Thursday, July 9, 2015

Millions of Tons of Coal Ash in Prince William County

There is a whole lot of coal ash in Prince William County-millions of tons of the stuff. It is all sitting on a peninsula where Quantico Creek meets the Potomac River in eastern Prince William County. All this coal ash was produced by Dominion Power at their Possum Point power plant. Coal ash is the remainder left after coal is burned to generate electricity. Dominion Power is proposing to “close in place” all that coal ash by capping a surface impoundment, and has begun to move more than 1 million cubic yards of coal ash into one impoundment at the Possum Point Power Station before obtaining final regulatory approval from the U.S. Environmental Protection Agency (EPA) and Virginia Department of Environmental Quality (DEQ).

Coal ash includes a number of by-products produced from burning coal, including:
  • Fly Ash, a very fine, powdery material composed mostly of silica made from the burning of finely ground coal in a boiler.
  • Bottom Ash, a coarse, angular ash particle that is too large to be carried up into the smoke stacks so it forms in the bottom of the coal furnace.
  • Boiler Slag, molten bottom ash from slag tap and cyclone type furnaces that turns into pellets that have a smooth glassy appearance after it is cooled with water.
  • Flue Gas Desulfurization Material, a material leftover from the process of reducing sulfur dioxide emissions from a coal-fired boiler that can be a wet sludge consisting of calcium sulfite or calcium sulfate or a dry powered material that is a mixture of sulfites and sulfates.
Last December, EPA Administrator, Gina McCarthy, signed the Disposal of Coal Combustion Residuals from Electric Utilities final rule, and it was published in the Federal Register (FR) on April 17, 2015. While the new rule was years in development, a proposed rule was published in 2013, the Duke Energy coal ash spill in North Carolina in February 2014 brought the need to the attention of the public.

Shortly after the release of the new rule, Dominion Virginia Power announced that they will close all of the ash ponds at its Virginia power stations including those in Dumfries at Possum Point in compliance with rules. Dominion had been working on plans based on the 2013 proposed rule in order to be prepared for when the final rule took effect. Pamela Faggert, Dominion's chief environmental officer and vice president of Corporate Compliance said; "We are working with the Virginia Department of Environmental Quality and other state agencies to develop closure plans that are in compliance with the new rules."

Possum Point from Google maps

According to the EPA, the final rule is the culmination of extensive study on the effects of coal ash on the environment and public health. The rule establishes technical requirements for disposing coal ash in landfills and surface impoundments under the Resource Conservation and Recovery Act (RCRA), the nation's primary law for regulating solid waste. Under RCRA, coal ash has been determined to be a non-hazardous material. The new rule classifies coal ash as a “solid waste,” similar to standard household garbage, instead of designating it as a “hazardous waste and the regulations are based on landfill regulations.

Environmental groups and their lawyers had hoped that the EPA would find that coal ash was a hazardous waste when they filed a lawsuit in 2012 to compel EPA to complete a review of the regulations applying to coal ash and issue necessary revisions. The finalized regulation requires that new disposal sites cannot be located in areas designated as wetlands or earthquake zones. Coal ash disposal site must have protective liners to prevent groundwater contamination. The rule also requires companies to conduct monitoring of disposal sites, clean up any existing contamination, and close and remediate unlined disposal sites that have polluted groundwater. Monitoring data, corrective action reports, and other important information about the site must be made available to the public.

For decades coal ash has been produced as a waste product from electricity generation, and is one of the largest types of industrial waste generated in the United States. According to the American Coal Ash Association's Coal Combustion Product Production & Use Survey Report, nearly 110 million tons of coal ash was generated in 2012. There are billions of tons of coal ash that need to be address nation wide.

Possum Point Power Station is owned by Dominion Power. It sits on a 650-acre site located in Dumfries Virginia in the eastern part of Prince William County that borders the Potomac River and the Quantico Creek. There are four generating units; three of which use natural gas as a fuel source, the other is oil fired. Two of the units that are fired using natural gas were converted from coal in May of 2003. Dominion Virginia Power has not burned coal at Possum Point for 13 years and is unlikely to burn coal to generate power in the future.

When EPA (and their contractors) surveyed coal ash ponds they found the ponds at Possum Point to be of “significant” hazard risk and to be in fair and satisfactory condition. Once Dominion has obtained the needed permits from DEQ the company intends to begin the actual closure work in Prince William which should improve the situation. The old unlined open ponds that have existed at Possum Point are being closed- properly, In May Dominion Power began work to consolidate all the coal ash into a single lined pond that will be dewatered, and capped with an impermeable membrane to prevent infiltration of rain that could carry contaminants into the groundwater.

For decades the millions of cubic yards of coal ash has sat in open ponds at Possum Point. Today there is estimated to be 3.7 million cubic yards of coal ash. According to preliminary regulatory disclosures, Dominion’s plan is to collect more than 1 million cubic yards of ash from four smaller ponds, put them in a 120-acre pond that already contains 2.6 million cubic yards of coal ash and cap it. The coals ash ponds being eliminated and properly closed predate modern environmental regulations and RCRA. The utility claims that the pond/ impoundment for all the ash is fully lined, but Southern Environmental Law Center. and the Potomac Riverkeeper Network contend it is only partially lined. In addition, state delegate Scott A. Surovell has called to remove all the coal ash from Possum Point and dispose of it elsewhere, though it is unclear where might be a better location.

However, it is essential to ensure that the liner for the coal ash permanent disposal pond is sound and fully covers the entire pond before Dominion proceeds with their closure plan. Moving waste from one site to another just creates another location for potential contamination from coal ash. These coal ash ponds have been open to the elements and taking on water for decades. Trace contaminants and metals in the coal ash have probably already leached into the groundwater, Quantico Creek and Potomac. Closing the coal ash on site would require continual monitoring and maintenance. This is probably best accomplished at an operating and regulated plant rather than at a remote cap and leave it location. All physical barriers fail over time this is addressed by monitoring and maintaining the systems.

 Possum Point is downstream from nearby drinking water supplies and is unlikely to impact local residents beyond what has already taken place over the decades. The closure plan should include site investigation to determine if groundwater has been impacted and ongoing monitoring of the groundwater to ensure that wetlands and the rivers are not impacted in the future. Dominion Power should fund expansion of the water well testing program we `run in Prince William County to allow well owners test their well water every year. Do it right, Dominion.

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