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

Transcription

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
Pirkey Power Plant,
2400 FM 3251
Hallsville, Texas
Project No: 315-068
Mr. Sirca:
Apex Geoscience Inc. (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 September 14, 2015, the Apex Inspector, William Gamblin, P.E., mobilized to the site and met
with American Electric Power (AEP) representative, Greg Carter, P.E., and Akron Consulting
representative, Lane Roberts, P.E., in the Engineering office of the H.W. Pirkey Power Plant
(hereafter referred to as the Site). Details of the past CCR landfill operations were discussed and
As-Builts for previous stages of landfill construction were exhibited and reviewed.
Apex representative William Gamblin, P.E., assisted by AEP representative, Greg Carter, and
Akron Consulting representative, Lane Roberts, 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 inspection of permanently capped areas was completed
in the morning, while the active disposal areas and areas under construction were inspected in
the afternoon.
On September 15, 2015, the Apex Inspector, William Gamblin, P.E., met with AEP
representatives, Greg Carter, P.E. and Terry Wehling, P.E. Groundwater monitoring wells
associated with the landfill were discussed in detail. Mr. Gamblin, assisted by Mr. Carter and Mr.
Wehling, field verified the locations and surface conditions of the monitor wells as well as the CCR
landfill leachate drain line outlets and non-contact let downs.
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Apex Geoscience | a division of Braun Intertec
The majority of the Pirkey Plant CCR Landfill is under permanent cover. In general, all permanent
cover areas were in good condition with little to no sign of erosion and good vegetative cover.
The vegetative cover consisted of consistent length grasses with almost no woody type bushes
or trees evident in the landfill areas. Areas of concern (AOCs) in the permanent area include
woody brush on the north slope of the “1995” cell (photo #8) associated with hay bales and metal
fence posts. Three erosional areas were evident: a small drainage erosional area on the north
slope of the “1995” cell (Photos #13,#14, and #15), a small drainage area on the north slope of
the “1999” cell (Photos #34 and #35), and erosion evident along the toe of slope of the “1987” cell
around the gas well (Photos #58, #59, and #60).
The areas of the landfill that were active and/or under construction showed significant erosional
activity with abundant rivulets and gulley formation along slopes. However, all of the runoff from
the active and/or under construction areas is contained in an onsite pond and recycled onsite. As
was noted by AEP personnel during the inspection, the exposed CCR hardens after coming in
contact with rainwater and the evident erosion appeared to be a short lived phenomenon and the
slopes appear to remain relatively stable (if left undisturbed) after one or two rain events. Some
of more recently constructed landfill slopes have a temporary cover of red soil that also showed
signs of significant erosion. The advantage of the temporary cover appears to be that while the
red soil eroded, enough rainwater infiltrated the temporary cover to harden the CCR underneath.
A particular concern with the active and/or under construction landfill areas is the storage capacity
of the retention pond designed to hold the runoff from these areas and the leachate from the entire
CCR landfill. Interviews with AEP personnel revealed that the storage capacity of the retention
pond was a concern during the flooding conditions of Spring 2015. The landfill are received eight
inches of rainfall in March, 6.3 inches of rainfall in March, and 12.82 inches of rainfall in May of
2015. It would be prudent for AEP to consider putting a permanent cover over the areas of the
active landfill as soon as it is deemed that final grades have been obtained and route the runoff
from those areas to non-contact drainage. Existing drainage letdown piping on the east and west
sides of the landfill allow for run off from permanent cover areas to be routed to non-retention
pond drainage. Additional pond capacity through dredging or pond expansion could accomplish
a similar goal.
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.
www.apexgeo.com
Sincerely,
William Gamblin, P.E.
Director, Environmental Division
Distribution:
(1) PDF Copy - Client
(1) Hard Copy - Client
www.apexgeo.com
1.0
INTRODUCTION
Apex Geoscience Inc. (Apex) was retained by American Electric Power (AEP) to
perform Coal Combustion Residue (CCR) Landfill Inspection activities at H.W. Pirkey
Power Plant property near Hallsville, Texas. Information regarding the project site
location and the users of this report is provided below:
Description
Site Name
AEP H.W. Pirkey Power Plant Property
Location (Street, City,
2400 FM 3251, Hallsville, Texas (hereafter referred to
State)
as the Site)
County
Person Requesting
Inspection (User)
User Address
Additional User of Report
Additional User Address
1.1
Harrison
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. The total acreage of the Pirkey CCR landfill, including closed, active,
and under construction areas is approximately 137 acres.
