East Kentucky Power Cooperative filed on Feb. 17 at the Kentucky Public Service Commission a post-hearing brief arguing for approvals needed fo new coal ash disposal facilities for its Dale plant.
The hearing was held Feb. 3 on an application filed in September 2014. The cooperative has proposed an amendment of its Environmental Compliance Plan for the purpose of recovering the costs of the project through EKPC’s Environmental Surcharge. EKPC requests that the commission issue a Certificate of Public Convenience and Necessity (CPCN) for the construction of a coal ash landfill at EKPC’s J. K. Smith Station to receive coal ash removed and transported from its William C. Dale Station. For various reasons, including proximity to the Kentucky River, Dale is not a good site for permanent disposal of this waste.
The project, which is necessitated by relevant state and federal environmental requirements relating to the permanent disposal of coal combustion residuals (CCR), represents the safest, most reasonable, least cost option for addressing the approximately 560,000 cubic yards of coal ash currently stored at the Dale Station property, EKPC said.
EKPC’s Dale Station, located on the Kentucky River at Ford in Clark County, is comprised of four baseload units comprised of pulverized coal-fired boilers with steam turbine generators. Units 1 and 2, each rated at 25 MW, were commissioned in 1954. Units 3 and 4, each rated at 75 MW, were commissioned in 1957 and 1960, respectively.
In April 2014, EKPC made the decision to close Dale Units 1 and 2 and begin exploring the marketing of the assets. At the time this matter was commenced, and in light of the impending deadline for compliance with the federal Mercury and Air Toxics Standards (MATS), EKPC planned to condition Dale Station Units 3 and 4 for indefinite storage beginning in April 2015. However, at the request of PJM Interconnection, EKPC sought and obtained from the Kentucky Department of Air Quality (DAQ) a one-year extension of the April 2015 deadline for compliance with MATS with respect to Dale Station Units 3 and 4 and, as a result, those units will remain operational through April 2016. Although the timeline with respect to the closure of Dale Station has been lengthened by one year to encourage reliability within PJM’s regional electric grid, the impending cessation of generation at Dale requires substantial work to be undertaken with regard to Dale’s ash ponds, EKPC noted.
EKPC engaged Burns & McDonnell Engineering to provide assistance in assessing the alternatives for ash disposal, leading to the decision to bury it at the J.K. Smith site.
The Feb. 17 brief added: “Notably, certain new federal environmental requirements are also relevant to this proceeding. On December 19, 2014, the U.S. Environmental Protection Agency (‘EPA’) issued the Disposal of Coal Combustion Residuals from Electric Utilities rule (‘CCR Final Rule’), which deals extensively with coal ash storage and disposal and is expected to become effective later this summer. While EKPC and Burns & McDonnell were first required to consider disposal alternatives that would comply with Kentucky environmental rules, they also designed the proposed Smith Special Waste Landfill to be compliant with the federal CCR Final Rule. Timely completion of the Project is imperative to ensure that EKPC complies with both the state and federal regulatory regimes.”