CLOSURE PLAN W.H. Sammis Coal Plant North and South Ponds Stratton, Ohio

Transcription

1 Prepared for: FirstEnergy Generation, LLC 76 South Main St Akron, OH CLOSURE PLAN W.H. Sammis Coal Plant North and South Ponds Stratton, Ohio Prepared by: Wincopin Circle, Floor 4 Columbia, Maryland October 2016 pdf 1 of 21

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3 Closure Plan W.H. Sammis Coal Plant North and South Ponds TABLE OF CONTENTS 1. INTRODUCTION Purpose Site Location Impoundment Description CCR RULE REQUIREMENTS FOR CLOSURE PLAN (B) CLOSURE PLAN Description of Closure Description of CCR Removal Procedure Excavation and Grading Decontamination Maximum Inventory of CCR Maximum Area Requiring a Final Cover Closure Schedule REFERENCES...6 LIST OF FIGURES Figure 1 Site Location Map: North and South Ponds Figure 2 Site Plan: North and South Ponds LIST OF APPENDICES Appendix A Procedures for Verification of CCR Removal Appendix B Drawings Appendix C Closure Plan Schedule ME1292/ (b) Written Closure Plan FNL i October 2016 pdf 3 of 21

4 Closure Plan W.H. Sammis Coal Plant North and South Ponds PLAN AMENDMENTS This closure plan is intended to meet the requirements of 40 CFR but can be amended at any time [pursuant to (b)(3)] due to a number of factors, including but not limited to: specified provisions in 40 CFR 257, federal or state regulatory changes, and facility operational or closure activity changes. ME1292/ (b) Written Closure Plan FNL ii October 2016 pdf 4 of 21

5 Closure Plan W.H. Sammis Coal Plant North and South Ponds 1. INTRODUCTION 1.1 Purpose Geosyntec Consultants (Geosyntec) has prepared this Closure Plan for FirstEnergy Generation, LLC (FirstEnergy) for the existing W.H. Sammis Coal Plant North Pond and South Pond (North and South Ponds) in Stratton, Ohio. This plan is prepared for compliance with the closure criteria of the Federal Coal Combustion Residuals (CCR) Rule, 40 CFR 257. This Regulation is referred to herein as the CCR Rule. In this document, the requirements of (b) and (c) for preparation of a closure plan by removal of CCR are addressed. 1.2 Site Location The North and South Ponds are located at the W.H. Sammis Plant (Plant) in Stratton, Jefferson County, Ohio. The Plant can be found on the United States Geological Survey (USGS) 7.5-minute topographic map for the Wellsville, Ohio Quadrangle (Figure 1). The Plant is located adjacent to Ohio State Route 7 and the Ohio River. The North and South Ponds are located in the southeast quadrant of the generating facility. 1.3 Impoundment Description The North and South Ponds were initially constructed circa 1959, modified in 1971, and further modified into their current configuration in The ponds are used for temporary storage of bottom ash (i.e., CCR) and treatment of other wastewater produced by plant operations. Each pond is typically in service for approximately six to nine months (depending on the volume of CCR and waste produced by the Plant s generating units) before being taken out of service for removal of accumulated CCR s, at which time the adjacent pond is used for temporary storage of CCR and plant wastewater. General maintenance activities are performed when a pond is out of service. When in service, water and bottom ash enter one corner of the North or South Pond and flow around the perimeter to the opposite corner where the water discharges through a concrete outlet riser fitted with a weir plate that governs the pond elevation. Water passes from the base of the outlet risers through buried conveyance pipes and enters into a storm drain buried along the northern perimeter of the North Pond, which discharges at an NPDES permitted outfall. The storm drain pipe is part of a network which passes run-on water from the west side of the Plant to the Ohio River. The storm drain network terminates at an endwall structure located adjacent to State Route 7 at the northeast corner of the North Pond. The discharge immediately enters a concrete box culvert beneath the road and enters into the Ohio River at the upstream side of the New Cumberland Lock and Dam. A site plan identifying the primary features of the North and South Ponds is presented on Figure 2. The culvert outlet at the endwall of the storm drain network, which discharges the combined stormwater and CCR impoundment effluent, is a permitted discharge point under the Ohio ME1292/ (b) Written Closure Plan FNL 1 October 2016 pdf 5 of 21

