huntington power plant - berkshire hathaway energy · 2015 coal combustion residuals annual...

2015 Coal Combustion Residuals Annual Inspection

Huntington Power Plant Huntington CCR Landfill

Prepared for PacifiCorp Energy North Temple Office 1407 West North Temple Salt Lake City, Utah 84116

Final December 29, 2015

URS Corporation 756 East Winchester, Suite 400 Salt Lake City, Utah 84107

2015 Huntington CCR Landfill Inspection i

Contents1 Findings ................................................................................................................................................. 1

2 Description and History of Huntington CCR Landfill ............................................................................. 3

2.1 General Overview ......................................................................................................................... 3

2.2 Location ......................................................................................................................................... 3

2.3 Huntington CCR Landfill Description ............................................................................................. 3

2.4 History ........................................................................................................................................... 4

2.5 Construction History ..................................................................................................................... 4

2.6 Review of Operating Record Files ................................................................................................. 4

2.6.1 Design and Construction Information ................................................................................... 4

2.6.2 Previous Periodic Structural Analyses ................................................................................... 5

2.6.3 Results of Inspection by a Qualified Person .......................................................................... 5

2.6.4 Results of Previous Annual Inspections ................................................................................ 5

3 Field Inspection of Huntington CCR Landfill ......................................................................................... 5

3.1 General .......................................................................................................................................... 5

3.2 Huntington CCR Landfill Geometry ............................................................................................... 6

3.3 Instrumentation ............................................................................................................................ 6

3.4 Volume of CCR .............................................................................................................................. 6

3.5 Observed or Potential Structural Weaknesses ............................................................................. 6

3.6 Observed Changes ........................................................................................................................ 6

4 Limitations and Consultant Qualifications ............................................................................................ 7

4.1 Limitations ..................................................................................................................................... 7

4.2 Professional Engineer Qualifications ............................................................................................ 7

5 References ............................................................................................................................................ 7

Appendices

Appendix A Photograph Log

Appendix B Annual Inspection Report Form

Appendix C Example PacifiCorp Inspection Form

2015 Huntington CCR Landfill Inspection 1

1 FindingsThis annual inspection and report are being completed for the purpose of providing due diligence by

PacifiCorp to ensure the safety of its coal combustion residual facilities. The inspection was performed

according to the requirements for annual inspections under Section 257.84 (for CCR landfills) of 40 CFR

Parts 257 and 261, Hazardous and Solid Waste Management System; Disposal of Coal Combustion

Residuals from Electric Utilities, Final Rule, dated April 17, 2015 [11].

URS found no observations, such as slumps, tension cracks or other movements that would indicate

imminent failure of the embankment for the Huntington Power Plant CCR Landfill (aka New Ash

Landfill). Figure 1‐1 on the following page is an aerial photograph of the landfill.

All of the photos in the Photograph Log in Appendix A are showing landfill conditions as a baseline to

compare when performing future inspections.


Figure 1‐1. Huntington Power Plant CCR Landfill


The CCR requirement for signage is not applicable to landfills. They are only required for surface water

impoundments. The following Figure 1‐2 shows a sign located at the entrance for the Huntington CCR

Landfill. The CCR Landfill landfill does not accept hazardous wastes.

Figure 1‐2

2 DescriptionandHistoryofHuntingtonCCRLandfill

2.1 GeneralOverviewThe Huntington Power Plant is owned and operated by PacifiCorp

The Huntington CCR Landfill is situated southeast of the Old Ash Landfill, and approximately 0.8 miles

southeast of the plant. Dry FGD scrubber waste, fly ash, and bottom ash is delivered to the Huntington

CCR Landfill by truck.

2.2 LocationThe Huntington Power Plant is located in Emery County, Utah, approximately seven miles northwest of

Huntington, Utah in Huntington Canyon, just west of Utah Highway 31 (UT‐31). Access to the plant is

provided by a paved road, which follows Deer Creek up a small tributary canyon of Huntington Canyon

and terminates at the Deer Creek Mine. See the vicinity map on Figure 1‐1 for the site location.

2.3 HuntingtonCCRLandfillDescriptionThis study specifically addresses the only active CCR Landfill.

A summary of pertinent data for the Huntington CCR Landfill is provided in Table 2‐1.


