by April 2020. It has been closed.
- Next Steps
- APCO will continue to conduct assessment monitoring at Amos’ bottom ash pond. Assessment monitoring looks at levels of up to 21 substances before and after the groundwater passes the CCR storage sites.
- APCO will analyze assessment monitoring results by January 2019. If we determine that changes in water quality are coming from the bottom ash pond, we will implement a site specific mitigation plan. This process will include the opportunity for public input.
- APCO is conducting detection monitoring of seven substances at the landfill. These “indicator” substances are used to determine the need for additional monitoring.
- We will stop placing CCR material in the bottom ash pond and will begin closure activities by Oct. 31, 2020, or we will abide by delayed closure provisions outlined in the rule.
- APCO will publish all assessment and detection monitoring data in its next annual groundwater report.
- Bottom Ash Pond
- Fly Ash Pond
- John E. Amos Landfill