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SOUTHERN INDIANA GAS AND ELECTRIC COMPANY
D/B/A
VECTREN ENERGY DELIVERY OF INDIANA, INC.
CAUSE NO. 45280
DIRECT TESTIMONY
OF
JAY D. MOKOTOFF
SENIOR ENGINEER GROUP MANAGER, CIVIL & ENVIRONMENTAL ENGINEERING
SPONSORING PETITIONER’S EXHIBIT NO. 3,
ATTACHMENTS JDM-1 THROUGH JDM-2
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 1
DIRECT TESTIMONY
OF
JAY D. MOKOTOFF
SENIOR PROJECT MANAGER, AECOM
Q. Please state your name, employer, and business address. 1
A. Jay Mokotoff, AECOM Technical Services, Inc (“AECOM”), 1300 East 9th Street, Suite 2
500, Cleveland, OH 44114. 3
Q. What position do you hold with AECOM? 4
A. I am a Senior Project Manager and manage the Civil and Environmental Engineering 5
Group for AECOM’s Cleveland office. 6
Q. Please describe your educational background. 7
A. I received a Bachelor of Science Degree in Civil & Environmental Engineering from the 8
University of Wisconsin (Madison, WI) in 1994. I am currently licensed as a Professional 9
Engineer in the states of Ohio, Indiana, North Carolina and Maryland. I am a certified 10
Project Management Professional (PMP Cert #1508845). 11
Q. Please describe your professional experience. 12
A. I have 20 years of solid waste management experience acting in roles starting as junior 13
engineer in 1998 and progressing through my engineering career to Senior Engineer, 14
Task Manager, Project Manager, Senior Project Manager, Program Manager and Group 15
Manager. I have experience managing large multi-disciplinary engineering programs for 16
private and public sector clients, including directing and executing the design and 17
implementation of large-scale civil and environmental engineering and construction 18
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 2
projects. My specific areas of experience include: overall solid waste management 1
(including coal combustion residuals (CCRs), municipal solid waste, industrial solid 2
waste, and construction and demolition debris); facility siting analyses, design and 3
permitting; facility closures; surface impoundment design and closure; environmental 4
alternatives analyses; economic analyses; addressing/resolving environmental 5
compliance issues; erosion and sediment control; stormwater management; and 6
planning, design and construction administration of civil/environmental projects. 7
Q. What are your duties and responsibilities as a Senior Project Manager? 8
A. My primary responsibility as a Senior Project Manager is to manage and lead consulting 9
and civil/environmental engineering design projects, technical evaluations and 10
alternative analyses. Specifically, at Vectren Energy’s request, AECOM prepared the 11
ABB Evaluation of Options for Pond Closure Report (the “Report”) dated 1/23/18). The 12
Report contains the evaluation of closing the Brown Ash Pond in order to ensure 13
compliance with federal and state regulations. With respect to preparation of the Report, 14
I was responsible for evaluating pond closure options, pond closure cost estimating, and 15
design of the closure-by-removal option. I also led the evaluation and comparison of 16
closure options for the project. Ms. Schmit’s testimony addresses the infrastructure 17
engineering components required for material handling, and the associated evaluation 18
and cost estimating of these features. 19
Q. Are you sponsoring any attachments in support of your testimony? 20
A. Yes. I am sponsoring Petitioner’s Confidential Attachment JDM-1 and Attachment JDM-21
2, including the following: 22
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 3
Document Title
JDM-1 Excerpts from Evaluation of Options for Pond Closure Report (Rev. 2 report dated 1/23/18)
JDM-2 AECOM CCR Qualifications
1
The entirety of the Report for which excerpts are included in Attachment JDM-1 2
will be included in the workpapers submitted in this Cause. 3
Q. How is the responsibility for the Report divided between you and Witness Schmit 4
for purposes of this proceeding? 5
A. Using the Table of Contents from the Report, I am responsible for Sections 1-3 and 5, 6
together with referenced Appendices. Ms. Schmit is responsible for Section 4 and its 7
referenced Appendices. Stated another way, I am the witness responsible for all parts of 8
the Report except for the evaluation and discussion of the infrastructure that is 9
necessary to load, store, handle and transport the CCR materials for beneficial reuse. 10
That portion of the Report is covered by Witness Schmit. 11
Q. What is the purpose of your Direct Testimony in this proceeding? 12
A. The purpose of my testimony is to explain the process of option development and the 13
evaluation and engineering work completed by AECOM related to closure of the ABB 14
Ash Pond in accordance with applicable federal and state regulations. 15
Q. Please describe AECOM and its qualification and experience performing the work 16
discussed in your testimony for CCR compliance. 17
A. AECOM is the industry leader in providing CCR-related professional services to our 18
utility clients. Based on our database of industry metrics, AECOM has prepared and 19
certified over 500 CCR documents associated with 145 CCR units. This is significantly 20
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 4
more certifications than those prepared by our industry competitors. Given this 1
experience and our strong CCR practice group, AECOM is very qualified to engage in 2
the work related to closure of the Brown Ash Pond. Our company CCR qualifications 3
are summarized in Attachment JDM-2 to this testimony. 4
Q. What CCR requirements drive the need to close the Brown Ash Pond? 5
A. In April of 2015, the ‘Disposal of Coal Combustion Residuals from Electric Utilities Rule’ 6
(Rule) went into effect (the “CCR Rule”). The CCR Rule regulates the safe disposal of 7
CCRs generated from operating coal-fired power plants. The Rule was established in 8
response to recent incidences in which coal ash and/or coal ash leachate contaminated 9
surface water, including the catastrophic failure of an ash impoundment that resulted in a 10
large-scale release of coal ash and flooding of more than 300 acres of land that occurred 11
in Kingston, Tennessee. Under the CCR Rule, surface impoundment is defined as a 12
facility or part of a facility that is a natural topographic depression, human-made 13
excavation, or diked area formed primarily of earthen materials (although it may be lined 14
with human-made materials), that is designed to hold an accumulation of liquid wastes 15
or wastes containing free liquids and that is not an injection well. The Ash Pond at 16
Brown falls into this category. 17
The CCR Rule stipulates specific design criteria for surface impoundments including a 18
requirement in §257.60 (a) that the base of the impoundment must be at least five feet 19
above the upper limit of the uppermost aquifer. Further, §257.101 stipulates that for 20
unlined impoundments the owner must monitor ground water quality. If any sampling 21
event detects contaminants at statistically significant levels above the CCR Rule 22
Appendix IV groundwater protection standards, the owner must perform a series of 23
actions including cessation of operation of the impoundment and initiate closure 24
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 5
activities (for unlined ponds) in accordance with §257.102. The mandate to close the 1
Brown Ash Pond has been triggered by both of these provisions of the CCR Rule. 2
Q. What was AECOM’s role in Vectren South’s analysis of the CCR Rule 3
requirements for the Brown Ash Pond? 4
A. AECOM evaluated the Brown Ash Pond in order to provide the Report on viable closure 5
options for the Pond to achieve compliance with the CCR Rule requirements as well as 6
relevant IDEM requirements. 7
Q. Please describe the nature and contents of the Report. 8
A. The purpose of the Report was to evaluate the various potential options for closure of 9
the ABB Ash Pond and provide Vectren with relevant scope, cost, and risk information 10
so that they could make an informed decision and select the best option for closure. 11
AECOM evaluated the following three main alternatives: 12
i. Closure by removal (CbR) with Beneficial Reuse – the pond is dewatered 13 and ponded ash is removed from the pond. Once ash has been 14 confirmed to be removed, the area is stabilized and vegetated. 15
ii. Closure in place (CiP) – the pond is dewatered and the ponded ash is 16 maintained within the limits of the pond. The ponded ash is 17 recontoured/graded into a configuration that is optimal for final closure 18 and a closure cap is constructed overtop the ash surface. Under this 19 scenario, groundwater monitoring is required throughout the post-closure 20 period. 21
iii. CiP with Future Removal and Onsite Landfill Disposal -- a sub-scenario of 22 CiP whereby after the Ash Pond has been closed by CiP, the CCR 23 materials contained within the closed pond would be removed and 24 disposed in an onsite landfill. In this case, a new onsite landfill would be 25 constructed at the Brown site and the CCR materials would be removed 26 from the closed pond and disposed in the onsite landfill. The onsite landfill 27 would subsequently be closed. 28
Each of the pond closure options were compared and contrasted, and were evaluated 29
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 6
based on their phasing, method of excavation and grading, dewatering, stormwater 1
removal, and material handling/processing and closure cap type. Storage and 2
transportation options were also evaluated and these items are addressed in Section 4 3
of the Report and in the testimony of Claire Schmit. 4
AECOM also evaluated the infrastructure required for a CbR option in which the CCR 5
material is transported via a pipe-conveyor from the Ash Pond to the Ohio River for 6
loading onto a barge and ultimate delivery to facilitate off-site beneficial reuse. That 7
portion of the Report is addressed in Claire Schmit’s testimony. 8
Bidding packages were prepared for each of the pond closure options (CiP, CbR with 9
Beneficial Reuse, and CiP with Future Removal to Onsite Landfill). A 60% of final level 10
of detail was provided in the designs that were included in the bidding packages. The 11
60% design drawings for the three options are provided in Appendices D, E and H of the 12
Report. Cost estimates (Class 3) were prepared for each of the closure options based 13
on an adjusted average of the bids received. Capital costs and lifecycle costs were 14
considered in the cost estimates. Cost estimate details are provided in Appendix B of the 15
Report. The development of the cost estimates is further described in Ms. Schmit’s 16
testimony. 17
A decision matrix was developed to weigh the relative advantages and disadvantages of 18
each of the closure options and to rank the closure options based on the assigned 19
criteria. This information is provided in Appendix P of the Report. 20
Q. Please describe the work performed by AECOM in order to prepare the Report. 21
A. AECOM began its work by development of a series of feasible and viable closure 22
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 7
options which conform to applicable engineering criteria and achieve compliance with 1
the CCR Rule and state requirements. As described within the CCR Rule, there are two 2
primary approaches for pond closure. The first of these is referred to as CbR and 3
involves excavation of the pond contents. The excavated materials are either 4
beneficially reused or disposed within an onsite or off-site landfill permitted to accept 5
these materials. The second option is referred to as CiP. This option generally involves 6
dewatering and grading of pond materials, followed by construction of an engineered 7
cap system over the limits of the pond to serve as a barrier against surface water 8
infiltration. 9
Following development of option concepts, various site constraints were defined, and 10
design and regulatory criteria were developed for and applied to each option. Each of 11
the options were developed and refined in a series of design iterations culminating in a 12
60-percent design level. 13
Q. Are there variations of these two closure options that produce additional 14
alternatives that were considered? 15
A. Yes. During the design process, an alternative analysis of components within each 16
option was conducted. The alternatives evaluation was subdivided into the following six 17
key components that form the basis of the analysis: Pond Closure, Excavation, 18
Dewatering, Handling, Processing and Storage. Each of these key components were 19
further analyzed based on multiple options within each component. As such, the 20
alternative evaluation was able to include an evaluation of multiple scenarios within each 21
of the key components. The following options were considered in the alternatives 22
analysis: 23
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 8
1. Pond Closure Options 1
a. Closure-in-Place (C-i-P) 2
b. Closure-by-Removal (C-b-R) 3
c. Partial Removal Option 1: 50% C-b-R / 50% C-i-P 4
d. Partial Removal Option 2: 75% C-b-R / 25% C-i-P 5
2. Excavation 6
a. Hydraulic Dredging 7
b. Drag Line 8
c. Conventional 9
3. Dewatering Options 10
a. Gravity Dewatering 11
b. Positive Dewatering 12
c. Combination of Gravity and Positive Dewatering 13
4. Handling Options 14
a. Trucking 15
b. Conveyor 16
5. Processing Options 17
a. Screening 18
b. Blending 19
c. Drying 20
6. Storage Options 21
a. Eurosilo 22
b. Dome Structure 23
24
Q. How were each of these options analyzed? 25
A. AECOM reviewed each of the options within these key components by using experience 26
based on similar prior projects (pond closure and infrastructure projects), by conducting 27
research specific to the various possible technologies and by discussing the potential 28
options with construction contractors and equipment vendors. In addition, AECOM 29
observed current CCR handling operations at the Brown Pond and the FGD Landfill to 30
obtain a better understanding of the site operations, existing contractor capabilities, site 31
restraints, etc. AECOM also observed CCR handling operations at ash ponds and CCR 32
landfills owned by other electric utilities to gain further insight into what might be the 33
most appropriate and effective CCR management methods for the Brown Pond. 34
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 9
Conceptual engineering designs were developed for each of the pond closure options. 1
They were each developed to approximately a 60% of final level of detail. To support 2
the conceptual engineering designs, the following activities were conducted: 3
- Field exploration and geotechnical testing of the CCR materials within the Brown Pond 4 to understand the material characteristics, including: moisture content, grain size, 5 moisture/density relationship, permeability and various strength parameters 6 (consolidation, shear, etc.). A Geotechnical Data Report (AECOM, December 2016) 7 was prepared to summarize the information gathered. 8
- Data obtained during the field exploration also assisted in the definition of the bottom of 9 ash elevation in various areas across the Brown Pond. This information was utilized to 10 support the CCR volume calculations. 11
- AECOM reviewed geotechnical data obtained by others (S&ME), based on reports 12 provided by Vectren. 13
- Geotechnical calculations to evaluate material settlement, dewatering, and slope 14 stability. 15
- Construction of a test pile in April 2017. The test pile was constructed by Blankenburger 16 Brothers, Inc. based on the Test Pile Plan developed by AECOM. The objective of the 17 test pile construction was to monitor the dewatering and drying of a mass of saturated 18 CCR excavated from the pond “at full scale”. Varying methods and efforts were 19 implemented to evaluate the drying of the materials. The CCR was regularly sampled 20 and tested for moisture content to develop an understanding of how drying of the 21 material occurs over time as the material is exposed to the elements. This work was 22 intended to emulate the excavation, drying and stacking operations that will be required 23 during the pond closure. A technical memorandum “Ash Test Pile Results and 24 Interpretation” (AECOM, July 31, 2017) was prepared by AECOM’s geotechnical team. 25
- Installation of a temporary dewatering system in January 2018. The dewatering system 26 was installed by MORETRENCH based on the plan developed by AECOM. 27
- Civil engineering calculations were conducted related to stormwater management 28 (including hydrologic and hydraulic modeling), material volume, excavation phasing, in-29 pond staging areas, excavation and conveyor loading demand, closure cap 30 configuration, geosynthetics design, closure cap soil-loss, erosion and sediment control, 31 among others. 32
33
The conceptual engineering designs, that were supported by the above engineering 34
activities, were utilized as a core component of the evaluation of each closure option and 35
served as the basis for the cost estimation. 36
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 10
Q. Where in the Report is this evaluation of each closure option considered? 1
A. Summary tables, criteria, and considerations associated with this evaluation are 2
provided in Appendix P of the Report. The outcome of this process is also discussed 3
within Section 3 of the Report. 4
Q. Does the Report include a summary that compares these options that were 5
considered? 6
A. Yes. This information is provided on the tables included within Appendix P. 7
Q. Based on the Report, has a closure approach been selected? 8
A. Yes. Vectren has elected to proceed with CbR with Beneficial Use to close the Ash 9
Pond. 10
Q. Please briefly describe the CbR with Beneficial Use alternative that has been 11
selected. 12
A. Six phases are proposed to remove CCR material in order to strategically stage the 13
removal of the CCR material from the Brown Ash Pond. 14
Free water will be removed prior to the start of each phase. CCR material will largely be 15
removed using conventional excavation techniques and equipment. However, as the 16
work progresses to lower elevations, hydraulic dredging and amphibious equipment will 17
be used to reach difficult-to-access areas. Excavated materials will be placed into 18
windrows which will be moved and worked as necessary to facilitate drying until the 19
desired moisture content has been achieved. The gravity dewatering system will be 20
used as long as possible before transitioning to positive dewatering options such as well 21
points and deep wells. 22
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 11
Stormwater will be controlled using a network of rim ditches and sumps. Ash-laden 1
stormwater will be prevented from entering clean closed areas and will be sent to a 2
treatment system. 3
Dewatered CCR material will be hauled to and stockpiled in a staging area within the 4
limits of the Ash Pond. The ash material will be transported from the staging area to the 5
barges on the Ohio River by means of the infrastructure (pipe conveyor, etc.) 6
constructed as part of this project. 7
Q. Will the public convenience and necessity be served by this CbR with Beneficial 8
Reuse approach for the Brown Ash Pond? 9
A. Yes. The selected option is the preferred alternative in terms of compliance, risk and 10
cost. The proposed CbR with Beneficial Reuse approach complies with the CCR Rule 11
and other applicable regulatory requirements (refer to Appendix O). The Report 12
compares and contrasts the multiple options based on both environmental 13
considerations/permitting and environmental risk considerations. Appendix P includes a 14
comparison matrix that identifies CbR as the option that has the lowest risk of requiring 15
future groundwater remediation due to source removal. 16
With respect to cost, there are a number of factors to be considered as discussed in Mr. 17
Games’ testimony. While the CiP options represent a lower estimated project cost, 18
these costs must be considered in context of overall risk and option acceptability. As 19
discussed in Ms. Retherford’s testimony, IDEM has yet to approve a CiP closure where 20
a portion of CCR remains in contact with groundwater as exists at the Brown Ash Pond. 21
Further, there are other cost risks with CiP involving potential for additional groundwater 22
remediation and future regulatory changes potentially requiring additional excavation 23
Petitioner’s Exhibit No. 3
JAY D. MOKOTOFF - 12
and disposal. For these reasons, source removal through CbR with Beneficial Reuse 1
provides the best approach for this site in terms of balancing upfront project cost, cost 2
certainty, and longer term risk. 3
Q. Does this conclude your direct testimony? 4
A. Yes, at this time. 5
DMS 14876620v1
Evaluation of Optionsfor Pond Closureat A.B. Brown Generating Stationas part of the Coal CombustionResidual Compliance Program
Prepared for:Vectren Corporation
January 23, 2018
Revision 2
Cause No. 45280Attachment JDM-1 (Public)
Page 1 of 114
Table of Contents
1. Introduction......................................................................................................................................... 5
Background and Site Description ........................................................................................................... 51.1
Summary of Work ................................................................................................................................. 61.2
Pond Closure and Ash Recycle Cost Estimate Summary ........................................................................ 81.3
2. Design Basis ..................................................................................................................................... 10
Civil Engineering Design Basis ............................................................................................................ 102.1
Closure in Place Design Basis ....................................................................................................102.1.1
Closure in Place with Future Removal and Onsite Landfill Disposal Design Basis.........................102.1.2
Closure by Removal for Beneficial Reuse Design Basis............................................................... 112.1.3
Ash Handling System Design Basis ..................................................................................................... 122.2
3. Closure Options ................................................................................................................................ 15
Closure in Place (CiP) ......................................................................................................................... 153.1
Phasing......................................................................................................................................153.1.1
Civil Grading ..............................................................................................................................163.1.2
Dewatering.................................................................................................................................163.1.3
Stormwater Removal ..................................................................................................................173.1.4
Closure ......................................................................................................................................173.1.5
CiP with Future Removal and Onsite Landfill Disposal .................................................................173.1.6
Cost Estimate Details .................................................................................................................183.1.7
Closure by Removal (CbR) for Beneficial Reuse .................................................................................. 193.2
Phasing......................................................................................................................................193.2.1
Excavation .................................................................................................................................223.2.2
Dewatering.................................................................................................................................223.2.3
Stormwater Removal ..................................................................................................................243.2.4
Processing .................................................................................................................................253.2.5
Decanting and Air Drying .................................................................................................... 253.2.5.1
Material Staging in the Conveyor Loading / Ash Staging Area .............................................. 263.2.5.2
Screening........................................................................................................................... 263.2.5.3
Cost Estimate Details .................................................................................................................273.2.6
4. Infrastructure to Support CbR for Beneficial Reuse......................................................................... 28
Material Storage and Final Processing................................................................................................. 284.1
Conveyor Loading / Ash Staging Area .........................................................................................284.1.1
In Pond Storage Structure ..........................................................................................................284.1.2
Material Handling .......................................................................................................................294.1.3
Ash Pond to Barge Loading ................................................................................................ 294.1.3.1
Reclaim Hopper and Stack Discharge Belt Feeder............................................................... 314.1.3.2
Pond Discharge Conveyor .................................................................................................. 324.1.3.3
Cost Estimate Details .................................................................................................................324.1.4
Material Transport ............................................................................................................................... 334.2
Wet and Dry Ash Barge Loading .................................................................................................334.2.1
Barge Loading.................................................................................................................... 344.2.1.1
Fugitive Dust Control .......................................................................................................... 354.2.1.2
Cost Estimate Details .................................................................................................................354.2.2
Electrical and Controls ........................................................................................................................ 364.3
2
Cause No. 45280Attachment JDM-1 (Public)
Page 2 of 114
Electrical Supply and Distribution ................................................................................................364.3.1
Electrical Supply................................................................................................................. 364.3.1.1
Electrical Distribution .......................................................................................................... 364.3.1.2
Electrical Design Activities ..........................................................................................................374.3.2
Instrumentation and Controls ......................................................................................................374.3.3
Cost Estimate Details .................................................................................................................384.3.4
Common Deliverables/Detailed Engineering ........................................................................................ 384.4
Work by Others ................................................................................................................................... 394.5
Assumptions ....................................................................................................................................... 394.6
Common ....................................................................................................................................394.6.1
Civil/Structural............................................................................................................................404.6.2
Electrical ....................................................................................................................................404.6.3
5. Schedule and Project Execution....................................................................................................... 41
Close-in Place Schedule ..................................................................................................................... 415.1
Landfill Schedule........................................................................................................................415.1.1
Closure-by-Removal Schedule ............................................................................................................ 415.2
Capital Upgrades Schedule ................................................................................................................. 415.3
– Site Location Map ................................................................................................................. 42Appendix A
– Estimate Details .................................................................................................................... 43Appendix B
– Design Basis Tables: Closure-in-Place and Closure-by-Removal........................................ 44Appendix C
– Ash Pond Closure in Place (60% Design Drawings)............................................................. 45Appendix D
– Ash Pond Closure in Place with Landfill (Design Drawings)................................................ 46Appendix E
– Landfill Location Restriction Map and Regulatory Location Restriction Criteria................. 47Appendix F
– Proposed Ash Removal Calculation (Volume & Time) for Phased Closure-by-Removal..... 48Appendix G
– Ash Pond Closure by Removal (60% Design Drawings) ...................................................... 49Appendix H
– Infrastructure Drawings and Sketches................................................................................... 50Appendix I
– Alternatives Evaluation and Drawings .................................................................................. 51Appendix J
– Electrical Load Lists and One-Line Diagrams ...................................................................... 52Appendix K
– Ash Recycle Level 1 Construction Schedules ...................................................................... 53Appendix L
– Ash Valuation Study ............................................................................................................. 54Appendix M
– Allowable Beneficial Reuse of Coal Combustion Residuals ................................................ 55Appendix N
– Environmental and Regulatory Considerations ................................................................... 56Appendix O
– Findings and Matrix of Options............................................................................................. 57Appendix P
– Ash Test Pile Results ............................................................................................................ 58Appendix Q
– AACE 18R-97 Reference Document...................................................................................... 59Appendix R
3
Cause No. 45280Attachment JDM-1 (Public)
Page 3 of 114
List of Tables
Table 1–1: Pond Closure and Ash Recycle Estimate Summary...........................................................................9
Table 2–1: Proposed Geocycle CCR Receiving Rates for 2018-2031................................................................ 11
Table 2–2: Ash Handling System Design Basis – Input Values..........................................................................12
Table 2–3: Ash Handling System Design Basis – Calculated Parameters ..........................................................13
Table 2–4: Economic Evaluation Assumptions .................................................................................................14
Table 3–1: Estimated Equipment Required throughout Duration of CCR Removal .............................................22
List of Figures
Figure 3.1 - Simplified Leachate Treatment Process Flow Diagram...................................................................18
Figure 4-1: Conveyor Loading/Ash Staging Conceptual Layout.........................................................................29
Figure 4–2: Subgrade Reclaim Hopper ............................................................................................................30
Figure 4–3: Pond Discharge Conveyor Transfer Station 1 ................................................................................30
Figure 4–4: Pond Discharge Conveyor Transfer Station 2 ................................................................................31
Figure 4–5: Barge Loading Modifications for Wet and Dry Ash Loading.............................................................34
List of Acronyms
CbR Closure by Removal .................................................................................................................... 5
CCR Coal Combustion Residual .......................................................................................................... 5
CiP Closure in Place .......................................................................................................................... 5
FGD Flue Gas Desulfurization ............................................................................................................. 5
AECOM AECOM Technical Services, Inc................................................................................................... 6
IAC Indiana Administrative Code ........................................................................................................ 9
Definitions
Process Moisture Content Weight of water divided by total weight of materials (solids + water)
% Moistureprocess = Ww / (Ws + Ww)
Geotechnical Moisture Content Weight of water divided by Weight of solids
% Moisturegeotechnical = Ww / Ws
4
Cause No. 45280Attachment JDM-1 (Public)
Page 4 of 114
1. Introduction
Background and Site Description1.1Vectren’s A. B. Brown Generating Station is a coal-fired power station located approximately 10 miles east of Mount
Vernon in Posey County, Indiana. The station is situated just west of the Vanderburgh-Posey County line and north of the
Ohio River, with the Ash Pond positioned on the east side of the generating station. A Site Location Map is included as
Appendix A. The station is owned and operated by Southern Indiana Gas & Electric Company, dba Vectren Power
Supply, Inc. (Vectren).
The A. B. Brown Ash Pond (Ash Pond) was commissioned in 1978. An earthen dam was constructed across an existing
valley to create the impoundment. This is currently referred to as the Lower Dam. In 2003, a second earthen dam
(currently referred to as the Upper Dam) was constructed northeast of the original dam, further up the valley to increase
the storage capacity within the impoundment. The addition of the second dam temporarily created the Upper Pond and
Lower Pond. The Upper and Lower Ponds were operated separately until 2016 when the Upper Dam was
decommissioned. The Upper Dam was constructed overtop ponded CCR materials and therefore the Upper and Lower
Ponds are hydraulically connected. In addition, a 10 foot wide breach was installed in the Upper Dam and the normal pool
elevation was lowered. Currently, the Upper Pond and the Lower Pond act as a single CCR unit referred to as the Ash
Pond, which has a combined surface area of approximately 164 acres.
The Lower Dam embankment is approximately 1,540 feet long, 30 feet high, and has 3H:1V (3 horizontal to 1 vertical)
side slopes covered with grassy vegetation. The embankment crest elevation is 450.9 feet and has a crest width of 20
feet. The operating elevation of the Lower Pond fluctuates from 439.0 feet to 444.0 feet. However, the pool normally
operates at an elevation of approximately 441.5 feet. The surface area of the Lower Pond is approximately 57 acres. The
surface area of the Upper Pond is approximately 107 acres and has a normal operating level of approximately 450 feet.
The Ash Pond impounds mixed CCR materials, consisting primarily of fly ash, with a lesser amount of bottom ash and
FGD scrubber by-product (calcium sulfite). In this Report, the terms “ash” and “CCR materials” are used interchangeably
to mean the mixed CCR materials currently impounded in the Ash Pond, and in certain specified cases, also includes the
2-feet of underlying native soil materials that may be impacted by CCRs.