Table 2‐1. Huntington Power Plant CCR Landfill Pertinent Data [2]

Parameter Description Facility

CCR Landfill

Approximate Current Area (acres) 551

Length (feet) 2,2001

Width (feet) 1,5001

Top Elevation (feet) 6690

Slopes (H:V) 3:12

Status Active Notes: H = Horizontal; V = Vertical 1. Value was estimated based on surface measurements from 2014 aerial

photographs. 2. Personal communication with Mr. Darce Guymon, Huntington on October

22, 2014. On final slope only.

2.4 HistoryBased on both verbal communication with plant staff and review of the supporting information, there is

no history of embankment failures for the Huntington CCR Landfill. Only minor surface erosion of the

landfill slopes has occurred and it has been contained on site. Small, inconsequential slumps observed

on the temporary filling slopes of the Landfill are contained within the landfill. Runoff containing CCR is

collected and retained in the Landfill Retention Basin and it has had no known discharges.

2.5 ConstructionHistoryIn 2002 the Huntington CCR Landfill began operating. Overburden material suitable for use as cover [9]

was stockpiled. Refer to Photo 1 showing stockpiled topsoil. Initial construction included the

construction of a retention basin below the final toe to capture runoff from the Huntington CCR Landfill.

The landfill was constructed on a relatively flat plateau in a small valley bounded on three sides.

2.6 ReviewofOperatingRecordFilesThe list of operating records to be reviewed during the annual inspection as contained in 40 CFS §257,

Disposal of Coal Combustion Residuals for Electric Utilities is “CCR unit design and construction

information required by §§2557.73(c)(1) and 257.74(c)(1), previous periodic structural stability

assessments required under §§257.73(d) and 257.74(d), the results of inspections by a qualified person,

and results of previous annual inspections”[11]. The following subsection describes the review of

operating record files.

2.6.1 DesignandConstructionInformationThe design drawings by CH2M Hill [14] for the Huntington CCR Landfill are retained in at the plant. In

2015, more current drawings were prepared by WET [12, 13] showing the boundary of the landfill and

the stormwater capture areas.


2.6.2 PreviousPeriodicStructuralAnalysesThere is no structural stability analysis for the Huntington CCR Landfill.

2.6.3 ResultsofInspectionbyaQualifiedPersonThe Huntington Landfill is subject to periodic inspections by the Huntington Power Plant staff. URS

reviewed the inspection reports; however, this is the beginning of the first cycle of inspections under

CCR regulations and the record is limited to a few weeks of inspections. These inspections are

documented and retained by PacifiCorp. A sample of this PacifiCorp’s Inspection Form can be found in

Appendix C.

2.6.4 ResultsofPreviousAnnualInspectionsThis is the initial and only annual inspection conducted under CCR rules [11] for the Huntington CCR

Landfill. PacifiCorp has completed other independent inspections by third parties. None of the

observations from this or previous inspections indicated imminent dam safety concerns.

This report and other pertinent reports and data are accessible at the following website:

http://www.berkshirehathawayenergyco.com/ccr/ppw.html

Section 5 of this report is a complete list of references for the Huntington CCR Landfill.

3 FieldInspectionofHuntingtonCCRLandfillA field inspection was conducted on September 15, 2015 by URS staff, Rick J. Cox, P.E.. Mr. Cox

participated previously in the CCR inspections in 2014 for the Huntington CCR Landfill [1]. Personnel

from the Huntington Power Plant, accompanied Mr. Cox during the 2015 field inspection.

A photo log documenting features and their condition at the time of the inspection is presented in

Appendix A. These photos are referenced in this report.

The completed Annual Inspection Report Form is presented in Appendix B. This checklist should be

considered an integral part of the report and remain attached whenever the report is forwarded or

otherwise reproduced.

An example of the weekly inspection report form completed by PacifiCorp staff is included in

Appendix C.

3.1 GeneralThe field inspection was performed by the URS inspector by driving the perimeter road and the crest,

stopping at approximately ¼ mile intervals or when observations warranted stopping. In addition, the

crest of the Retention basin was walked and the condition of the downstream embankment observed.

Photos of the outer face of the landfill were taken to provide a baseline for future inspections. All of the

photos in the Photograph Log, Appendix A, serve as a baseline since there are no photos of observed

deficiencies.


Features and conditions were documented on the Annual Inspection Report form (Appendix B) and

were photographed. The approximate locations of the photos are detailed in the inspection photo log

overview map located at the beginning of the Photograph Log, Appendix A. In addition to documenting

current features, the photo log of existing conditions is intended on aiding future inspections.

