CCR Compliance History of Construction Spurlock Ash … files/Spurlock... · ESP Electrostatic...

29
Spurlock CCR Surface Impoundment History of Construction East Kentucky Power Cooperative Coal Combustion Residual Rule Compliance Revision 0 August 5, 2016

Transcript of CCR Compliance History of Construction Spurlock Ash … files/Spurlock... · ESP Electrostatic...

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Spurlock CCR Surface Impoundment History of Construction

East Kentucky Power Cooperative

Coal Combustion Residual Rule Compliance

Revision 0 August 5, 2016

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Spurlock CCR Surface Impoundment History of Construction

Prepared for

East Kentucky Power Cooperative Coal Combustion Residual Rule Compliance

Winchester, Kentucky

Revision 0 August 5, 2016

Prepared by

Burns & McDonnell Engineering Company, Inc. Kansas City, Missouri

COPYRIGHT © 2016 BURNS & McDONNELL ENGINEERING COMPANY, INC.

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Spurlock CCR Surface Impoundment History of Construction Table of Contents

East Kentucky Power Cooperative TOC-1 Burns & McDonnell August 2016 Rev. 0

TABLE OF CONTENTS

Page No.

1.0  INTRODUCTION ............................................................................................... 1-1 1.1  CCR Rule Compliance ......................................................................................... 1-1 1.2  Spurlock Ash Pond .............................................................................................. 1-3 1.3  H.L. Spurlock Power Station CCR Production .................................................... 1-4 

1.3.1  Fly Ash .................................................................................................. 1-4 1.3.2  Bottom Ash ........................................................................................... 1-4 1.3.3  Gypsum ................................................................................................. 1-5 1.3.4  FGD Scrubber Sludge ........................................................................... 1-5 1.3.5  Boiler Slag ............................................................................................ 1-5 

2.0  DESIGN ............................................................................................................. 2-1 2.1  Foundation ........................................................................................................... 2-1 2.2  Spillway ............................................................................................................... 2-2 2.3  Bottom of Pond .................................................................................................... 2-2 

3.0  CONSTRUCTION .............................................................................................. 3-1 3.1  Embankments ....................................................................................................... 3-1 3.2  Liner ..................................................................................................................... 3-1 3.3  Protective Cover ................................................................................................... 3-1 

4.0  INSTRUMENTATION ........................................................................................ 4-1 4.1  Survey Monuments .............................................................................................. 4-1 4.2  Piezometers .......................................................................................................... 4-1 4.3  Inclinometers........................................................................................................ 4-1 

5.0  SURVEILLANCE AND MAINTENANCE .......................................................... 5-1 5.1  Periodic Inspections ............................................................................................. 5-1 

5.1.1  7-Day Inspections ................................................................................. 5-1 5.1.2  30-Day Inspections ............................................................................... 5-1 5.1.3  Annual Inspections ................................................................................ 5-1 5.1.4  5-Year Structural Stability Assessment ................................................ 5-2 

5.2  Maintenance and Repair Procedures .................................................................... 5-2 

6.0  STRUCTURAL INSTABILITIES AND REMEDIAL ACTIONS .......................... 6-1 

7.0  REVIEW AND REVISIONS ............................................................................... 7-1 

8.0  RECORD OF REVISIONS................................................................................. 8-1 

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Spurlock CCR Surface Impoundment History of Construction Table of Contents

East Kentucky Power Cooperative TOC-2 Burns & McDonnell August 2016 Rev. 0

APPENDIX A – USGS 7½ MINUTE TOPOGRAPHICAL QUADRANGLE MAP 

APPENDIX B – DESIGN DRAWINGS 

APPENDIX C – GEOTECHNICAL EVALUATION 

APPENDIX D – CONSTRUCTION SPECIFICATIONS 

APPENDIX E – BATHYMETRIC SURVEYS 

APPENDIX F – INSTRUMENTATION REPORTS 

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Spurlock CCR Surface Impoundment History of Construction Table of Contents

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LIST OF TABLES

Page No.

