1 CCR Fugitive Dust Control Plan Mill Creek Generating Station Louisville Gas & Electric Company Jefferson County, Kentucky October 2015
2 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 1 Executive Summary Mill Creek stores coal ash in a surface impoundment and the on-site special waste landfill. A portion of the surface impoundment walls serves as part of the floodwall for Jefferson County. Due to this, the operation of the surface impoundment is regulated and inspected by the Army Corp of Engineers in addition to local, state and federal EPA agencies. Mill Creek personnel regularly inspect the surface impoundment internally and with 3rd party structural engineering firms as part of the LG&E Impoundment Integrity Program (IIP). The Mill Creek surface impoundment is classified as a dam based upon its size and operation. EPA classifies a dam s hazard class based upon the potential to impact the public if a major breach was to occur. This classification does not indicate the likelihood for a breach, only the potential for impact. Due to the location of the Mill Creek surface impoundment to a residential neighborhood, EPA and the state have classified the surface impoundment as a high-hazard dam. Coal ash, as well as soil, is a type of particulate matter (PM) and the ambient air in the area is continuously monitored by the Louisville Metro Air Pollution Control District (APCD) for compliance with EPA standards. The facility utilizes control equipment to remove PM from the gas stream prior to its emission from the stacks. Controls include an electrostatic precipitator (ESP), pulse-jet fabric filter (PJFF) and flue gas desulfurization (FGD) unit. Louisville Gas and Electric Company (LG&E) is required to identify, describe, and implement coal combustion residual (CCR) fugitive dust control measures to minimize CCR from becoming airborne at the Mill Creek Generating Station. CCR fugitive dust controls were reviewed to identify the most applicable and appropriate for the on-site conditions to minimize the CCR from becoming airborne at the facility. Areas handling CCR material included ash storage areas, paved and unpaved roads, surface impoundments and Special Waste Landfill. Evaluation of applicable and appropriate fugitive dust control measures included a review of onsite conditions, EPA fugitive dust control guidance and case studies and search of the EPA Clearinghouse for approved Best Available Control Technology (BACT). This CCR fugitive dust control plan has been prepared to comply with the requirements as defined under Subtitle D of the Resource Conservation and Recovery Act and has been approved by a certified professional engineer.
3 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 2 Table of Contents Executive Summary... 1 Introduction... 3 Section 1 Site Description... 3 Section 2 - Description of Potential Sources of Dust at Mill Creek Generating Station... 5 Potential Sources... 5 Fly Ash Handling... 5 Landfill... 5 Unpaved Roads... 6 Paved Roads... 6 Surface Impoundments... 6 Section 3 - Control Measures to Minimize Emissions... 7 General Practices... 7 Fly Ash Storage and Handling Unit... 7 Landfill... 7 Unpaved Roads... 8 Paved Roads... 8 Surface Impoundments... 8 Ash Pond... 8 Emergency Pond... 8 Construction Runoff Pond... 9 Dead Storage Pond... 9 Clearwell Pond... 9 Section 4: Complaint Response and Documentation Section 5: Monitoring and Reporting Dust Control Plan Measures Section 6: Professional Engineer Certification... 11
4 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 3 Introduction Coal ash is the result of unburned rock and minerals associated with the combustion of coal for power generation. The amount of coal ash generated is dependent upon the amount of mineral matter (clay, quartz, etc.) in the coal when it is mined. Coal ash is comprised primarily of silica (sand) and is similar in appearance and feel to sand. Approximately one-third of the coal ash generated at Mill Creek is beneficially reused as concrete additive and in the cement manufacturing process. In addition, coal ash has been approved for direct application to roadways in the winter months for traction control and as a soil additive for agricultural purposes. Coal ash is similar in composition to soil with a metal content comparable to the minerals naturally occurring in the area soils from which it was mined. Fly ash is defined and regulated as a special waste. Coal ash does not meet the definition of either a solid waste or hazardous waste based upon its physical properties. In addition, the levels of heavy metals such as arsenic and lead contained in coal ash are similar as those the levels found in Kentucky soils. Control equipment is utilized at the facility to remove greater than 99 percent of the ash from the stack emissions. This ash is beneficially reused, stored in the surface impoundment or placed in the onsite landfill. Applicable and appropriate CCR fugitive dust control measures for the Mill Creek Generating Station are outlined for ash storage areas, paved and unpaved roads, surface impoundments and the Special Waste Landfill. Community or citizen complaints related to the handling of CCRs are handled in accordance with the Complaint Response and Documentation process described in Section 4. The contents of this plan will be reviewed at least annually to assess the effectiveness of the described dust control measures based upon the controls implemented and CCR related complaints. Information will be compiled for an Annual CCR Fugitive Dust Control Report that will be posted on the LG&E and KU CCR Rule Compliance Data and Information website. Section 1 Site Description LG&E s Mill Creek Generating Station (Mill Creek) is located in southwestern Louisville at Dixie Highway. Mill Creek generates electric energy for local and remote distribution. Coal is the primary fuel utilized in electric generation at Mill Creek. Coal is delivered on the site by rail car and barge with shipments either placed in a storage pile or fed directly to the electric generation process. The Mill Creek site consists of approximately 500 acres along the Ohio River. The existing operation is spread throughout the property. The primary emission generating activities at the facility consist of four operational coal fired boilers (emission units U1, U2, U3 and U4), used for generation of electricity via steam turbines and generators. The units use natural gas as the start up. All boiler units are equipped with emission control systems as follow: low NOx burner electrostatic precipitators (ESP) pulse jet fabric filters (PJFF)* sorbent injection*