3.2 HuntingtonCCRLandfillGeometryThe Huntington CCR Landfill is bounded on three sides by natural topography, leaving just one side with

a slope created from CCR material. This slope is subsequently covered with newly deposited CCR

material creating benches approximately 15 to 20 feet high; consequently, there is no current

permanent slope associated with the landfill. The slope of the CCR for each bench is the natural angle of

repose and appears to be approximately 1.5 horizontal to 1 vertical. Refer to photos 11 and 12.

The landfill currently covers approximately 102.66 acres [13] and from topographic information

provided by the plant, it rises approximately 150 feet from the toe to the crest. The elevation of the

crest is approximately 6690 feet amsl. A topographic map in the Maxim Technologies, Inc. geotechnical

report [9] shows two small drainages within the landfill footprint. Runoff for these drainages is now

collected by the access road borrow ditch and discharges to a culvert under the road down gradient

from the landfill. The offsite runoff is captured by the Duck Pond. Consequently, only on‐site runoff is

collected by the Landfill Retention Basin (see Figure 1‐1).

The retention basin is capable of retaining a 100‐year, 6‐hour storm event and is located below the

western slope of the Huntington CCR Landfill [3]. Runoff from the landfill is collected and disposed of

through evaporation. Any runoff or groundwater discharge that would escape the Retention Basin is

collected at the Duck Pond, which is downgradient from the Retention Basin.

3.3 InstrumentationThere is no permanent instrumentation within the landfill itself. Landfill instrumentation is not required

by the CCR rule.

A target for aerial photography was observed to be in fair condition. Refer to Photo 3, Appendix A.

3.4 VolumeofCCRThe Huntington plant staff estimate from past data that the current volume of CCR stored in the landfill

is approximately 4.7 to 5.0 million cubic yards.

3.5 ObservedorPotentialStructuralWeaknessesThere were no appearances of actual or potential structural weakness or existing conditions that are

disrupting, or have the potential to disrupt the operation and safety of the CCR unit.

3.6 ObservedChangesThis is the initial and only annual inspection conducted under the CCR rules [11] for the Huntington CCR Landfill. However, PacifiCorp historically commissioned other third party inspections that were not


related to the CCR rules, the latest being completed by URS in 2014 [1]. This report of observed changes is based on the 2014 report.

There were no observed changes from the 2014 inspection and the 2015 inspection other than

correction of two deficiencies identified in the 2014 inspection report.

4 LimitationsandConsultantQualifications

4.1 LimitationsThis report presents observations, and conclusions drawn from a review of pertinent documents

referenced in Section 5, and a field inspection of the Huntington CCR Landfill. The field inspection was

limited to the interior of the perimeter road. The purpose of the review and inspection has been to

assess the safety or adequacy of the facilities against catastrophic failure of the major constructed

elements during normal operations or unusual or extreme events based on visual inspection and

available information. A secondary purpose is to identify any potential deficiencies related to the CCR

rules [11].

The conclusions and professional opinions presented herein were developed by the independent

consultant and are in accordance with generally accepted engineering principles and practices at the

time and location the services were provided. URS makes no other warranty, either expressed or

implied.

4.2 ProfessionalEngineerQualificationsThe professional engineer for this inspection is Rick J. Cox. He is licensed in the State of Utah (171899)

as a structural engineer. He has over 32 years experience in civil/structural engineering and has

performed inspections and safety evaluations on dams, canals and numerous other water containing

structures.

5 References[1] URS, “2014 Coal Combustion Residuals Impoundment Inspection and Assessment – Huntington

Power Plant Ash Landfill,” January 6, 2015.

[2] Cornforth Consultants Inc., “Phase I Geotechnical Assessments, Scrubber Pond, Sludge Pond, Old

Ash and New Ash Landfills, Huntington Power Plant,” Huntington, Utah, 2009.

[3] PacifiCorp Electric Operations, “Combustion Waste Embankment Project: Operations Manual,”

Huntington Power Plant, Huntington, Utah, 2001.

[4] PacifiCorp Energy, “Thermal Generation Fact Sheets: Huntington Plant,” 2011. [Online].

Available: http://www.pacificorp.com/es/thermal.html. [Accessed: 12‐Nov‐2014].

[5] United States Environmental Protection Agency [EPA], “40 CFS Part 261, Notice of Regulatory

Determination on Wastes From the Combustion of Fossil Fuels,” May 22, 2000.


[6] Water & Environmental Technologies PC, “Industrial Landfill Permit Renewal Application:

Huntington Power Plant,” Salt Lake City, Utah, 2006.