Currently there are approximately 5.9 million cubic yards of CCR material within the Ash Pond, divided between the Lower
Pond (approximately 2.2 million cubic yards) and the Upper Pond (approximately 3.7 million cubic yards). This quantity
includes a 2-foot depth of over-excavation of the underlying soil materials across the entire Ash Pond footprint. To
determine the volume of CCR material present within the Ash Pond, current survey data was compared to pre-
development grades from 1975-1976 to obtain a volume of impounded CCR material. This volume represents an in-situ
volume of mostly saturated CCR materials (geotechnical moisture content range of 15% to 50%). Refer to “Definitions” in
this Report for definitions of “geotechnical” moisture content and “process” moisture content.
The CCR material described above is subject to regulation by Federal CCR Rule (40 CFR 257). As such, the Ash Pond
closure work must begin by 2024 for Vectren to be compliant with the CCR regulations.
The following aerial photo of the Ash Pond was taken November 2017.
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Summary of Work1.2The purpose of this Evaluation Report (Report) is to evaluate the potential cost and schedule for Ash Pond closure options
including closure in place (CiP) and closure by removal (CbR). These options were presented in Revision 0 of this report
submitted to Vectren on May 2, 2017.
In this updated revision of the Report, a sub-scenario of the CiP method was further evaluated whereby, at some point in
the future after the Ash Pond has been closed in place, Vectren would be required or would choose to remove the CCR
materials contained within the closed pond. In this case, a new onsite landfill would be constructed and the CCR
materials would be removed from the closed pond and disposed in the onsite landfill. The onsite landfill would
subsequently be closed.
AECOM also evaluated the infrastructure required for a CbR option in which the CCR material is transported off-site for
beneficial reuse. Vectren has discussed options for beneficial reuse of CCR material with Geocycle, a subsidiary of
LaFarge Holcim. Geocycle has the ability to beneficially reuse the CCR material as feedstock to their cement production
process.
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Several methods were evaluated for each closure option; this revision of the Report contains the details of the selected
methods only. Other options, not selected, were removed from the body of the Report and detailed in Appendix J.
This Report has been updated from the May 2, 2017 version to include an updated Class 3 cost estimate for each of the
closure options and associated selected methods to achieve closure. The estimates are based on construction and
equipment quotes received from qualified subcontractors and vendors.
The following process variations were evaluated as part of developing each of the pond closure and CCR materials
recycling options:
1) Pond Closure Options
a) Closure-in-Place (CiP) (standard and with Future Removal and Onsite Landfill Disposal)
i) Clay Liner
ii) Geo Liner
b) Closure-by-Removal (CbR) for Beneficial Reuse
2) Excavation Options
a) Hydraulic Dredging
b) Drag Line
c) Conventional
3) Dewatering Options
a) Gravity Dewatering
b) Positive Dewatering
c) Combination of Gravity and Positive Dewatering
4) Handling Options
a) Trucking
b) Conveyor
5) Material Processing Options
a) Screening
b) Blending
c) Drying
6) Storage Options
a) Eurosilo
b) Dome Structure
c) In-Pond Storage Structure
7) Transport Options
a) Barge Loading Wet Ash
b) Barge Loading Wet and Dry Ash
There are a number of key environmental and regulatory considerations associated with implementation of both the CbR
and CiP alternatives implemented under the provisions of the Federal CCR Rule (40 CFR 257). These contemplations are
included in Appendix O.
To fully assess the total cost impact of a CbR option, AECOM conducted a study to determine the market value of
reclaimed ponded ash. The purpose of this benchmark study was to 1) identify potential customers for the ABB ponded
ash in addition to Geocycle, 2) identify fossil plants in the US that are currently recycling ponded ash for beneficial reuse,
3) estimate the approximate market value of reclaimed ponded ash and 4) estimate the market demand in the future. This
study is included in Appendix M.
AECOM has developed a decision matrix in order to weigh the relative advantages and disadvantages of each ash
recycle option presented in the report. The decision matrix scores and ranks both non-monetary and monetary factors
using assigned weighting of importance factors. The matrix was not utilized for determining the selected methods but is
available for use in the future decisions related to this pond closure. The matrix is included in Appendix P.
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Pond Closure and Ash Recycle Cost Estimate 1.3
SummaryTable 1-1 provides a summary estimate for the two principal pond closure options: Closure in Place (CiP) and Closure by
Removal (CbR), and associated Ash Recycle options as defined in the Summary of Work section, above. The estimates
include engineering and project management services, procurement, construction and lifecycle costs. Capital costs,
including engineering and project management services, procurement and construction, are defined as distinct one-time
costs that occur prior to closure or non-operational items occurring during closure construction. Lifecycle costs are
defined as costs that occur during closure construction that are multi-phase or continuing costs necessary to carry-out or
manage the closure, as well as longer-term maintenance costs.
Costs to account for additional scope items after the finalization of the design and construction details have been included
in the “Remaining Design & Construction Details” column and are between 10-15% of the cost estimates, depending on
the certainty of the design. An industry average fee amount of 10% of the estimated costs has been included for
engineering and construction contractor(s) fees. The costs included are in 2017 dollars and have not been adjusted for
escalation. The estimates provided are Class 3 based on AACE RP no.18R-97 Standard, included in Appendix R.
Design basis and scope details for each of these closure options are provided in the following sections of this Report.
Additional cost estimate development details for each option are included in Appendix B – Cost Estimate Details.
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2. Design Basis
This section describes key assumptions as well as economic and design-related input parameters that were used to guide
the conceptual designs and associated cost estimation. Regulatory standards followed during the design process are
referenced as appropriate.
Civil Engineering Design Basis2.1The A.B. Brown Generating Station is currently scheduled to close in December 2023, with a new combined-cycle power
plant to be constructed in its place. Consequently, any pond closure or CCR material removal activities must be performed
around normal plant operations through 2023. Due to current operating condition requirements, the water surface
elevation in the Lower Pond must be maintained at 440 feet until the plant is closed.
Regulatory standards used as part of the design basis include the USEPA’s Final CCR Rule (CFR Part 257, published
October 19, 2015), Indiana’s Solid Waste Rules (329 IAC Article 10), and Indiana Surface Impoundment Closure
Guidance document. Regulatory aspects of this project are further discussed in Appendix O. The various technical
parameters used as part of the closure system design standards are provided in the Design Basis Tables: Closure-in-
Place and Closure-by-Removal located within Appendix C.
Closure in Place Design Basis2.1.1
Under the standard CiP scenario, the project will be complete once construction activities for the closure in place cover
system are finalized. The design basis for the standard CiP scenario was determined by minimizing the quantity of fill
material needed to achieve the final cover system grades while also trying to limit the amount of pond dewatering required
to safely construct the final cover system. It was also driven by stormwater management requirements including channels
over the final cover system to collect and convey runoff to the stormwater outfall. The channels enable a reduction in long-
term maintenance of the final cover system, by limiting settlement and erosion of the final cover system, while also
maintaining compliance with the CCR Rule and the “Surface Impoundment Closure Guidance” (Closure Guidance) from
the Indiana Department of Environmental Management (IDEM), Office of Land Quality.
Construction for a CiP option is estimated to take approximately 5 years (60 months) to complete. A start date of January
1, 2024 has been assumed for this study based on the A.B. Brown Station close date discussed above. The Ash Pond
CiP Design Drawings are provided in Appendix D.
Closure in Place with Future Removal and Onsite Landfill 2.1.2Disposal Design Basis
As discussed in the Summary of Work section, an additional sub-scenario was developed in this revision of the Report for
the CiP option. The additional sub-scenario entails the future removal of the CCR materials from the closed Ash Pond and
disposal in a future developed onsite landfill. The proposed location of the new landfill is to the north of the ABB Station
and north of the existing FGD Landfill on property owned by Vectren. The design basis for the proposed onsite landfill
complies with the Indiana Solid Waste Land Disposal Regulations (329 IAC 10), specifically those sections applicable to
non-municipal solid waste landfills, as well as compliance with the USEPA CCR Rule 40CFR 257.60. Location restrictions
for the proposed landfill location were compared against the IDEM Rule 25 criteria (329 IAC 10-25) and those identified in
the CCR Rule. Multiple sources of publicly available data were brought together to prepare a location restriction map to
compare the proposed landfill location to the various location restriction criteria provided. The landfill location restriction
map, along with summary tables applicable to the regulatory location restriction criteria, are provided in Appendix F.
The design of the landfill cells and closure system was developed in accordance with both the IDEM and CCR Rule
requirements. While there are numerous requirements applicable to the design of new CCR landfills, the key elements of
the design basis include the following:
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1) The footprint of the landfill within the proposed limits of waste was estimated as 75 acres. The footprint was
developed to dispose approximately 5.0 million cubic yards (“dry” volume) based on the estimated volume of CCR
materials that will exist within the CiP Ash Pond (including the removal of 2-feet of subgrade below the existing CCR
material.
2) A buffer of 5-feet between the base of the landfill liner system and the uppermost groundwater aquifer. The
groundwater data used as the basis for this comparison includes the following information provided by Vectren:
“Groundwater Flow Map – Inglefield Sandstone Member” prepared by ATC on May 22, 2017 and the “Groundwater
Monitoring Location for Compliance – Figure 3” prepared by Haley & Aldrich in February 2016.
3) Evaluation of existing subsurface conditions, including soil classification and depth to bedrock based on soil borings
conducted by Patriot Engineering in February 2016.
The Onsite CCR Landfill Design Drawings are provided in Appendix E.
Closure by Removal for Beneficial Reuse Design Basis2.1.3
Table 2–1: Proposed Geocycle CCR Receiving Rates for 2018-2031
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AECOM utilized these projected material receiving rates, along with various measured material properties, as a basis to
calculate the estimated CCR material removal time for each of the CbR excavation phases. A table summarizing these
calculations (“Proposed Ash Removal Calculation (Volume & Time) for Phased Closure-by-Removal”) is included in
Appendix G. Geocycle has also indicated that the CCR material must meet certain other material properties in order to be
used in their process. Specifically, the particle diameter must be less than 0.75 inches and the process moisture content
must be at or less than 18%. Material testing conducted by AECOM has indicated that the CCR material must be
processed in order to meet these criteria.
In theory, the material processing, transportation and storage infrastructure should be constructed prior to commencement
of the CCR material removal process. However, Vectren may elect to excavate, dry and stockpile the CCR materials
onsite in advance of infrastructure completion. Once the upgrades to the barge-loading system are installed and
commissioned, it will then be possible to truck CCR material directly to the existing dry fly ash silo area for transportation
onto the barge. This system would provide a temporary solution until the remaining infrastructure is completed. While the
trucking will likely result in additional material handling costs, it is a possible scenario for consideration to allow for an
earlier start of the dewatering and excavation activities. For purposes of this Report, we have assumed that the CCR
removal activities will begin in July 1, 2018. The Ash Pond CbR Design Drawings are provided in Appendix H.
Ash Handling System Design Basis2.2The ash handing system includes all equipment associated with moving recycled pond ash from the pond to the barges.
This includes handling, transport, storage and loading in barges. The system design basis will support the proposed
Geocycle schedule to remove all ponded ash within 13 years. Input values used in the evaluation are summarized in
Table 2-2. Calculated parameters based on these inputs are listed in Table 2-3. Table 2-4 provides the assumptions used
as part of the economic evaluation.
Table 2–2: Ash Handling System Design Basis – Input Values
Input Parameters: Unit Value Comments
Pond ash, wet in the pond Tons 8,000,000
Value determined based on
pond size and current
production rate
Pond ash reclaim production rate, wet cy/day 1,500 - 3,000
Pond ash average water content in pond, avg. wt% 33 Range 14 - 43% (water/ total)
Pond ash moisture content to barge, avg. wt% 18 (water/total weight)
Pond ash moisture content to barge, min wt% 15 (water/total weight)
Pond ash moisture content to barge, max (Design) wt% 25 (water/total weight)
Density of dewatered ash (capacity) lb/ft3 95
Density of dewatered ash (loading) lb/ft3 120
Schedule duration to remove all ponded ash years 10
Planned working days in pond area per year days/year 250 5 days/week, 50 weeks/year
Days lost to weather & equipment shutdown days/year 25
Pond ash removal work day, maximum duration hours 10Crews working during
daylight hours only
Pond ash transfer conveyor op. capacity % 80 Intermittent ash loading
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Input Parameters: Unit Value Comments
Barge loading conveyor design capacity (existing) Tph 700 Existing conveyor capacity
Barge loading system op. capacity – wet ash % 80
Barge loading system op. capacity - dry ash % 50Current operation, limited due
to dusting
Barge loading dock efficiency % 80Positioning barges during
loadout.
Barges loaded per day, maximum # 2
Design Dry fly ash production
(AB Brown ash production through 2024)Tpy 200,000
AB Brown, Culley and
Warwick fly ash.
Ash storage capacity new storage, wet Tons 9,500
Truck capacity (off road/on road) Tons30 Pond 15
Road
Off road trucks used only in
pond.
Barge capacity Tons 1,800
Rail Car Capacity Tons 120 Vectren jumbo rail car
Table 2–3: Ash Handling System Design Basis – Calculated Parameters
Calculated Values: Unit Value Comments
Pond Ash Handling
Ponded ash, dry tons 5,360,000 (dry ash weight)
Ponded ash to barge, wet tons 7,146,667 (max. moisture, 25%)
Pond ash processed tph 318
Truckloads to conveyor, 30 ton loads trucks/hour 11
Pond ash conveyor design capacity tph 397 New pond ash conveyors
Wet Ash Barge Loading
Barge loads of ash in storage # 5
Barge loading rate, average tph 560Maximum barge loading capacity is
700 tph
Loading time per barge for pond ash hours 4Includes barge positioning and dock
efficiency.
Pond ash loaded in barges daily tpd 2,552
This is the minimum amount of ash
that will have to be barged. The
barges will leave the plant full.
Pond ash loaded in barges weekly tpw 12,762 5 days/week.
Number of barges of pond ash loaded - 1.4
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Calculated Values: Unit Value Comments
per day
Number of barges of pond ash loaded
per week- 7
Number of barges of pond ash loaded
per year- 319
Dry Ash Barge Loading
Barge loading rate for dry ash tph 350 Reduced loadout rate due to dusting.
Loading time per barge for dry ash hours 6
Number of barges of dry ash per day # 0.5
Number of barges of dry ash per week # 2 - 3
Number of barges of dry ash per year # 111
Barge Loading Dock Design Requirements
Design barge loading capacity tph 700Design capacity of existing barge
loading system.
Barge loading time per day hours 6 - 12Will take 6 hours for one barge 12
hours for two.
Barges loaded per day # 1 - 2
This is the barges required to
transport both dry and wet ash.Barges per week # 7 - 8
Barges per year # 431
Table 2–4: Economic Evaluation Assumptions
Economic Evaluation Assumptions Unit Value Notes
Electrical cost $/kWh 0.05
Diesel fuel $/gal 3.50
LaborLoaded
Rates
Foreman $/hr 70.00
Operation & Maintenance $/hr 55.00
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3. Closure Options
The details for the two principal closure options, Closure in Place (CiP) and Closure by Removal (CbR) for Beneficial
Reuse are presented in this section. Two partial removal alternatives (for contingency planning purposes) were evaluated
as part of this study: Partial Closure Alternative #1 (50% CbR / 50% CiP) and Partial Closure Alternative #2 (75% CbR /
25% CiP). The partial removal options further serve to represent the 50% and 75% interim phases of the complete
Closure by Removal option. These details have been included in Appendix J in this revision of the Report.
In development of the closure options, several different alternatives for excavation and dewatering were evaluated with
the objective of determining the most feasible, appropriate, and cost-effective method for ash removal. All alternatives for
excavation and dewatering for the two principal closure alternatives, CiP and CbR, are presented in Appendix J in this
revision of the Report. Only the excavation and dewatering options deemed most viable for the project are discussed in
this section. The selected closure methods are described below.
Closure in Place (CiP)3.1The CiP evaluation includes the excavation and regrading of approximately 3 million cubic yards of CCR material within
the Ash Pond, which will allow for the positive drainage of stormwater and ultimately the construction of a final cover
system including a stormwater management ditch system and outfall. This CCR material regrading, final cover system
installation, and stormwater management ditch system and outfall installation will allow the approximately 5.9 million cubic
yards of CCR material to be closed within the limits of the Ash Pond. Closure and lifecycle costs associated with the CiP
are presented at the end of this section.
Phasing3.1.1
The CiP option considers three phases of construction. These phases are described in detail below:
Phase 1 (CiP) – Free water removal and CCR Dewatering
Following Plant closure in December 2023, Phase 1 begins with the removal of free water from the Upper Pond, via
gravity flow through temporary stormwater ditches and/or pumping systems, and discharged to the Lower Pond. Free
water will concurrently be removed from the Lower Pond, which will be pumped to a future defined treatment system. After
Plant closure, it is understood that water treatment will likely be required; however, based on discussions with Vectren, it is
assumed that the costs for treatment will be borne by the future combined-cycle plant. Once free water has been
removed, the phreatic surface will be lowered by the excavation of the final cover system ditches (primary ditches) and
any secondary ditches. These ditches are needed to promote pore water drainage (passive dewatering) to the lower pond
area/primary stormwater basin. A positive dewatering system (well points) will also be utilized concurrently with the
passive dewatering system in the areas of the deepest excavation to further lower the phreatic surface. A temporary
phreatic surface monitoring system will also be installed as excavation proceeds, as the phreatic surface must remain
approximately 10 feet, but no less than 5 feet, below the working surface. Phase 1 will also include the necessary clearing
and filling outside of the Ash Pond limits to achieve the designed final cover grading.
Phase 2 (CiP) - Excavation and Regrading
Phase 2 includes the excavation and regrading of approximately 1.26 million cubic yards of CCR material within the ash
pond, which includes portions of the upper dam. This regrading, or placement of CCR material fill, will first occur in the far
reaching ash pond “fingers” as needed, and then continued within the main area of the ash pond. At this point, the
phreatic surface dissipation will need to be verified prior to the beginning of the cover system construction. If the phreatic
surface has not reached an acceptable depth, then construction of the cover system will need to be delayed. Once those
acceptable depths are reached, the cover system can begin to be installed, once again starting in the far reaching ash
pond “fingers” and continuing within the main area of the ash pond. A secondary stormwater basin will then be
constructed southeast of the primary stormwater basin, so that the lower pond area/primary stormwater basin can be
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dewatered, the CCR material can be regraded, and the cover system can be installed. At this point the lower dam can be
partially removed and the stormwater outfall can be constructed.
Phase 3 (CiP) – Completion and Restoration
Phase 3 continues with the secondary stormwater basin being removed and dewatered. The CCR material can then be
regraded, and the cover system can be installed which finishes the cover system installation. This will then be followed by
the construction of the access road crossing the ash pond and the associated culverts and stormwater energy dissipation
structures. Final restoration can then begin to occur for areas disturbed during construction, with contractor mobilization
occurring once the site is sufficiently stabilized.
Civil Grading3.1.2
The overall limits of the ash pond will remain unchanged, with the lower dam being partially removed and fill being placed
outside of the ash pond limits to promote positive drainage over the final cover system. The partial removal of the lower
dam includes lowering the crest of the dam approximately 30 feet to minimize the amount of dewatering that is required as
well as to minimize the amount of borrow soil that is needed to safely achieve final cover grades. The upper dam will also
be removed, as necessary, to achieve final CCR material grades and final cover grades.
The shape of the CCR material surface within the ash pond will be modified/regraded to provide an inverted grading plan
with slopes ranging from 2% to 8% along with a series of stormwater ditches with a minimum slope of 1% to convey runoff
to the Ohio River via an unnamed tributary. This regrading of the CCR material surface will require approximately 1.26
million cubic yards of CCR material to be excavated and placed throughout the ash pond as fill to minimize the amount of
borrow soil fill required.
The final cover system will then be placed directly on top of the modified/regraded CCR material surface. This is
discussed in Section 3.1.5 Closure.
Dewatering 3.1.3
Free water removal, followed immediately by a gravity dewatering system installed at the same time as a positive
dewatering system, and operated concurrently for the duration of the project, was established to be the most effective
dewatering alternative. The free water will be removed from Pools C2, C1, B, and A, as well as the Lower Pond, in order
to allow water to begin to seep from the ponded CCR material and to allow installation of the gravity and passive
dewatering systems.
The gravity dewatering system will consist of a network of excavated ditches that will be installed only in areas of the ash
pond where permanent cuts below the current phreatic surface (which is located between El. 450 and 455 feet) will be
implemented. The ditches will drain by gravity from northeast to southwest to a sump within the lower pond/primary
stormwater basin. Seepage collecting in the sump will be continuously pumped out. The system of dewatering ditches will
also intercept and collect surface water drainage and route it to the sump.
The positive dewatering system will be installed in areas of deep excavation (15 feet or more below existing grades) and
will consist of a network of closely spaced well points, installed in lines and discharging to trunk lines (header piping).
Dewatering of the CCR material will be achieved by creating positive suction at the well points and then pumping the
water removed through the header piping. Detailed design of the positive system should be by the specialty contractor
that will install and operate it. A full-scale pilot test (conducted ahead of the installation of the system) could help to
facilitate and optimize its design.
The gravity dewatering system, an analysis to determine the rate of dewatering was conducted using SEEP/W software.
Based on the analysis, the excavated ditches will be spaced at intervals of 300 feet apart, which was based on a balance
of achieving a reduction in the phreatic surface as quickly as possible while maintaining enough distance between the
ditches to allow access for conventional excavating equipment. The SEEP/W model results indicate that the diches
constructed at the spacing indicated will be able to reduce the phreatic surface in their vicinity to the targeted elevation
within 6 to 9 months of construction.
SEEP/W results also indicated that the maximum seepage flow from the rim ditch and sump network will be very small in
relation to anticipated stormwater flows.
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Stormwater Removal 3.1.4
During closure-in-place of the CCR materials, stormwater will initially collect within the existing pools C2, C1, B, and A, as
well as the Lower Pond. A series of ditches and pumps will promote drainage from Pool C2 through Pools C1, B, and A,
and ultimately to the Lower Pond. During the dewatering process, the CCR material fill placement process, which is within
the northern “fingers” of the Upper Pond, and the final cover system installation process (Phase 1 and the beginning of
Phase 2), the excavated ditch network associated with the gravity dewatering system, which will ultimately become the
final cover stormwater channel system, will direct stormwater from the Upper Pond to the Lower Pond area/primary
stormwater basin. Once the final cover system is installed over the northern “fingers” as well as the main area of the
Upper Ash Pond, the secondary stormwater basin, the Lower Pond area/primary stormwater basin final cover system, and
the stormwater outfall will be constructed. This will allow stormwater that is not draining to the secondary stormwater basin
to be discharged through the stormwater outfall since it will no longer be considered contact stormwater. Once the final
cover system is installed over the area draining to the secondary stormwater basin, indicating removal of the secondary
stormwater basin, stormwater will be fully managed within the final cover stormwater ditch system and discharged through
the stormwater outfall.
Closure3.1.5
The final cover system for the CiP alternative will comply with 329 IAC 10-30-2 as well as the Final CCR Rule. The final
cover system area is approximately 164 acres, and is designed to promote positive drainage, minimize surface water
infiltration, support vegetation, and provide an aesthetically acceptable final surface. Fill materials will additionally be
placed outside of the Ash Pond limits to promote positive drainage over the final cover system.
The Final Cover System consists of the following components, from top to bottom:
1) 6-inch Topsoil or Amended Cover Soil
2) 24-inch Final Cover System Soil
3) Geocomposite Drainage Layer
4) Textured 40-mil LLDPE Geomembrane
CiP with Future Removal and Onsite Landfill Disposal 3.1.6
In order to best understand the potential financial and regulatory risks to the CiP alternative, Vectren requested that a
separate sub-scenario of the CiP method be evaluated whereby, at some point in the future after the Ash Pond has been
closed in place, Vectren would be required or would choose to remove and dispose the CCR materials contained within
the closed pond. In this scenario, a new onsite landfill would be constructed and the CCR materials would be removed
from the proposed future CiP Ash Pond, staged as necessary, and hauled to the newly constructed landfill for disposal.
Following the operation of the CCR landfill for the duration necessary to dispose of the approximately 5.0 million cubic
yards of “dry” CCR materials, a closure system would be constructed over the completed landfill. Finally, the remaining
valley in the area of the prior Ash Pond would be restored.
The footprint of the landfill within the proposed limits of waste was estimated as 75 acres, based on the estimated volume
of CCR materials that will exist within the CiP Ash Pond (including the removal of 2-feet of subgrade below the existing
CCR material). The floor and side slope liner system configuration for the CCR landfill consists of the following
components, from bottom to top:
1) Subgrade layer2) Compacted clay layer (permeability, Kv ≤ 1x10
-7cm/sec)
3) 60 mil textured HDPE geomembrane4) Geocomposite leachate collection layer
5) Leachate drainage layer (12-inches sand)
The final cover system configuration for the CCR landfill consists of the following components, from top to bottom:
1) 30-inch final cover system soil layer (vegetated top 6-inch Topsoil/Amended Cover Soil Layer and bottom 24-inch Infiltration Soil Layer)
2) Geocomposite subsurface drainage layer
3) 40 mil textured LLDPE geomembrane
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Leachate will be temporarily stored in a dual walled flakeglass resin-lined tank and treated through an onsite leachate
treatment facility prior to its discharge to either the future combined-cycle power plant or via a revised NPDES discharge
permit. The proposed treatment concept for the leachate stream involves the initial reduction of total suspended solids
(TSS), followed by chemical iron co-precipitation of the target metals followed use of a sorbent media to target additional
selenium (selenate) reduction as needed. Co-precipitation is a commonly used process that consists of pH adjustment
and rapid mixing with coagulant addition (ferric chloride or ferric sulfate), flocculation (polymer addition), and clarification
using a lamella clarifier. Final cleanup of the treated water is accomplished via additional filtration. Solids produced in the
TSS removal, chemical precipitation, and filtration steps will be dewatered and disposed. The selenium adsorbent media
will also require periodic removal for disposal and/or regeneration. Removal of arsenic, selenium (selenite), and other
target metals is achieved via iron-co-precipitation using an oxidant (e.g. potassium permanganate), ferric chloride or ferric
sulfate, and polymer addition. Mercury removal, if required, is accomplished using organo-sulfide addition. Acid or
caustic reagents are also required for pH adjustment in the process.
Figure 3.1 - Simplified Leachate Treatment Process Flow Diagram
The total area required for the WWT system is estimated at 75’ X 200’ (15,000 sq ft). Given the climate at the AB Brown,
a heated building enclosure will be required. Power requirements for the 200 gpm process rate are estimated to be 70 KW
equivalents. Typical staffing requirement for this type of WWT facility, if not fully automated, is 24/7 for two personnel. If
fully automated, the system can run unattended during off-hours and weekends shifts, with base level staffing of 10 to 12
hours per day Monday through Friday, and part-time coverage on the weekends.
Stormwater will be managed utilizing Best Management Practices (BMPs), including a combination of swales, berms, and
erosion control materials (e.g., wattles, erosion control blankets, etc.) to reduce the effects of long slopes and help slow,
filter, and spread overland flows. A sedimentation basin and associated discharge structure will be constructed to manage
stormwater during construction and landfill operation.
Cost Estimate Details3.1.7
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Closure by Removal (CbR) for Beneficial Reuse3.2CbR for beneficial reuse consists of the removal of approximately 5.9 million cubic yards of CCR material from within the
Ash Pond, including the removal of 2-feet of subgrade below the existing CCR materials. The CbR evaluation considers
six phases of CCR material removal to achieve full removal. The Ash Pond CbR Design Drawings are included in
Appendix H.
Closure and lifecycle costs associated with the CbR are presented at the end of this section.