5 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 4 flue gas desulfurization systems (FGD) Selective Catalytic Reduction (SCR) Units 3 and 4. * Controls for Unit 3 will be in operation in Coal Combustion Residuals (CCRs) generated at the facility includes fly ash, bottom ash boiler slag, and flue gas desulfurization (FGD) solid by-products (gypsum). CCRs not beneficially used are disposed of and treated in a large on-site surface impoundment (Ash Pond) or placed into the on-site KYDWM-permitted landfill. The Ash Pond was designed to receive ash sluice waters with a monitored discharge into the Ohio River, consistent with the facility s KPDES permit. A portion of the gypsum is routed to the on-site gypsum pelletizing plant and shipped off-site via truck, rail or barge for beneficial reuse as an agricultural amendment. Gypsum that is not used beneficially is landfilled onsite. Gypsum waters are primarily sent to settling ponds or are discharged to the Ash Pond.
6 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 5 Section 2 - Description of Potential Sources of Dust at Mill Creek Generating Station Potential Sources 40 CFR defines CCR fugitive dust as airborne CCR material that is emitted from any source other than a stack or chimney. Facility operations at Mill Creek that were evaluated for applicable and appropriate fugitive dust control measures include the following: Fly Ash Handling Landfill Unpaved Roads Paved Roads Surface Impoundments Fly Ash Handling The fly ash storage and handling operations are located on the southwest side of the plant site, in front of the landfill. Fly ash is transported via an enclosed blower system, which includes a transfer line from central bins where fly ash is collected from hoppers located near each of the coal-fired boilers. Each fly ash silo is equipped with a baghouse and can load-out on either a wet or dry material. In wet fly ash load-out, fly ash is fed into a pug mill where water is introduced, before being transferred to an open top truck for transfer to the landfill. In dry fly ash load-out, material is transferred via an air chute into enclosed trucks prior to transporting off site. Potential Fugitive Dust Sources include: Material transfer points Truck loading Landfill The Mill Creek landfill contains coal combustion residuals consisting of bottom ash, fly ash, and gypsum. This landfill was engineered to meet continuous compliance with Kentucky Division Waste Management structural requirements and measurements. Potential fugitive dust from the landfill may be caused by: Wind erosion Heavy equipment performing grading on contours and slopes within active areas Mechanical traffic on haul roads
7 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 6 Unpaved Roads Unpaved roads at the Mill Creek site are typically graveled. Vehicle access to unpaved roads is limited to contractors and employees performing required operational duties. Potential fugitive dust from unpaved roads may be caused by: Dry road conditions Wind erosion Vehicle traffic Material fallout from vehicle traffic Paved Roads The paved roads are asphalt or concrete surfaced and traffic is limited to contractors and employees. Potential fugitive dust from paved roads may include: Material tracked from unpaved surfaces onto paved roads by vehicle traffic Material fallout from vehicle traffic Surface Impoundments Surface impoundments at Mill Creek consist of the Ash Pond, Emergency Pond, Construction Runoff Pond, Dead Storage Pond, and Clearwell Pond. Potential fugitive dust from the surface impoundments may be caused by: Wind erosion. Dry conditions Mechanical traffic on ash pond haul road Stacking activities
8 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 7 Section 3 - Control Measures to Minimize Emissions General Practices A CCR qualified individual or designee will be available during hauling and placement activities and to help assess the need for dust control. In the event dry weather persists, the frequency of watering will be adjusted to control fugitive dust emissions. If it is determined that weather conditions have contributed to the control of fugitive dust emissions, watering operations may be suspended until such time as it appears necessary for the control of fugitive dust emissions. A water log will be kept to demonstrates when watering was required. Watering will be suspended when ambient air temperatures are below freezing or if ice is present. Alternative commercially available control measures to watering will be used as needed, to control fugitive dust. Fly Ash Storage and Handling Unit Transfer of materials is suspended if conveying equipment is not in proper working condition. Gypsum is sluiced to the process with a moisture content that will be adjusted as necessary to facilitate compaction and minimize dusting. Fly ash will be conditioned with water from the plant service water in the pug mill mixer prior to being placed in the landfill. Fly ash is not stockpiled in storage piles. Mitigation procedures may include wetting of the material or covering of the trucks, to prevent fugitive emissions from trucks hauling dry material likely to become airborne. Landfill CCR is conditioned with service water in the pug mill prior to be loaded into trucks and transported to the landfill. CCR is bladed in place in approximate horizontal, 12-inch maximum lifts. Erosion control will be achieve thru compaction in accordance with the plant s Special Waste Landfill Permit # Visual inspections will be conducted of the landfill for fugitive dust and areas will be watered as needed. A water log will be kept to demonstrate when watering was required. Vehicle access will be restricted for authorized use only. Signage states that all vehicular traffic on landfill haul roads and site roads are restricted to 15 mph.
