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.
Two Flint Creek Plant ash storage sites are included in the CCR monitoring program:
- The primary bottom ash pond and
- The landfill.
Both storage sites are in active use. SWEPCO is working on a plan to close the primary bottom ash pond. Flint Creek Plant has a dry fly ash handling system and the fly ash is stored in a lined landfill. The landfill has an “intermediate” liner. Flint Creek Plant now places all material above the liner.
In 2017, Flint Creek Plant put more than 64,000 tons of CCR material to beneficial reuse.
- Coal Combustion Residuals Monitoring & Reporting
Southwestern Electric Power Company (SWEPCO) has completed the first steps in the new groundwater monitoring program under this rule.
SWEPCO took a series of groundwater samples at the boundaries of both 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 Flint Creek 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, pH, 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, beryllium, chromium, radium and selenium 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 proactively reached out and met with plant neighbors and community leaders to answer questions about the data collected so far and to discuss next steps.
Here’s how AEP/SWEPCO conducted the monitoring:
- The primary bottom ash pond – six wells and
- The landfill – 11 wells.
- Alternate Source Reviews
Independent third parties completed Alternate Source Reviews for the primary bottom ash pond and landfill sites at Flint Creek 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 Flint Creek Plant’s landfill site. The plant will continue sampling groundwater at the site to determine any future need for additional monitoring.
An alternate source for groundwater impacts was not found for the bottom ash pond.
- 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 SWEPCO recently completed the required review of location restrictions for Flint Creek Plant’s CCR storage sites. This review found:
- The Flint Creek primary 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 Flint Creek landfill meets all location restrictions.
- Next Steps
- SWEPCO will continue to collect samples at all of these wells twice each year.
- We will stop placing CCR material in the primary bottom ash pond and will begin closure activities by Oct. 31, 2020, or we will abide by delayed closure provisions outlined in the rule. AEP and SWEPCO will continue with groundwater monitoring activities as required by the CCR rule.
- If SWEPCO determines that an ash storage site is impacting the groundwater, we will expand monitoring to find out if there are water quality impacts farther away from the storage sites themselves.
- If additional monitoring shows that changes in groundwater are coming from our ash storage sites, we will seek public input as we develop a mitigation plan to address these impacts.
- Primary Bottom Ash Pond