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
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Page 1 of 10
§257.84(b). A site inspection of the entire permitted boundary was conducted including
areas under construction, active disposal areas, and capped areas. Observations for
signs of instability were noted, principally consisting of erosion.
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Page 2 of 10
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
Landfill Construction Consultant
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
Lane Roberts, P.E., Civil Design Engineer, Akron
Consulting LLP
Terry Wehling, P.E., Principal Environmental Engineer,
AEP - SWEPCO
Field Inspection Activities
The weather during the landfill inspection was sunny, warm, with a light breeze and no
rain was recorded for seven (7) days prior to the inspection. On September 14, 2015, the
Apex Inspector, William Gamblin, P.E., mobilized to the site and met with AEP
representative, Greg Carter, P.E., and Akron Consulting representative, Lane Roberts,
P.E. in the Engineering office of the H.W. Pirkey Plant. Details of the past CCR landfill
operations were discussed and As-Builts for previous stages of landfill construction were
exhibited and reviewed.
Apex representative William Gamblin, assisted by AEP representative, Greg Carter, and
Akron Consulting representative, Lane Roberts conducted a comprehensive site
inspection of the entire CCR landfill area. Photographic documentation of the inspection
is included in Appendix 1. The inspection of permanently capped areas was completed
in the morning, while the active disposal areas and areas under construction were
inspected in the afternoon.
On September 15, 2015, the Apex Inspector, William Gamblin, P.E. met with AEP
representatives, Greg Carter, P.E. and Terry Wehling, P.E.. Groundwater monitoring
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Page 3 of 10
wells associated with the landfill were discussed in detail. Mr. Gamblin was assisted by
Mr. Carter and Mr. Wehling in the field verification of the location and surface condition of
the CCR landfill leachate drain line outlets and non-contact let downs.
2.3
Leachate Collection Outlets
Three (3) outlets were evident along the southern edge of the active and under
construction landfill areas and were identified as leachate collection outlets. Two of these
were actively flowing and showing signs of silt build up around them (one significantly).
Existing drainage letdown piping on the east and west sides of the landfill allow for run off
from permanent cover areas to be routed to non-retention pond drainage.
2.4
Coal Combustion Residue Volume
In accordance with §257.84(b) the approximate volume of CCR contained in the unit at
the site during the time of inspection was estimated by AEP personnel to be approximately
17,984,000 cubic yards of material.
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Page 4 of 10
3.0
FINDINGS
The majority of the H.W. Pirkey Plant CCR Landfill is under permanent cover. In general,
all permanent cover areas were in good condition with little to no sign of erosion and good
vegetative cover. The vegetative cover was composed of consistent length grasses with
almost no woody type bushes or trees evident in the landfill areas. Areas of concern
(AOCs) in the permanent area include woody brush on the north slope of the “1995” cell
(photo #8) associated with hay bales and metal fence posts. Three erosional areas were
evident: a small drainage erosional area on the north slope of the “1995” cell (Photos
#13,#14, and #15), a small drainage area on the north slope of the “1999” cell (Photos
#34 and #35), and erosion evident along the toe of slope of the “1987” cell around the
gas well (Photos #58, #59, and #60).
The areas of the landfill that were active and/or under construction showed significant
erosional activity with abundant rivulets and gulley formation along slopes. However, all
of the runoff from the active and/or under construction areas is contained in an onsite
pond and recycled onsite. As was noted by AEP personnel during the inspection, the
exposed CCR hardens after coming in contact with rainwater and the evident erosion
appeared to be a short lived phenomenon and the slopes appear to remain relatively
stable (if left undisturbed) after one or two rain events. Some of more recently constructed
landfill slopes have a temporary cover of red soil that also showed signs of significant
erosion. The advantage of the temporary cover appears to be that while the red soil
eroded, enough rainwater infiltrated the temporary cover to harden the CCR underneath.