9 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 8 Unpaved Roads Mill Creek utilizes a water truck(s) to keep the roadways and entrance and exit areas within the site wet in order to control fugitive dust emissions. Mill Creek will maintain records for the watering operations performed on all unpaved roads. Vehicle access will be restricted for authorized use only. Signage states that all vehicular traffic on landfill haul roads and site roads are restricted to 15 mph. Paved Roads All passenger vehicles, including employee vehicles entering and leaving the facility, will be limited to paved roads and parking lots to prevent the generation of dust, unless required for direct performance of operational duties. Should operational duties cause dust to transfer to paved roads, the material will be cleaned. Signage states that all vehicular traffic on landfill haul roads and site roads are restricted to 15 mph. Roads will be maintained in such a manner as to prevent the tracking of debris onto any public road. Surface Impoundments Ash Pond Signage states that all vehicular traffic on landfill haul roads and site roads are restricted to 15 mph. Vehicle access will be restricted for authorized use only. A water truck(s) will be utilized to keep the site wet in order to control fugitive dust emissions. Bottom ash is deposited in a wet process. Storage piles are temporarily used and watered as necessary based on visual observations. Stockpiled material is either placed in the landfilled, sent offsite for beneficial reuse, or relocated to another area of the pond to promote drainage and settlement time. Emergency Pond Gypsum fines and associated storm water runoff is collected via a wet process, which minimize fugitive dust. Storage piles are temporary used and watered as necessary based on visual observations. Stockpiled material is placed in the landfill.
10 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 9 Construction Runoff Pond Gypsum contact water is collected via a wet process, which minimize fugitive dust. Material from this process is not dredged. Dead Storage Pond Gypsum contact water is collected via a wet process, which minimize fugitive dust. Material from this process is not dredged. Clearwell Pond Collects service water and water from Cooling Towers. Receives overflow waters from the Dead Storage Pond. Material from this process is not dredged.
11 CCR Fugitive Dust Control Plan - Mill Creek Generating Station Page 10 Section 4: Complaint Response and Documentation Complaints related to CCR management may be received by Customer Commitment or the facility voice message system provided in the Neighbor-To-Neighbor communication. The complaint is forwarded to and tracked by Environmental Affairs. The complaint is reviewed and a response is provided by either the Mill Creek Environmental Coordinator or Environmental Affairs within 3 business days of the complaint. The response may include a visit to the resident to specifically review the nature of the complaint. The complaint is documented on the internal complaint form. Lift tape sampling may be conducted, if warranted, for complaints of neighbors adjacent to the facility. A record of the complaint and summary of sampling results will be maintained in the Mill Creek Environmental files and with LKE Environmental Affairs Department. If a sample is collected, results will be provided to the respective party within 6-8 weeks from the collection of the sample. Section 5: Monitoring and Reporting Dust Control Plan Measures Monitoring of the fugitive dust control measures will vary dependent upon site observations and the nature of any complaints. Monitoring is performed by numerous mechanisms. These include: logs from water trucks; weekly surface impoundment and landfill inspection records; documentation of CCR related complaints; and MAXIMO Work Orders related to CCR dust in applicable areas. A summary of the complaints and controls implemented will be reviewed annually by LKE Environmental Affairs Department and the Mill Creek Environmental Coordinator. The annual review will evaluate the adequacy of control measures and provide a recommendation for any changes to the CCR Fugitive Dust Control Plan. A log of the review will be maintained in the LKE Environmental Affairs Department files.