Phasing3.2.1
The CbR for beneficial reuse considers six phases of CCR material removal. These phases are described below.
Phase I (CbR) – CCR removal – 450 feet Upper Pond
Phase I includes removal of CCR material to elevation 450.0 feet within the Upper Pond, as shown on the Ash Pond CbR
Design Drawings (attached in Appendix H). Upon completion of Phase I, 1.5 million cubic yards (25% by volume) of the
ponded CCR material will have been removed and 4.4 million cubic yards of CCR material will remain. For the purposes
of this evaluation, it has been assumed that Phase I will begin in July 2018 and end in approximately March 2023.
CCR material removal will begin in the portion of the Upper Pond that is currently above the water line. CCR material will
be removed using conventional excavation equipment and placed into windrows for drying. Windrows will be moved and
worked as necessary to facilitate drying until CCR material has achieved the desired moisture content. CCR material
removal will occur at varying locations within the Upper Pond throughout the duration of this phase. As a result, windrows
and stockpiles will likely have to be relocated as necessary within the footprint of the Upper Pond. Excavation methods
are discussed in more detail in Section 3.2.2. As part of the Phase I excavation activities, CCR materials that currently
exist in the approximately 3-acre area proposed for the Conveyor Loading / Ash Staging Area will be removed and
temporarily relocated into the Upper Pond. The area will then be regraded to an approximate slope of 2% to facilitate
surface water and pore water drainage back into the Upper Pond. The CCR material will be hauled to and stockpiled at
the Conveyor Loading / Ash Staging Area, the design of which is discussed in Section 3.2.5.
Prior to CCR material removal, all free water will be removed from the pools (Pools A, B and C) around the edge of the
Upper Pond and pumped or otherwise conveyed to the Lower Pond. Ditches will be constructed connecting the pools
around the edge of the Upper Pond with an outfall placed in Pool A. These ditches will be progressively excavated during
CCR material removal to an approximate water surface elevation of 440 feet to drain pore water from the CCR material.
Dewatering is discussed in more detail in Section 3.2.3.
Stormwater will be controlled throughout the phase using the network of rim ditches and sumps. Pumps or siphons will be
used to move stormwater through the various pools and then to remove stormwater from sumps to the Lower Pond.
Stormwater removal is discussed in more detail in Section 3.2.4.
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Phase II (CbR) – CCR Removal 445 feet Upper Pond
Phase II includes removal of CCR material to elevation 445.0 feet within the Upper Pond, as shown in the Ash Pond CbR
Design Drawings (Appendix H). Upon completion of Phase II, 1.9 million cubic yards (33%) of the site’s ponded CCR
material will have been removed and 4.0 million cubic yards of CCR material will remain. Phase II will begin in
approximately March 2023 and end in approximately December 2023.
The majority of CCR material removal in this phase will be conducted using conventional excavating equipment. Based on
the estimated CCR material removal rates, the station will still be active when Phase II begins. Consequently, the water
surface elevation in the Lower Pond must still be maintained at an elevation of 440.0 feet. As a result, gravity dewatering
will decrease in effectiveness in areas closer to the Lower Pond, potentially causing CCR material removal difficulties in
areas of the Upper Pond that are farther away from gravity dewatering features. Subsequently, it may be necessary to use
pontoon-mounted excavation equipment in addition to conventional excavators. CCR material removal in Phase II will
occur throughout the reduced footprint of the Upper Pond. Excavating methods for this phase are described in more detail
in Section 3.2.2.
As in Phase I, wet CCR material removed from the excavation will be placed in windrows, which will be moved and
worked as necessary to facilitate drying until CCR material has achieved the desired moisture content. Windrows and
stockpiles may be relocated as necessary within the footprint of the Upper Pond. The CCR material will be hauled to and
stockpiled in the Conveyor Loading / Ash Staging Area as discussed in Section 3.2.5.
Dewatering in Phase II is likely to expand upon the dewatering efforts completed in Phase I. The pools will be mucked out,
relieving pore water pressure within the Upper Pond. Dewatering methods for this phase are described in more detail in
Section 3.2.3.
Stormwater will continue to be controlled throughout the phase using the network of rim ditches and sumps. Pumps or
siphons will be used to move stormwater through the various pools and then to move stormwater to the Lower Pond as
necessary. Stormwater removal methods for this phase are described in more detail in Section 3.2.4.
Phase III (CbR) – CCR Removal 445 feet – Lower Pond
Phase III consists of removal of CCR material in the Lower Pond above elevation 445.0 feet, as shown in the Ash Pond
CbR Design Drawings (Appendix H). Upon completion of Phase III, 2.4 million cubic yards (40%) of the site’s ponded
CCR material will have been removed and 3.5 million cubic yards of CCR material will remain. Phase III will begin in
approximately December 2023 and end in approximately October 2024. The staging of Phase III and Phase IV can be
interchanged, depending upon progress of dewatering in the Upper and Lower Ponds.
CCR material will be removed from the Lower Pond using conventional excavating equipment and placed into windrows
for drying. Windrows will be moved and worked as necessary to facilitate drying until CCR material has achieved the
desired moisture content. The CCR material will be hauled to and stockpiled in the Conveyor Loading / Ash Staging Area
in a manner similar to previous phases. CCR material removal will occur at varying locations within the Lower Pond
throughout the duration of the phase. As a result, windrows, staging areas, and stockpiles will likely have to be relocated
as necessary within the footprint of the Lower Pond. Excavation methods for this phase are discussed in more detail in
Section 3.2.2.
Dewatering for Phase III will begin with free water removal from the Lower Pond. Dewatering for this phase is described in
more detail in Section 3.2.3.
As in previous phases, stormwater will continue to be controlled using a network of rim ditches and sumps. However,
since the Lower Pond will no longer be in service, it is likely that a stormwater treatment system will be required in order to
discharge stormwater offsite. Again, pumps or siphons will be used to move stormwater through the various pools.
Stormwater removal methods for this phase are described in more detail in Section 3.2.34.
Phase IV (CbR) – CCR Removal Upper Pond Fingers - 427 feet (50% Removal Stage)
Phase IV consists of CCR material removal in the “fingers” area of the Upper Pond above elevation 427.0 feet as shown
in the Ash Pond CbR Design Drawings. Upon completion of Phase IV, 2.9 million cubic yards (50%) of the site’s ponded
CCR material will have been removed and 3.0 million cubic yards of CCR material will remain. Phase IV will begin in
approximately October 2024 and end in approximately September 2025, but may begin earlier depending on progress of
dewatering in the Upper and Lower Ponds.
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The elevation of the CCR material removed during Phase IV will be much lower than what was encountered in Phases I to
III. Consequently, it is expected that a gravity dewatering system alone will not be sufficient to remove the pore water from
within the CCR material. Accordingly, we expect the dewatering system to consist of a combination of gravity and positive
dewatering. The positive dewatering system will likely consist of both well points and deep wells. Dewatering methods for
this phase are described more in Section 3.2.3.
The majority of CCR material removed in this phase will be completed using conventional excavation equipment. CCR
material will be removed using conventional excavating equipment and placed into windrows for drying. Windrows will be
moved and worked as necessary to facilitate drying until CCR material has achieved the desired moisture content. The
CCR material will be hauled to and stockpiled in the Conveyor Loading / Ash Staging Area in a manner similar to previous
phases.
Stormwater will continue to be controlled throughout the phase using the network of rim ditches and sumps used to drain
pore water and will be pumped to the Lower Pond as necessary. Stormwater removal methods for this phase are
described in more detail in Section 3.2.4.
Phase V (CbR) – CCR Removal – Both Ponds - 432 feet (75% Removal Stage)
Phase V, consists of removal of CCR material to elevation 432.0 feet in both the Upper and Lower Ponds, as shown in the
Ash Pond CbR Design Drawings. The dam between the Upper and Lower Ponds will be removed during this phase. Upon
completion of Phase V, 4.4 million cubic yards (75%) of the site’s ponded CCR material will have been removed. 1.5
million cubic yards of CCR material will remain. Phase V will begin in September 2025 and end in approximately July
2028. CCR material removal during Phase V will be conducted primarily using conventional excavation equipment, with
hydraulic dredging and amphibious equipment used as necessary to reach difficult-to-access areas. As in previous
phases, the CCR material will be removed using conventional excavating equipment and placed into windrows for drying.
Windrows will be moved and worked as necessary to facilitate drying until the CCR material has achieved the desired
moisture content. The CCR material will be hauled to and stockpiled in the Conveyor Loading / Ash Staging Area in a
manner similar to previous phases.
CCR material removal will occur at varying locations within the Upper and Lower Ponds throughout the duration of the
phase. As a result, windrows, staging areas, and stockpiles will likely have to be relocated as necessary within the
footprint of the Upper Pond. Excavation methods are discussed in more detail in Section 3.2.2.
Dewatering during Phase V will be conducted using a combination of gravity and positive dewatering methods.
Dewatering for Phase V is discussed in more detail in Section 3.2.3.
Stormwater will be controlled throughout the phase using the network of rim ditches and sumps. Pumps will be used to
move stormwater through the various pools and then to sumps throughout the Upper and Lower Ponds. Ash-laden
stormwater will be prevented from entering clean closed areas and will be sent to a treatment system. Stormwater
removal for Phase V is discussed in more detail in Section 3.2.4.
Phase VI (CbR) – Final CCR Removal – both Ponds (100% Removal Stage)
The final phase of closure by removal, Phase VI, consists of full removal of CCR material to 2 feet below native grades in
both the Upper and Lower Ponds, as shown in the Ash Pond CbR Design Drawings. Upon completion of Phase VI, all 5.9
million cubic yards (100%) of the site’s ponded CCR material will have been removed across the entire footprint of the Ash
Pond.
As in Phase V, CCR material removal during Phase VI will continue to be conducted primarily using conventional
excavation equipment, with hydraulic dredging and amphibious equipment used as necessary to reach difficult-to-access
areas. As in previous phases, the CCR material will be removed using conventional excavating equipment and placed into
windrows for drying. Windrows will be moved and worked as necessary to facilitate drying until the CCR material has
achieved the desired moisture content. The CCR material will be hauled to and stockpiled in the Conveyor Loading / Ash
Staging Area in a manner similar to previous phases. CCR material removal will occur at varying locations within the
Upper and Lower Ponds throughout the duration of the phase. As a result, windrows, staging areas, and stockpiles will
likely have to be relocated as necessary within the footprint of the Upper Pond. Excavation methods are discussed in
more detail in Section 3.2.2.
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Dewatering during Phase VI will be conducted using a combination of gravity and positive dewatering methods. Where
possible, the network of ditches and sumps will be expanded and graded to drain to a proposed sump at the toe of the
existing Lower Pond dam embankment.
Stormwater will be controlled throughout the phase using the network of rim ditches and sumps used to drain pore water.
Pumps will remove stormwater from sumps throughout the Upper and Lower Ponds, sending it to a treatment system.
Stormwater removal for Phase VI is discussed in more detail in Section 3.2.4.
The post-excavation standard for Closure-by-Removal activities is discussed in Appendix O. Upon completion of the CbR
activities and regulatory confirmation of “clean closure” (if required), the resulting excavated surface will be regraded to
provide positive surface drainage, minimize potential erosion and future maintenance. The entire disturbed area will be, to
the extent possible, restored to the original condition of the valley prior to the construction of the Ash Pond. Restoration of
the original valley will include placement of topsoil and permanent vegetative stabilization.
Excavation 3.2.2
Multiple excavation methods were evaluated to remove the CCR material from the Ash Pond. Each method’s
effectiveness and feasibility was examined and is discussed in Appendix J. Conventional excavation was determined to
be the best option due to its relatively low costs and high production rates. Furthermore, based on the rate at which
Geocycle will take ash, sufficient CCR material is available at the higher elevations (approximately El. 460-feet down to El.
445-feet) that can be gravity drained.
If necessary, amphibious long-reach pontoon excavators can be used where the subgrade is not stable enough to allow
access for standard equipment. Hydraulic dredging will also be used in areas where dewatering may be difficult or time
consuming in conjunction with conventional equipment in order to achieve production goals. The anticipated conventional
excavating equipment would include:
1) Medium size excavators (approximately 3 to 4 cubic yard bucket size, e.g., John Deere 350G excavator or
equivalent): Used to excavate CCR materials directly from the pond.
2) Dozers (medium size, e.g., Caterpillar D6N or equivalent): Used mostly to process CCR materials for drying by
creating and moving windrows.
3) Articulated trucks (40 cubic yard capacity, e.g., Volvo A40D or equivalent): Used mostly to transport CCR materials
excavated by excavator to processing areas.
4) Front end loaders: Used to load screener and move CCR materials as necessary.
The number of equipment used in excavation will increase as Geocycle’s demand increases. Estimated numbers of
equipment needed in each phase are shown in Table 3-1.
Table 3–1: Estimated Equipment Required throughout Duration of CCR Removal
Equipment Name Phases I-III Phases IV-VI
Medium excavator 1 2
Medium dozer 1 1
Articulated truck 2-3 3
Front end loader 1 1
Dewatering 3.2.3
Dewatering of the ponded CCR material materials will be an important component of the closure system. Dewatering will
condition the CCR materials to facilitate mass excavations and will also be required to appropriately improve and maintain
the Ash Pond surface’s ability to support the heavy construction equipment necessary to excavate and haul material to
implement the closure activities.
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When in a saturated condition and in the presence of a permanent phreatic surface, fly ash and bottom ash materials are
inherently unstable, have very low bearing capacity, and are subject to localized liquefaction when subject to vibrations
induced by construction equipment. Therefore, it will be of paramount importance to maintain the pond phreatic surface
below the elevation on which construction equipment will operate. Construction vibrations have a tendency to wick water
upward through the ash mass via capillary action. The phreatic surface must be maintained with a sufficient vertical
distance underneath the ground surface to mitigate this effect. As such, the primary objective of the dewatering system
will be to lower and maintain the pond phreatic surface at any work area to 5-10 feet below the current surface grade in
any area of work, at any time, so that a safe and stable working surface is established.
Dewatering will inherently remove interstitial water and reduce the water content of the ash mass, which will improve its
handling characteristics. This will make the subsequent process of excavation more efficient and will reduce the time and
effort required to condition the excavated material to the target water content.
Multiple dewatering methods were evaluated including gravity dewatering, active dewatering and a combined system of
passive and active dewatering. Each method’s effectiveness and feasibility was examined and is discussed in Appendix J.
A combined system of gravity with positive dewatering was found to be the best overall option. Installation and operation
of the passive system can be implemented with typical construction equipment and practices and is therefore anticipated
to be substantially less costly relative to the positive system. It is therefore beneficial to mobilize the gravity system early
on and to utilize it for as long as possible, before initiating the positive system. While the Lower Pond remains in
operation, the maximum drawdown that can be achieved by the passive system will be limited to the normal operating
pool level of the Lower Pond (El. 440 feet +/-), since that pond will continuously feed the phreatic surface at that level.
Therefore, the passive system can facilitate excavations down to about El. 445. This corresponds to Phases I, II, and III of
the proposed sequence for CbR, which will occur between 2018 and 2024.
To begin the dewatering process, the free water will be removed from Pools C2, C1, B, and A in order to allow water to
begin to seep from the ponded CCR material. Rim ditches will be constructed in Phase I to allow gravity dewatering of
CCR material to the lowest extent possible. Water that collects in existing pools C2, C1, B, and A as well as the sump and
rim ditch network will be pumped to the Lower Pond.
During Phase II, gravity dewatering will continue to be used exclusively. The rim ditches constructed during Phase I will be
deepened to continue lowering the phreatic surface within the Upper Pond. Material in the pools will also be mucked out
to lower the phreatic surface in these areas.
Dewatering for Phase III will begin with free water removal from the Lower Pond. After free water removal is complete, rim
ditches and sumps will be constructed within the Lower Pond to continue lowering the phreatic surface through gravity
dewatering.
After completion of Phase III, dewatering for Phase IV will continue using gravity dewatering, but gravity dewatering will
likely have to be supplemented with positive dewatering. The positive dewatering system should be installed in the Phase
IV excavation area (north and northeast area of the Upper Pond) and put into operation some months prior to the end of
Phase III. Wellpoints may be required to lower the phreatic surface enough for stable work conditions prior to the end of
Phase III. The positive system, likely including both wellpoint and deep well systems, will then be utilized for the balance
of the CbR operation (through the end of Phase VI). It is anticipated that in construction practice, the positive system will
be installed and operated in relatively large but limited footprint areas, ahead of when excavations are to actively take
place at that area – i.e., the entire system will not be constructed all at once across the pond, rather, the system will be
constructed in increments, operated, and then moved/reinstalled in the same sequence as the excavations. This will allow
the project to take advantage of any natural drawdown of the phreatic surface that can be realized once the Lower Pond is
drained, and will allow for tailoring of the positive system based on actual performance.
An important component of the dewatering system will be implementation of a phreatic surface monitoring program, to
verify that the systems are performing as intended. The system should be installed at the beginning of the project and be
maintained throughout all excavation activities, as follows:
1) The monitoring system should consist of a number of vibrating wire piezometers or conventional standpipe
piezometers (or a combination of both), installed on a regular grid throughout the excavation footprint.
2) Specifically, the piezometers should be installed at spacing/locations such that there is not less than 1 piezometer per
3 acres of footprint, and such that piezometers are located uniformly across the footprint. The piezometers will be
located in the bays that are in between the dewatering ditches or well point lines.
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3) The piezometers should be configured to be capable of detecting the depth of the static phreatic surface at the
location of the piezometer and shall be adjusted as necessary as the excavation proceeds.
4) The piezometers should be monitored on a regular basis to confirm that the phreatic surface is drawn down to the
appropriate level at any time. It is anticipated that the frequency of monitoring will be high (monitoring events several
times per week) early on during operation of the dewatering systems when drawdown is actively occurring, and then
less (weekly to bi-weekly) once the systems’ performance has been proven and the drawdown is being maintained.
Stormwater Removal 3.2.4
During removal of CCR material, stormwater in the Upper Pond will collect within existing pools C2, C1, B, and A. Rim
ditches used for dewatering CCR material will also direct stormwater from the center of the pond to the pools at the
edges. After a rain event, stormwater will drain throughout the ditch network, with remaining stormwater pumped from
Pools C2 to C1, C1 to B, and B to A. Stormwater will then be pumped from Pool A to the Lower Pond.
During Phases I and II, pumps will activate between the pools as described above and a single 2,000 gpm pump will be
the main pump to pump all stormwater from Pool A in the Upper Pond to the Lower Pond. This main 2,000 gpm pump is
sufficiently sized to maintain stormwater runoff below the working elevation within the Upper Pond for smaller storm
events. It is expected that storm events greater than the 5-year recurrence interval will require additional pumps to prevent
stormwater runoff from impacting CCR material removal in the Upper Pond. During these first two phases, the Lower
Pond will still be receiving plant flows, and will continue to utilize the existing pumphouse to recycle water back to the
plant and use the existing stormwater bypass routing if necessary.
During Phase III, the same 2,000 gpm pump is proposed to discharge stormwater from Pool A in the Upper Pond to the
Lower Pond. As with the previous two phases, it is expected that storm events greater than the 5-year recurrence interval
will require additional pumps to prevent stormwater runoff from excessive ponding in the Upper Pond. The Lower Pond
water surface elevation will be lowered to provide additional stormwater storage within the pond and to prevent larger
storm events from impacting CCR material removal in the Lower Pond. The existing pump could be utilized, although set
to operate at a lower elevation, to achieve the stormwater goals necessary to allow continued CCR material removal in
the Lower Pond.
During Phase IV, two (2) main discharge pumps are proposed in the Upper Pond. During this phase, the Upper Pond will
be separated into two areas that will collect stormwater. The upper portion of the Upper Pond will be clean closed, and
one (1) 1,200 gpm pump is proposed to pump clean stormwater to Pool A in the lower portion of the Upper Pond. A 2,000
gpm pump in Pool A will pump all stormwater from the Upper Pond to the Lower Pond. As in the other phases, it is
expected that additional pumps will be required to maintain stormwater control during storm events exceeding the 5-year
recurrence interval storm. These additional pumps will allow CCR material removal work to continue without stormwater
interference.
During Phase V, a cutoff ditch will be constructed between the working area within the Upper Pond and the clean closed
“fingers” area of the Upper Pond to prevent CCR-impacted stormwater from flowing into the clean closed area. A
stormwater sump will be installed in the “fingers” area of the Upper Pond to pump clean stormwater to the NPDES outfall.
One (1) 2,000 gpm pump is sufficient to handle smaller storm events. For storm events with greater than a 5-year
recurrence interval, additional pumps will be required to keep clean stormwater from entering the working CCR material
removal area of the Upper Pond.
During Phase VI, a stormwater sump will be installed near the toe of the existing Lower Pond dam embankment to pump
clean stormwater over the embankment to the NPDES outfall. Two (2) 2,000 gpm pumps will be sufficient to handle
smaller storm events. For storm events with greater than a 5-year recurrence interval, additional pumps will be required to
avoid excessive ponding within the clean closure area. A network of ditches sloped at a minimum of 0.5% will be installed
for the final condition within the pond. A conceptual illustration of this network is shown in the Ash Pond CbR Design
Drawings included in Appendix H.
Water from the dewatering ditches will also be diverted into the stormwater sumps. However, the flows required by the
dewatering system are expected to be much smaller than the flows required for the stormwater removal system. The
combined pump size to manage both dewatering and stormwater flows will be 2,200 gpm.
The main pumps proposed are expected to control stormwater runoff efficiently within the ponds by maintaining water
surface elevations a few feet below the proposed CCR material removal excavation elevation, up to the 5-year recurrence
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interval storm event, minimizing stormwater impacts on the proposed CCR material removal work that could cause delays
to the project.
For larger storm events, it will be imperative for on-site personnel to monitor water elevations within the pond. It is
expected that additional or larger pumps will be required to prevent impacts to CCR material removal work during those
storm events. It is not considered cost effective to keep large stormwater removal pumps onsite throughout the duration of
the project. It would be more cost effective to rent these pumps during the events that exceed the 5-year event or
whenever more effective stormwater removal is desired.
The main pumps described in this section could utilize a 6- to 10-inch discharge pipe depending on the manufacturer
recommendation for each pump(s) chosen. After plant closure, treatment of CCR-impacted stormwater will be required
prior to its discharge through an NPDES outfall.
A network of ditches sloped at a minimum of 0.5% will be installed for the final condition within the pond. A conceptual
illustration of this network is shown on the Overall Grading Plan in the Ash Pond CbR Design Drawings within Appendix H.
Processing 3.2.5
As stated in Section 2.1.3, Geocycle has indicated that the CCR material must meet certain material properties to be used
in their process. Specifically, the maximum particle diameter must be less than 0.75 inches and the maximum process
moisture content must be less than 18%. Based on the results of the CCR material testing conducted by AECOM, it was
concluded that the ponded CCR material must be processed to meet these criteria.
This subsection discusses the CCR material processing methods to be implemented directly at the Ash Pond itself,
including decanting and air drying, material staging, and screening. The evaluation of proposed processing methods to be
performed after transporting wet CCR materials from the Ash Pond, including drying in a rotary dryer or blending with new
dry fly ash, are discussed in Appendix J in this revision of the Report. These drying methods were not considered to be
feasible for use directly at the Ash Pond. The following subsections discuss the decanting and air drying, material staging
and material screening methods that were deemed the most feasible and effective.
As excavations increase in depth, the CCR material removed will likely continue to increase in water content. The use of
the dewatering methods, as discussed in Section 3.2.3, will be paramount in the contractor’s ability to effectively manage
the CCR material removal process. Material with very high water content will require decanting prior to processing the
material into windrows for additional drying. It is likely that air drying times for removed CCR material will increase as work
progresses by phase. As CCR material is removed from the “fingers” area of the Upper Pond to native ground, care must
be taken to stage the material appropriately to avoid contamination of clean areas.
Decanting and Air Drying 3.2.5.1
The extent of decanting and drying of the CCR materials that will be required depends on the effectiveness of the
contractor at implementing their dewatering plan, weather conditions and material-specific properties, among other
considerations. AECOM developed an Ash Drying/Dewatering Test Pile Plan (“Work Plan”) and supported the
implementation of this Work Plan to gain an improved understanding of how the specific mix of CCR materials from this
Ash Pond will be behave with respect to decanting and drying. AECOM worked with Vectren’s contractor Blankenberger
Brothers, Inc. (BBI) who performed the work between late March and early May 2017. BBI constructed access roads and
pads, excavated approximately 700 CY of saturated CCR materials from the Ash Pond in the area east of the former
Upper Dam embankment, and then formed the excavated materials into two separate stockpiles that were configured
differently. Vectren sampled and tested the moisture content of the stockpiled CCR materials on a regular basis. The Work
Plan (AECOM, March 2, 2017) and a memorandum titled “Ash Test Pile Results and Interpretation” (AECOM, July 31,
2017) are provided in Appendix Q. The results of this testing were used to develop the methodology recommended in this
section with regards to the decanting and air drying of the CCR materials.
Upon excavation, and to the extent necessary, wet ponded CCR materials will be temporarily placed adjacent to the
excavation area to allow for initial decanting of water and to allow any free water (if present) to run off of the material.
When the material is sufficiently dry to be “worked”, medium dozers (e.g., a Caterpillar D6N) will shape the CCR materials
into windrows to allow air drying. The maximum height of windrows should be approximately 10 feet, with maximum
1H:1V side slopes. In consultation with subject matter experts, these approximate dimensions were determined to be the
most effective to allow efficient drying and ease of working with equipment. Throughout the course of the drying process,
these windrows will be worked with dozers several times to allow uniform drying of CCR material throughout the windrow.
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It is also expected that the drying time required in the summer will be substantially less than what is required in the winter.
Subject matter experts have indicated CCR material drying time may be four times longer in the winter relative to the
summer.
Material windrowing or drying areas will be situated differently depending on the progress of the phase of excavation.
Since drying will occur within the footprints of the Upper and Lower Ponds, it will be necessary to occasionally move or
expand these areas to allow excavation and processing of CCR materials to proceed to deeper elevations or new areas.
The CCR material drying areas will also need to be coordinated with the various elements of the gravity and/or active
dewatering systems. A minimum size of approximately 3 acres has been estimated to allow for drying of approximately
one week’s ash production. This minimum size will likely be sufficient during the summer months as CCR material dries
faster due to the longer hours and warmer temperatures. However, the minimum size may have to be increased in the
winter months due to the need for increased drying times. Windrows should be spaced adequately within this area to
enable equipment to maneuver. Furthermore, the drying areas must be sloped such that water will drain from the wet
CCR materials in a planned fashion towards sumps or other collection areas. A conceptual detail of this area is provided
in the Ash Pond CbR Design Drawings.
It is anticipated that the majority of the windrowing and drying will be conducted prior to hauling material to the “Conveyor
Loading / Ash Staging Area” located within the northwestern perimeter of the Upper Pond (refer to Ash Pond CbR Design
Drawings). In certain situations; however, the contractor may think it advantageous to only decant the material in the pond
area adjacent to the excavation followed by hauling the material closer to or within the Conveyor Loading / Ash Staging
Area for further processing. The Conveyor Loading / Ash Staging Area is discussed in the next subsection.
Material Staging in the Conveyor Loading / Ash Staging Area3.2.5.2
The Conveyor Loading / Ash Staging Area will be one of the first elements to be constructed, since it will be used from the
beginning of the excavation phases as an area to stage and screen the CCR material prior to its load out onto the
conveyor. During operation of excavation Phases I through V, it is anticipated that the area will be located in the north
western perimeter of the Upper Pond (refer to Ash Pond CbR Design Drawings). However, during operation of the final
excavation Phase VI, it may be advantageous to relocate this area closer to the Lower Pond. Sufficient quantities of CCR
materials will be relocated into the Conveyor Loading / Ash Staging Area based on the demand rate of the CCR material.