3.1.
Inspection Findings by Cell Designation:
“1984” Cell
The “1984” Cell is under permanent cover and in good shape with a well-established
grassy vegetative cover over its entirety. The “1984” Cell is shown on Figure 2
(Appendix 2). The north and east sides of the cell slope relatively steeply down to the
natural grade while the rest of the cell is relatively flat. No concerns or issues with erosion
were noted.
“1987” Cell
The “1987” Cell is predominantly under permanent cover and in good shape with a wellestablished grassy vegetative cover over its entirety. The “1987” Cell is shown on Figure
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Page 5 of 10
2 (Appendix 2). The western corner of the cell is in the active portion of the landfill and
has no cover. The north, west, and south sides of the cell are on the flatter plateau of the
landfill. An existing oil/gas well with associated tanks and appurtenances exists along the
east edge of the landfill and wraps around the well site, which existed prior to the landfill
being constructed. The cell topography slopes relatively steeply down from all directions
toward this well pad. Erosion and some woody brush is evident along the toe of the
steep slopes around the oil/gas well (Photos #58, #59, and #60).
“1993” Cell
The eastern half of “1993” Cell under permanent cover and in good shape with wellestablished grassy vegetative cover over its entirety. The “1993” Cell is shown on Figure
2 (Appendix 2). The western half of the cell is not covered and is in the active area of
the landfill. A drainage divide runs north/south through middle of the cell and divides the
two halves of the cell. The northern corner of the cell is on the landfill plateau and is
relatively flat while the rest of the cell slopes steeply to the east or the west. No concerns
or issues with erosion were noted.
“1995” Cell
The “1995” Cell is under permanent cover and in good shape with a well-established
grassy vegetative cover over its entirety. The “1995” Cell is shown on Figure 2
(Appendix 2). The north side of the cell slopes relatively steeply down to the natural
grade while the rest of the cell is relatively flat. A road is evident on the northern slope
and may be a point of erosion in the future. An erosion feature is evident on the north
slope (Photos #13, #14, and #15). Woody brush is evident associated with a previous
hay bale and steel posts on the north slope.
“1997” Cell
The “1997” Cell is in the middle of the landfill. The “1997” Cell is shown on Figure 2
(Appendix 2). The majority of the cell is not covered and is in the active area of the
landfill while the northern portion is under permanent cover and in good shape with a wellestablished grassy vegetative cover. The northern section of the cell is on the landfill
plateau and is relatively flat and slopes off to the east while the rest of the cell slopes
steeply to the south. No concerns or issues with erosion were noted.
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“1999” Cell
The northern two thirds of the “1999” Cell is under permanent cover and in good shape
with a well-established grassy vegetative cover. The “1999” Cell is shown on Figure 2
(Appendix 2). The southern third of the cell is in the active portion of the landfill and is
not covered. The northern edge of the cell slopes steeply down to the natural grade while
the middle section of the cell is on the landfill plateau and is relatively flat and slopes off
to the north. The southern portion is in the active portion of the landfill and slopes steeply
to the south. A small drainage erosional area on the north slope of the “1999” cell is
evident on a terrace (Photos #34 and #35).
“2005E” Cell
The northern two thirds of the “2005E” Cell is under permanent cover and in good shape
with a well-established grassy vegetative cover. The “2005E” Cell is shown on Figure 2
(Appendix 2). The southern third of the cell is in the active portion of the landfill and is
not covered. The northern edge of the cell slopes steeply down to the natural grade while
the middle section of the cell is on the landfill plateau and is relatively flat and slopes off
to the north. No concerns or issues with erosion were noted.
“2005W” Cell
The majority of the “2005W” Cell is under permanent cover and in good shape with a wellestablished grassy vegetative cover. The “2005W” Cell is shown on Figure 2 (Appendix
2). There is a portion of the southern third of the cell that is in the active portion of the
landfill and is not covered. Half of the northern edge of the cell slopes steeply north down
to the natural grade while the majority of the cell slopes steeply off to the west. A small
portion of the cell slopes to the south along the southern edge. No concerns or issues
with erosion were noted.
