13 January 2016 Mr. Gene Sirca Jr., P.E., S.E. American

Apex Geoscience
215 South Fannin Street
Amarillo, TX 79106
Phone: 806.677.0600
Fax: 855.581.8081
Web: apexgeo.com
13 January 2016
Mr. Gene Sirca Jr., P.E., S.E.
American Electric Power
1 Riverside Plaza
Columbus, OH 43215
Phone: 614.716.3240; Email: [email protected]
Re:
Initial Annual CCR Landfill Inspection Report
Welsh Power Plant,
1187 CR 4865
Pittsburg, Texas
Project No: 315-068
Mr. Sirca:
Apex Geoscience (Apex), a division of Braun Intertec is pleased to submit the attached Coal
Combustion Residuals (CCR) Landfill Inspection Report for the above-referenced property.
On October 6, 2015, the Apex Inspector, William Gamblin, P.E., mobilized to the site and met with
American Electric Power (AEP) representatives, Greg Carter, P.E., and Michael Brice, in the office
of the Welsh Power Plant (hereafter referred to as the Site). Details of the past CCR landfill
operations were discussed and historical maps and surveys of previous stages of landfill
construction were exhibited and reviewed.
Apex representative, William Gamblin, P.E., assisted by AEP representatives Greg Carter, and
Michael Brice conducted a comprehensive site inspection of the entire CCR landfill area.
Photographic documentation of the inspection is included in Appendix 1 of the attached report.
The majority of the Welsh Plant CCR Landfill is active and not under permanent cover. The
eastern third of the landfill area has had minimal CCR related operations/activity for the last few
years while the middle and western thirds of the landfill area are actively utilized in the processing
and staging of CCR for beneficial reuse as fly ash products.
In general, the landfill CCR areas were in good condition with little sign of erosional issues. Good
vegetative cover was evident on the eastern berm and much of the northern berm, however, the
remaining berms appeared to be constructed out of CCR material and had little to no vegetative
AA/EOE
cover. Woody type bushes and/or trees were evident in several of the landfill areas and berms.
Areas of concern (AOCs) in the permanent area include the outer berms along the south, west,
and northwestern edges of the landfill area that appear to be constructed of CCR material with no
engineered cover system and little to no vegetative cover. Trees, brush, and other “woody” type
vegetation are evident in several landfill and berm areas. The east berm slope of the landfill has
an active seep that is believed to originate from the CCR landfill area. Minimal sloughing was
observed on the eastern berm. The eastern third of the CCR landfill area has not been active
recently and vegetation has begun to be reestablished. Non-CCR related debris is evident in
several places within the designated landfill area.
We appreciate the opportunity to have provided you with our environmental consulting services.
If you have any questions concerning this report, or if we may be of further assistance, please
contact our office.
Sincerely,
William Gamblin, P.E.
Director, Environmental Division
Distribution:
(1) PDF Copy - Client
(1) Hard Copy - Client
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Apex Geoscience | a division of Braun Intertec
1.0
INTRODUCTION
Apex Geoscience Inc. (Apex) was retained by American Electric Power (AEP) to
perform Coal Combustion Residuals (CCR) landfill inspection activities at Welsh Power
Plant property located near Pittsburg, Texas. Information regarding the project site
location and the users of this report is provided below:
Site Name
Description
AEP Welsh Power Plant Property
Location (Street, City,
State)
1187 CR 4865, Pittsburg, Texas (hereafter referred to
as the Site)
County
Person Requesting
Inspection (User)
User Address
Additional User of Report
Additional User Address
Titus
1.1
Mr. Gene Sirca Jr., P.E., S.E. of AEP
1 Riverside Plaza, Columbus, Ohio 43215
AEP SWEPCO
1 Riverside Plaza, Columbus, Ohio 43215
Purpose
The United States Environmental Protection Agency (USEPA) published a final Rule to
regulate the disposal of CCR as solid waste under Subtitle D of the Resource
Conservation Recovery Act (RCRA) (hereafter referred to as the Final Rule). A Preamble
to the Final Rule and the Final Rule were published in the Federal Register, Volume 80,
No. 74, Part II on April 17, 2015 and the Rule falls under 40 CFR Part 257. The Welsh
Power Plant CCR Landfill falls under Scope and Purpose of the Rule. Accordingly, an
initial annual inspection of the CCR landfill was performed in accordance with §257.84(b)
and other pertinent references to the Rule.