6 Closure Plan W.H. Sammis Coal Plant North and South Ponds Environmental Protection Agency (OEPA), National Pollutant Discharge Elimination System (NPDES), Permit No. OH The North Pond is regulated by the Ohio Department of Natural Resources (ODNR) Dam Safety Program as a Class II Dam, File No ME1292/ (b) Written Closure Plan FNL 2 October 2016 pdf 6 of 21

7 Closure Plan W.H. Sammis Coal Plant North and South Ponds 2. CCR RULE REQUIREMENTS FOR CLOSURE PLAN (b) Pursuant to (b) of the CCR Rule, this closure plan includes: (i) A narrative description of how the CCR unit will be closed, including a description of the procedures to remove the CCR and decontaminate the CCR unit. (ii) An estimate of the maximum inventory of CCR ever on-site over the active life of the CCR unit. (iii) An estimate of the largest area of the CCR unit ever requiring a final cover at any time during the CCR unit s active life. (iv) A schedule for completing all activities necessary to satisfy the closure criteria, including an estimate of the year in which all closure activities will be completed as well as duration of such activities. Part 3 of this document presents the closure plan required by the CCR Rule. The table below summarizes where the CCR Rule requirement s are addressed in this document. The North and South Ponds are to be closed by the removal of CCR. As such, the requirements of (b)(1)(iii) are not applicable. RULE SECTION (b)(1)(i) (b)(1)(ii) RULE REQUIREMENT Narrative of How Unit Will be Closed Narrative of How Unit Will be Closed by Removal of CCR LOCATION WHERE ADDRESSED IN DOCUMENT Section 3.1 Section (b)(1)(iv) CCR Maximum Inventory Estimate Section (b)(1)(v) Cover System Area Estimate Section (b)(1)(vi) Schedule for Completing Closure Activities Section 3.5 ME1292/ (b) Written Closure Plan FNL 3 October 2016 pdf 7 of 21

8 Closure Plan W.H. Sammis Coal Plant North and South Ponds 3. CLOSURE PLAN 3.1 Description of Closure Per (b)(1)(i), this section provides a narrative description of the unit closure. The North and South Ponds will both undergo a clean closure procedure (i.e., CCR will be removed from the units and the units decontaminated). Once CCR is removed and the units decontaminated, the area will be made available for future development to support site operations. 3.2 Description of CCR Removal Procedure Excavation and Grading The North and South Ponds provide temporary storage of CCR that is regularly removed for offsite disposal. As such, provisions for the removal and disposal of CCR from the units are wellestablished. At the end of the operating life of the North and South Ponds, CCR removal will begin with gravity dewatering of the CCR by draining free water through the existing outlet risers. Once sufficiently dewatered, CCR excavation operations will utilize standard construction equipment such as, hydraulic excavators, frontend loaders, and bulldozers to manipulate and load CCR into highway dump trucks for off-site disposal. Based on the original design plans for the North and South Ponds, which are described in the report History of Construction, W.H. Sammis Coal Plant North and South Ponds, Stratton, Ohio (Geosyntec 2016), CCR is anticipated to extend to an approximate elevation of 680 ft-msl in each pond. In addition, the original design plans indicate that ash was used in construction of the North and South Pond embankments. Consequently, ash within the embankments is part of the embankment and is not intended to be removed during closure. CCR placed within the North and South Ponds for disposal will be excavated to a lateral and vertical extent sufficient to remove visual evidence of the CCR. Ash within the embankment, which is exposed during closure will be covered with a minimum 1-ft thick layer of soil to protect the integrity of the embankment. Documentation that CCR has been removed to the required extent will be confirmed by a third-party according to the procedures presented in Appendix A. Once CCR is removed, the interior areas of each pond will be prepared as follows: Interior slopes and floor will be regraded to promote positive stormwater drainage; Existing concrete riser structures within each pond will be retained and the drawdown orifices opened to permit free discharge of stormwater; Access ramps with a stabilized driving surface will be maintained to permit vehicle access to the base of each former pond; and A permanent seed mixture and temporary erosion control blankest (on slopes) will be used to minimize surface erosion. ME1292/ (b) Written Closure Plan FNL 4 October 2016 pdf 8 of 21