“2012” Cell
The “2012” Cell is in the active portion of the landfill and is not covered. The “2012” Cell
is shown on Figure 2 (Appendix 2). The western and southern slopes of the cell have a
temporary cover of red soil. The center along with the northern and eastern portions of
the cell are relatively flat and are being utilized to stage CCR. The western edge slopes
steeply to the west and the southern edge slopes steeply to the south. No concerns or
issues with erosion were noted.
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“2015” Cell
The “2015” Cell is in the active portion of the landfill and is not covered. The “2015” Cell
is shown on Figure 2 (Appendix 2). The western and southern slopes of the cell have
a temporary cover of red soil. The center along with the northern and eastern portions
of the cell are relatively flat and are under construction or being utilized to stage CCR.
The western edge slopes to the west and the southern edge slopes to the south. No
concerns or issues with erosion were noted.
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4.0
CONCLUSIONS, OPINIONS, AND RECOMMENDATIONS
It is recommended that normal maintenance including vegetation control through mowing
and brush removal be continued. The following areas require additional attention and/or
repair as follows:
“1995” Cell
The AOC noted in the permanent area is a small erosional area on the north slope of the
“1995” cell that requires repair. Also, the woody brush, hay bales, and steel posts on the
north slope need to be removed.
“1999” Cell
The AOC noted in the permanent area is a small erosional area on the north slope of the
“1999” cell that requires repair.
“1987” Cell
Areas of erosion evident along the toe of slope of the “1987” cell around the gas well need
to be addressed and/or repaired and woody brush removed.
Leachate Collection
The soil accumulated around and in the leachate drainage outlets needs to be removed
periodically to prevent restriction of flow.
Retention Pond
A particular concern with the active and/or under construction landfill areas is the storage
capacity of the retention pond designed to hold the runoff from these areas and the
leachate from the CCR landfill. Interviews with AEP personnel revealed that during the
Spring 2015 flooding conditions, the storage capacity of the retention pond was a
concern. It would be prudent for AEP to consider putting a permanent cover over the
areas of the active landfill as soon as it is deemed that final grades have been obtained
and route the runoff from those areas to non-contact drainage. Additional pond capacity
through dredging or pond expansion could accomplish a similar goal.
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Page 9 of 10
APPENDICES
Appendix 1 – Photographs
H.W. PIRKEY POWER PLANT LANDFILL
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
(1) Date: September 14, 2015. Time: 10:21 a.m. Dir: South
Description: East slope of 1984 cell.
(2) Date: September 14, 2015. Time: 10:21 a.m. Dir: Southwest
Description: East slope of 1984 cell.
(3) Date: September 14, 2015. Time: 10:21 a.m. Dir: West Northwest
Description: Northeast corner slope of 1984 cell.
(4) Date: September 14, 2015. Time: 10:22 a.m. Dir: West
Description: North slope of 1984 cell. 1999 and 2005 cells in the distance.
Description: North slope of 1984 cell. Vegetation on midsection of slope.
Description: North slope of 1984 and 1995 cells.
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
(8) Date: September 14, 2015. Time: 10:29 a.m. Dir: West Southwest
Description: North slope of 1984 and 1995 cells. Hay bales and steel posts.
Description: North slope of 1984, 1995, and 1999 cells.
(10) Date: September 14, 2015. Time: 10:31 a.m. Dir: East
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
Description: North slope of 1995 cell. Gulley erosion evident along road.
Description: Gulley erosion evident along road on north slope of 1995 cell.
Description: North slope of 1995 cell. Gulley erosion evident along road.
Description: North slope and plateau of 1995 and 1999 cells.
(18) Date: September 14, 2015. Time: 10:48 a.m. Dir: West Southwest
Description: Plateau of landfill on 1995 and 1999 cells.
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
Description: Plateau of landfill on 1995, 1997, and 1999 cells.