The dried CCR material will be staged in this area for additional air drying (as necessary) and screening followed by
conveyor loading. It is estimated that an approximate area of 3-acres will be required to provide sufficient room for
material staging and conveyor loading. A description of the Conveyor Loading / Ash Staging Area and the associated In
Pond Storage Structure is provided in Section 4.1 of this Report.
Screening 3.2.5.3
The CCR materials will be passed through a screener. Screening will serve to remove any larger particles that may be
present within the CCR material as well as debris that may have accumulated in the pond over time. Scalping and
standard screeners were considered as part of the screening evaluation. Scalping screeners are intended to remove large
oversized objects from the material being processed, while standard screeners have finer screening processes that are
able to produce uniform finished product. Since the majority (~90%) of the CCR materials within the pond are expected to
pass through a standard #4 sieve, use of a separate standard screener to finely classify material is likely unnecessary.
Subject matter experts have recommended a McCloskey R230 scalping screener (or equivalent) as a system capable of
removing large debris while producing an acceptable product to meet Geocycle’s stated requirements.
An important consideration in the screening process is the moisture content of the material being screened. Wetter
material may slow down the rate of screening to approximately 1,500 tons per day, which is significantly slower than the
optimum estimated rate of 5,000 tons per day possible during dry conditions. As the rate at which Geocycle takes CCR
material increases, it may be necessary to use an additional screener, not included in the estimate, to meet required
production rates.
Following the screening of the CCR material, a final material stockpile will be managed using a front end loader to load
the conveyor. The conveyor system will transport the CCR material from the final material stockpile to the barge-loading
site on the Ohio River.
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Cost Estimate Details3.2.6
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4. Infrastructure to Support CbR for Beneficial Reuse
Once the excavated CCR material has been dried to the target moisture content, sufficient quantities of CCR materials will
be relocated to the Conveyor Loading / Ash Staging Area based on the demand rate of the CCR material. The Conveyor
Loading / Ash Staging Area will include an In Pond Storage Structure for final processing of the material prior to conveyor
transport to the barge loading system.
Material Storage and Final Processing4.1A covered storage structure, referred to herein as the In Pond Storage Structure, will be located within the Conveyor
Loading / Ash Staging Area. The In Pond Storage Structure will be utilized to store the processed CCR material prior to
conveyor transport to the barge loading system. In addition to the In Pond Storage Structure, the following two options
were also considered: (1) a concrete storage dome and (2) a Eurosilo storage silo. Both these storage options were
located in the Dry Fly Ash (DFA) area, adjacent to the existing barge loading conveyor. These options are discussed in
detail in Appendix J in this revision of the Report.
Conveyor Loading / Ash Staging Area4.1.1
The excavation and preparation of the area proposed for the Conveyor Loading / Ash Staging Area was previously
discussed in Section 3.2.5.2. Based on AECOM’s and Vectren’s interpretation of the CCR Rule, to temporarily stage the
CCR materials in this area for ultimate beneficial reuse, the area must be “containerized” in order to not be considered a
CCR Pile (and by definition, a CCR landfill). The term “containerized” refers to the placement of CCR material on an
impervious base while managing leachate and stormwater runoff from this area. Therefore, a floor on grade will be
constructed to form an impermeable barrier between the CCR materials in the Conveyor Loading / Ash Staging Area and
the underlying subsurface. The floor will consist of the following (from bottom to top): compacted subgrade, flexible
membrane liner, 6 inches of sand, and 18 inches of aggregate. The elevation of the floor on grade will be approximately
equal to the surrounding area of the Ash Pond to allow effective entry and exit of vehicles and operating equipment. The
recommended configuration of the Conveyor Loading / Ash Staging Area is shown in Figure 4-1.
In Pond Storage Structure4.1.2
The In Pond Storage Structure will be located within the 1.6 acre Conveyor Loading / Ash Staging Area. The purpose of
the In Pond Storage Structure is to provide protection to the CCR materials and associated operating equipment against
precipitation and other exterior elements, as well as to reduce the potential for fugitive dust emissions. The In Pond
Storage Structure will consist of a framed fabric storage structure constructed overtop the floor on grade that was
discussed in the previous subsection. The structure will include the following:
1) Clear span interior with sufficient length, width and height to support efficient operations. Approximate dimensions
are 170-ft x 400-ft as shown in Figure 4-1 with a minimum eave height of 25 feet at the wall.
2) Reinforced concrete foundation around perimeter of structure. The construction of the foundation will be coordinated
with the construction of the floor on grade.
3) Knee-wall or Jersey barriers around perimeter of building to protect the structure from damage by operating
equipment
4) Field office with a nominal size of 12 feet by 12 feet. The office will include HVAC, but not plumbing. Temporary
restroom facilities will be used and will be located adjacent to the In Pond Storage Structure.
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Figure 4-1: Conveyor Loading/Ash Staging Conceptual Layout
Material Handling 4.1.3
Multiple options were considered to transport CCR material from the pond to the barges or rail cars for loading. Options
included installing a new conveyor system or trucking the material to storage in the DFA area and then loading it on the
existing barge loading system. These options are detailed in Appendix J in this revision to the Report.
The most technically feasible and lowest cost option is installation of a new pipe conveyor to take dried and screened
CCR material from the pond directly to the existing barge loading conveyor.
Ash Pond to Barge Loading4.1.3.1
The conveyor run from the Upper Ash Pond to the existing barge loading conveyor is approximately 5,600 feet with an
overall decrease in elevation of 85 feet. Excavated, dried and screened CCR material within the In Pond Storage
Structure at the Conveyor Loading / Ash Staging Area will be pushed into a subgrade ash reclaim hopper using dozers or
large capacity pay loaders. A typical elevation and plan view of the reclaim hopper and conveyor are shown in Figure 4-2.
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Figure 4–2: Subgrade Reclaim Hopper
The Stack Discharge Belt Feeder will take CCR material from the hopper to the Transfer Station 1 where it will be fed to
the Pond Discharge Conveyor. A typical elevation and plan view of the transfer station and conveyor is shown in Figure
4-3.
Figure 4–3: Pond Discharge Conveyor Transfer Station 1
From the transfer station, ash will be conveyed 5,600 feet to the discharge location at the existing barge loading pipe
conveyor. The initial routing includes nominal 15’ clearance at roadway crossings. A plan view of the conveyor route is
located in Appendix I. The conveyor will discharge to the existing Barge Pipe Conveyor at transfer station 2. A typical plan
view of the transfer station, conveyor and belt take-up are shown in Figure 4-4.
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Figure 4–4: Pond Discharge Conveyor Transfer Station 2
The following interlocks will be included in the control logic to ensure that the belt feeder only operates with a discharge
path in service:
1) Stack Discharge Belt Feeder will not start unless Pond Discharge Conveyor is running.
2) Pond Discharge Conveyor will not start unless the Barge Loading Pipe Conveyor is running.
The following sub-sections summarize the equipment and key components included in the estimated cost:
Reclaim Hopper and Stack Discharge Belt Feeder 4.1.3.2
The Reclaim Hopper and Stack Discharge Belt Feeder collect material from the storage area and transfer it to the new
pipe conveyor system. The Reclaim Hopper and Stack Discharge Belt Feeder systems will be provided with:
1) Grizzly and reclaim hopper with a nominal capacity of 1,000 ft2. Hopper is constructed of mild steel with an abrasion
resistant steel liner.
2) One trough-belt conveyor with a design capacity of 700 tph and nominal belt width of 30 inches. A vertical belt take-up will be located adjacent to Transfer Station 1.
3) Instrumentation required to control and safely operate the equipment including: emergency pull cord switches (both sides), warning horns, belt misalignment switches, belt rip switch, zero speed switch, and local push button stations. Field instruments will be wired back to the PLC located in the Ash Pond Area electrical building.
4) The reclaim hopper pit will be located in the subgrade pit. A 6’Wx 6’Lx 6’H runoff collection sump will be located in the base of the pit to collect any water draining into this area. The sump will include a 50 gpm submersible pump and HDPE piping to discharge collected water back to the ash pond.
5) Transfer station complete with a lined chute, access steel and working beam located above the conveyor drive section.
6) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be located close to the existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near the belt feeder.
c) The belt feeder will be provided with a 50 HP VFD motor.
d) Wiring between the local junction box and belt feeder components will be completed by the construction contractor performing the work.
7) A technical and performance specification package will be developed and issued to the belt feeder vendor for the equipment and ancillary equipment.
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8) The contractor performing the construction scope of work will receive, unload, and install the equipment. Assembly
will be monitored by the equipment vendor. Design will include drawings and technical specifications for installing the
system components.
Pond Discharge Conveyor 4.1.3.3
1) The new Pond Discharge Conveyor will transfer solids from the storage area to the Barge Loading Pipe Conveyor. The new pipe conveyor system will be provided with:
2) The pipe conveyor is 12 inches in diameter, approximately 5,600 feet long with belt speed is up to 500 fpm. Belt speed can be adjusted by the operator with a VFD drive.
3) A 10’ wide gravel road along both sides of the pipe conveyor route is included in the estimate for maintenance access. Walkways are included at the head and discharge of the pipe conveyor.
4) Structural and mechanical modification of the existing 16 inch Barge Loading Pipe Conveyor for the new transfer point is included. An evaluation of the Barge Loading Pipe Conveyor will be performed during the detailed design phase.
5) Modifications that may be required of the mechanical components including guides, forming idlers and impact idlers have not been fully evaluated. Foundations for the conveyor are included in the estimate.
6) Transfer station complete with a lined chute, access steel and working beam for hoist. Modification of the barge loading pipe conveyor structure for the new loads is included.
7) The transfer station will include a runoff collection sump collect and retain water that has been in contact with the CCR material. The estimate includes the following:
a) 6’Wx 6’Lx 6’H concrete sump with a 50 gpm submersible pump
b) Nominal 5,000 gallon containment tank.
c) Local control panel transferred collected water to tanker truck for disposal.
8) Instrumentation required to control and safely operate the equipment including: emergency pull cord switches (both sides), warning horns, belt misalignment switches, belt rip switch, zero speed switch, and for control and local push button stations. Instruments will be wired back to the closest PLC in the Ash Pond area or Dry Fly Ash loading area.
9) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be located close to the existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near the conveyor.
c) The conveyor will be provided with three (3) 150 HP motor(s). Two at the head and one at the tail.
d) Wiring between the local junction box and conveyor components will be completed by the construction contractor performing the work.
10) A 10’ wide gravel road along both sides of the pipe conveyor route is included in the estimate for maintenance access.
11) Walkways are included at the head and discharge of the pipe conveyor.
12) A technical and performance specification package will be developed and issued to the conveyor vendor for the equipment and ancillary equipment.
13) The contractor performing the construction scope of work will receive, unload, and install the equipment. Assembly will be monitored by the equipment vendor. Design will include drawings and technical specifications for installing the system components.
Cost Estimate Details4.1.4
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Material Transport 4.2The existing Barge Loading Pipe Conveyor will transport CCR material to the barge loadout system. The design will be
reviewed for the new operating conditions related to handling recycled ash. The mass of material handled will not increase
relative to current operations, and based on information from the conveyor Vendors, it is expected the Barge Loading Pipe
Conveyor can handle the new material with the proposed upgrades at the DFA transfer station. An allotment has been
included in the estimate for the upgrade scope.
Two options were considered for the ash loading system; loading wet ash only and a system to load wet or dry ash. The
wet only option is described in Appendix J in this revision of the Report.
Wet and Dry Ash Barge Loading4.2.1
The existing barge loading system is designed to handle and load only dry ash. In the existing system, the pipe conveyor
discharges ash into a 3 ton surge bin. From the surge bin, a rotary valve meters the ash onto a series of air-slide
conveyors and on to an extendable loadout chute. The existing system includes dust collection for the conveyors and
loading spout. It also includes a portable bin vent filter to collect fugitive dust that accumulates in the barge headspace
during loading.
Fugitive dust emissions during barge loading are an on-going concern. The barges used to transport dry fly ash were
designed to transport grain and coarse materials. As a result, the barge covers do not fit tightly and fugitive dust emissions
limit the loadout rate. Currently barges are loading at approximately 350 tph, about 50% of system design capacity.
Loading dry fly ash requires 6 – 8 hours when this operation could be completed in under 4 hours if dust emissions were
not a limitation. To increase the dry fly ash loading rate to facilitate the loading of CCR material in addition to fly ash,
modification of the dry loading system to control fugitive dust emissions is required.
Previous work by Vectren indicates that significant venting of the barge headspace is required when loading dry fly ash.
Based in a survey of barges, the venting requirement is 50,000 cfm to maintain a negative draft and reduce fugitive dust
emissions to a manageable level. A preliminary design for this venting system has been developed by others and been
included the Appendix I drawings that include upgrade of the barge loading system.
To load both wet and dry ash, several modifications of the Barge Loading system are required. First the 3 ton surge bin
will be replaced with a chute. The transfer and slewing air-slide conveyors will be replaced with fully enclosed transfer
belt conveyors. A drag chain conveyor will be used to collect material that spills from the conveyor and return it to the
transfer conveyor. The slew and extendable chute are new, but similar in concept to current design. A diagram of the
proposed modifications is shown in Figure 4-5.
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Figure 4–5: Barge Loading Modifications for Wet and Dry Ash Loading
Modification of the foundation supporting the barge loading structure is included in the estimated scope. These
modifications are required to support the additional wet/dry equipment loads and address the settlement of the foundation.
The modifications include new deep foundations and structural steel to reduce the loading on the existing river cell.
The following modifications will be provided:
Barge Loading 4.2.1.1
1) Demolish the existing 3 ton surge bin and associated structural supports.
2) Demolish the existing transfer air slide conveyor, slewing air slide conveyor and extendable loadout chute.
3) One interconnecting chute between the Barge Loading Pipe Conveyor discharge and the intermediate transfer belt conveyor.
4) One intermediate transfer belt conveyor. Transfer conveyor is fully enclosed with hood and side seal plates. Conveyor includes a drag chain (scavenging conveyor) to collect dribble and reintroduce it with the feed.
5) One slewing belt conveyor. Slewing conveyor is fully enclosed with hood and side seal plates. Conveyor includes a drag chain (scavenging conveyor) to collect dribble and reintroduce it with the feed.
6) One slewing system to support new slewing belt conveyor.
7) Strengthening of the top pivot bearing housing to support the new slewing belt conveyor guying rope.
8) One telescoping loadout Spout replacing the existing spout.
9) One bag filter system, 120 cfm
10) Modification of structural steel bracing for the new components.
11) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in the new electrical building that will be located on the new dust collector platform barge .
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near the barge loading system.
c) The Transfer Belt Feeder will be provided with a 15 HP motor.
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d) The Transfer Belt Feeder drag conveyor will be provided with a 2 HP motor.
e) The Slewing Belt Conveyor will be provided with a 15 HP motor.
f) The Slewing Belt Conveyor drag conveyors will be provided with a 3 HP motor.
g) Wiring between the local junction box and components on the belt feeder is completed by the construction
contractor performing the work.
12) Barge loading cell modifications
a) Installation of a system of piles, both vertical and battered, capped by a structural steel framing grid. This will be used to support the barge tower column loads currently supported by the river cell.
b) Piles will be driven from a barge located in the river.
Fugitive Dust Control4.2.1.2
The fugitive dust management system includes a new dust collector and canopy with side walls to reduce dust emissions.
1) New platform with steel grating to support the new dust collector and baghouse
2) Baghouse Dust Collector
a) Pulse jet baghouse dust collector, 50,000 cfm capacity, 26’(L) x 12’ (W) x 39’ (H)
b) Total filter area 12,600 ft2, 3.94:1 A/C, 646 polyester felt bags
c) Vent fan, 50,000 CFM, 200 HP
d) Housing, 10 gauge carbon steel, painted, +/- 20 in. w.c.
e) Ash collection hopper and pneumatic conveying system
f) Vent air discharge stack
3) Compressor and Dryer
a) 50 cfm compressor, air dryer and receiver tank, 25 HP
4) Snorkel and Ductwork
a) Snorkel arm for venting barge head space during loading
b) Ductwork from snorkel to baghouse, 48” carbon steel, painted
5) Barge Canopy
a) Barge canopy will be provided per drawings in Appendix I
Cost Estimate Details4.2.2
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Electrical and Controls4.3Electrical distribution and controls will be located in each of the three areas: (1) Conveyor Loading/Ash Staging Area, (2)
DFA Unloading Area and (3) Barge Loading Area. The scope included for each area is summarized in the following sub-
sections.
Electrical Supply and Distribution 4.3.1
The CCR material handling and loading system requires new electrical supply and distribution. A new 12470V
transmission line feed is required for the DFA Unloading and Barge Loading Areas. In the Conveyor Loading/Ash Staging
Area, a new 4160V feed will be supplied from the AB Brown plant.
As part of the upgrade scope, new electrical feeds will be provided to the existing MCC that supplies the DFA unloading
system and the MCC that supplies the Barge Loading system. These systems are fed from a plant supply that is currently
under-sized for the service. The new electrical feeds were sized to include power supply to two new fly ash truck blowers
in the DFA Unloading Area. In the Barge Loading Area, new loads associated with the fugitive dust collector system and
the new wet/dry ash loading equipment will be supplied from a new MCC line-up. The existing MCC will be fed from the
new MCC as well. In summary, the new 12470V electrical feed will remove all loads in the DFA Unloading Area and
Barge Loading Area from the existing plant supply. The electrical load list and one line diagrams are located in Appendix
K. Full details of the electrical supply scope are provided below.
Electrical Supply4.3.1.1
1) Electrical Supply - Conveyor Loading / Ash Staging Areaa) Medium voltage 4160V feed from existing field electrical cabinet located to the south of the Conveyor Loading /
Ash Staging Area. Switch cabinet is powered from the AB Brown plant.
2) Electrical Supply – Dry Fly Ash and Barge Loading Area
a) This new 12470V supply will require extension of the Ford Road circuit and upgrades to the transmission and distribution infrastructure. A budget proposal was provided by Vectren Energy Delivery. The following scope and costs are included in the estimated costs:
b) 6,000 foot extension of the Ford Road circuit including removal of old single phase cable and installation of new three phase 1/0 AAAC. Includes the replacement of 29 three phase poles.
c) Recloser – remove existing reclosers and install three Versatech reclosers
d) Regulators – install three phase regulator bank
Electrical Distribution4.3.1.2
1) Electrical Distribution – Conveyor Loading / Ash Staging Area
a) Medium voltage feed from the existing 4160V electrical cabinet in the pond area to the switchgear assembly in the electrical room. Cable will be routed in tray or conduit and supported from the conveyor. The area electrical building will be located adjacent to conveyor ash conveyor transfer station 1.
b) One 4160V/480V, 300 kVA pad mount transformer.
c) One prefabricated electrical building (180SF, 12 X 15) complete with HVAC, convenience lighting, plugs, etc. The building foundation is included in the estimate.
d) The electrical building will house the 4160V switchgear, 480V MCC, VFD drives
e) One MCC line-up that will house feeder breakers/starters for the equipment.
f) A new PLC will be installed for control integration. PLC will communicate via fiber optic cable with plant DCS system and PLC located in the DFA unloading and barge loading areas.
g) Feeds internal to the building will utilize cable tray and elevated raceways. Cable tray and conduit will be utilized to feed loads to equipment and the new office building.
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2) Electrical Distribution - Dry Fly Ash (DFA) Unloading Area
a) Medium voltage 12470V feed from the metering station to the new DFA area electrical room. Cable will be fed via an overhead to underground riser pole, through a duct bank and terminated at the switchgear assembly. The electrical building will be located to the north of the existing DFA silo at an elevation above the designated 100 year flood plain.
b) One 12470/4160V, 2000 kVA pad mount transformer and two 4160V/480V, 500kVA transformers.
c) One prefabricated electrical building (600SF, 40 X 15) complete with HVAC, convenience lighting, plugs, etc. The enclosure will house the 12470V switchgear, 4160V switchgear, and 480V MCC, VFD drives and PLC.
d) One 4160V, 1200A metal clad, medium voltage switchgear assembly with four cubicles (main plus 3 feeder). One feed will supply the existing dry fly ash unloading and storage system, one will supply the new CCR material handling equipment and one will supply the new Pond Ash pipe conveyor drive.
e) One MCC line-up that will house feeder breakers/starters for the equipment.
f) A new PLC will be installed for controls integration. The PLC will communicate via fiber optic cable link with the plant’s DCS system and the other PLC located in the Barge loading Area.
g) Feeds internal to the building will utilize cable tray, and elevated raceways and cable tray will be utilized to feed loads external to the building.
h) The foundation for the electrical building is included in the estimate.
3) Electrical Distribution - Barge Loading Area
a) Medium voltage 12470V feed from the DFA unloading area to the switchgear assembly in the barge loading area electrical building. Cable will be routed on poles from DFA unloading area switchgear to the barge loading area. The area electrical building room will be located on a new platform in the barge loading area.
b) One 12470/480V, 1000 kVA pad mount transformer.
c) One prefabricated electrical building (375SF, 25 X 15) complete with HVAC, convenience lighting, plugs, etc. The enclosure will house the 12470V switchgear, 480V MCC, VFD drives and PLC.
d) One MCC line-up that will house feeder breakers/starters for the equipment. Also included is a 600 amp 480V feed to the existing barge loading MCC.
e) A new PLC will be installed for controls integration. The PLC will communicate via fiber optic cable link with the plant’s DCS system and the other PLC located in the Conveyor Loading / Ash Staging Area.
f) Feeds internal to the building will utilize cable tray, and elevated raceways and cable tray will be utilized to feed loads external to the building.
g) The platform supporting the electrical building is included in the estimate
Electrical Design Activities4.3.2
For the new scope referenced above, the following activities will be performed:
1) Existing system one-line drawings that are affected will be updated.
2) Power system studies(Load Flow, Short Circuit, Coordination) will be performed for new MV switchgear loads
3) New one-line drawings for additional loads will be created.
4) MV Switchgear one lines, MCC wiring diagrams/schematics for the new motors will be provided.
5) Development of cable schedule for new power cables to electrical room.
6) Development of technical specifications for procurement and installation of electrical equipment.
Instrumentation and Controls4.3.3The following equipment and design activities will be provided to facilitate installation of the CCR infrastructure equipment.
1) One new PLC and two remote IO panels will be provided. The PLC will be installed in the new electrical building in the Ash Pond area.
2) Three (3) HMI consoles and control stations are included. One in the electrical building in the barge loading, dry fly ash (DFA) and ash pond areas.
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3) Control Logic – Control logic for the CCR ash handing and loading system will be developed.
4) Factory Acceptance Test (FAT) to review logic will be performed.
5) Certified as-built cabinet layout and cabinet wiring diagrams will be issued post FAT.
6) Graphics – Graphics screens and Miscellaneous, trends, faceplates, etc. will be developed by the PLC vendor.
Cost Estimate Details4.3.4
Common Deliverables/Detailed Engineering4.4The following items are common the design of the entire CCR recycle infrastructure system.
1) Process Flow Diagram and Material Balance – New process flow diagram and material balance to indicate major process streams affected will be provided.
2) Piping and Instrument Diagrams (P&ID) – New P&IDs to reflect the new system will be provided. Existing P&IDs will be updated if CADD files of the existing P&IDs are available for edit by AECOM. Otherwise, redline mark-ups of the existing P&IDs will be provided.
3) General Arrangement Drawings –Plan-view and elevation-view general arrangement drawings of the new and modified areas will be developed from a three-dimensional (3-D) CADD model.
4) Geotechnical Investigation and Report – A geotechnical investigation will be performed. The investigation report summarizing the results will be issued to Vectren.
5) Civil/Structural Design Drawings – Plans, sections, and details applicable to all reinforced concrete, structural steel, and architectural scope items will be provided.
6) Electrical and I&C Design Drawings – Develop single line drawings for the new electrical distribution, location and installation detail drawings, grounding, power cable routing, schematics, and wiring diagrams. Existing drawings of owner system one-line diagrams will be revised.
7) Demolition Drawings – Drawings defining equipment and components to be removed will be provided.
8) Line List – Line list will include information such as size, number, service, insulation, heat tracing, segment endpoint identifiers (i.e., “To/From”), design temperature and pressure, and testing pressure and temperature (if applicable).
9) Piping Drawings – Orthographic and isometric piping drawings for new and modified piping systems with diameter greater than 2-1/2 inches shall be provided.
10) Valve List – The valve list will include information such as size, type, end connection type, pressure rating, manufacturer, model number, line number or equipment reference, and P&ID number reference.
11) Instrument List – The instrument list will include information such as type, manufacturer, range and line number or equipment reference, and P&ID number reference.
12) Equipment List – An equipment list will be provided of all new and upgraded equipment including information such as size, type, pressure rating, manufacturer, model number, line number reference, and P&ID number reference.
13) Tie-in List – Tie-in list will include information such as number, service, insulation, segment endpoint identifiers (i.e., “To/From”).
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14) Specialty Item List – The specialty list will include information such as installer, furnisher, device type, datasheet number, and description.
15) Cable/Conduit Schedule – The cable/conduit schedule will include information such as type, size, and area.
16) I/O List – List of all analog and digital I/O associated with the fly ash conditioning system.
17) Technical Specifications – Technical specifications will be developed for procured items and construction.
18) Construction support – Engineering Construction support has been included in the estimate to answer RFIs.
19) Control Description – English language narrative in a word document to describe the intended process operation and functional sequencing of the new ash recycle system.
20) Operation and Maintenance Manuals – Electronic Operation and Maintenance Manuals will be requested from the equipment suppliers, reviewed and provided to Vectren.
21) Training – An AECOM Engineer and a representative from the conveyor and barge loading vendors will be on site for
two four (4) hour training sessions. The purpose of these sessions is to train the Operations, Maintenance and other
staff on the new recycle ash system. Training material will be produced in Microsoft PowerPoint and will be provided
prior to the training class. Owner may video tape the training if they would like.
Work by Others4.51) Modifications/development of system operating procedures (input will be provided by AECOM).
2) Testing required to verify the integrity of any equipment reused as part of the upgrade effort not identified as part of this study.
3) Repairs to restore existing equipment to suitable condition or to address differing site conditions not discovered and identified as part of this study.
4) Cleaning of the project area necessary for construction activities to begin.
5) Supply of all construction utilities including potable water, electricity, and communications connections to temporary construction facilities and construction work areas.
6) Removal of construction debris generated during construction.
7) All necessary permits.
8) Integration and configuration of new controls (e.g., software modifications) into existing plant PLC/DCS.
9) Resolution of discovery field items such as undergrounds, differing site conditions, etc.
10) Any modifications to existing systems not noted in Section 4.
11) Modifications or upgrades to existing UPS system.
Assumptions 4.6
Common4.6.11) The cost estimate does not include any cost for any modifications required in the river to ensure barge loading can be
completed without a tug boat. It should be noted that permitting any river modifications can impact the overall
schedule. AECOM can evaluate this during detail design but no cost has been included in this estimate for this effort.
2) Existing structures, equipment and components that must be modified for installation of the project-related equipment
are in good condition and do not require repairs as a prerequisite for engineering and construction.
3) The engineering services cost estimate allowance includes commercial and technical evaluation of original equipment
manufacturer (OEM) proposals.
4) All piping will be designed in accordance with ASME B31.3.