9 Closure Plan W.H. Sammis Coal Plant North and South Ponds Site plans identifying major features of the post-closure conditions of each pond are presented in Appendix B Decontamination As of October 2016, no groundwater monitoring data is available for review against groundwater protection standards for constituents listed in Appendix IV of 257. Decontamination of the North and South Ponds will be accomplished by removal of CCR as described in Section Maximum Inventory of CCR Analysis of the stage-storage relationship of pond was performed to evaluate the maximum inventory of CCR, assuming CCR is deposited to the elevation of the outlet weir. The stage-storage relationship for each pond is presented in the report, History of Construction, W.H. Sammis Coal Plant North and South Ponds, Stratton, Ohio (Geosyntec 2016). Results of the analysis indicate the estimated maximum inventories of CCR within the North and South Ponds at the time of closure will be no greater than 24,100 yd 3 (elev ) and 55,200 yd 3 (elev..9), respectively. 3.4 Maximum Area Requiring a Final Cover The North and South Ponds are to be closed by removal of CCR. Therefore, the maximum area requiring final cover is zero (0) acres. The combined area of the North and South Pond requiring excavation and grading to implement the CCR removal is approximately 9.0 acres. 3.5 Closure Schedule The following list identifies the major milestones associated with closure of the ponds. Notify ODNR Dam Safety Program of the intent to decommission the North Pond; Prepare and post notification of intent to close in accordance with (g); Prepare Construction Grading Plans and Specifications (Contract Documents) for closure of the North and South Ponds; Solicit Contractor bids for execution of the work described in the Contract Documents; Initiate construction in conformance with the Contract Documents; Stabilize the site with permanent vegetation in conformance with the Contract Documents; Prepare Engineer s Certification for closure; Prepare and post notification of completion in accordance with (h). A duration based schedule including each of these milestones is presented in Appendix C. As demonstrated by the schedule, completion of the closure process is expected to be accomplished in a time period not exceeding 24 months from the date when operations cease. This period is well within the allotted 5-year (60 month) closure timeframe required by the CCR Rule. ME1292/ (b) Written Closure Plan FNL 5 October 2016 pdf 9 of 21

10 Closure Plan W.H. Sammis Coal Plant North and South Ponds 4. REFERENCES United States Environmental Protection Agency (USEPA) (2015). Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals from Electric Utilities; Final Rule. Title 40 Code of Federal Regulations, Parts 257 and 261. Geosyntec (2016). History of Construction, W.H. Sammis Coal Plant North and South Ponds, Stratton, Ohio. Geosyntec Consultants Inc. 17 October ME1292/ (b) Written Closure Plan FNL 6 October 2016 pdf 10 of 21

11 pdf 11 of 21 FIGURES

12 ³ P:\GIS\Sammis Power Station - ME1292\Report 1\Figure 1 - Site Location Map N&S Ponds.mxd; RDW/MS; 13-Oct-2016 North and South Ponds Notes: Topographinc map provided by U.S Geological Survey on 13 October East Liverpool South, West Virginia (1985), and Wellsvill, Ohio (1986) 2,000 1, ,000 Feet Site Location Map: North and South Ponds Sammis Power Station Stratton, Ohio Figure Columbia, Maryland pdf 12 of 21 October