[7] Woodward‐Clevenger & Associates Inc., “Geotechnical Services Ash Storage Areas and Haul

Road, Huntington Canyon Plant,” Huntington, Utah, 1973.

[8] Woodward‐Clyde Consultants, “Ash and Coal Storage Areas: Huntington Canyon Power Plant,”

Huntington, Utah, 1977.

[9] Maxim Technologies Inc., “Geotechnical Services, Huntington Plant ‐ Ash Landfill,” Huntington,

Utah, 1999.

[10] United States Geological Survey [USGS], “2008 Interactive Deaggregations,” 2014. [Online].

Available: http://geohazards.usgs.gov/deaggint/2008/. [Accessed: 13‐Nov‐2014].

[11] 40 CFS § 257 Disposal of Coal Combustion Residuals from Electric Utilities, April 17, 2015.

[12] Water & Environmental Technologies PC, “Combustion Waste Landfill Volume Analysis,” March

30, 2015

[13] Water & Environmental Technologies PC, “Huntington Run‐on/Run‐off,” December 3, 2015

[14] CH2M Hill, “Combustion Waste Embankment drawings,” June 28, 2000.

2015 Huntington CCR Landfill Inspection

AppendixA

PhotographLog

Inspection Photographs PacifiCorp Energy

Huntington Power Plant September 15, 2015

Page No. A-1



Page No. A-2

Photograph No. 1 View of area being cleared and topsoil being removed for stockpiling.

Photograph No. 2 Existing groundwater monitoring well near west perimeter road.



Page No. A-3

Photograph No. 3 Target for periodic aerial photography of landfill. Target located new west perimeter road.

Photograph No. 4 Culvert upstream inlet to Retention Basin (south side). No blockage.



Page No. A-4

Photograph No. 5 Culvert inlet to Retention Basin (south side). No blockage.

Photograph No. 6 Upstream side of culvert inlet to Retention Basin (east side). Blockage observed in 2014 has been cleared.



Page No. A-5

Photograph No. 7 Downstream side of culvert inlet (east side). Blockage observed in 2014 has been removed.

Photograph No. 8 Preferential drainage path observed in 2014 has been filled in.



Page No. A-6

Photograph No. 9 Downstream face of maximum embankment section of Retention Basin.

Photograph No. 10 North face of embankment of Retention Basin.



Page No. A-7

Photograph No. 11 Working face of landfill. View east.

Photograph No. 12 Area of current deposition of ash.



Page No. A-8

Photograph No. 13 Top of landfill. Temporary cover of bottom ash.

Photograph No. 14 Stockpiled topsoil (light brown color) on the top of landfill.



Page No. A-9

Photograph No. 15 Northeast boundary of ash landfill. Note woody debris is from clearing for topsoil stockpiling.

Photograph No. 16 View of current area of deposition. View to the southwest.



Page No. A-10

Photograph No. 17 Current signage for CCR landfill. To be replaced.


AppendixB

AnnualInspectionReportForm

Annual Landfill Inspection Report

Issue Date: 8-24-2015 Form XXXXX Revision A

Page 1 of 2

Feature Name:

Huntington CCR Landfill Feature ID: Date:

September 15,2015 Station/Owner PacifiCorp

County, Emery

State Utah

Inspected By Rick J. Cox, P.E.

Date 9‐15‐15

Phone No. 801‐904‐4096

Type of Inspection Initial Periodic Follow up Other Weather Wet Dry Snow Cover Other

Remarks Inspector accompanied by Russ Wilson, Senior Environmental Analyst, Huntington Power Plant. This was the initial inspection under CCR regulations. Cox performed 2014 inspection.

Total Precipitation last 24 hrs Light rain earlier in the day of inspection.

COVER

PROBLEMS COVER

1. None 2. Animal burrows 3. Animal damage 4. Weeds & Brush

5. Vegetation >2” dia. 6. Vegetation islands 7. Poor grass cover 8. Slope Stability

9. Settlement 10. Cracks 11. Erosion 12. Rills

13. Seepage 14. Ponding 15. Other

Vegetation Gravel Soil

Other Temp. bottom ash

Comments /Action Items: Stockpiling of topsoil. No permanent cover yet placed on landfill.