1.2
Scope of Services
Apex was tasked to provide an initial coal combustion residuals (CCR) landfill inspection
at the power plant. A qualified Apex Professional Engineer (P.E.) performed the initial
annual inspection and the findings are documented in this comprehensive, signed and
sealed report. The landfill inspection addressed and fulfilled the minimum requirements
as set forth in Subpart §257.84(b). A site inspection of the entire CCR landfill boundary
was conducted including areas under construction, active disposal areas, and CCR
beneficial reuse staging areas. Observations for signs of instability were noted, principally
consisting of erosion.
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Page 1 of 6
2.0
LANDFILL INSPECTION
The following provides detailed information regarding the field activities completed at
the Site during the Coal Combustion Residuals landfill inspection.
2.1
Personnel
The following personnel were instrumental in the completion of this project. Their duties
are identified as follows:
Function
Landfill Inspector
AEP Environmental Manager
AEP Groundwater Specialist
2.2
Description/Title/Company
William Gamblin, P.E., Environmental Director, Apex
Geoscience Inc.
W. Greg Carter, P.E., Senior Engineer, AEP - SWEPCO
Michael W. Brice, Plant Environmental Coordinator, AEP
- SWEPCO
Field Inspection Activities
The weather during the landfill inspection was sunny, warm, with a light breeze and
records indicated no precipitation occurred for seven (7) days prior to the inspection. On
October 6, 2015, the Apex Inspector, William Gamblin, P.E., mobilized to the site and met
with AEP representatives Greg Carter, P.E. and Michael Brice in the office of the Welsh
Power Plant. Details of the past CCR landfill operations were discussed and drawings
and surveys for previous stages of landfill construction were exhibited and reviewed.
Apex representative William Gamblin, assisted by AEP representatives Greg Carter and
Michael Brice, conducted a comprehensive site inspection of the entire CCR landfill area.
Photographic documentation of the inspection is included in Appendix 1.
2.3
Leachate Collection Outlets
No leachate collection system is evident at the site. Geotechnical investigations, provided
by AEP and reviewed by Apex, have revealed an approximately 10 foot (ft) thick natural
clay layer immediately under the landfill cell.
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Page 2 of 6
2.4
Coal Combustion Residue Volume
In accordance with §257.84(b) the approximate volume of CCR contained in the unit at
the site was estimated by MTG Engineers & Surveyors, Inc. to be approximately 835,544
cubic yards of material.
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Page 3 of 6
3.0
FINDINGS
The majority of the Welsh Plant CCR Landfill is an active staging area for the reuse of
generated CCR as fly ash. The total acreage of the Welsh CCR landfill, including active
areas is approximately 39 acres. In general, the landfill area was in good condition with
little sign of significant erosion. Good vegetative cover was noted on the east and much
of the north berm slopes, however, the remaining berm slopes had little to no cover and/or
contained trees and shrubs. All of the runoff from the CCR landfill areas is directed to the
primary ash pond.
Areas of concern (AOCs) associated with the landfill area include:
1. Outer berms along the south, west, and northwest edges of the landfill area appear
to be constructed of CCR material with no engineered cover system and little to no
vegetative cover (Photos #1, #2, #4, #7, #19, and #20).
2. Trees, brush, and other “woody” type vegetation is evident in several landfill and
berm areas (Photos #6, #7, #8, #10, #11, #12, #14, #16, #17, #18, and #20).
3. The east berm slope of the landfill has an active seep that is believed to originate
from the CCR Landfill area and could jeopardize the integrity of the berm slope
(Photos #14 and #15). Minimal sloughing was also observed on the eastern berm.
4. The eastern third of the CCR landfill area has not been active recently and
vegetation has begun to be reestablished (Photos #16 and #17).
5. Non-CCR debris is evident in several places within the designated landfill area
(Photo #18).
6. Groundwater monitoring well labelling is not evident on some well protective
housings. (Photos #21 and #22).
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Page 4 of 6
4.0
CONCLUSIONS, OPINIONS, AND RECOMMENDATIONS
Overall, the Welsh Power Plant CCR landfill showed only limited signs of erosional issues.
The CCR landfill is primarily utilized as a staging area in the processing and beneficial
reuse of CCR materials. No closed section of the landfill exists to date and therefore no
permanent cover systems were inspected. As noted in the findings above, several issues
regarding the CCR landfill were discovered.