13 ³ Discharge at Headwall Ohio Route 7 48-in RCP 30-in HDPE 24-in RCP with HDPE Liner 24-in HDPE Outlet Riser and Valve Vault Primary Outlet 3 Outlet Riser and Valve Vault Primary Outlet 48-in HDPE Overflow Outlet 12" HDPE Overflow Outlet 48" HDPE North Pond South Pond 3 48" RCP with HDPE Liner P:\GIS\Sammis Power Station - ME1292\Report 1\Figure 2 - Site Plan N&S Ponds.mxd; MS/RDW; 13-Oct-2016 pdf 13 of 21 3 Legend 3 Manhole 24 inch pipe 30 inch pipe 48 inch pipe Notes: RCP - Reinforced Concrete Pipe HDPE - High-Density Polyethylene 1. Aerial imagery accessed via ArcGIS Online and provided by the United Stated Department of Agriculture on 13 October Image is dated 24 October All pipe and structure locations are approximate Feet Site Plan: North and South Ponds Sammis Power Station Stratton, Ohio Columbia, Maryland October 2016 Figure 2

14 APPENDI A Procedures for Verification of CCR Removal pdf 14 of 21

15 Closure Plan Appendix A W.H. Sammis Coal Plant North Pond and South Pond PURPOSE AND SCOPE PROCEDURES FOR VISUAL VERIFICATION OF CCR REMOVAL This document describes the procedures to be followed for verification of removal of Coal Combustion Residual (CCR) from the W.H. Sammis Coal Plant North and South Ponds. This procedure does not address design of the excavation, construction materials, disposal of excavated material, or stabilization of disturbed ground. PROCEDURES FOR VERIFICATION OF DECONTAMINATION Verification that CCR waste will be removed from the North and South Ponds will be made based on visual observation. The observer will use the procedures below to verify that CCR waste has been completely removed from the unit. The observer shall be familiar with the Contract Documents, Grading Plans, and Closure Plan for the North and South Pond. Each pond shall be divided into a grid system with each location given a unique identifier. Upon confirmation by the excavation contractor that all CCR has been removed from a grid the observer shall traverse the grid in a systematic pattern which allows for observation of the entire area. The observer shall document through field notes and photographs whether or not any visible CCR is present. Should CCR be identified, a minimum 10 ft offset around the point or area will be marked and a minimum of an additional 6-inches of material excavated. The observer will re-check the area and if CCR remains present, the excavation area will continue to be expanded laterally in 10-ft increments until no visible ash is observed. Should excavation expose ash, which was used in construction of the pond embankments, the exposed ash shall be covered with a minimum of 1 foot of soil. At the completion of excavation, before backfilling or otherwise grading an area which has been documented as having CCR completely removed, a post-removal survey shall be performed to record the depth and extent of CCR removal. DOCUMENTATION At the completion of the work a closure documentation report will be prepared. The report will verify that the work has been performed in accordance with the Contract Documents and with the latest version of the Closure Plan. At a minimum, the report will include: (i) field documentation of the closure activities (notes and photographs); (ii) description of any changes to the Contract Documents made during CCR removal work; and ME1292/Appendix A - Verification_ FNL Page 1 of 2 October 2016 pdf 15 of 21

16 Closure Plan Appendix A W.H. Sammis Coal Plant North Pond and South Pond (iii) post-removal drawings prepared by a licensed surveyor, which depict the conformance grids, excavation grades, and the location of any embankment areas where ash was identified and subsequently covered in accordance with this procedure and the Closure Plan. ME1292/Appendix A - Verification_ FNL Page 2 of 2 October 2016 pdf 16 of 21