5) All material will be provided with manufacturer’s standard coating systems and colors. Cost allowances for
specialized coating systems or colors are not included in the study-related cost estimates.
6) Start-up spares are included in the price of the project. Recommended capital spares noted on the future spare parts
list are the responsibility of Vectren and are not included with the project.
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Cause No. 45280Attachment JDM-1 (Public)
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7) Demolition activities other than those required for installation of the noted scope are not included.
8) Taxes and insurance are not included in the study-related cost estimates.
9) No lead or asbestos is present in the Barge Loading Structure. No allowance for abatement of either material has
been included.
10) The costs for engineering services have been estimated on the basis of the schedule as defined in Appendix L.
AECOM assumes a schedule of approximately 28 months in duration, including 16 months for construction. Changes
to these schedule durations could affect the project price
Civil/Structural 4.6.21) Structural engineering and design for new structural systems will be completed in accordance with the 2014 Indiana
Building Code.
2) Facilities included in this scope of work do not require a design that is compliant with the Americans with Disabilities
Act (ADA).
3) The total load-carrying capacity of the existing barge loading structure and the river cell that supports the structure
are unknown and for this study are being treated as if additional structural capacity is available to support the
modifications required for the ash handling scope options described. The capacity of the existing barge loading
structural system will be evaluated in detail during detailed design. Costs for structural reinforcement of the existing
barge loading structural system (including the river cell) are not included in the study-related cost estimates.
4) Existing structures to be modified as part of the scope options described by this study will not be upgraded to comply
with current design codes or the current building code.
5) A geotechnical investigation is required for detailed design and will be performed no later than the beginning of the
engineering phase of the project.
6) The shallow foundation system design for the dome-style storage concept is based on an assumed allowable soil
bearing capacity of 2000 pounds per square foot.
7) The shallow spread footing foundation system concept for the new conveyor system is based on an assumption that
the soil along the preliminary conveyor routing from the ash pond to the location of the new storage structure is
suitable for a spread footing design.
Electrical 4.6.31) New electrical buildings are required in three places (1) Conveyor Loading / Ash Staging Area, (2) DFA Unloading
Area and (3) Barge Loading Area.
2) Estimate is based on a non-hazardous and unclassified area.
3) All cable and electrical raceways shall be routed overhead where possible. All other runs will require underground
duct-banks.
4) New cable will be run in new tray, new conduit or existing cable tray.
5) All conduits 2” and smaller shall be field routed. General conduit routing locations shall be provided.
6) Assume VFD/Soft Starts on motors 20HP and above that are fed by the new 12470V supply to the Dry Fly Ash
Loading area. This includes all electrical loads in the (1) Conveyor Loading / Ash Staging Area and (2) DFA
Unloading Area.
7) New and upgraded motor loads shall be monitored but not controlled by the DCS.
8) Electrical equipment in barge load and pond ash areas will require platforms to raise equipment above 100 year flood
plain.
40
Cause No. 45280Attachment JDM-1 (Public)
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5. Schedule and Project Execution
Close-in Place Schedule5.1A Level 1 schedule depicting the major engineering, procurement and construction activities for the closure of the A. B.
Brown CCR impoundment is included in Appendix L. The Close-in-Place schedule follows the phasing structure described
in Section 3.1.1 of the report.
The construction duration is based on a 5-10 work week for 50 weeks a year. The critical path consists of the dewatering
activities, excavation and regrading activities, and the installation of the geosynthetic liner system.
Landfill Schedule5.1.1
A second Close-in-Place schedule has been included in Appendix L in this revision to the Report which depicts the
construction activities for installing a landfill. This effort, as described in Section 3.1.6, includes the excavation and
removal of the Close-in-Place cap system, the construction of a new landfill on the A.B. Brown property, the closure-by-
removal of the CCR material, and the hauling and subsequent disposal of this material in the new landfill. The durations of
the activities depicted in this schedule have been based on the schedules provided by the bidders, though no schedule
was used exclusively. The future construction schedule, therefore, may vary from what is shown here.
Closure-by-Removal Schedule5.2A Level 1 schedule depicting the major engineering, procurement and construction activities for the closure of the A. B.
Brown CCR impoundment is included in Appendix L. The Closure-by-Removal schedule follows the same phasing
structure as described in Section 3.2.1 of the report.
The construction duration is based on a 5-10 work week for 50 weeks a year. Excavation production is based on providing
CCR material to Geocycle at their requested delivery rate. This rate starts at 200,000 tons/year and increases by 100,000
tons/year to a maximum of 600,000 tons/year. This maximum rate is sustained for the remaining duration of the project.
Further detail is provided in the table shown on the Closure-by-Removal schedule.
Excavation is assumed to begin in July 2018. CCR material could be excavated, dried and stockpiled onsite in advance of
the capital infrastructure being completed.
Capital Upgrades Schedule5.3A Level 1 schedule depicting the project’s major engineering, procurement and construction activities is included in
Appendix L. This schedule covers the capital upgrades required to support the Ash Recycle project. The schedule
includes sections for Material Handling, Processing, Storage and Transportation, with additional sections for engineering
and electrical upgrades.
The overall construction duration is 16 months, and the durations are based upon a 5-10 work week. Three months of pre-
engineering work are included in the schedule to facilitate the detailed engineering effort, which is expected to last seven
to eight months. This effort runs in parallel with procurement and subcontracting activities. Mobilization is scheduled for
August 2018 to begin foundation work.
The lead time of the new pipe conveyor, which runs from the pond storage facility to the dry fly ash silo area, is the critical
path of the schedule. In order to commence excavation and dewatering sooner, CCR material could be trucked directly to
the dry fly ash silo area for transportation onto the barge. This temporary solution could begin as soon as the upgrades to
the barge-loading system are complete and would suffice until the pipe conveyor is commissioned.
41
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– Estimate DetailsAppendix B
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Infrastructure Estimate Backup
Appendix B 45
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Close-in-Place Estimate Backup
Appendix B 49
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Closure-by-Removal Estimate Backup
Appendix B 52
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Infrastructure Construction Bid Pricing
Appendix B 54
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Pond Closure Construction Bid Pricing
Appendix B 56
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– Design Basis Tables: Appendix CClosure-in-Place and Closure-by-Removal
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Ve
ctre
n - A
B B
row
n A
sh
Ba
sin
Clo
su
re P
roje
ct (6
0%
)
De
sig
n B
as
is T
ab
les
: Clo
su
re-in
-Pla
ce
an
d C
los
ure
-by
-Re
mo
va
l
Crite
riaIn
dia
na
So
urc
e
Cap S
yste
m C
om
ponents
6 in
che
s of to
pso
il plu
s 18
inch
es (1
0-5 cm
/sec)
infiltra
tion
laye
r (alte
rna
tive
s acce
pta
ble
bu
t
mu
st no
t ha
ve
a p
erm
ea
bility
gre
ate
r tha
n 1
0-5
cm/se
c.
6 in
che
s of to
pso
il plu
s 24
inch
es fo
r slop
es
< o
r = to
15
%, 3
6 in
che
s for slo
pe
s < 1
5%
>
25
%, a
nd
48
inch
es fo
r slop
es >
25
%
32
9 IA
C 1
0-3
0-2
.c2
(As re
fere
nce
d b
y ID
EM
Office
of La
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urfa
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Gu
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)
6 in
che
s of to
pso
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18
inch
es o
f infiltra
tion
soil la
ye
r,
ge
oco
mp
osite
dra
ina
ge
laye
r,
an
d 4
0 m
il LLDP
E g
eo
me
mb
ran
e
6 in
che
s of to
pso
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s 24
inch
es o
f
infiltra
tion
soil la
ye
r, ge
oco
mp
osite
dra
ina
ge
laye
r, an
d 4
0 m
il LLDP
E
ge
om
em
bra
ne
.
6 in
che
s of to
pso
il plu
s
24
inch
es o
f coh
esiv
e so
il lay
er, 6
inch
es
of sa
nd
/dra
ina
ge
laye
r, 12
oz/sy
no
nw
ove
n g
eo
textile
ove
r 40
mil LLD
PE
ge
om
em
bra
ne
.
Cap S
yste
m S
lop
eN
/A
1%
to 3
3%
(Fo
r slop
es in
du
cing
cha
nn
elize
d flo
w o
f
storm
wa
ter, ID
EM
ha
s ind
icate
d th
at th
is
min
. req
uire
me
nt m
ay
be
red
uce
d to
1 %
,
pe
r IPL C
losu
re P
lan
s)
32
9 IA
C 1
0-3
0-2
.c3
(As re
fere
nce
d b
y ID
EM
Office
of La
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Qu
ality's S
urfa
ce Im
po
un
dm
en
t Clo
sure
Gu
ida
nce
)
3%
to 2
0%
2%
to 5
%2
% to
12
%
Sto
rmw
ate
r Channel (O
ver C
ap
) Geom
etry
N/A
N/A
N/A
V sh
ap
ed
-swa
leT
rap
ezo
ida
l (4:1
side
slop
es)
Tra
pe
zoid
al (3
:1 sid
e slo
pe
s)
Sto
rmw
ate
r Channel (O
ver C
ap
) Desig
n S
torm
N/A
25
Ye
ar S
torm
32
9-1
0-1
5-8
.a1
9
(As re
fere
nce
d b
y ID
EM
Office
of La
nd
Qu
ality's S
urfa
ce Im
po
un
dm
en
t Clo
sure
Gu
ida
nce
)
IDE
M D
rain
ag
e M
an
ua
l; 10
0 Y
ea
r, 6 h
ou
r
an
d 2
4 h
ou
r storm
eve
nts w
ith th
e H
UF
F
third
qu
artile
rain
fall d
istribu
tion
25
Ye
ar S
torm
(be
low
ge
oco
mp
osite
ou
tlet)
10
0 Y
ea
r Sto
rm
(con
tain
ed
with
in ch
an
ne
l)
No
t De
fine
d in
Clo
sure
Pla
n
Sto
rmw
ate
r Channel (O
ver C
ap
) Min
. Slo
pe
N/A
1%
to 3
3%
(Fo
r slop
es in
du
cing
cha
nn
elize
d flo
w o
f
storm
wa
ter, ID
EM
ha
s ind
icate
d th
at th
is
min
. req
uire
me
nt m
ay
be
red
uce
d to
1 %
,
pe
r IPL C
losu
re P
lan
s)
32
9 IA
C 1
0-3
0-2
.c3
(As re
fere
nce
d b
y ID
EM
Office
of La
nd
Qu
ality's S
urfa
ce Im
po
un
dm
en
t Clo
sure
Gu
ida
nce
)
1%
1%
1%
Sto
rmw
ate
r Dow
n C
hute
/ Energ
y D
issip
atio
n D
esig
n S
torm
N/A
10
0 Y
ea
r Sto
rm
Ge
ne
ral G
uid
elin
es fo
r Ne
w D
am
s an
d
Imp
rove
me
nt to
Existin
g D
am
s in In
dia
na
Se
ction
4.2
. (Fu
rthe
r de
fine
d b
y V
ectre
n
con
ve
rsatio
ns w
ith sp
ecific co
nta
cts,
statin
g th
at D
NR
wo
uld
no
t con
side
r a
da
m re
gu
late
d a
s lon
g a
s it is no
t
imp
ou
nd
ing
wa
ter).
IDE
M D
rain
ag
e M
an
ua
l; 10
0 Y
ea
r, 6 h
ou
r
an
d 2
4 h
ou
r storm
eve
nts w
ith th
e H
UF
F
third
qu
artile
rain
fall d
istribu
tion
10
0 Y
ea
r Sto
rmN
ot D
efin
ed
in C
losu
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lan
Sto
rmw
ate
r Channel (N
ot O
ver C
ap
) Shap
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/AN
/AN
/AV
sha
pe
d a
nd
Tra
pe
zoid
al (2
:1 sid
e
slop
es)
Tra
pe
zoid
al (4
:1 sid
e slo
pe
s)T
rap
ezo
ida
l (3:1
side
slop
es)
Sto
rmw
ate
r Channel (N
ot O
ver C
ap
) Desig
n S
torm
N/A
25
Ye
ar S
torm
32
9-1
0-1
5-8
.a1
9
(As re
fere
nce
d b
y ID
EM
Office
of La
nd
Qu
ality's S
urfa
ce Im
po
un
dm
en
t Clo
sure
Gu
ida
nce
)
IDE
M D
rain
ag
e M
an
ua
l; 10
0 Y
ea
r, 6 h
ou
r
an
d 2
4 h
ou
r storm
eve
nts w
ith th
e H
UF
F
third
qu
artile
rain
fall d
istribu
tion
10
0 Y
ea
r Sto
rmN
ot D
efin
ed
in C
losu
re P
lan
Sto
rmw
ate
r Channel (N
ot O
ver C
ap
) Min
. Slo
pe
N/A
N/A
N/A
0.3
0%
1%
1%
Sto
rmw
ate
r Channel E
rosio
n P
rote
ctio
nN
/A
Gra
ss Linin
g - C
ha
nn
el slo
pe
< 5
% a
nd
ve
locity
< 5
ft/s
Stru
ctura
l Linin
g (rip
rap
) - Ch
an
ne
l slop
e >
5%
an
d v
elo
city >
5 ft/s
Ind
ian
a D
rain
ag
e H
an
db
oo
k
Se
ction
5.7
; Ind
ian
a S
torm
Wa
ter Q
ua
lity
Ma
nu
al C
ha
pte
r 7
Esta
blish
me
nt o
f ve
ge
tative
gro
wth
(ne
tting
, soil sta
biliza
tion
, etc. sh
all b
e
use
d a
s ne
ed
ed
).
Gra
ss Linin
g - C
ha
nn
el slo
pe
< 5
% a
nd
ve
locity
< 5
ft/s
Stru
ctura
l Linin
g (rip
rap
) - Ch
an
ne
l slop
e
> 5
% a
nd
ve
locity
> 5
ft/s
Ap
pro
pria
te v
eg
eta
tion
will b
e
esta
blish
ed
to p
rev
en
t the
ero
sion
rate
from
exce
ed
ing
5 to
ns/a
cre/y
ea
r
(req
uire
d b
y 32
9 IA
C 1
0-3
0-2
.c1). A
suita
ble
see
d m
ixture
com
plia
nt w
ith
the
20
16
IDO
T S
tan
da
rd S
pe
c will b
e
use
d.
Culv
ert D
esig
n S
torm
N/A
10
Ye
ar S
torm
(do
no
t ove
rtop
roa
d d
urin
g
10
0 Y
ea
r Sto
rm)
IDO
T 2
01
3 D
esig
n M
an
ua
l Ch
ap
ter 2
03
IDE
M D
rain
ag
e M
an
ua
l; 10
0 Y
ea
r, 6 h
ou
r
an
d 2
4 h
ou
r storm
eve
nts w
ith th
e H
UF
F
third
qu
artile
rain
fall d
istribu
tion
25
Ye
ar S
torm
(do
no
t ove
rtop
roa
d
du
ring
10
0 Y
ea
r Sto
rm)
No
t De
fine
d in
Clo
sure
Pla
n
Culv
ert O
utle
t Ero
sio
n P
rote
ctio
n D
esig
n S
torm
N/A
10
Ye
ar S
torm
Ind
ian
a D
rain
ag
e H
an
db
oo
k S
ectio
n 5
.10
;
Ind
ian
a S
torm
Wa
ter Q
ua
lity M
an
ua
l
Ch
ap
ter 7
No
t De
fine
d1
0 Y
ea
r Sto
rmN
ot D
efin
ed
in C
losu
re P
lan
Ero
sio
n S
oil L
oss
N/A
5 to
ns/a
cre/y
ea
r
32
9 IA
C 1
0-3
0-2
.c1
(As re
fere
nce
d b
y ID
EM
Office
of La
nd
Qu
ality's S
urfa
ce Im
po
un
dm
en
t Clo
sure
Gu
ida
nce
)
5 to
ns/a
cre/y
ea
r5
ton
s/acre
/ye
ar
5 to
ns/a
cre/y
ea
r
Re
gu
lato
ryP
ara
mete
rC
ulle
yA
B B
row
nIP
&L
Clo
su
res
CC
R R
ule
Appendix C 61
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� Alternatives Evaluation and Appendix JDrawings
198
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1. Alternatives Evaluation
The Report discusses the two principal closure options, Closure in Place (CiP) and Closure by Removal (CbR) for
Beneficial Reuse. This appendix discusses the additional alternatives that were evaluated as part of the two principal
closure options, along with the alternatives for infrastructure required for a CbR option in which the CCR material is
transported off-site for beneficial reuse. Two partial closure alternatives (for contingency planning purposes) were
evaluated as part of this study: Partial Closure Alternative #1 (50% CbR / 50% CiP) and Partial Closure Alternative #2
(75% CbR / 25% CiP). The partial closure options further serve to represent the 50% (Phase IV) and 75% (Phase V)
interim phases of the complete (100%) Closure by Removal option discussed in the Report. Much of this content was
presented in Revision 0 of the Report and has been moved to this appendix with this new revision.
The following variations were evaluated as part of developing each of the pond closure and CCR materials recycling
options, and are discussed in this appendix:
1) Pond Closure Options
a) Closure-in-Place (CiP)
i) Geosynthetics Final Cover System
ii) Clay Final Cover System
b) Closure-by-Removal (CbR) for Beneficial Reuse
i) Partial Closure Alternative #1 (50% CbR / 50% CiP)
ii) Partial Closure Alternative #2 (75% CbR / 25% CiP)
2) Excavation Options
a) Hydraulic Dredging
b) Drag Line
c) Conventional
3) Dewatering Options
a) Gravity Dewatering
b) Positive Dewatering
c) Combination of Gravity and Positive Dewatering
4) Material Handling Options
a) Trucking
b) Conveyor
5) Material Processing Options
a) Screening
b) Blending
c) Drying
6) Storage Options
a) Dome Storage
b) Eurosilo®
c) In-Pond Storage Structure
7) Transport Options
a) Barge Loading Wet Ash
b) Barge Loading Wet and Dry Ash
c) Rail Car
Schedules for the 50% C-b-R / 50% C-i-P schedule, the 75% C-b-R / 25% C-i-P schedule and the Close-in-Place
schedule are included in Appendix L. The construction durations for these schedules were developed assuming a 5-
10 work week for 50 weeks a year, including 25 weather days.
The following estimate was also prepared to compare the cost impact of several options.
Appendix J 199Appendix J 199
Cause No. 45280Attachment JDM-1 (Public)
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Ap
pe
nd
ix J
20
0Cause No. 45280Attachment JDM-1 (Public)
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Clay Final Cover System: While a sufficient quantity of soils is assumed to be available from a nearby borrow
source on land owned by Vectren, the material properties required for the 24-inch compacted soil layer may not be
met by this borrow source. The CCR Rule requires that these soils be less than or equal to the permeability of the
natural subsoils present, or not greater than 1x10-5
cm/sec, whichever is less permeable. Results of permeability
testing of the subsoils below the existing CCR material indicate a range from 9x10-8
to 7x10-5
cm/sec. Based on
AECOM�s experience at the AB Brown site while constructing the buttress for the Lower Dam, the permeability of the
nearby borrow sources will be on the order of 1x10-6
cm/sec, which may not be considered by the regulatory
authorities (IDEM) to be less than the permeability of the natural subsoils present. While AECOM proposes an
average permeability of 1x10-6
cm/sec be acceptable for the compacted soil layer, thus allowing the use of the local
borrow source, this may not be acceptable to IDEM and therefore presents a risk to its use. In addition, the use of a
compacted soil (clay) layer as the infiltration barrier is less effective than the use of geosynthetics. The compacted
soil layer is subject to desiccation cracking during the summer months as well as damage due to freeze/thaw cycles
and root intrusion from woody vegetation. Because the infiltration of water through the soil cap and into the underlying
CCR material will be higher when compared to the geosynthetic cap, the risk of contamination to the groundwater is
therefore greater. Lastly, while the capital cost of a clay final cover system is less expensive than the geosynthetic
final cover system, the cost of maintaining a clay final cover system is more expensive.
In summary, the geosynthetic cap will likely be more expensive than the clay cap; however, the clay cap will not be as
effective at reducing the infiltration of water into the underlying CCR material thereby maintaining the risk of
contamination to groundwater.
Closure by Removal (CbR) for Beneficial Reuse1.2The main body of the Report, Revision 1, discusses the complete set of (100%) CbR for Beneficial Reuse options,
including the phasing methodology (six phases) and methods for excavation, stormwater management, dewatering
and processing. This section of the appendix discusses two partial closure alternatives, including:
· Partial Removal Closure Alternative #1 � consists of a 50% CbR and 50% CiP closure system
· Partial Removal Closure Alternative #2 � consists of a 75% CbR and 25% CiP closure system
These partial closure alternatives were evaluated for contingency planning purposes for a situation whereby only a
portion (50% or 75%) of the CCR materials have been removed from the Ash Pond and successfully recycled,The
remaining portion (50% or 25%) of the ponded materials cannot be recycled thereby necessitating that these
residuals be closed-in-place. These alternatives are discussed in the continuing subsections, along with their
respective phasing, excavation and dewatering alternatives.
Partial Removal Closure Alternative #1 (50% CbR / 50% CiP)1.2.1
Partial Removal Closure Alternative #1 consists of a 50% CbR and 50% CiP closure system. This alternative has
been developed to support Vectren�s contingency planning for a situation whereby 50% of the CCR materials (by
volume) have been removed from the Ash Pond and successfully recycled, but the remaining 50% of the ponded
materials cannot be recycled and must be closed-in-place. Conceptual level design drawings for Partial Removal
Closure Alternative #1 are included in this appendix. Closure for the 50% CbR alternative assumes that the �fingers�
area of the Upper Pond would be �clean closed� (as shown for Phase IV on the referenced Drawings). Clean closure
will include the removal of 2 feet of native soils below the CCR materials. Stormwater entering the clean closed and
capped areas will be collected by a central channel approximately 4,250 feet in length, sloped at 0.5%.
The remaining 50% of the CCR material within the Upper and Lower Ponds will be regraded and capped with a final
cover system that complies with 329 IAC 10-30-2 as well as the Final CCR Rule. For the 50% CiP, the closure cap
would cover a remaining pond area of approximate 97 acres. The cap is designed to promote positive drainage,
minimize surface water infiltration, support vegetation, and provide an aesthetically acceptable final surface. Fill
materials will additionally be placed outside of the Ash Pond limits to promote positive drainage over the final cover
system.
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The proposed final grades of the cover system will have a minimum slope of 2% and will provide a series of inverted
stormwater channels (graded towards the central channel), with a minimum slope of 1% to convey clean stormwater
runoff to the Ohio River via an existing unnamed tributary.
Stormwater management features and erosion controls will be integrated with the grading and placement of the final
cover system to promote positive surface drainage, minimize erosion, and minimize long-term maintenance.
Stormwater management plans and details are provided in the referenced Drawings in this appendix.
As previously discussed in this appendix for the CiP alternative, the same two final cover system configurations were
considered: the Geosynthetics Final Cover System and the Clay Final Cover System.
This alternative entails the CbR of 2.9 million cubic yards of CCR material from the Upper and Lower Ponds, and the
CiP of 3.0 million cubic yards of CCR material that will remain. CCR material will be removed in four phases, with
each phase having different phasing, excavation, dewatering, and stormwater management requirements.
Alternatives for these components are examined in detail in the continuing subsections. Closure and lifecycle costs
associated with the 50% CbR / 50% CiP are also presented.
Phasing1.2.1.1
The 50% closure by removal evaluation utilizes the first four phases of CCR material removal detailed in Section
3.2.1 of the Report and as identified on the referenced Drawings in this appendix.
Excavation Methods1.2.1.2
Multiple excavation methods were evaluated for the 50% closure by removal evaluation. Each method�s effectiveness
and feasibility for removing 50% of the site�s CCR material is examined below.
A. Conventional Excavation
Conventional excavation was the selected method and is discussed in detail in Section 3.2.2 of the Report.
B. Hydraulic Dredging
Excavation using solely hydraulic dredging without dewatering CCR material was evaluated as a removal method. In
this option, dredges would remove wet CCR material underwater and pump it to rim ditches or other containment
areas to allow for decanting before further processing. It was determined that a 12-inch cutter head dredge would be
sufficient to meet required production rates.
After consulting with subject matter experts, and taking into account the varying moisture conditions of the ponded
CCR material, hydraulic dredging was determined to have lower production rates and less reliable equipment than
standard excavation. Additionally, much of the CCR material within the pond is already dry and would require mixing
with water for removal via dredge. This renders hydraulic dredging not viable for removal of sufficient quantities of the
CCR material within the pond. However, it may be suitable to utilize hydraulic dredging to supplement conventional
excavation equipment in circumstances where use of conventional excavation equipment would be logistically difficult
or time consuming.
C. Dragline or Skyline Excavator
Use of only dragline or skyline excavators to excavate ash with no dewatering was evaluated. In a skyline excavation
system, a �clam shell� bucket would be maneuvered on cables between two mobile towers (head and tail) to excavate
ash from the Upper and Lower Ponds. In a dragline-only excavation system, dragline excavators would be track-
mounted or �walking� and operate within the pond, similar to conventional excavators. The advantage of these
systems would lie in their long reaches and large bucket size, which would enable large volumes of material to be
excavated quickly.
Both dragline and skyline excavators have been successfully used in the mining industry to excavate large volumes
of material at a low cost per ton average. However, both the dragline and skyline excavators have an extremely high
initial capital expense. One subject matter expert estimated that a system large enough to span the distances across
the Upper and Lower Ponds would have to be custom-designed for the project, resulting in high upfront costs for
design and construction. This subject matter expert stated that the system would cost at least $15M to manufacture.
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Access restrictions and anchoring considerations also present considerable challenges. For instance, the head tower
of a skyline excavator must be anchored using a large counterweight or by mooring to dead-men in order to prevent
tipping. As a result, a skyline excavator system would require installation of either stable access points (able to
support the head tower and the counterweight) or dead-men around the perimeter of the Upper and Lower Pond,
further increasing the cost of the system. Additionally, use of a skyline excavator would require frequent relocation of
the cable towers to allow the bucket to access all areas of the Upper and Lower Ponds. As the excavator is only able
to pull material in a line towards the head tower, significant conventional equipment would be still be required to
process material for drying prior to transport to loading areas.
Use of a dragline excavator would be able to solve many of the technical challenges presented by a skyline
excavator. However, conventional equipment would still be required to process material, meaning it would likely not
replace enough equipment to offset its large upfront capital expense. Lastly, a dragline excavator would also require
subgrade preparation before moving, adding additional time and expense.
Additionally, both dragline and skyline excavators remove ash by pulling the CCR materials towards the excavator.
Therefore, removing ash in the portion of the pond closest to the dragline/skyline excavator will require the materials
to be pulled out of the pond, thereby necessitating a subsequent stage where this surrounding area would need to be
further excavated or cleaned to meet the closure by removal standards.
Due to the high initial capital cost along with the access restrictions, anchoring considerations and fact that
conventional excavation equipment would still be required to process material, the use of dragline/skyline excavation
methods was dismissed from further consideration in this analysis.
D. Amphibious Excavators
Use of only amphibious equipment to excavate ash without dewatering was also evaluated. This option would include
use of pontoon-mounted excavators or barge-mounted excavators to remove wet ash from the pond. This option was
not considered further because other removal methods, such as hydraulic dredging, would also still be required to
excavate deeper ash. Additionally, amphibious equipment has lower production rates and would not be efficient in
removing the large volumes of ash needed to meet Geocycle�s demand. However, it may be suitable to utilize
amphibious excavators to supplement conventional excavation equipment in circumstances where using conventional
excavation equipment would be logistically difficult or time consuming.