(20) Date: September 14, 2015. Time: 10:48 a.m. Dir: Southeast
(21) Date: September 14, 2015. Time: 10:49 a.m. Dir: East Southeast
Description: Plateau of landfill on 1995 and 1984.
Description: Plateau of landfill on 1984 cell.
Description: Plateau of landfill on 1984 cell.
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
Description: Plateau and east slope of 1984 cell.
(26) Date: September 14, 2015. Time: 11:00 a.m. Dir: South Southeast
Description: Plateau of landfill on 1987 cell. Oil/Gas well to the south.
(27) Date: September 14, 2015. Time: 11:01 a.m. Dir: South Southwest
Description: Plateau of landfill on 1987 cell. Slopes down to oil/gas well
from 1987 cell.
Description: Plateau of landfill on 1987 cell. Slopes down to oil/gas well from
1987 cell.
Description: Plateau of landfill on 1984 cell northwest of oil/gas well.
Description: Plateau of landfill on 1999 and 1997 cells.
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
Description: Plateau of 1999 and 2005 cells.
Description: Plateau of 1999 and 2005 cells.
Description: North slope of 1999 and 2005 cells. Erosion on terrace.
(35) Date: September 14, 2015. Time: 11:10 a.m. Dir: East Southeast
Description: North slope of 1999 and 2005 cells. Erosion on terrace.
Description: Letdown inlet on terrace on north slope of 2005 cell.
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
Description: West slope of 2005W cell.
(38) Date: September 14, 2015. Time: 11:16 a.m. Dir: South southwest
(41) Date: September 14, 2015. Time: 11:22 a.m. Dir: Northwest
Description: West slope and plateau of 2005W cell with letdown piping.
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
Description: West slope of 1999 and 1997 cell. West slope of 1987 cell.
Description: South slope of 2005W cell.
Description: South slope of 2005W cell. 2015 cell in background.
Description: 2012 cell.
Description: West slope of 1987 cell. Active landfill activity in 2012, 1985
pond, and 1997 area.
Description: Plateau of 1987 and 1993 cell.
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
Description: South slope of 2012 and 1987 cell. Note: Gray color of CCR
and red color of temporary cover soil. 2015 cell in background.
Description: West slope of 1993 cell.
(51) Date: September 14, 2015. Time: 11:43 a.m. Dir: Northeast
Description: Plateau of southern section of 1987 cell. Let down inlet.
Description: Southeastern slope of 1987 and 1993 cells.
Description: Southeastern slope of 1987 and 1993 cells.
Description: Southeastern slope of 1987 cell.
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
(55) Date: September 14, 2015. Time: 11:48 a.m. Dir: North
Description: Slope of 1987 cell down to oil/gas well.
Description: Slope of 1987 cell down to oil/gas well.
(57) Date: September 14, 2015. Time: 2:06 p.m. Dir: West
Description: Let down outlet on east toe of 1987 cell.
(58) Date: September 14, 2015. Time: 2:09 p.m. Dir: Northeast
Description: Erosion at toe of oil/gas well slope of 1987 cell.
(60) Date: September 14, 2015. Time: 2:12 p.m. Dir: North Northwest
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
(61) Date: September 14, 2015. Time: 2:15 p.m. Dir: Southwest
Description: Toe of oil/gas well slope of 1987 cell.
(62) Date: September 14, 2015. Time: 2:26 p.m. Dir: North Northwest
Description: Drainage divide of the 1993 cell.
(63) Date: September 14, 2015. Time: 2:26 p.m. Dir: Northwest
Description: Western slope of 1993 cell. 2012 cell in background.
Description: Erosion on exposed, hardened CCR of 1993 cell.
Description: Erosion on exposed, hardened CCR of 1993 and 1987 cells,
and 1985 pond area of the landfill.
Description: Erosion on exposed, hardened CCR of 1993 and 1987 cells, and
1985 pond area of the landfill.
2400 FM 3251
HALLSVILLE,
TEXAS
PROJECT NUMBER
315-068
(67) Date: September 14, 2015. Time: 2:40 p.m. Dir: East
Description: Outlet of leachate collection system.
APPENDIX 2 – Site Maps

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

Transcription

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