17 APPENDI B Drawings pdf 17 of 21

18 A B C D E IRON PIN ELEV ' N: ' E: ' A N PIPE PIPES PIPE A TOP CONC. PAD ELEV. = 692.4' MH TOP CONC. PAD B C D HV PIPE ELEV. = 692.6' NP NP ACCESS RAMP NORTH POND BOTTOM EL W.E PLAN NORTH POND SCALE: 1" = 40' PIPE PIPE MH EISTING OUTLET STRUCTURE TO REMAIN MH Brush LEGEND OF SYMBOLS AND ABBREVIATIONS GENERAL NOTES: MAJOR CONTOUR MINOR CONTOUR UNDERGROUND DRAINAGE LINE GUARD RAIL FENCE LINE EDGE OF WATER SLOPE ARROW 1. SOURCE OF TOPOGRAPHIC INFORMATION: FROM GROUND CONTROL SURVEYS JANUARY 18 AND 29, 2016 AND FROM AERIAL PHOTOGRAPHY DATED APRIL 28, HORIZONTAL CONTROL IS BASED ON OH NORTH NAD83, STATE PLANE COORDINATES BY THE KEYNET VRS NETWORK. ALL COORDINATES ARE TRUE STATE PLANE. 3. VERTICAL CONTROL IS BASED ON NAVD88 VERTICAL DATUM, GEOID12A BY THE KEYNET VRS NETWORK. 4. UNDERGROUND UTILITY LOCATIONS ARE BY OTHERS AND WERE NOT VERIFIED BY L.R. KIMBALL USING REMOTE SENSING TECHNIQUES. DEVELOPMENT NOTES: MH PIEZOMETER MANHOLE POST SIGN LIGHT POLE UTILITY POLE 1. ECAVATE, DISPOSE, AND DOCUMENT CCR REMOVAL ACCORDING TO THE CLOSURE PLAN. 2. APPLY PERMANENT SEEDING TO ALL DISTURBED AREAS, APPLY TEMPORARY EROSION CONTROL MAT TO ALL DISTURBED SLOPES. 3. PROVIDE COMPACTED GRAVEL SURFACE ALONG THE ACCESS RAMP. B C D E. GRADE 0 40' 80' SCALE IN FEET P:\CADD\1292 SAMMIS\DRAWINGS\FIGURES\NORTH AND SOUTH PONDS ANALYSIS\ /23/ :44 AM CHRIS GRANDE E F ELEVATION (FEET) POND ELEV: PROP. BOTTOM OF POND DISTANCE (FEET) (NP) NORTH POND PROFILE HORIZONTAL: 1" =40' VERTICAL: 1" =5' ELEVATION (FEET) TITLE: PROJECT: SITE: REV DATE WINCOPIN CIRCLE, FLOOR 4 COLUMBIA, MARYLAND USA PHONE: THIS DRAWING MAY NOT BE ISSUED FOR PROJECT TENDER OR CONSTRUCTION, UNLESS SEALED. SIGNATURE DATE DESCRIPTION NORTH POND CLOSURE PLAN W.H. SAMMIS COAL PLANT STRATTON, OHIO DESIGN BY: DRAWN BY: CHECKED BY: REVIEWED BY: APPROVED BY: WMS CPG SWH WMS WMS DATE: PROJECT NO.: FILE: DRAWING NO.: 1 DRN APP AUGUST 2016 ME1292A OF 2 E F pdf 18 of