Dewatering Methods1.2.1.3
Dewatering of the ponded ash materials will be an important component of the closure system. Dewatering will
condition the ash materials to facilitate mass excavations and will also be required to appropriately improve and
maintain the pond surface�s ability to support the heavy construction equipment necessary to implement the closure
activities.
When in a saturated condition and in the presence of a permanent phreatic surface, fly ash and bottom ash materials
are inherently unstable, have very low bearing capacity, and are subject to localized liquefaction when subject to
vibrations induced by construction equipment. Therefore, it will be of paramount importance to maintain the pond
phreatic surface below the elevation on which construction equipment will operate. Construction vibrations have a
tendency to wick water upward through the ash mass via capillary action. The phreatic surface must be maintained a
sufficient vertical distance underneath the ground surface to mitigate this effect. As such, the primary objective of the
dewatering system will be to lower and maintain the pond phreatic surface at any work area to 5-10 feet below the
current surface grade in any area of work, at any time, so that a safe and stable working surface is established.
Dewatering will inherently remove interstitial water and reduce the water content of the ash mass, which will improve
its handling characteristics. This will make the subsequent process of excavation more efficient and will reduce the
time and effort required to condition the excavated material to the target water content.
Multiple dewatering methods were evaluated for the 50% CbR evaluation. Each method�s effectiveness and feasibility
for removing 50% of the site�s CCR material is examined below.
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A. Gravity Dewatering System
A passive, gravity dewatering system would consist of a network of excavated ditches into which pore water from the
CCR materials will seep. The ditches will drain by gravity from northwest to southeast to a rim ditch which will be
constructed along the southeast perimeter of the Upper Pond. The rim ditch will discharge to a sump located within
Pool A, from which collected pore water will be continuously pumped. The system of dewatering ditches and rim ditch
will also intercept and collect surface water drainage and route collected water to Pool A. Construction access to the
areas between the dewatering ditches will be provided via the northern side of the pond, and excavations will take
place in the areas between the ditches.
The ditches will need to be of sufficient size and designed with close enough spacing to facilitate a uniform drawdown
of the pond phreatic surface as rapidly as possible. AECOM has performed preliminary seepage analyses of the
passive system as part of this study. These analyses indicate the following:
1) Ditches should have at least 15 feet bottom width, and sideslopes of approximately 3H:1V to minimize sloughing
and maintenance issues.
2) The maximum spacing between ditches should be 300 feet (center of ditch to center of ditch), in order to achieve
uniform drawdown of the pond phreatic surface between ditches.
3) Rates of seepage inflow to the system will be relatively small. For example, peak seepage flow rates into the
entire passive system installed across the Upper Pond will be on the order of only 100 gpm. This rate will be
much smaller than that from surface water run-off, so design of the sump pumping system will be governed
primarily by the surface water inflows.
4) Once the passive system has been constructed in the configuration described above and put into operation, the
phreatic surface will drop to its equilibrium level within a period of 6 to 9 months. The equilibrium level is
estimated to be 2 to 3 feet higher than the lowest invert of the ditch system, due to the effect of infiltration from
run-off into the pond during construction.
Dewatering using gravity methods alone would have several disadvantages. For instance, this system would not be
able to lower the water surface significantly below the Lower Pond�s water surface elevation of 440 feet prior to
December 2023, due to gradual recharge of water from the Lower Pond to the Upper Pond. An additional
disadvantage is that the contractor will have less control over the phreatic surface than with positive dewatering. As a
result, uncertainty and variability in ash production rates is likely. Variability in the hydraulic conductivity of the ash
may also limit the effectiveness of the gravity dewatering system in certain areas.
The use of gravity dewatering alone was rejected, as it will likely not be possible to maintain a phreatic surface 5 to
10 feet below the working surface, especially in Phase IV when the working surface will be at an elevation of 427 feet.
B. Positive Dewatering System
The positive dewatering system will consist of a network of closely spaced well points, installed in lines across the
footprint of the pond and discharging to trunk lines (header piping). Ash dewatering will be achieved by creating
positive suction at the well points and then pumping the water through the header piping to be discharged to the
Lower Pond for treatment at the plant.
As the ash is a fine-grained, moderate to low permeability soil, drawdown of the phreatic surface will be localized
around each well point. To achieve a uniform drawdown of the pond, it will be necessary to configure the well points
at close spacing within each line, and the lines themselves will also have relatively tight spacing across the pond
footprint. Well point spacing and line spacing is anticipated to be on the order of 10 feet and 100 feet, respectively.
Excavations will take place in the areas between the well point lines.
Detailed design of the positive system should be developed by the specialty contractor that will install and operate the
system.
The incremental dewatering depth of a well point system would be greater than that of the passive system, since the
well points can be installed deep into the ash column. It is anticipated that the well points can lower the pond phreatic
surface 20 to 25 feet in a single installation. At areas of the pond where the ash column is thick (including the area
under the upper dam and to the east and west of it) deeper dewatering depths should be possible if the well points
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are complemented with the addition of a deep well network made up of more widely spaced but larger diameter,
higher capacity elements with a larger pumping apparatus.
While positive dewatering would likely be effective in lowering the phreatic surface quickly, well points are be
expensive to install and maintain. As with gravity dewatering, variability in the hydraulic conductivity of the ash may
also limit positive dewatering�s effectiveness in certain areas. Lastly, positive dewatering�s effectiveness would also
vary based upon the proximity of the well points to the Lower Pond, which would act as a source of recharge to
locations with groundwater elevations below 440 feet. As with gravity dewatering, prior to December 2023, positive
dewatering would be most effective in areas farther away from the Lower Pond that would not recharged as quickly.
Use of positive dewatering alone was rejected due to high mobilization/demobilization costs and the high cost of
operating the system for the long duration of this project. Additionally, enough CCR material is located at elevations
such that dewatering will not be required for several years, allowing the much cheaper gravity dewatering to lower the
phreatic surface to the extent possible.
C. Combined Dewatering System
Gravity dewatering combined with positive dewatering was found to be the best overall option and is discussed in
detail in Section 3.2.3 of the Report.
Cost Estimate Details1.2.1.4
AECOM prepared a Class 4 construction cost estimate for the Partial Removal Closure Alternative #1 (50% CbR /
50% CiP) for contingency planning purposes. A summary of the costs are provided in Section 1 of this appendix. The
cost estimate was prepared based on the 30% level design presented in the Partial Removal Closure Alternative #1
Design Drawings, presented later in this appendix. These costs were also presented in the previous revision of the
Report.
The cost estimate for the Partial Removal alternative is subdivided into the following six major components:
1) Mobilization/Demobilization: includes mobilization, insurance, project administration, surveying and
demobilization.
2) Dewatering and Stormwater Management: includes free water removal; passive dewatering of pore water; active
dewatering of pore water; and management of contact-stormwater.
3) Closure-by Removal Construction: includes phased excavation of 50% of the volume of CCR materials from the
Ash Pond, material decanting and staging; and construction of the Ash Staging / Conveyor Loading Area.
4) Closure-in-Place Construction: includes CCR material grading and subgrade preparation for the remaining CiP
area; separate costs for both geosynthetic and clay final cover system scenarios; erosion and sediment control;
and site restoration.
5) Engineering and CQA: includes engineering services pre-construction; engineering services during construction
of the pond closure; and construction quality assurance (CQA) field support.
6) Post-Closure: includes 30-years of groundwater monitoring and separate maintenance costs for both
geosynthetic and clay final cover system scenarios.
Partial Removal Closure Alternative #2 (75% CbR / 25% CiP)1.2.2
Partial Removal Closure Alternative #2 consists of a 75% CbR and 25% CiP closure system. This alternative has
been developed to support Vectren�s contingency planning for a situation whereby 75% of the CCR materials (by
volume) have been removed from the Ash Pond and successfully recycled., The remaining 25% of the ponded
materials cannot be recycled, thereby necessitating that these residuals be closed-in-place. Conceptual level design
drawings for Partial Removal Closure Alternative #2 are included in this appendix.
Upon removal of 75% of the CCR materials within the Upper and Lower Ponds, the remaining 25% of the materials
will be regraded and capped with a final cover system that complies with 329 IAC 10-30-2 as well as the Final CCR
Rule. As stated, the remaining 25% volume of CCR materials will be regraded to achieve appropriate grades for long-
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term stormwater drainage. Two grading concepts for 75% Closure by Removal were evaluated: minimal regrading
and footprint reduction.
The minimal grading option would consist of an inverted 86 acre cap with a central channel directing stormwater off of
the cap. The footprint reduction option would consist of regrading the CCR materials into a mounded area (similar to
a typical landfill) in order to achieve reduced closure cap costs through footprint reduction. While the second option
would result in significantly less area to be capped, it also presents significant technical challenges. Construction of a
mounded area will require significantly more earthwork than the minimal grading option. Post-construction settlement
of the mounded area would also result in additional long-term maintenance costs compared to an inverted cap
system. Based on these considerations, the second option, minimal grading, was chosen for the purposes of this
evaluation.
Similar to the Partial Removal Closure Alternative #1, stormwater entering the clean closed and capped areas will be
collected by a central channel approximately 4,250 feet in length, sloped at 0.5%. The closure cap slopes towards the
central collection channel at a slope of 2.0%.
For the 25% CiP portion of this alternative, the closure cap would cover an area of approximately 76 acres. As with
the Partial Removal Closure Alternative #1, the cap is designed to promote positive drainage, minimize surface water
infiltration, support vegetation, and provide an aesthetically acceptable final surface. Fill materials will additionally be
placed outside of the Ash Pond limits in order to promote positive drainage over the final cover system. The proposed
final grades of the cover system will have a minimum slope of 2% and will provide a series of stormwater channels
(graded towards the central channel) with cross slopes of1% to convey clean stormwater runoff to the Ohio River via
an existing unnamed tributary.
Stormwater management features and erosion controls will be integrated with the grading and placement of the final
cover system to promote positive surface drainage, minimize erosion and minimize long-term maintenance.
Stormwater management plans and details are provided in the referenced Drawings in this appendix.
As previously discussed in this appendix for the CiP alternative, the same two final cover system configurations were
considered: the Geosynthetics Final Cover System and the Clay Final Cover System.
This alternative entails the removal of 4.4 million cubic yards of CCR material from the Upper and Lower Ponds, and
the CiP of 1.5 million cubic yards of CCR material that will remain. CCR material will be removed in five phases, with
each phase having different phasing, excavation, dewatering, and stormwater management requirements.
Alternatives for these components are examined in detail in the continuing subsections. Closure and lifecycle costs
associated with the 75% CbR / 25% CiP are also presented.
Phasing1.2.2.1
The 75% closure by removal evaluation utilizes the first five phases of CCR material removal detailed in Section 3.2.1
of the Report and identified in the referenced Drawings presented later in this appendix.
Excavation Methods1.2.2.2
Several methods of excavation were evaluated for the 75% closure by removal evaluation. Each method�s
effectiveness and feasibility for removing 75% of the site�s CCR material is examined below.
A. Conventional Excavation
Conventional excavation was the selected method and is discussed in detail in Section 3.2.2 of the Report.
Amphibious equipment may need to perform a larger role as equipment operates in areas that may be more difficult
to dewater.
B. Other Options
As with the 50% stage of CCR material removal described in Partial Removal Closure Alternative #1, other options
evaluated include hydraulic dredging, use of dragline or skyline excavators, and use of amphibious equipment.
Hydraulic dredging may be more effective as CCR material is removed from deeper elevations. More groundwater
infiltration will occur as water is pumped out of the groundwater table and the gradient between the pond and the
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excavation increases. If pools of groundwater are unable to be removed rapidly enough to allow conventional
excavation, boat-mounted hydraulic dredging equipment may continue to remove ash from these pools.
Dragline excavators, skyline excavators, or amphibious excavators are not expected to perform any more effectively
for a 75% CCR material removal process as compared to the 50% CCR removal process. Please refer to Section
1.2.1 of this appendix for more discussion regarding these excavation options.
Dewatering Methods1.2.2.3
Gravity dewatering methods will continue to be used in Phase V (CCR Removal from Both Upper and Lower Ponds �
432 feet), with positive dewatering used as necessary. Inverts of ditches and sumps will be lowered as excavation
proceeds throughout the phase. Well points and deep wells will also be moved as necessary within the footprint of
the Upper and Lower Ponds to support excavation.
Cost Estimate Details1.2.2.4
AECOM prepared a Class 4 construction cost estimate for the Partial Removal Closure Alternative #2 (75% CbR /
25% CiP) for contingency planning purposes. A summary of the costs are provided in Section 1 of this appendix. The
cost estimate was prepared based on the 30% level design presented in the Partial Removal Closure Alternative #2
Design Drawings presented later in this appendix. These costs were also presented in Revision 0 of the Report.
The cost estimate for the CiP alternative is subdivided into the same six major components identified in Section
1.2.1.4 for the Partial Removal Closure Alternative #2. The methodology used to develop the costs is identical to that
which was previously described for the Partial Removal Closure Alternative #1 Section.
Material Handling Options1.3Multiple material handling options were considered to transport CCR material from the pond to the barge or a rail
loading system. Transport options included trucking the CCR material from the pond to a storage facility in the DFA
area and installing a new conveyor system either from the pond to a storage facility in the DFA area or from an in-
pond storage structure to the existing pipe conveyor system. Utilizing a pipe conveyor to transport the CCR material
from an in-pond storage structure to the DFA areas was selected as the preferred option and is discussed in the
Report.
Trucking Option1.3.1
One method to transport CCR material from the ash pond to the storage facility in the DFA area is truck hauling. This
option is depicted on the PFD titled �Truck Ash Hauling� The proposed truck route is shown in this appendix. The
trucks will be filled with ash at the pond, transport the ash to the DFA area, and dump the ash into a receiving bin
CCR material will be transported to a storage dome via the Truck Unloading Belt Feeder and the Storage Feed
Conveyor. The trucks will take the same route back to the ash pond area for the next load. The Process Flow
Diagram (PFD) and conveyor general arrangement (GA) depicting the dome storage facility, are shown in this
appendix.
An interlock will be required for the truck-conveyor option that prohibits the start of the Truck Unloading Belt Feeder
unless the Storage Feed Conveyor is running. The interlock will ensure that the Truck Unloading Belt Feeder only
operates with a discharge path in service. The belt feeder and conveyor will be supplied with zero speed sensors and
misalignment switches so it will be possible to remotely monitor the operation of the equipment. The Storage Feed
Conveyor will be designed with a probe to indicate when the ash pile has reached maximum height. If reaching
maximum height the conveyor will trip.
Truck Road Improvements1.3.1.1
1) In order to truck the ash from the ash pond to the storage area, development of new road ways and improvement
of existing roads will be required such that all roads are capable of handling heavy truck traffic. The truck routing
is attached later in this appendix.
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2) A concrete pad will be required for the trucks to unload the ash. The pad will be 100 feet by 200 feet and will
include curbs to contain any water spillage. Any spillage will be directed to the sump that is described in the Ash
Storage section.
3) Trucks and front end loaders will be required to transport the ash. These are included in the estimate provided
later in this document.
Equipment to Transfer Ash from Truck Loading to Storage Facility1.3.1.2
1) One trough belt feeder (Truck Unloading Belt Feeder) designed with a capacity of 400 short tons per hour (stph)
will be installed to transport the ash from the truck unloading area to the storage facility conveyor.
2) One trough conveyor (Storage Feed Conveyor) designed with a capacity of 400 short tons per hour (stph) will be
installed to transport the ash from the belt feeder to the storage facility.
3) A transfer tower structure will be provided at the termination of the Truck Unloading Belt Feeder and the Storage
Feed Conveyor for the transfer of ash to the storage facility.
4) Foundations for the conveyors and area preparation will be required and are included in the estimate.
5) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building located close to the
existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near the
belt feeder.
c) The belt feeder will be provided with a 75 HP VFD motor. The trough conveyor will be provided with 125 HP
motor.
d) Wiring between the local junction box and belt feeder components will be completed by the construction
contractor performing the work.
6) A technical and performance specification package will be developed and issued to the belt feeder vendor for the
conveyor equipment and ancillary equipment.
7) The contractor performing the construction scope of work will receive, unload, and install the equipment.
Assembly will be monitored by the equipment vendor. Design will include drawings and technical specifications
for installing the system components.
Cost Estimate Details1.3.1.3
The estimated costs for trucking material are based on the use of 15 ton trucks to haul processed ash from the truck
loading point in the pond to the ash storage area. The round trip is approximately 5.6 miles over both plant and public
roadways. One hour is estimated per trip including loading, unloading and transit time. It is assumed that the truck
hauling services would be contracted and no capital was estimated for purchase of trucks. An allocation of $350,000
was included for road maintenance over the 13 year period.
Conveyor System1.3.2
Horizontal Trough Conveyor1.3.2.1
Both pipe (tube) and horizontal curve trough conveyors were considered for this application. Trough conveyors are
generally less expensive and have lower power requirements, but are limited to routes where a large horizontal
radius can be accommodated (2500� � 3300�). Pipe conveyors are best suited for conveying material across
environmental sensitive areas and for routes that require use of a tight horizontal radius. The design capacity for AB
Brown, 400 to 700 tph, is at the low end of the size range where a horizontal curved conveyor is economically
competitive with a pipe conveyor. Working with a Supplier, two conceptual routes were developed for AB Brown.
Neither of the proposed routes was viable due to interference with existing operating facilities (coal pile) or would
require significant modification of the barge loading conveyor. In consideration of the design challenges and routing
constraints, a curved horizontal trough conveyor design was not recommended for this application.
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Pipe Conveyor1.3.2.2
A pipe conveyor option to transfer CCR material stored in the ash pond directly to the barge loading system was
evaluated. For this option, the conveyor capacity was increased to 700 tph to increase the barge loading rate and
maintain consistency with the design of the existing barge loading system. This transport option is the recommended
option and is detailed in the main Report.
Another option considered for the pipe conveyor was to transfer CCR material from the ash pond area to a storage
facility in the DFA area. For this approach, the CCR material will be stockpiled in the pond and trucked a short
distance to the Stack Discharge Belt Feeder. In order to ensure maximum production, the trucks will dump the ash
directly into a Stack Discharge Belt Feeder. The 400 tph belt feeder will direct the ash to Ash Conveyor 1 (AC1), a
pipe conveyor, which will transfer ash from the ash pond area to the storage facility. The pipe conveyor routing is
shown later in this appendix.
An interlock will be required for the pipe conveyor option that prohibits the start of the Stack Discharge Belt Feeder
unless Ash Conveyor 1 is running. The interlock will ensure that the belt feeder only operates with a discharge path in
service. The belt feeder and conveyor will be supplied with zero speed sensors and misalignment switches to enable
remote monitoring of the equipment. The pipe conveyor will be designed with a probe to indicate when the ash pile
has reached a maximum height. If reaching maximum height the conveyor will trip.
The equipment required to transfer ash from the ponds to a storage facility in the DFA area is described below.
A. Belt Feeder � Ash Pond Conveyor
1) One trough-belt feeder (Stack Discharge Belt Feeder) designed with a capacity of 400 short tons per hour (stph)will be located in the ash pond area. The feeder will transport ash from the stacking area to Ash Conveyor 1.
2) Foundations for the belt feeder and area preparation will be required. The foundation system is included in theestimate.
3) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be locatedclose to the existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near thebelt feeder.
c) The belt feeder will be provided with a 15 HP VFD motor.
d) Wiring between the local junction box and belt feeder components will be completed by the constructioncontractor performing the work.
4) A technical and performance specification package will be developed and issued to the belt feeder vendor for theequipment and ancillary equipment.
5) The contractor performing the construction scope of work will receive, unload, and install the equipment.
Assembly will be monitored by the equipment vendor. Design will include drawings and technical specifications
for installing the system components.
B. Ash Conveyor 1 � Pond to Storage Area
1) One pipe conveyor (Ash Conveyor 1) with a capacity of 400 tph will be required to transport ash from the ashpond area to the storage structure which will be either a storage dome or Eurosilo®.
2) Foundation for the Ash Conveyor 1 will be required and is included in the estimate.
3) A maintenance road will be required along the pipe conveyor and is included in the estimate.
4) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be locatedclose to the existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near theconveyor.
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c) The conveyor will be provided with a 700 HP motor.
d) Wiring between the local junction box and conveyor components will be completed by the constructioncontractor performing the work.
5) A technical and performance specification package will be developed and issued to the conveyor vendor for theequipment and ancillary equipment.
6) The contractor performing the construction scope of work will receive, unload, and install the equipment.Assembly will be monitored by the equipment vendor. Design will include drawings and technical specificationsfor installing the system components.
Cost Estimate Details1.3.2.3
Budgetary quotes were received for the pipe conveyor equipment for this alternative option and a Class 4 cost
estimate was prepared for the installation and are included in Section 1 of this appendix. Lifecycle costs for the ash
pipe conveyor includes the electrical power for the main motor and an allocation for maintenance and operation. One
replacement of the main conveyor belt is included in the cost. This is in addition to an annual allocation for general
inspection and maintenance of the belt. The belt is automatically controlled and requires a nominal amount of
Operations support. One hour per day has been allocated for Operations.
Material Processing Options1.4Several ash processing options were considered in the evaluation to produce an acceptable recycle ash product.
Although multiple processing operations were considered, simple low cost techniques have been identified alongside
the more involved and high cost options.
Ash processing techniques include:
1) Screening
2) Blending
3) Ash Drying
Ash Screening1.4.1
Screening1.4.1.1
Possible methods to screen the CCR material include no processing, use of a scalping screener, or use of a standard
screener. The first of these options, the no processing option, assumes that CCR materials would be sent directly to
Geocycle after sufficient dewatering has occurred. This option was rejected due to the fact that it would allow out-of-
specification material to enter the material handling system and Geocycle�s feedstock, potentially disrupting
operations. Additionally, based on the experience of subject matter experts, the material may form large clumps which
could be retained after transit to Geocycle if no additional processing is conducted. As Geocycle specified that the
material to be less than 0.75 inch in size, clumps in the finished product would also potentially cause production
issues at the plant.
As a result, the CCR materials will be passed through a screener to ensure only appropriately sized materials is
transferred to Geocycle. Options for screening include either scalping screens or standard screeners. Scalping
screeners are intended to remove large oversized objects from the material being processed, while standard
screeners have finer screening processes that are able to produce uniform finished product. Since the majority
(~90%) of the CCR materials within the pond are expected to pass through a standard #4 sieve, use of a separate
standard screener to finely classify material is likely unnecessary. The selected screening method is a scalping
screener, which is further discussed in Section 3.2.5.3 of the Report.
All ash screening operations will occur at the pond in the Conveyor Loading / Ash Staging Area, prior to loading CCR
materials on the conveyor or into trucks.
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Ash Blending1.4.2
Ash blending involves mixing wet recycle ash with dry ash from the existing dry ash storage system. Blending dry ash
with the wet ash provides the following benefits:
· Reduce the water content of the wet recycle ash,
· Reduces the potential for dusting at the barge loading facility, and
· Loading only wet ash reduces the cost, complexity and reliability of the barge loading system.
There are two options for blending wet and dry ash. Both options are based on preliminary designs that must be
verified for feasibility. The first option for blending involves use of the Eurosilo® and was presented by the vendor.
The technology has not been applied for this particular application, but has been applied in similar applications. The
second option is applicable for both the Eurosilo® and dome storage options. There are several blending
technologies available; however, further evaluation is required to determine which is best suited for this application.
· Ash Blending in Eurosilo® - If using Eurosilo® for storage, dry ash can be pneumatically transported to
the silo and blended with the wet recycle ash as it is loaded into the silo. The wet and dry ash will be further
blended when reclaimed from the silo. The blended ash will then be transported to the existing reconfigured
barge loading system that will have to be designed for wet ash loading.
· Standalone Ash Blending - The second blending option can be used with either dome storage or
Eurosilo®. In this option, wet and dry ash will be blended just before transfer to the barge loading pipe
conveyor. A twin screw mixer, pug mill or similar device can be installed in the DFA and used to blend the
wet recycle ash with the dry ash from the existing silo. The blended ash would then be fed to the existing
barge loading conveyor. This option has the advantage of retaining the full capacity of the Eurosilo® to store
recycle ash and it eliminates conveying the dry ash to the Eurosilo®.
Both ash blending options require further evaluation to verify reliability while achieving acceptable levels of fugitive
dust emissions. Blending provides a lower cost option for loading ash into the barges and will likely reduce the barge
loading time. However, blending was not deemed the best option for barge loading. The existing barge loading
system will be modified to handle either wet or dry fly ash instead of a blended product. The blending options
discussions below are for reference and were removed from the main body of the Report as part of the Revision 1
effort.
Blending1.4.2.1
The blending scope included in the estimate, and described below, only applies to the Eurosilo® option. For this
evaluation, a detailed scope and cost were not developed for a standalone ash blending concept (described in
second bullet of 1.4.2 above). The equipment necessary to install a Eurosilo® is described in section 1.5.2 and the
additional blending and storage system is as follows:
1) Pneumatic feed system transporting the dry fly ash from the existing storage silo to the Eurosilo®. The
pneumatic system will consist of:
a) Rotary Air Lock Feeders � 1(1+0), variable speed drive rotary airlock feed valve with a 1.5 hp drive, 25 TPHcapacity
b) Ejector Feeder � 1(1+0), 4� ejector feeder, 25 TPH capacity
c) Conveying Air Blower � 2(1+1), Pressure discharge blower rated for 450 scfm at 13 psig, 50 hp motor withinlet filter and silencer
d) Fly Ash Transfer Feed Bin � 1(1+0), 10�(d) x 6�(h) fly ash feed transfer bin, shop fabricated carbon steelconstruction
e) Manual Fly Ash Feed Bin Isolation Valve � 2(1+1), manual 12� knife gate valve, carbon steel construction
f) Automated Fly Ash Feed Bin Isolation Valve � 2(1+1), automated on/off 12� knife gate valve, carbon steelconstruction
g) Bin Vent Bag Filter � 1(1+0) � Bin vent bag filter, 16 bags in a 4 x 4 array with pulse jet cleaning, 500 cfmvent fan, 1 hp
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h) Fly Ash Conveying and Feed Piping
i) 1 (1+0), carbon steel, 4� SCH 80, 600� total
j) 1 (1+0), carbon steel, 12� SCH 40, 60� total
2) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be located inthe ash pond area.
b) Power and control feeds will be provided from the control cabinets in the new electrical building to localjunction boxes installed near the pneumatic feed system. The power requirements are listed in bullet a.above
c) Wiring between the local junction box and dryer components will be completed by the constructioncontractor performing the work.
3) A technical and performance specification package will be developed and issued to the dryer vendor for theequipment and ancillary equipment.
4) The contractor performing the construction scope of work will receive, unload, and install the equipment.Assembly will be monitored by the equipment vendor. Design will include drawings and technical specificationsfor installing the system components.
Cost Estimate Details1.4.2.2
A Class 4 cost estimate was prepared for the Eurosilo® blending option and shown in Section 1 of this appendix.
Budgetary equipment quotes were received and the construction costs were estimated. Lifecycle costs for blending
include electrical power and an allocation for routine equipment maintenance. Sufficient funds have been allocated
for replacement or major overhaul of the blowers, high wear segments of the transport piping, airlock feeders, valves
and bin vent filter bags. In consideration of the accelerated erosion rates associated with the transport and handling
of fly ash, a larger amount was allocated for the maintenance of this equipment.
Ash Drying1.4.3
The base option for drying the ash is to place the material on concrete pads for dewatering while periodically
mechanically working the material. This method is expected to sufficiently dewater the ash, however as a contingency
plan, an ash drying system can be utilized.