Actions None Maintenance Monitoring Minor Repair Engineering

SLOPES & PER

IMETER

BER

MS

PROBLEMS COVER: 1. None 2. Animal burrows 3. Animal damage 4. Weeds & Brush

5. Vegetation >2” dia. 6. Bare spots >25ft2 7. Poor grass cover 8. Slope Stability

9. Settlement 10. Cracks 11. Erosion 12. Rills

13. Seepage 14. Ponding 15. Other

Vegetation Gravel Soil Asphalt

Other

OBSERVATIONS

16. Do slopes and berms provide positive drainage? Yes No NA

17. Is there exposed waste on exterior slopes? No exterior slopes Yes No NA

Comments /Action Items: Only slopes are temporary interior slopes. Perimeter berm created by haul road prevents off‐site runoff coming onto landfill.


LECHATE

SYSTEM

PROBLEMS

1. None 2. Sump

3. Piping leaking 4. Containment Leaking

5. Tank leaking 6. Other

OBSERVATIONS

7. Is the Leachate transmission system functioning properly? Yes No NA

8. Is the leak detections system functioning properly? Yes No NA

Comments /Action Items: There was a temporary leachate system that has been abandoned and buried. No discharge.


Annual Landfill Inspection Report

Issue Date: 8-24-2015 Form XXXXX Revision A

Page 2 of 2

Feature Name:

Huntington CCR Landfill Feature ID: Date:

September 15,2015

Inspector Signature

Date 9‐15‐2015

EROSION SED

IMEN

T CONTR

OLS

PROBLEMS 1. None 2. Channel

3. Ditch Failure. 4. Ditch Washouts

5. Debris 6. Sediment

7. Silt Fences 8. Filter Socks

9. Rip Rap Aprons 10. Other

OBSERVATIONS

11. No erosion or sediment controls Yes No

12. Are drop structures in good repair? Yes No N/A

13. Are perimeter run‐on diversion ditches present and in good repair? Yes No N/A

14. Are perimeter run‐off diversion ditches present and in good repair? Yes No N/A

Comments /Action Items Item 13 above. Observed culvert was buried under the haul road. Ditch remains effective because culvert is beyond location of CCR materials, no threat of washing CCR materials.


Other

Observations

1. Are temporary covers functioning as intended? Just bottom ash as temporary cover for dust control.

Yes No N/A

2. Are Stormwater systems functioning as intended? Yes No N/A

3. Fences and Gates in good condition? Yes No N/A

4. Security devices in good condition? Yes No N/A

5. Signs in good condition? New sign planned. Existing sign acceptable. Yes No N/A

6. Reference monuments/Survey Monuments in good condition? Yes No N/A

Comments /Action Items



AppendixC

ExamplePacifiCorpInspectionForm

1

Issue Date: Rev. 2

Huntington Landfill Inspection Report

CCR Landfill Name: Huntington CCR Landfill Date: Inspected By:

Inspection Frequency: Routine Weather/Seismic Event Other: _______________________________________

Type of Landfill: Active Inactive Weather Conditions: Wet Dry Snow Cover Windy Other

Op

erat

ion

s

Checks & Observations 1. Placement procedures are being followed. Yes No 2. Dust control is effective. Yes No 3. Dust control logs are complete and available. Yes No 4. Haul road maintained and dust controlled. Yes No Observations:

Actions: None Maintenance Monitoring Engineering Notification/Work Order#:

Cov

er (

if a

pp

lica

ble

)

Problems Cover

None Animal burrows Animal damage

Slope stability Settlement Cracks

Erosion Rills

Seepage Ponding Other

Vegetation Gravel Soil Other

5. Exterior slopes in good condition, with no exposed CCR waste (non-beneficial). Yes No Observations:


Slo

pes

& P

erim

eter

Ber

ms

Problems Cover

None Animal burrows Animal damage

Slope stability Settlement Cracks

Erosion Rills

Seepage Ponding Other

Vegetation Gravel Soil Other

Observations 6. Slopes and berms provide positive drainage. Yes No Observations:


2

Issue Date: Rev. 2

Ero

sion

Sed

imen

t C

ontr

ols

Problems

None Ditch Failure Ditch Washouts

Debris Sediment

Berms Bales/Waddles

Other

Observations 7. Erosion or sediment controls in good condition. Yes No 8. Drop inlet or other storm water controls structures are in good repair. Yes No 9. Perimeter run-on and run-off diversion ditches present and in good repair. Yes No Observations:


Oth

er

Observations 10. Temporary covers functioning as intended. Yes No 11. Storm water systems functioning as intended. Yes No 12. Any appearance of actual or potential structural weakness and other conditions which are disrupting or have the potential to disrupt the operation or safety of the CCR landfill?

Yes No

13. Other non-structural or non-emergency safety issues. Yes No Observations:


Inspector Signature: ________________________________________________ Date: _________________________

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