19 A B C PIPE 3 4 N HV A B C D E F G SOUTH POND BOTTOM EL W.E SP SP PIPE TOP CONC. PAD ELEV. = 694.1' PIPE TOP CONC. PAD ELEV. = 694.7' ACCESS RAMP TANK EISTING OUTLET STRUCTURE TO REMAIN MH I Brush LEGEND OF SYMBOLS AND ABBREVIATIONS GENERAL NOTES: MAJOR CONTOUR MINOR CONTOUR UNDERGROUND DRAINAGE LINE GUARD RAIL FENCE LINE EDGE OF WATER SLOPE ARROW MH PIEZOMETER MANHOLE POST SIGN LIGHT POLE UTILITY POLE 1. SOURCE OF TOPOGRAPHIC INFORMATION: FROM GROUND CONTROL SURVEYS JANUARY 18 AND 29, 2016 AND FROM AERIAL PHOTOGRAPHY DATED APRIL 28, HORIZONTAL CONTROL IS BASED ON OH NORTH NAD83, STATE PLANE COORDINATES BY THE KEYNET VRS NETWORK. ALL COORDINATES ARE TRUE STATE PLANE. 3. VERTICAL CONTROL IS BASED ON NAVD88 VERTICAL DATUM, GEOID12A BY THE KEYNET VRS NETWORK. 4. UNDERGROUND UTILITY LOCATIONS ARE BY OTHERS AND WERE NOT VERIFIED BY L.R. KIMBALL USING REMOTE SENSING TECHNIQUES. DEVELOPMENT NOTES: A B C D 1 - PLAN SOUTH POND SCALE: 1" = 40' 1. ECAVATE, DISPOSE, AND DOCUMENT CCR REMOVAL ACCORDING TO THE CLOSURE PLAN. 2. APPLY PERMANENT SEEDING TO ALL DISTURBED AREAS, APPLY TEMPORARY EROSION CONTROL MAT TO ALL DISTURBED SLOPES. 3. PROVIDE COMPACTED GRAVEL SURFACE ALONG THE ACCESS RAMP. D 700 E. GRADE ' 80' P:\CADD\1292 SAMMIS\DRAWINGS\FIGURES\NORTH AND SOUTH PONDS ANALYSIS\ /23/ :54 AM CHRIS GRANDE E F ELEVATION (FEET) POND ELEV: DISTANCE (FEET) (SP) SOUTH POND PROFILE HORIZONTAL: 1" =40' VERTICAL: 1" =5' PROP. BOTTOM OF POND ELEVATION (FEET) TITLE: PROJECT: SITE: REV DATE WINCOPIN CIRCLE, FLOOR 4 COLUMBIA, MARYLAND USA PHONE: THIS DRAWING MAY NOT BE ISSUED FOR PROJECT TENDER OR CONSTRUCTION, UNLESS SEALED. SIGNATURE DATE DESCRIPTION SOUTH POND CLOSURE PLAN W.H. SAMMIS COAL PLANT STRATTON, OHIO DESIGN BY: DRAWN BY: CHECKED BY: REVIEWED BY: APPROVED BY: WMS CPG SWH WMS WMS DATE: PROJECT NO.: FILE: DRAWING NO.: 2 DRN APP AUGUST 2016 ME1292A OF 2 E F pdf 19 of

20 APPENDI C Closure Plan Schedule pdf 20 of 21

21 ID Task Name Duration 1 CLOSURE PROCESS 20.5 mons CLOSURE PLAN SCHEDULE North and South Pond (CCR Impoundments) FirstEnergy W.H. Sammis Coal Plant Stratton, Ohio Year 2 Year 3 M-1 M1 M2 M3 M4 M5 M6 M7 M8 M9 M10 M11 M12 M13 M14 M15 M16 M17 M18M19 M20 M21 M22 M23 M24 M25 M26 Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct N CLOSURE PROCESS 2 INITIATE CLOSURE PROCESS 1 mon INITIATE CLOSURE PROCESS 3 Final Receipt of CCR, Notify ODNR Dam Safety of Intent to Decommission North Pond 0 days 9/1 4 Post Notification of Intent to Close (g) 0 days 9/28 5 DESIGN AND BIDDING 9 mons 6 Prepare Construction Grading Plans and Specifications 6 mons 7 Solicit Contractor Bids and Award 3 mons DESIGN AND BIDDING Prepare Construction Grading Plans and Specifications Solicit Contractor Bids and Award 8 CONSTRUCTION 10.5 mons 9 Construction Grading and Excavation 4.5 mons 10 Stabilize Site with Permanent Vegetation 6 mons 11 CONCLUDE CLOSURE PROCESS 1 mon 12 Prepare Engineer's Certification 1 mon 13 Post Notification of Closure Completion (h) 0 days CONSTRUCTION Construction Grading and Excavation Stabilize Site with Permanent Vegetation CONCLUDE CLOSURE PROCESS Prepare Engineer's Certification 3/28 pdf 21 of 21 Page 1