ADEM Public Hearing March 30, 2021 Proposed Coal Combustion Residuals Permits under the Solid Wastes and Recyclable Materials Management Act for Alabama Power Company

ADEM Public Hearing
March 30, 2021
Proposed Coal Combustion Residuals Permits under the Solid Wastes and Recyclable Materials Management Act for Alabama Power Company

PEP Statement
presented by Jennifer Denson, Executive Director

Partners for Environmental Progress (PEP) is a non-profit organization of local business leaders who share the vision of applying science-based environmental best practices to business and community issues. PEP members support strong economic growth balanced with sound environmental stewardship. Our 220+ member companies represent large and small manufacturers, shipbuilders, engineering firms, industrial suppliers, and support services. Together, they employ more than 22,000 local individuals. PEP member companies routinely go above and beyond government regulations and compliance to implement innovative projects to reduce their carbon footprint and to protect and conserve the local natural resources that make the Alabama Gulf Coast a desirable place to live and work.

On behalf of the PEP Board of Directors, after careful review of many sources of information and facts, PEP supports ADEM’s issuance of Alabama Power’s Coal Combustion Residuals (CCR) permit to close the Plant Barry Ash Pond and the CCR permit to operate for the Plant Barry Gypsum pond.

In 2015, the EPA provided two equally safe and protective options for utilities to choose to close their coal ash ponds: a.) cap in place; b.) excavate and transport tons of ash to a lined landfill. The subsequent 2018 ADEM State CCR program requires Alabama Power to submit a closure plan for approval. Both EPA approved options are challenging, expensive and have risks.

Coal ash ponds have their own specific geographic or hydrologic features that provide different risks and benefits. Therefore, there is not a one size fits all approach. The decision for each pond should be based on the features of that pond and in the best interests of the environment and the local community.

Alabama Power has developed a workable plan to cap the ash in place. This plan complies with all state and federal guidelines and in fact, goes above and beyond what is required. Using advanced engineering, redundant systems and other plans, Alabama

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Power is addressing the risks inherent to ground water, flooding, and community impact. Alabama Power has developed a plan that they feel the science supports as the safest long-term plan compared to the risks associated with the excavation and transportation option.

The coal ash pond at Plant Barry has a unique natural solid clay layer that extends up to 28 feet below the ash pond. This is a significant natural barrier to protect the ground water. Scientific analysis by Marlon Cook, Plant Barry Hydrogeologic Conditions Summary, 2019, commissioned by the Mobile Bay National Estuary Program, finds that once de-watered contamination of the alluvial and Miocene aquifers underlying the pond at Plant Barry would be highly unlikely. If it occurs, It will reach only a small, isolated portion of the floodplain.

Alabama Power began monitoring groundwater under the pond in 2016 and found some leaching of certain heavy metals into the alluvial aquifer. However, there is no impact or risk to neighbors, nearby waterways or drinking water sources. As mentioned, the clay layer above the alluvial aquifer largely restricts water from the pond going into the river supply. The alluvial aquifer does not flow to drinking water sources but to the Mobile River. The small amount of leaching moves three feet per year to the river. Once the materials reach the river, the quantity and speed of the river carry them downstream and makes them almost impossible to detect. Once there, the low concentrations in the river present little if any health risks to humans. It is expected that the dewatering of the ash will prevent additional leaching. If it does not, Alabama Power is required by ADEM to find other means of mitigation.

Alabama Power’s plan to dewater, cap in place and monitor, goes above and beyond regulation to include additional risk management features. To close the pond and control and manage flood risk, Alabama Power will:

• Provide advanced water treatment to the water removed from the coal ash ponds to be sure it meets environmental standards before it is removed.
• Reduce the size of the ash pond by 45% by excavating and moving material farther away from rivers and waterways, creating an additional buffer of 750 yards from the Mobile River.
• Construct a redundant dike system.
• Route stormwater runoff into an adjacent pond.
• Develop a drainage system that will channel any water infiltrating the ash into an onsite water treatment plant.
• Build a subsurface retaining wall around the entire consolidated pond as an additional groundwater protection. The retaining wall will extend below ground and tie into the clay layer to effectively seal the material in place.

• Install a specially engineered barrier over the top of the ash to keep it place and to avoid penetration.
• Alabama Power will monitor groundwater around the pond for at least thirty years.

  There are significant risks involved with the other option to excavate and relocate the ash to an offsite lined landfill. The number of trucks required to move the 22 million cubic yards of ash will significantly increase, perhaps double the time, to complete the project, compared to cap in place. This will increase the risks to the health and safety of workers. ALDOT anticipates additional traffic accidents will occur due to additional trucks on the limited roadways around the site. Plus, the lined landfills in our state are either too close to drinking water sources to be a feasible option or are mostly located near poor or minority communities which already have a disparate lack of resources.

  ADEM’s review of the Alabama Power permit has determined the proposed facility will be in compliance with the State and federal solid waste disposal requirements and therefore, protective of public health and the environment. PEP supports the conditions ADEM has set for the permit, including groundwater monitoring, maintaining the integrity of the final cover system throughout the life and post-closure period and the establishment of corrective action requirements to remediate in case of contamination.

  Considering ADEM’s findings and Alabama Power’s additional methods to control and manage flood risk, PEP supports the issuance of the permits to allow Alabama Power Company to implement their plans for the coal ash pond closures at Plant Barry and to operate the Gypsum pond.