In order to dry the ash, the ash from the pond will be trucked to dryers that will be located adjacent to the ash pond.
The trucks will dump the ash into a belt feeder that will direct the ash to the dryer. The product from the dryer will be
conveyed to a storage building. From there, dry ash will be conveyed to the DFA and then transferred the existing
pipe conveyor as described in Section 3.4, and then loaded on barges. The product from the dryer will have
approximately 15 wt% moisture. The dryers will come equipped with a baghouse filter, cyclone and ID fan to comply
with EPA fugitive dust emission requirements. The PFD for this option is located in the drawing section of this
appendix.
The controls for the dryer will be provided by the vendor. The dryer feeder belt should not be started before the dryer
is in operation and the dryer discharge conveyor is running.
Ash Drying Equipment and Scope of Work1.4.3.1
The following equipment is required for installation of an Ash Drying system.
1) Three 125 ton dryers will be provided. The ash leaving the dryers will have a moisture content of approximately15 wt%. The dryers will come equipped with a baghouse filter and cyclone to comply with EPA fugitive dustemission requirements. The dryer will also be supplied with an ID fan to overcome the pressure drop across thebaghouse and cyclone.
2) 1,000 feet of 2 inch schedule 40 carbon steel piping will be provided to transport natural gas from tie-in point tothe dryers.
3) A slab foundation for the dryers is included in the estimate. The dryers are 8.5 feet diameter and 47 feet long andalso required ancillary equipment. The pad will be 100 feet by 200 feet. The dryers will be located in the ashpond area which will require civil preparation for installation of the foundation.
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4) One storage building will be required to store ash product from the dryer. The storage building will have threesides and an open front to allow dried ash to be stacked and reclaimed with a front end loader. The building willbe 100 feet long and 40 feet wide.
5) The foundation for the dry ash storage building is included in the estimate.
6) One pipe conveyor is included to transport the ash from the storage building to the dome building in the storagearea.
7) One dome storage with discharge belt feeder and conveyor to the existing barge loading pipe conveyor.
8) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be located inthe ash pond area.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near thedryer.
c) Wiring between the local junction box and dryer components will be completed by the constructioncontractor performing the work.
9) A technical and performance specification package will be developed and issued to the dryer vendor for theequipment and ancillary equipment.
10) The contractor performing the construction scope of work will receive, unload, and install the equipment.Assembly will be monitored by the equipment vendor. Design will include drawings and technical specificationsfor installing the system components.
Cost Estimate Details1.4.3.2
A Class 5 cost estimate was prepared for the ash drying scope shown in Section 1 of this appendix. Budgetary
equipment quotes were received and the construction costs were estimated. Lifecycle costs for drying include natural
gas, electrical power, operations and maintenance labor. It was assumed that two operations staff would be required
to operate the dryer, 5 days per week. An additional allocation was included for maintenance staff and replacement
parts. Operations and maintenance costs are expected to be high for this equipment as reflected by the high cost in
the estimate.
Material Storage Options1.5The function of a storage structure is to keep the material out of the weather, allow for further drying and reduce the
potential for fugitive dust emissions. Several options were evaluated for storage of the CCR material at either the ash
pond or in the DFA unloading area. Processed CCR material would be stored in one of these areas prior to being
transported for loadout. In the DFA unloading area, the two options considered were dome storage or Eurosilo®
storage, these options are discussed below. At the ash pond, a fabric storage structure was evaluated and selected
as the preferred option and is discussed in the Report. The dome storage and Eurosilo® discussions below are for
reference and were removed from the main body of the Report as part of the Revision 1 effort.
Dome Storage Option1.5.1
Ash Conveyor 1 will be routed to the top of the dome and will discharge ash into the dome storage. The dome will be
designed to hold 9,500 tons of ash. In order to reclaim the ash from the dome, a front end loader will be required to
feed the Dome Discharge Feeder that discharges to Ash Conveyor 3. The PFD and GA drawings for this option are
located in the drawing section of this appendix.
The Dome Discharge Feeder will be supplied with zero speed sensors, misalignment switches and other devices to
enable remote monitoring of the belt feeder.
The Dome Discharge Feeder will be equipped with an interlock to prevent a feeder start before Ash Conveyor 3 is in
service. The interlock will ensure that the feeder can only operate with a discharge path in service.
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Dome Structure1.5.1.1
1) The ash will be stored in a dome that is 100 feet in diameter and 70 feet tall. The dome capacity will be 9,500tons of ash.
2) Vendor will design and construct the foundation system.
3) Design and construction of the site preparations to provide a construction-ready area for the dome vendor isincluded in the estimate.
4) Stair tower and platforms to access the pipe conveyor equipment located at the top of the dome are included inthe estimate.
5) A technical and performance specification package will be developed and issued to the dome vendor for theequipment and ancillary equipment.
6) Vendor will construct the dome.
Dome Discharge Belt Feeder1.5.1.2
1) One belt feeder (Dome Discharge Belt Feeder) designed with a capacity of 700 tph will be located in the domestorage area. The feeder will transport ash from the storage facility to Ash Conveyor 3.
2) Foundation for the belt feeder and area preparation is included in the estimate.
3) Control Cabinet and Junction Box
(a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be locatedclose to the existing fly ash silo.
(b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near thebelt feeder.
(c) The belt feeder will be provided with a 15 HP VFD motor.
(d) Wiring between the local junction box and components on the belt feeder is completed by the constructioncontractor performing the work.
4) A technical and performance specification package will be developed and issued to the belt feeder vendor for theequipment and ancillary equipment.
5) The contractor performing the construction scope of work will receive, unload, and install the equipment.
Assembly will be supervised by the equipment vendor. Design will include drawings and technical specifications
for installing the system components.
Cost Estimate Details1.5.1.3
A Class 4 cost estimate was prepared for the dome structure and is included in Section 1 of this appendix. AECOM
solicited furnish and erect budgetary quotes from dome storage suppliers. Lifecycle costs for dome storage are
associated with the front end loader required to manage and reclaim material from the dome. Due to the non-uniform
characteristics of the ash, reclaim of material from the dome is a manual operation. One operator for 50 hours per
week, plus the associated cost for the loader and diesel fuel, has been included in the evaluated cost.
Eurosilo® Option1.5.2
Ash conveyor 1 will be routed to the top of the Eurosilo® dome where the ash will descend through a telescopic spout
and be distributed in horizontal layers by means of a screw conveyor system suspended from a slewing-bridge
structure. When the ash is reclaimed, the screw conveyors will reverse and transfer the ash into a chute discharging
to the reclaim conveyor. In order to avoid, uncontrollable ash flow to the reclaim conveyor, a shutter system will be
installed at the discharge of the chute and used during ash reclaim operations. The Eurosilo® is designed to hold at
least 9,500 tons of ash. The PFD and GA drawings for this option are located in the drawing section of this appendix.
The Eurosilo® will be provided with instrumentation so it will be possible to control the ash distribution and reclaim
from a control room. The controls will ensure that it is not possible to start reclaiming the ash before Ash Conveyor 3
is running.
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Eurosilo® Structure1.5.2.1
1) The ash will be stored in a concrete Eurosilo® 78 feet diameter and 107 feet tall. The Eurosilo® storage capacitywill be 9,500 tons. The Eurosilo® bypass and discharge conveyor is included in the vendor scope.
2) The foundation will be designed and supplied by Eurosilo® vendor.
3) Platforms and a stair tower are included in the estimate, so as to provide access to the pipe conveyor equipmentlocated in the Eurosilo®.
4) The site preparation for the Eurosilo® foundations is included in the estimate.
5) Control Cabinet and Junction Box
(a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be locatedclose to the existing fly ash silo.
(b) Power and control feeds will be provided from the control cabinets to local junction boxes installed in theEurosilo®. The following motors are included:
i. Filling screw: 20 HP
ii. Winch System: 10 HP
iii. Slewing Drives (2): 3 HP
iv. Digging Screw: 100 HP
v. Equalizing Screw: 100 HP
vi. Discharge Screw Conveyor (2): 20 HP
(c) Wiring between the local junction box and Eurosilo® components is completed by the constructioncontractor performing the work.
6) A technical and performance specification package will be developed and issued to the Eurosilo® vendor for theequipment and ancillary equipment.
7) Construction of the silo and installation of the internals is included in Eurosilo® vendor scope.
Cost Estimate Details1.5.2.2
A Class 4 cost estimate was prepared for the Eurosilo® option and are included in Section 1 of this appendix. A
budgetary quote was received for the Eurosilo® and construction was estimated. Lifecycle costs for Eurosilo®
storage include maintenance and nominal 2 hours per day of labor. Electrical power associated with the loading and
reclaiming equipment has been included.
Common Equipment � Eurosilo® and Dome Option1.5.3
Ash Conveyor 3 - Storage Area to Barge Pipe Conveyor1.5.3.1
Ash discharged from the storage facility (either the dome or the Eurosilo®) will be collected by ash conveyor 3 that
will transport the ash to the existing barge pipe conveyor.
Ash conveyor 3 will have an interlock so it will only start after the barge pipe conveyor is in service. This will ensure
that the conveyor only operates with an active discharge path.
Storage Runoff Containment1.5.3.2
Any runoff water that has contacted the ash will be collected in the storage runoff containment sump. The sump will
be provided with a submersible pump. The water from the sump will be pumped to a tank truck for disposal. There will
be a local control panel so the truck driver can start and stop the storage containment transfer pumps. The sump will
have a level indicator to alarm when level is high and to initiate a pump shutoff when the sump level gets low to
protect the pumps from running dry.
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Storage Runoff Containment Sump Scope
1) One 8�Wx 8�Lx 8�H concrete sump to collect runoff water from the storage facility will be provided and is includedin the estimate.
2) One pump to transfer the water from the sump to a tank truck is included in the estimate. The pump will be asubmersible pump with a capacity of 75 gpm.
3) One level transmitter to monitor the level in the sump will be provided.
4) 125 feet of 100� carbon steel piping is included in the estimate.
5) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be locatedclose to the existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near thebelt feeder.
c) The pump will be provided with a 5 HP motor.
d) Wiring between the local junction box and components on the belt feeder is completed by the constructioncontractor performing the work.
6) A technical and performance specification package will be developed and issued to the pump vendor for theequipment and ancillary equipment.
7) The contractor performing the construction scope of work will receive, unload, and install the equipment.
Assembly will be monitored by the equipment vendor. Design will include drawings and technical specifications
for installing the equipment.
Cost Estimate Details1.5.3.3
The equipment common to either the Dome Storage or the Eurosilo® option was estimated and included in the Class
4 estimate for each option in Section 1 of this appendix.
Material Transport Options1.6In addition to the Wet and Dry Ash Loading option described in the Report Section 4.2.1, loading of Wet Ash only was
also considered and is described in the following section for reference.
Wet Ash Loading1.6.1
Loading only wet ash through the pipe conveyor and the barge load out can be achieved by blending the dry ash from
A.B. Brown and the dry ash coming in from other Vectren power plants with the wet pond ash. Alternatively, the dry
ash from A.B Brown could be sluiced into the pond and the dry ash coming in from other Vectren power plant could
be landfilled. The costs associated with landfilling this dry ash are included in Table 1.1. Ash Recycle Estimate
Summary. As discussed in the Ash Blending section of this appendix, the scope for ash blending requires additional
evaluation. Unloading wet ash only will require that the existing loading system is modified to accommodate loading
wet ash. The modification will consist of replacing the existing surge bin with a chute. In addition, the existing air slide
will be replaced with a transfer belt feeder and a slewing conveyor. The conveyor will direct the wet ash to a new
loadout spout that will ensure the wet ash is loaded uniformly on the barge. In order to minimize spillage, the belt
feeder and conveyor will be enclosed and equipped with drag conveyors to catch any spillage. The existing dust
collecting system is not required for this option so it can be abandoned in place.
The transfer belt feeder will have an interlock to prevent the ash feeder from starting before the slewing conveyor is in
service. The interlock will ensure that the feeder only operates with having an active discharge path. In addition, both
the belt feeder and slewing conveyor will be unable to start if the spout is not in position to load the ash in the barges.
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Wet Ash Loading Scope1.6.1.1
1) The existing barge loading facility will be upgraded to handle wet ash. The following modifications will beprovided:
a) One chute to replace the existing surge bin.
b) Fully enclosed Transfer Belt Feeder with small drag conveyor to collect dribble and carry back.
c) Fully enclosed Slewing Belt Conveyor with small drag conveyor to collect dribble and carry back.
d) New extendable Loadout Spout replacing the existing spout.
2) The new configuration will be heavier than the existing system so the estimate includes an allowance forstructural steel bracing to ensure the unloading system remains structurally sound.
3) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be locatedclose to the existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near thebarge loading system.
c) The Transfer Belt Feeder will be provided with a 15 HP motor.
d) The Transfer Belt Feeder drag conveyor will be provided with a 2 HP motor.
e) The Slewing Belt Conveyor will be provided with a 15 HP motor.
f) The Slewing Belt Conveyor drag conveyor will be provided with a 3 HP motor.
g) Wiring between the local junction box and components on the belt feeder is completed by the construction
contractor performing the work.
Cost Estimate Details1.6.1.2
A Class 5 estimate for the wet ash barge loading system was prepared with budgetary vendor quotes and a factored
construction estimate. It is included in Section 1 of this appendix. Lifecycle costs for wet ash barge loading includes 2
operators for 50 hours per week. The estimated barge loading time is 4 hours per barge to load up to 10 barges per
week. Electrical power and an allocation for maintenance of the barge loading conveyors have been included.
Implementation of this option would also require that the dry fly ash from the F. B. Culley and Warrick plants, currently
exported through the existing dry fly ash barge loading system at A. B. Brown, would need to be disposed of. Costs to
landfill the F. B. Culley and Warrick dry fly ash is estimated and included in Section 1 of this appendix.
Rail Car Loading1.6.2
For the rail car loading option, CCR material will be stockpiled underneath a 2 acre fabric structure within in the ash
pond. The structure will cover 4 windrows, each 30� (w) x 15� (h) x 200� (L), and provide a staging area for the
processed material.
As with the previous pond storage option, a payloader or dozer will be used to push processed ash into the Stack
Discharge Belt Feeder via a subgrade reclaim hopper. The 700 tph belt feeder will direct the ash to Pond Discharge
Conveyor. Ash will then be conveyed to a transfer tower where it will be fed to the Rail Car Loading belt feeder. The
Pond Discharge Conveyor will be a pipe conveyor with a capacity of 700 tph.
The rail car loading station will be located on the rail loop, just to the east of the trestle. A conceptual arrangement for
the pond storage area, conveyor, belt feeders and rail car loading station is shown in the drawings included in this
appendix. Ash would be loaded directly into rail cars from a chute at the end of the belt feeder. Table 1 summarizes
typical rail car capacity and loading times. At a maximum feed rate of 700 tph, a rail car would be loaded in 15 -20
minutes.
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Table 1. Rail Car Capacity and Loading Time
Description Units Value
Inputs:
Maximum Ash Production tpw 12,000
Rail Car Size cyd 4,300
Rail Car Capacity tons 120
Maximum Feed Rate tph 700
Loading Efficiency % 50 � 70%
Calculated:
Time to Load Rail Car minutes 15 � 20
Time to Load 25 Cars hours 6 � 9
Rail Cars per Week # rail cars 100
Loading all the CCR material in rail cars will require 4 loadouts per week at the maximum production rate. Rail cars
can be loaded, and then moved to an available spur line until sufficient cars are loaded for a unit train. Approximately
100 cars per week would be required at maximum ash production capacity.
The belt feeders and transfer pipe conveyor would all be equipped with a variable speed drive and the capacity to be
stopped and restarted. The ash loading rate would be measured with an in-motion scale. Rail cars would be
automatically positioned using a remotely operated shuttle car and optical sensors.
A summary of the evaluated scope for this option is as follows:
Belt Feeder � Ash Pond Conveyor1.6.2.1
1) One trough-belt feeder (Stack Discharge Belt Feeder) designed with a capacity of 700 short tons per hour (stph)
will be located in the ash pond area. The feeder will transport ash from the stacking area to Pond Discharge
Conveyor.
2) Grizzly and reclaim hopper will be provided. This will make it possible to have a dozer push the ash into the
reclaim hopper that feeds the Stack Discharge Belt Feeder.
3) Foundations for the belt feeder and area preparation will be required. The foundation system is included in the
estimate.
4) A transfer tower structure will be provided to feed the ash from the Stack Discharge Belt Feeder to the Pond
Discharge Conveyor.
5) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be located
close to the existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near the
belt feeder.
c) The belt feeder will be provided with a 50 HP VFD motor.
d) Wiring between the local junction box and belt feeder components will be completed by the construction
contractor performing the work.
6) A technical and performance specification package will be developed and issued to the belt feeder vendor for the
equipment and ancillary equipment.
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7) The contractor performing the construction scope of work will receive, unload, and install the equipment.
Assembly will be monitored by the equipment vendor. Design will include drawings and technical specifications
for installing the system components.
Pond Discharge Conveyor � Pond to Rail Car Loading Feeder1.6.2.2
1) One pipe conveyor (Pond Discharge Conveyor) with a capacity of 700 tph will be required to transport ash from
the ash pond area to the Rail Car Loading Conveyor. Approximate run length of 1,600 feet.
2) Foundation for the Pond Discharge Conveyor will be required and is included in the estimate.
3) A maintenance road will be required along the pipe conveyor and is included in the estimate.
4) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be located
close to the existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near the
conveyor.
c) The conveyor will be provided with a 350 HP motor.
d) Wiring between the local junction box and conveyor components will be completed by the construction
contractor performing the work.
5) A technical and performance specification package will be developed and issued to the conveyor vendor for the
equipment and ancillary equipment.
6) The contractor performing the construction scope of work will receive, unload, and install the equipment.
Assembly will be monitored by the equipment vendor. Design will include drawings and technical specifications
for installing the system components.
Belt Feeder - Rail Car Loading Feeder1.6.2.3
1) One belt feeder (Rail Car Loading Feeder) designed with a capacity of 700 short tons per hour (stph) will be
located in rail car loading area.
2) Foundations for the Rail Car Loading Feeder and transfer tower will be required. The foundation system is
included in the estimate.
3) A transfer tower structure will be provided to feed the ash from the Pond Discharge Conveyor to the Rail Car
Loading Feeder.
4) Control Cabinet and Junction Box
a) The main control cabinets/PLCs will be mounted remotely in a new electrical building that will be located
close to the existing fly ash silo.
b) Power and control feeds will be provided from the control cabinets to local junction boxes installed near the
belt feeder.
c) The belt feeder will be provided with a 15 HP VFD motor.
d) Wiring between the local junction box and belt feeder components will be completed by the construction
contractor performing the work.
5) A technical and performance specification package will be developed and issued to the belt feeder vendor for the
equipment and ancillary equipment.
6) The contractor performing the construction scope of work will receive, unload, and install the equipment.
Assembly will be monitored by the equipment vendor. Design will include drawings and technical specifications
for installing the system components.
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– Ash Valuation StudyAppendix M
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1. Environmental and RegulatoryConsiderations
There are a number of key environmental and regulatory considerations associated with implementation of both
the CbR and CiP alternatives. In summary, the CbR and CiP scenarios will be implemented under the provisions
of the recently-promulgated Federal CCR Rule (40 CFR 257). However, the regulatory scenario is complicated in
that Indiana is currently still relying upon its Surface Impoundment Closure Guidance which in many ways is
more stringent than the CCR Rule. In addition, there is also some level of future regulatory uncertainty regarding
the requirements that apply to closure of CCR Surface Impoundments in Indiana. In the short term, Indiana has
decided to adopt an emergency rule (on February 10, 2016) incorporating the Federal CCR Rule into 329 IAC 10.
The amendments in the emergency rule became permanent on December 10, 2016. Looking forward, the
Indiana Department of Environmental Management (IDEM) plans to update Indiana’s regulations pertaining to
CCR disposal facilities. While these future regulations are intended to be generally equivalent to the CCR Rule, it
is likely given the current guidance and IDEM’s position on certain matters on other similar facilities within Indiana
that the future regulations will be more stringent than those of the Federal CCR Rule. For the purposes of this
evaluation, it is assumed that the project will be designed to comply with the Federal CCR Rule. However, certain
additional elements have also been included, where appropriate, based on the IDEM Surface Impoundment
Closure Guidance as well as agency precedents/positions established during review of other CCR surface
impoundment closure projects. AECOM recommends that design and other closure-related technical criteria be
reviewed with IDEM prior to completion of design for the selected alternative and required closure plan
submission.
In the addition to the uncertainty regarding regulatory considerations, there are a number of additional key
regulatory and environmental considerations pertaining to other elements of the closure scenarios. These items
are addressed in the following sections.
Beneficial Use Considerations for Closure by1.1
Removal ActivitiesThe CCR Rule contains certain provisions that allow for and promote beneficial use of CCR material. Benefical
use of CCR means the CCR meets all of the following conditions:
1) The CCR must provide a functional benefit;
2) The CCR must substitute for the use of a virgin material, conserving natural that would otherwise need to be
obtained through practices, such as extraction;
3) The use of the CCR must meet relevant product specifications, regulatory standards or design standards,
when available, and when such standards are not available, the CCR is not used in excess quantities; and
4) When unencapsulated use of CCR involving the placement on the land of 12,400 tons or more in non-
roadway applications, the user must provide certain defined technical demonstrations (40 CFR 257.53).
The Federal CCR Rule does not apply to certain practices that meet the definition of a beneficial use of CCR.
Based on the proposed end use of the CCR in the CbR scenario, the material is believed to meet the first three
items above. With respect to Item 4, the material is not believed to be “encapsulated” rather than
“unencapsulated” in its end use. Encapsulated beneficial use is defined as a “beneficial use of CCR that binds
the CCR into a solid matrix that minimizes its mobilization into the surrounding environment.” Examples of
“unencapsulated use” include use of CCR in flowable fill, structural fills, waste stabilization/solidification, use in
agriculture as a soil amendment, and aggregate.
These considerations have specific application to staging, storage, loading and/or processing of CCR outside the
Ash Basin limits in the CbR scenario. Areas of storage or processing of CCR outside a defined Surface
Impoundment or Landfill would normally be defined as a “CCR Pile.” CCR Pile is defined as “any non-
containerized accumulation of a solid, non-flowing CCR that is placed on land. CCR that is beneficially used off-
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site is not a CCR Pile.” However, in order to not be considered a CCR Pile (and subject to the Landfill provisions
of the Federal CCR Rule”, the material must be “containerized.” The term “containerized” is defined as placement
of CCR on an impervious base such as asphalt, concrete, or a geomembrane; leachate (contact water) and run-
off collection; and walls or wind barriers. These provisions would apply to staging, storage, loading, and or
processing of CCR areas in the CbR scenario.
NPDES Permitting Related to Dewatering1.2
ActivitiesNational Pollutant Discharge Elimination System (NPDES) permitting in Indiana is a dynamic process as the state
works to integrate the new Effluent Limitation Guidelines, the National Recommended Water Quality Standards
(WRWQS) as well as address permitting for CCR-related dewatering into existing NPDES permits. With respect
to these considerations, a number of specific assumptions are needed with respect to management of dewatering
and other contact water flows prior to and after plant shutdown.
AECOM understands that the CiP scenario would not be implemented until after plant shutdown. Therefore, pre-
shutdown and pre-closure water management is assumed to continue under the existing water management
scenarios. In the CbR scenario, AECOM understands that material excavation would occur as early as late 2018.
In this scenario, it is assumed that flow regime would consist of the current stormwater and process flows plus
dewatering flows. Further, excavation will be initiated in the upper pond area and the lower pond will continue to
be used for settling capacity until plant shutdown. Thus, operations will continue under the current management
practices and NPDES-related provisions. It is assume that the lower pond will provide adequate setting capacity
and no additional treatment will be needed.
Following plant shutdown in both the CiP and CbR scenarios, it is assumed that the current non-stormwater flows
(i.e., plant process and non-process streams) into the pond will cease. Efforts will be made to divert stormwater
around the pond to the extent possible. However, contact stormwater as well as dewatering flows will still require
management either as part of the new combined cycle operation or under the terms of a modified NPDES permit
with dewatering flows included. Because the current NPDES permit (dated February 28, 2017) includes
monitoring of typical parameters associated with CCR, it is possible that a minor modification could be granted by
IDEM to discharge dewatering flows under the current permit provisions. However, following a period of
monitoring data collection, it is anticipated that mixing zone and wasteload allocation (WLA) calculations to
calculate Water Quality Based Effluent Limitations (WQBELs) as part of a Reasonable Potential Evaluation
(RPE).
The level of treatment which may be required for discharge of dewatering wastewaters is unknown. For other
similar facilities, this typically involves solids removal (i.e., settling, filtration, etc.) prior to discharge. However,
because the facility ultimately discharges to the significant flow of the Ohio River, WQBELs may be more
favorable that for other facilities. Due to the unknowns associated with future NPDES permit/treatment
requirements and the understanding that some level of onsite treatment will be required for ongoing post-
shutdown flows, it is assumed that these flows will be conveyed, comingled and treated at a centralized facility.
The costs for this treatment facility have not been provided in this evaluation.
Post-Excavation “How Clean is Clean?”1.3Standard for Closure by Removal Activities
Because CCR material will be entirely removed under the CbR scenario, a demonstration of “clean closure” will
be required following completion of excavation. The Federal CCR Rule states that closure is achieved when all
CCR in the surface impoundment is removed. The rule also states “CCR removal and decontamination of the
CCR unit are complete when constituent concentrations throughout the CCR unit and any areas affected by
releases from the CCR unit have been removed and groundwater monitoring concentrations do not exceed the
groundwater protection standards” in Appendix IV.
In addition to the Federal CCR Rule, IDEM Surface Impoundment Closure Guidance generally defines “clean
closure” as removal of material to “background concentrations.” However, IDEM has been increasingly open to
consideration of a less-onerous risk-based approach consistent with that of other states.
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For the purpose of this evaluation, it is assumed that 2 feet of soil material below the base grades of the unit will
be removed in the CbR scenario. In addition, it is assumed that that post-closure groundwater monitoring will only
be required under the CiP scenario.
Environmental Impacts/Regulatory1.4
Considerations for Truck Haul Road, ConveyorSystem, and Barge Loading/Unloading System
In order to deliver the wet ash to the barge loading/unloading system, AECOM is proposing delivery either by
truck via a haul road or a conveyor system. Potential environmental impacts and presumed regulatory
considerations are summarized below for both options of wet ash transport and for the required improvements to
the barge loading/unloading system.
Truck Haul Road1.4.1
The proposed truck haul road would originate at the northwest corner of the upper pond and will traverse north
through the AB Brown property until reaching West Franklin Road. Truck traffic would travel south on West
Franklin Road to the proposed fly ash storage location. Portions of this existing access road are unpaved and
therefore, dust suppression would be necessary in order to control fugitive dust emissions. Best Management
Practices (BMPs), such as having a water truck available during hauling activities to ensure the haul road is
sprayed down on a regular basis, should be implemented for fugitive dust emission control. No other potential
environmental impacts and/or regulatory considerations are presumed to be necessary given this road consists of
existing paved and unpaved roads.
Conveyor System1.4.2
USACE Permitting
An alternative to the truck haul road is a conveyor system which would transport the wet ash to the barge loadout
system. Similar to the truck haul road, the conveyor would originate at the northwest corner of the upper pond but
would travel in a general southwesterly direction to the proposed fly ash storage location. Section 404 of the
Clean Water Act (CWA) requires a permit before dredged or fill material may be discharged into waters of the
United States (WOTUS), including wetlands. A wetland/stream delineation along the path of the conveyor is
recommended in order to fully understand the extent of necessary USACE permitting.
