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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

thorn

New Stamp

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


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


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


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


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


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


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


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


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


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



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



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


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


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


Electrical and Controls ........................................................................................................................ 364.3

2


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


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


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


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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Page 5 of 114

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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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.


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.


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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.


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


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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.


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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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.

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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


Page 41 of 114

– Estimate DetailsAppendix B

44


Page 42 of 114

Infrastructure Estimate Backup

Appendix B 45


Page 43 of 114


Page 44 of 114


Page 45 of 114


Page 46 of 114

Close-in-Place Estimate Backup

Appendix B 49


Page 47 of 114


Page 48 of 114


Page 49 of 114

Closure-by-Removal Estimate Backup

Appendix B 52


Page 50 of 114


Page 51 of 114

Infrastructure Construction Bid Pricing

Appendix B 54


Page 52 of 114


Page 53 of 114

Pond Closure Construction Bid Pricing

Appendix B 56


Page 54 of 114


Page 55 of 114


Page 56 of 114


Page 57 of 114

– Design Basis Tables: Appendix CClosure-in-Place and Closure-by-Removal

60


Page 58 of 114

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d

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> 5

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;

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d1

0 Y

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r Sto

rmN

ot D

efin

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in C

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lan

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N/A

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ns/a

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ea

r

32

9 IA

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po

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nce

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5 to

ns/a

cre/y

ea

r5

ton

s/acre

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ar

5 to

ns/a

cre/y

ea

r

Re

gu

lato

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ara

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B B

row

nIP

&L

Clo

su

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CC

R R

ule

Appendix C 61


Page 59 of 114

� Alternatives Evaluation and Appendix JDrawings

198


Page 60 of 114

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


Page 61 of 114

Ap

pe

nd

ix J

20

0Cause No. 45280Attachment JDM-1 (Public)

Page 62 of 114

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.

Appendix J 201


Page 63 of 114

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.


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.


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


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.


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.


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.


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.




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.



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.


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

Appendix J 211


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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


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.



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.

Appendix J 212


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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.


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.



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.

Appendix J 213


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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.


(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.


Assembly will be supervised by the equipment vendor. Design will include drawings and technical specifications



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.

Appendix J 214


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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.


(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.


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.

Appendix J 215


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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.



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.



for installing the equipment.


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.

Appendix J 216


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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.



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



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.

Appendix J 217


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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.


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.


belt feeder.





equipment and ancillary equipment.

Appendix J 218


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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.





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


5) A technical and performance specification package will be developed and issued to the conveyor vendor for the





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.





belt feeder.









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– Ash Valuation StudyAppendix M

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– Environmental and Appendix ORegulatory Considerations

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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-

Appendix OAppendix O 301


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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



Page 100 of 114

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



Page 101 of 114

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.



Page 102 of 114

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.



Page 103 of 114

– Findings and Matrix of Appendix POptions

307


Page 104 of 114

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Page 105 of 114

Appendix P

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Page 114 of 114

Coal Combustion Residuals ManagementIntegrated Life Cycle Services

Cause No. 45280Attachment JDM-2

Page 1 of 16

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

1 AECOM


Page 2 of 16

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


Page 3 of 16

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.


3 AECOM


Page 4 of 16

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.

4AECOM


Page 5 of 16

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.


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.


Page 6 of 16

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.

6AECOM 6AECOM


Page 7 of 16

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

5.87

7.96

10.5110.85

8.69

4.85

4.78

7.54

5.47

4.48

4.69

1.94

3.13

2.492.39

1.71.46

1.131.03

1.2 1.27 1.15 0.990.83 0.81 0.85

0.47 0.94

0.51

0

2

4

6

8

10

12

Pre-Alliance

Alliance Work

TRIR

5.87

7.96

10.5110.85

8.69

4.85

4.78

7.54

5.47

4.48

4.69

1.94

3.13

2.492.39

1.71.46

1.131.03

1.2 1.27 1.15 0.990.83 0.81 0.85

0.47 0.94

0.51

0

2

4

6

8

10

12

Pre-Alliance

Alliance Work

TRIR

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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


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


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


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


Combined heating and power

Distributed energy

High performance buildings and communities

Smart Cities

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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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