It is recommended that permanent berms defining the perimeter of the landfill area have
permanent cover systems installed on their outer slopes. Berm slopes need a
geotechnical evaluation performed to ensure their long-term stability
A vegetation control program be enacted to remove undesirable trees and shrubs in the
landfill and berm areas and maintain proper vegetative cover on permanent slopes.
Normal maintenance and vegetation control should involve mowing and brush removal
be as needed.
Active seep areas in berms need to be addressed by installing and maintaining proper
drainage appurtenances. Sloughing of the permanent berms should be addressed and
rectified.
Long-term inactive areas, such as the eastern third of the CCR landfill, should be closed
and a permanent cap and cover placed over the CCR landfill unit.
Non-CCR debris/trash should be removed from within the designated landfill area and the
general maintenance of the landfill unit needs to include debris removal as well as
vegetation control.
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Page 5 of 6
APPENDICES
Appendix 1 – Photographs
WELSH POWER PLANT LANDFILL
1187 CR 4865
PITTSBURG,
TEXAS
PROJECT NUMBER
315-068
(1) Date: October 6, 2015. Time: 9:05 a.m. Dir: Northwest
Description: Berms and Entrance to CCR staging/landfill area.
(2) Date: October 6, 2015. Time: 9:05 a.m. Dir: East
Description: Berm near entrance to CCR staging/landfill area
(3) Date: October 6, 2015. Time: 9:06 a.m. Dir: Northeast
Description: CCR staging/landfill area.
(4) Date: October 6, 2015. Time: 9:12 a.m. Dir: East
Description: North slope of CCR staging/landfill area.
(5) Date: October 6, 2015. Time: 9:13 a.m. Dir: Northeast
Description: CCR material staged outside of staging/landfill unit.
(6) Date: October 6, 2015. Time: 9:15 a.m. Dir: East Northeast
Description: Heavy vegetation in CCR staging/landfill area.
WELSH POWER PLANT LANDFILL
1187 CR 4865
PITTSBURG,
TEXAS
PROJECT NUMBER
315-068
(7) Date: October 6, 2015. Time: 9:15 a.m. Dir: Northwest
Description: Berms slope on staging/landfill area.
(8) Date: October 6, 2015. Time: 9:18 a.m. Dir: North Northwest
Description: Drainage line from CCR slurry staging box.
(9) Date: October 6, 2015. Time: 9:21 a.m. Dir: West
Description: CCR staging/landfill area.
(10) Date: October 6, 2015. Time: 9:23 a.m. Dir: Northwest
Description: Woody vegetation in CCR staging/landfill area.
(11) Date: October 6, 2015. Time: 9:29 a.m. Dir: Northeast
Description: Northern edge of Landfill/staging area. Note brush/tree.
(12) Date: October 6, 2015. Time: 9:30 a.m. Dir: South
Description: Wooded vegetation in CCR staging/landfill area.
WELSH POWER PLANT LANDFILL
1187 CR 4865
PITTSBURG,
TEXAS
PROJECT NUMBER
315-068
(13) Date: October 6, 2015. Time: 9:32 a.m. Dir: Southeast
Description: Eastern berm slope with possible sluffing.
(14) Date: October 6, 2015. Time: 9:35 a.m. Dir: South
Description: East berm slope with seepage area and woody vegetation.
(15) Date: October 6, 2015. Time: 9:37 a.m. Dir: Northwest
Description: East berm slope with seepage area.
(16) Date: October 6, 2015. Time: 9:45 a.m. Dir: East
Description: Vegetation in eastern third of the CCR staging/landfill area.
(17) Date: October 6, 2015. Time: 9:45 a.m. Dir: Southeast
Description: Vegetation in eastern third of the CCR staging/landfill area.
(18) Date: October 6, 2015. Time: 9:47 a.m. Dir: Southeast
Description: Debris in CCR staging/landfill area.
WELSH POWER PLANT LANDFILL
1187 CR 4865
PITTSBURG,
TEXAS
PROJECT NUMBER
315-068
(19) Date: October 6, 2015. Time: 9:48 a.m. Dir: Southwest
Description: Southern berm constructed of CCR material.
(20) Date: October 6, 2015. Time: 9:50 a.m. Dir: East
Description: Southern berm slope with brush and trees.
(21) Date: October 6, 2015. Time: 10:27 a.m. Dir: Northwest
Description: Monitor Well cover not labeled.
(22) Date: October 6, 2015. Time: 10:49 a.m. Dir: East Southeast
Description: Monitor Well cover not labeled.
APPENDIX 2 – Site Maps