If USACE permitting is necessary, Vectren would need to adhere to the U.S. Fish and Wildlife Service’s (USFWS)
Indiana bat tree clearing schedule restrictions. According to the “Indiana Bat (Myotis sodalis) Draft Recovery
Plan: First Revision, April 2007”, tree clearing should only occur from October 15 to March 31 in areas that
contain potential summer habitat, such as Posey County. Tree clearing is defined as the removal of all trees � 5-
inches in diameter at breast height (dbh), or 4.5-feet above the ground, and does not include the selective
removal of suitable Indiana bat roost trees.
Rule 5 Stormwater Construction Permit
Construction activities associated with construction of the conveyor system and the proposed fly ash storage
location resulting in greater than one-acre of disturbed land would require a Rule 5 Stormwater Construction
Permit. This could include support structures for the conveyor, any laydown areas, access roads, etc. Rule 5
requires the development of a Construction Plan which includes a Stormwater Pollution Prevention Plan
(SWPPP). The SWPPP would provide details concerning erosion and sediment controls.
Barge Loading/Unloading System1.4.3
USACE Permitting
In order for the existing barge loadout system to be able to accommodate the wet, heavier ash, improvements will
be necessary, such as adding supports to the loadout system which will be located below the ordinary high water
mark (OHWM) of the Ohio River. Section 404 of the CWA requires a permit before dredged or fill material may be
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discharged below the OHWM of a United States Army Corps of Engineers (USACE)-jurisdictional stream, or a
WOTUS. A wetland delineation along the bank of the barge loadout system plus any other areas where
construction activities associated with this system are anticipated is recommended in order to fully understand
the extent of necessary USACE permitting. In addition, the USACE is required to consult with the US Fish and
Wildlife Services who will likely request a mussel survey be conducted in the vicinity of the limits of disturbance in
the Ohio River.
Construction in a Floodway
The barge loadout system is located in the FEMA-regulated floodway and 100-year floodplain. Construction
projects located in a floodway can result in varying degrees of loss of the effective cross sectional flow area at a
project site as well as upstream and downstream of a project site. For many projects that result in a negligible
cumulative loss of the effective cross sectional flow area, the Indiana Department of Natural Resources (IDNR)
has developed non-modeling hydraulic assessment worksheets that document and compute the effect the project
will have on the effective cross sectional flow area without requiring extensive hydrologic and hydraulic (H&H)
computer modeling for the permit application. Projects that are not eligible for a non-modeling assessment
approach or larger projects which may cause an increase to the base flood elevation of more than 0.14-foot.
AECOM cannot make a determination on whether H&H modeling will be necessary for this project until additional
design details are available.
Public Notice must be served to the adjacent property owners after the Construction in a Floodway permit
application is received by the IDNR. An adjacent property owner is someone whose property shares a common
border or point with the tract of land where the proposed construction will take place and within a 1/4 mile of the
construction limits. Also, a Mitigation Plan will be necessary if wetland impacts exceed 0.1-acre in the regulated
floodway.
Summary of Regulatory Permitting for Closure1.5by Removal
The CbR of the Ash Pond will require procurement of various regulatory permits prior to initiating or completing
closure construction activities. The regulated activities and anticipated subsequent permits are as follows:
1) USACE Section 404 Individual Permit –The barge loadout system may require improvements in order to
handle wet ash for the geocycle option. These improvements will likely involve adding supports to the barge
loadout system in order to accommodate the heavier and larger conveyor components. In the event these
improvements involve placement of fill or construction of materials below the OHWM of the Ohio River, an
Individual 404 Permit will be required for potentially significant impacts (it is possible that minor impacts
could be addressed under a Nationwide Permit). In the event an Individual Permit is necessary, significant
permit approval time should be expected (on the order of 1 to 2 years). With respect to wetland impacts, a
wetland delineation/stream assessment is recommended in order to determine if additional permitting will be
required due to construction activities (such as those associated with a conveyor system or processing area)
outside of the Ash Basin within undeveloped land. It is possible design modifications can be made, as
appropriate, to avoid potential wetland impacts.
2) Indiana Department of Environmental Management (IDEM) Individual Section 401 Water Quality Certification
(WQC) - Section 401 WQC is a required component of a federal permit and must be issued before a federal
permit can be granted. It is likely that the CbR activities would result in “more than minimal impacts to water
quality”, according to the IDEM, which can be defined as a cumulative permanent impact of 300 linear feet or
more of WOTUS. It is presumed that the aforementioned improvements to the barge loadout system would
result in greater than 300 feet of linear impact to the Ohio River.
3) Individual NPDES Permit Modification – A modification to Vectren’s existing individual NPDES permit will
likely be necessary in order to include the discharge which will result from the dewatering of the Ash Basin
during closure activities as well as addressing post-closure conditions. Currently, Outfall 004 discharges
emergency stormwater overflow from the Ash Basin. Following the CbR activities, Outfall 004 will discharge
stormwater associated with industrial activity.
4) Dam Modification/Decommissioning Permit - The CbR activities will result in the partial removal of the Upper
and Lower Dams as needed to achieve the final CCR material grading and the final cover grading. Following
CbR activities, the Upper and Lower Dams will be removed from the Indiana Department of Natural
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Resources (IDNR) registry of regulated dams. These activities will need to be addressed through a
permitting process. States vary in how they are approaching permitting and dam decommissioning
associated impoundment closures, but states are typically addressing these activities in a single permit
submittal process where the modifications, project phasing, and decommissioning are addressed.
5) Construction in a Floodway Permit – The placement of fill within the regulated floodway requires IDNR
approval. The aforementioned barge loadout system improvements would likely trigger the need for this
permit. Depending on the amount of fill and/or placed in the floodway would determine if hydraulic modeling
would be required.
6) Posey County Floodplain Development Permit – Any development in an identified flood hazard area requires
approval from the County. The aforementioned barge loadout system improvements might be located in the
100 year floodplain.
7) Rule 5 Stormwater Construction permit (stormwater associated with construction activities) – Any
construction activities occurring outside of the Ash Basin which subsequently results in greater than one acre
of land disturbance would trigger the need for a Rule 5 permit. This could include a potential borrow area,
any laydown areas, access roads, etc. Rule 5 requires the development of a Construction Plan which
includes a SWPPP.
Summary of Regulatory Permitting for Onsite1.6
LandfillAs discussed in Section 3.1.6 of the Report, a sub-scenario of the CiP method was further evaluated whereby, at
some point after the Ash Pond has been closed in place, Vectren would be required or would choose to remove
the CCR materials contained within the closed pond. In this case, a new onsite landfill would be constructed and
the CCR materials would be removed from the closed pond and disposed in the onsite landfill. Following
completion of operation and filling activities, the onsite landfill would subsequently be closed. The proposed
location of the new landfill is to the north of the ABB Station and north of the existing FGD Landfill on property
owned by Vectren. Conceptual design drawings of the proposed onsite landfill are included in Appendix E.
The Onsite Landfill will require procurement of various regulatory permits prior to initiating or completing
construction activities. The regulatory activities and anticipated permitting activities are as follows:
1) Location restrictions for the proposed landfill location were compared against the IDEM Rule 25 criteria
(specifically 329 IAC 10-25-2) and those identified in the CCR Rule (specifically, 40 CFR 257 60-64, and 40
CFR 257 3-1 through 3.3). These regulations address concerns for wetlands encroachment, endangered
species habitat, floodways/floodplain, public water supply, separation from the uppermost aquifer, fault
areas, seismic impact zone, unstable areas, and surface water protection. Multiple sources of publicly
available data were brought together to prepare a preliminary landfill location restriction map. This map,
along with summary tables applicable to the regulatory location restriction criteria, are provided in Appendix
F. Recommendations for further data analysis prior to final design of the landfill and mitigation methods for
possible conflicts are presented below.
a) Several unnamed “streams” are indicated on the location restriction map; however, based on
discussions with Vectren, these may actually be intermittent drainage features. In addition, the National
Wetland Inventory (NWI) data suggest a moderate to high probably of site wetlands. A wetland
delineation/stream assessment is recommended in order to determine if additional permitting will be
required within the footprint of the landfill due to construction activities.
b) A Jurisdictional Determination should be performed for noted streams within the area of the proposed
landfill.
c) Due to the possible presence of two identified endangered bat species, construction activities, including
clearing of any trees, should be accomplished outside the timeframe of bat hibernation. Other seasonal
development restrictions may also apply.
d) The location of existing potable water wells within 600 feet of the limit of waste should be verified.
e) The location of dwellings within 600 feet of the limit of the limit of waste should be verified. A residential
dwelling currently exists at 8200 West Franklin located at the southwest corner of the property.
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f) Necessary zoning changes for landfill development should be identified. The area is currently zoned for
agriculture by Posey County.
g) Further geotechnical analysis should be performed to confirm whether site meets the requirement of the
fault areas, seismic impact zone, and unstable areas within the CCR Rule.
h) An evaluation of the site related to its cultural/historical significance is recommended.
2) USACE Section 404 Individual Permit may be required.
3) An Individual NPDES Permit Modification may be required to include the discharge which will result from the
discharge from the proposed sedimentation basin and/or from the leachate treatment facility. It is also
possible that a new NPDES Permit, as opposed to a modification to the existing permit, would be required
that is specific to the onsite landfill.
4) Air permitting modifications may be required due to the increased activity of hauling CCR materials from the
pond to the new onsite landfill, as well as the associated operation of the landfill.
5) Rule 5 Stormwater Construction permit (stormwater associated with construction activities) – Any
construction activities which result in greater than one acre of land disturbance would trigger the need for a
Rule 5 permit. This would include the landfill area itself, as well as potential borrow areas, laydown areas,
access roads, etc. Rule 5 requires the development of a Construction Plan which includes a SWPPP.
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– Findings and Matrix of Appendix POptions
307
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Appendix P
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Appendix P
Table 7±1: Evaluation Criteria
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Appendix P 309
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Coal Combustion Residuals ManagementIntegrated Life Cycle Services
Cause No. 45280Attachment JDM-2
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The new CCR rule brings new requirements to this already complex industry. We will help you manage demands and mitigate disruptions and risks that could impact your employees, customers and local community—all of which could be costly to your business’s long-term prospects.
Our teams bring the full strength of our insight and knowledge to you. We connect expertise and geographies, delivering the answers you need when you need them.
We work with you, delivering insight so you can navigate and manage all aspects of the industry including the complexities that the new CCR rule presents. Our experts can help you:
− Assess and comply − Upgrade and repair − Close and replace − Convert and dewater − Monitor and report − Remediate − Innovate − Construct
The U.S. Environmental Protection Agency published its new rule tightening regulations for coal combustion residuals management. New mandates are required to meet this already complex requirement.
We understand the challenges you face, and we’re here to help.
1000dedicated CCR specialists
400offices across the U.S.A.
175impoundments benefiting from our services
45utilities receiving our expertise in CCR
Coal Combustion Residuals Management
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Providing a life cycle of services that meet industry standards and responsibly manage CCR, while balancing a safe, profitable and efficient utility operation.
We know that industry knowledge counts, so we put CCR management solutions at the center of our power services. Our professionals know the CCR rule from the inside out.
Each power company defines their needs differently. That’s why we partner with you, combining CCR and power expertise to deliver integrated services across the entire project life cycle. Our insight begins with project planning and extends through construction.
Along the way, we incorporate a thorough knowledge of coal-fired boilers and associated air pollution control systems to deliver customized, cost effective, sustainable and value added services. We foster the best possible innovative results for CCR compliance, new units, dry conversions, dewatering systems, water management and groundwater monitoring/remediation.
ASSESS AND COMPLY
UPGRADE AND REPAIR
CLOSE AND REPLACE
CONVERT AND DEWATER
MONITOR AND REPORT
REMEDIATE
CONSTRUCT
INNOVATE
Life cycle services
Industry RecognitionEngineering News-Record’s 2016 Top 500 Design Firm Survey recognized us as the industry’s #1 firm overall.
#1 Design Firm #1 Hazardous Waste #1 Site Assessment and Compliance #2 Clean Air Act Compliance #4 Power
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Above:Achieved compliance through efficient investigations (reuse of past information) associated with groundwater and structural integrity for existing CCR units.
Used extensive experience in liquefaction to predict a lower potential using complex methods that allowed the CCR unit to remain open.
Assess and complyWe use site characterization measures such as surveys, subsurface investigations, aquifer testing, fate and transport modeling, groundwater assessments, data evaluation, visualization and statistical analysis to determine groundwater corrective actions and CCR and subsurface conditions. And we discuss these concepts with you, providing clear communication channels so that together, we can deliver assessments that satisfy regulators and meet your project needs.
Compliance
Meeting CCR rule requirements can be challenging. Utility and independent power producers are working hard to meet the complex demands. We can help. Our understanding of the complexities of compliance is second to none.
We’ve written extensively on the subject, developing a summary and series of guidance documents about the CCR rule and its applications and are well-versed about the ins and outs of this challenging rule. We’ve also developed strong relationships with key regulators so we can expedite approvals and support you through the compliance process. Given the complexity of the many facets associated with compliance, we foster partnerships with our clients from strategy and planning through construction.
Our team will help your team to understand and meet regulatory deadlines while avoiding issues that impinge on smooth business operations.
Assessment and compliance form the foundation of well-managed CCR operations. We provide engineering solutions that help pinpoint and address issues uncovered during inspections and monitoring.
Assessments
Our assessments identify technical issues at the very beginning of your project, allowing time for strategic planning and evaluations. We focus on facilitating regulatory compliance, establishing costs and determining what and when modifications will be required for each CCR unit.
Coal Combustion Residuals Management
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Below:Led a potential failure mode analysis with client and contractors that delineated impacts for which a targeted remediation plan was developed.
Improved CCR units stability and safety through assessment and implementation of fleetwide remedial measures for CCR units subject to stability and seepage concerns.
Upgrade and repairOur combined knowledge and experience drive upgrade strategies across all forms of sites. And our insight into scheduling, costs and benefits gives you a clear advantage as you work to upgrade your sites.
Repair
Our professionals have completed more than 4,000 dam projects worldwide and are leaders on all types of dams as well as impoundments, dikes and levees. We apply our knowledge to evaluate existing CCR units. We take assessing and repairing deficiencies and other issues into account balancing the cost effectiveness of repair upgrades with closure and replacement to determine the best course of action for you and your CCR sites.
CCR sites and site conditions are varied and we take those variable factors into account when we deliver upgrades and repairs. That’s where our integrated team approach produces results. We combine our key leadership roles in power industry organizations, with CCR management and engineering to provide you with consistent, cost efficient and high quality upgrades and repairs.
Upgrade
We deliver integrated services across the CCR and power markets. Our team incorporates our long-standing expertise in dams, solid waste, power plant engineering, and more through every partnership.
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Close and replaceWe apply innovative analytic tools and methods to CCR closures. When closure is required, our professionals evaluate all options, traditional and non-traditional, so you are prepared and can make the selection of the best possible available approach.
Replacements
When you need to replace your storage with landfill projects, look for a team that has a track record of success. We have permitted and designed landfills throughout the United States and incorporate design features that ease construction and operations.
Innovation is at the core of our work and our customized Opti-Site process identifies candidate sites using geographic information system mapping, decision analysis and detailed criteria.
Our experienced professionals can construct new landfills on a subcontractor or direct hire basis.
Construction is an integral part of our professionals’ experience. We know how to reduce the annual fill materials required, allow gradual operations transitions and select the most suitable closure option.
A deep bench of professional resources can go a long way to delivering a well-planned CCR closure and replacement program. Our dedicated team brings comprehensive planning, order and efficiency to these complex processes. We have the capability to construct closures and replacements whenever and wherever they are required.
Closures
Our pond closure strategies are deliberate and well thought out, bringing you customized and cost effective solutions that incorporate condition assessment and employ materials and cap designs to meet regulatory and post closure requirements.
Coal Combustion Residuals Management
5 AECOM5 AECOM
Left:Provided full life cycle services to deliver and assist in selecting a contractor to implement closure of a 160+ acre impoundment in full compliance with the CCR Rules. Unique challenges were embraced with an alternative evapotranspiration cap system.
Integrated solutions applied to deliver a stable pond closure and repair of a failed embankment incorporating a deep soil mixing wall.
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Below:AECOM, through its joint venture with Advatech, designed and constructed a dewatering system for gypsum.
Provided continuity throughout the lifecycle of the project as the designer for bottom ash and gypsum dewatering facilities, while delivering innovation through a blending process for a dry, stable product.
Convert and dewaterOur solutions are anything but boiler plate. We understand the important place that technology selection holds in meeting plant objectives. Whether it’s extending operating life or meeting today’s environmental regulation, our technical staff designs customized solutions based on our clients’ specific needs, delivering strategies that will optimize plant performance. Our experience covers the marketplace. We’ve worked with nearly all systems with today’s technology including submerged systems, pneumatic ash extractor systems, dewatering bin systems and continuous dewatering and recirculation systems delivering results that meet your goals.
High profile ash pond failures have changed industry standards for conveying and dewatering with new installations and retrofits now using dry fly ash conveying methods.
We can help coal power plant operators with active ash retention ponds evaluate their options and the processes they will need to tackle to convert from wet ash to dry ash systems.
We have completed some of the largest ash conversion projects in the United States over the last decade. A trusted utility partner, our professionals have conducted pilot studies with the Electric Power Research Institute and the United States Department of Energy for first of a kind technologies and processes. And we’ve used that knowledge to help smooth the way for utilities converting coal power plant systems from wet to dry.
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Above:Developed a predictive modelling tool for water balance and quality that facilitated improved operation and better selection of treatment technology(ies).
Established a fleetwide, groundwater monitoring network that compliments existing instrumentation and complies with multiple state and federal programs.
Monitor and reportWe also provide initial and ongoing monitoring to evaluate contamination in response to permit issues, discharge permits, special agency requests and as voluntary actions.
As part of our consulting services, our team documents processes and trains plant personnel on routine inspection requirements. We also use historic data collection and evaluation to monitor projects and develop needed reports.
We understand the essential role that groundwater monitoring and reporting on CCR sites play in your overall operations. Our monitoring and reporting services are top notch and encompass system design and installation, data evaluation and reporting and assessment planning – all developed to meet your compliance needs.
Our experience extends to such efforts as groundwater monitor system design, installation and testing as well as detection, assessment and compliance monitoring.
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Below:Implemented corrective actions during the decommissioning of a coal plant through a targeted remediation plan (saving costs) and focused excavation and removal of impacted soils/groundwater.
Executed an effective in-situ remediation using direct-push technology to inject amendments into the subsurface in order to target and treat delineated areas of impacted soil and groundwater.
RemediateOur approach begins with site condition evaluations that identify alternatives and feasibility evaluations that help target each client’s goals.We handle all types of remedial solutions, tailoring our technologies to your specific site needs. We provide solutions that include such technologies as physical and chemical barrier systems, hydraulic containment/removal and treatment and natural attenuation remedies. Our innovative technologies round out our complete toolkit for each individual project and can provide you with the services needed to make your remediation project a success.
Our long-established relationships with federal, state and local regulatory agencies can provide you with the information you need to make the process run as smoothly as possible.
Remediating CCR sites has long been one of the top challenges within our industry. And with the new CCR rule in place, the path to effective remediation is even more difficult to navigate.
We know. And we can guide you through.
Our engineers and scientists will work with you, providing a customized remediation road map. Our remediation services address the full business life cycle of project needs, from planning to operation to sustainable long-term follow through. From preparing risk assessments to remedial design, construction and operations and maintenance, we unite disciplines and tools to complete and implement soil and groundwater remedial designs across all types of CCR sites.
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InnovateOur innovative approach to our clients’ challenges encompasses such measures as the use of solar installations at closed CCR impoundments or landfills, which can provide multiple opportunities for solar power production and revenue generation. We also enable beneficial reuse and recycling of CCR, using them as ingredients in concrete, structural fill, blasting grit and roof shingles.
We evaluate competing technologies and varied site visualization tools and incorporate our own customized tools including environmental sequential stratigraphy technology, and concise and accurate cost estimates using industry-accepted technology standards (RACER™).
From stabilization, dewatering and modeling technologies to construction and execution innovations, our professionals ensure full compliance delivering turnkey solutions. We are driven and committed to prove ourselves through your success.
Insight and innovation are the keys to effective CCR management. We continuously conduct research and development to provide our clients with best-in-class technologies, pioneering strategies that solve current and future regulatory and operational challenges. We provide design and build, operations and maintenance, monitoring resources, geotechnical services, groundwater modeling, risk assessment, and numerous other innovative and established tools to meet your CCR management needs.
Our experienced professionals balance opportunities for innovation with traditional, low cost and value added solutions. We have a long history of thinking outside of the box, providing power and industrial market sectors with technology research, development, demonstration, commercialization, and technology implementation.
Below:Avoided the high cost and regulatory challenges of a new pond by developing a FGD thickened slurry for dry disposal.
Repurposed a closed landfill through the installation of a solar generating facility over the finished site that doubled the utility’s solar capacity.
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ConstructOur teams apply creative vision, technical expertise, interdisciplinary insight and local experience, addressing complex challenges in new and better ways. Our vast expertise in engineering, procurement, and construction provides our clients with a full-services-aligned approach for development and operations.
We provide a full suite of pre-construction and construction-related services and solutions for projects of varying scope, budget, schedule and complexity. Our services are tailored to fit your needs as your project progresses or increases in complexity.
We’ve tackled all kinds of complex projects including CCR impoundment and landfill construction and closure, wet-to-dry conversions, CCR materials dewatering, roads, water/runoff control, waste product containment,
Below:Provided SCR support steel as part of our dry flue gas desulfurization and selective catalytic reduction retrofits on units 1 and 4 of a fossil power plant.
Delivered barge and heat recovery steam generator stack sections used to provide clean and reliable energy from coal as part of our client’s diversified portfolio of nuclear, gas and renewable generation.
Services across a project life cycle; local knowledge backed by global resources.
These words are more than just catch phrases. They are ingrained philosophies, the keys to managing our clients’ projects. As a leading provider of engineering, procurement and construction services, we have decades of experience in serving your power, oil and gas, mining and water/wastewater needs.
We unite expertise in geotechnical engineering, dewatering, groundwater and remediation, project and program managers, environmental specialists, technology providers, permitting specialists, cost and schedule specialists, consultants, procurement specialists and construction specialists.
groundwater monitoring and remediation and site support facilities, including warehouse and inventory facilities, maintenance/repair shops, engineering and administrative offices, wash bays and change houses.
Our extensive preplanning activities align your project activities and goals while we work with you to develop the overall project roadmap—fitting the key activities and milestones together to meet objectives, and develop a flexible and adaptable work plan and schedule, to meet change management requirements. These activities provide a clear vision of the path to project success.
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The power of the relationship
Our integrated approach means we deliver on all components of the project's life cycle.AECOM offers utilities the benefits of an integrated approach through every phase of a project’s life cycle. Our integrated approach makes AECOM’s broad engineering, procurement, construction and startup service portfolio available under a single contract.
AECOM can help you address the power generation issues of today. We
can implement clean air systems to reduce emissions. We can deal
with regulatory requirements and permitting. AECOM can plan and
implement programs to deal with coal combustion residuals.
The work can be challenging. Obstacles can present
themselves.
We can overcome them together because we’re more to each other than customer and supplier. We’re more than a list of projects in an experience matrix. We’re partners focused on achieving a single goal. Together.
The power of the relationship transcends project goals. It translates into safer, more efficient projects that are delivered on time, within budget while achieving performance goals.
It’s what transforms a good opportunity
into a successful project.
In
novative solutions
Competitive price Integrated delivery
Utilit
y his
tory
Dedicated team
Safety
Value proposition to the utility
This means a quick start up on even the smallest project because a single management team will understand and respond with full knowledge of your expectations and requirements.
The result is improved safety, quality, schedule and cost performance across the board.
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Safety A core value at AECOM
One of the values of a close client relationship is the ability to positively influence quality, schedule, cost and, most importantly, project safety.
AECOM is regularly cited as one of “America’s Safest Companies” and has industry-leading safety statistics.
TVA alliance safety performance
The positive safety results of an alliance relationship and a top-to-bottom corporate commitment to safety are best demonstrated by the safety performance of AECOM.
Safety is a corporate value that is shared at every level of the corporation. CEO Michael Burke was one of nine corporate leaders named by the National Safety Council in 2015 as “CEOs Who ‘Get It.’”
Organizations recognizing AECOM for outstanding safety accomplishments
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12AECOM
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AECOM has been recognized throughout the industry with numerous awards from Power magazine, Power Engineering magazine, Powergrid International, Environmental Business Journal and Platts Global Energy.
Power markets we serve
Hydropower and dams
Hydropower project feasibility studies and concept development
Planning, permitting, design
Engineering, procurement, construction
Dams, reservoirs and hydraulic structures
Power plant design, refurbishment and automation
River basin studies and sustainable water resource planning
Hydrological, topographical and geotechnical investigations
Flood studies and safety evaluations
Asset valuations and management
Proprietary instrumentation and data management system, DamSmartTM
Nuclear
Preliminary project analysis
Private participation/financing advice
Engineering, procurement, construction
Balance of plant
Maintenance
Major modifications, such as steam generator replacements
Public involvement, planning and implementation
Environmental resource studies and impact assessment
Permitting
Project and construction management
Waste treatment advisory services
Decommissioning and demolition
Coal, natural gas, geothermal
Coal, natural gas, geothermal EPC
CCR management (compliance, engineering and construction)
Least cost generation expansion planning
Power plant feasibility studies concept design
IPP project planning and development
Power systems analysis, system planning, protection, controls and SCADA
Fuel conversion (turbines and boilers)
Major retrofits, such as clean air systems
Engineering, procurement, construction
Due diligence/investigations
Rehabilitation and upgrades
Asset management
Transmission and distribution
Network consulting, outage sequencing, planningPower systems analysisSubstation and transmission line designEarthing analysis and designPower system protectionCommunicationsSCADA and energy management systemsLoad dispatch centersMeteringAsset valuations and managementEngineering, procurement, constructionProgram managementHigh voltage underground / underwater cablesSystem planning
Renewable energy
Preliminary project analysis
Wind assessments
Load forecasting
Private participation / financing advice
Engineering, procurement, construction
Public involvement, planning and implementation
Environmental resource studies and impact assessment
Permitting
Project and construction management
Start-up
Smart energy
Energy management
Energy efficiency
Grid modernization including microgrids
Battery storage
Integrated smart infrastructure
ESPC/ESCO
Environmental permitting, public involvement, and planning
Engineering, procurement, construction
Combined heating and power
Distributed energy
High performance buildings and communities
Smart Cities
14
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For more information, contact:
Mark Rokoff, P.E. National Practice Lead, CCR Management T 1-216-215-5419 E [email protected]
aecom.comP_FF_CCR_Management_LifeCycleServices_20161212
©2016 AECOM. All Rights Reserved
About AECOM
AECOM is built to deliver a better world. We design, build, finance and operate infrastructure assets for governments, businesses and organizations in more than 150 countries. As a fully integrated firm, we connect knowledge and experience across our global network of experts to help clients solve their most complex challenges. From high-performance buildings and infrastructure, to resilient communities and environments, to stable and secure nations, our work is transformative, differentiated and vital. A Fortune 500 firm, AECOM had revenue of approximately $17.4 billion during fiscal year 2016. See how we deliver what others can only imagine at aecom.com and @AECOM.
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