East Kentucky Power Co-op permits coal ash removal plan for Dale

The U.S. Army Corps of Engineers is taking comment until Feb. 12 on a Section 404 Clean Water Act application from East Kentucky Power Cooperative related to closure of coal waste landfill area at the Dale power plant in Clark County, Ky.

“The applicant proposes to close its coal ash storage impoundments (Coal Ash Ponds #2, 3 and 4) at its Dale Power Station,” said a Corps notice. “These ponds are being removed as part of the plant’s planned closure. Under the proposal, the existing coal ash waste within the ponds would be excavated and hauled 28 miles to EKPC’s Special Waste Landfill at Smith Station near Trapp in Clark County. A total of approximately 507,000 cubic yards of material would be removed, which includes all existing pond berms.

“In order to remove the coal ash waste a power transmission line would have to be removed, and then ultimately the entire area would have to be regraded to ensure positive site drainage. In order to accomplish these proposed activities, a total of 0.845 acres of twelve (12) adjacent wetlands would be impacted. In addition, a total of 75 linear feet o ftwo (2) ephemeral stream channels would be impacted. Further, a section of bank along the Kentucky River would be re-graded and then stabilized resulting in impacts below the Ordinary Highwater Mark (OHW).

“The applicant evaluated eight (8) alternatives for the removal and closure of the coal ash waste ponds, ultimately selecting the existing Special Waste Landfill at Smith Station. Three of these alternatives included evaluating various on-site options; however, due to physical site constraints and the proximate location of waters to the coal ash ponds, none of these options would result in the reduction of impacts to ‘waters of the U.S.’ In addition, two of these alternatives were found to be considerably more expensive than the preferred alternative. The remaining five (5) alternatives involved the disposal of the coal ash waste at an off-site location. Three of these options were determined to be cost prohibitive and one alternative was later dropped due to public opposition. The preferred alternative avoids and minimizes impacts to the greatest extent practicable and is more economically feasible. This alternative also utilizes an area that has previously been approved by the Kentucky Division of Waste Management and the Corps.”

EKPC wants to add a year of life to two Dale coal units, but other two are doomed

In the meantime, at the request of PJM Interconnection, East Kentucky Power Cooperative has decided to extend, pending regulatory approval, by one year its timeline for shutting the coal-fired Units 3 and 4 at its Dale power plant. EKPC on Dec. 18 filed with the Kentucky Public Service Commission an update within a case it lodged in September for permission to build the coal ash landfill at its J.K. Smith coal plant that will take ash from Dale, which is due for retirement due to federal Mercury and Air Toxics Standards (MATS) compliance needs.

“Since the filing of its Application, EKPC has held numerous, extensive discussions with the regional transmission organization of which it is a member, namely PJM Interconnection, LLC (‘PJM’),” said the update. “During these discussions, PJM has expressed concern regarding near-term generation capacity and the adequacy of available resources to maintain the reliability of the high voltage electricity grid that PJM operates. PJM’s most pressing concern relates to its 2015/2016 Delivery Year, during which it projects a significant decrease in the amount of available generation due to retirements associated with MATS and/or general economic conditions.

“In an effort to address the anticipated decline in available generation resources, PJM has requested that EKPC alter its plan to place Dale Station Units 3 and 4 in indefinite storage as of April 2015. In particular, PJM has requested that EKPC seek from the Kentucky Department for Air Quality (‘DAQ’) a one-year extension of the deadline for compliance with MATS with respect to Dale Station Units 3 and 4. PJM believes that having Dale Station Units 3 and 4 available during the 2015/2016 Delivery Year, and specifically during the winter of 2015/2016, will help ensure resource adequacy and promote reliable operations. After consultation with PJM, and in light of its own analysis, EKPC has decided that it is willing to assist PJM and thus seek from the DAQ a one-year extension of the deadline for MATS compliance with respect to Dale Station Units 3 and 4. This action, if successful, will enhance the reliability of the electric grid operated by PJM with little to no financial risk borne by EKPC. Additionally, having Dale Station Units 3 and 4 operational through the 2015/2016 Delivery Year will allow them to remain available to collect revenues from PJM’s capacity market during that timeframe.”

Don Mosier, Executive Vice President and Chief Operating Officer of EKPC, said in accompanying testimony that Dale is home to four units comprised of pulverized coal-fired boilers with steam turbine generators. Units 1 and 2, each rated at 25 MW, were commissioned in 1954. Dale Station Units 3 and 4, each rated at 75 MW, were commissioned in 1957 and 1960, respectively.

Mosier added: “In April of 2014, EKPC made the decision to close Dale Station Units 1 and 2 and begin exploring the marketing of the assets. Nothing has changed with respect to the operational status of Dale Station Units 1 and 2, and those assets are not at issue in this supplemental testimony. Due to the costs of operating Dale Units 3 and 4, EKPC does not anticipate that PJM will actually dispatch the units a significant amount during the pertinent timeframe. Even if Dale Units 3 and 4 are dispatched to a greater extent than projected, however, the expected incremental increase in coal ash produced is minimal.”

The PSC has established a Jan. 14 deadline for parties to request more information from EKPC about the temporary life extension plan for the two Dale units, with a Jan. 23 deadline for EKPC to respond to such requests.

About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.