Table 1-1: Spurlock Ash Pond History of Construction Compliance Summary ......................... 1-2 Table 2-1: Summary of Spurlock Ash Pond Dike Dimensions and Size .................................... 2-1 Table 3-1: Native Soil Properties ................................................................................................. 3-1 

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Spurlock CCR Surface Impoundment History of Construction Table of Contents

East Kentucky Power Cooperative TOC-4 Burns & McDonnell August 2016 Rev. 0

LIST OF FIGURES

Page No.

Figure 2-1: Spurlock Ash Pond Typical Cross Section ............................................................... 2-2 Figure 2-2: Spurlock Ash Pond Area-Capacity Curve ................................................................ 2-3 

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Spurlock CCR Surface Impoundment History of Construction List of Abbreviations

East Kentucky Power Cooperative i Burns & McDonnell August 2016 Rev. 0

LIST OF ABBREVIATIONS

Abbreviation Term/Phrase/Name

ALM Asset Life Management

BMcD Burns & McDonnell

CCR Coal Combustion Residual

CFR Code of Federal Regulation

CMMS Computerized Maintenance Management System

EKPC East Kentucky Power Cooperative

EPA Environmental Protection Agency

ESP Electrostatic precipitator

FGD Flue gas desulfurization

KPDES Kentucky Pollution Discharge Elimination System

KYDOW Kentucky Division of Water

RCRA Resource Conservation and Recovery Act

USC United States Code

USGS United States Geological Survey

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Spurlock CCR Surface Impoundment History of Construction Introduction

East Kentucky Power Cooperative 1-1 Burns & McDonnell August 2016 Rev. 0

1.0 INTRODUCTION

On April 17, 2015, the EPA issued the final version of the federal Coal Combustion Residual Rule (CCR

Rule) to regulate the disposal of CCR materials generated at coal-fired units. The rule will be

administered as part of the Resource Conservation and Recovery Act (RCRA, 42 United States Code

[U.S.C.] §6901 et seq.), using the Subtitle D approach.

East Kentucky Power Cooperative (EKPC) is subject to the CCR Rule and as such must compile a

History of Construction for existing CCR surface impoundments (to the extent feasible) per 40 CFR

§257.73. This document provides the History of Construction for the existing CCR surface impoundment

(Kentucky Division of Water [KYDOW] Dam No. 938) at the H.L. Spurlock Power Station located near

the town of Maysville, Kentucky in Mason County owned and operated by:

East Kentucky Power Cooperative 4775 Lexington Road P.O. Box 707 Winchester, KY 40392

1.1 CCR Rule Compliance

The Preamble to 40 Code of Federal Regulation (CFR) §257 indicates the Environmental Protection

Agency (EPA) has acknowledged that much of the construction history of the surface impoundment may

be unknown or lost. This is due to many owners or operators of CCR units not possessing documentation

on the construction history or operation of the CCR unit. Information regarding construction materials,

expansions or contractions of units, operational history, and history of events was frequently difficult for

the owners or operators to obtain and subsequently difficult to compile into a History of Construction

document. The EPA intends facilities to provide relevant design and construction information only if

factual documentation exists. EPA does not expect owners or operators to generate new information or

provide anecdotal or speculative information regarding the CCR surface impoundment’s design and

construction history. As such, for existing CCR surface impoundments, 40 CFR §257.73(c) (1)

recommends the History of Construction contain the suggested information only to the extent feasible.

Table 1-1 contains a summary of the suggested information located in 40 CFR §257.73(c) (1) related to

the History of Construction for existing CCR surface impoundments. Information used to develop this

table was compiled to the extent feasible from available data related to the design, construction, and

maintenance of the Spurlock ash pond (CCR surface impoundment) based on the aforementioned

interpretation of the Preamble to 40 CFR §257.

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Spurlock CCR Surface Impoundment History of Construction Introduction

East Kentucky Power Cooperative 1-2 Burns & McDonnell August 2016 Rev. 0

Table 1-1: Spurlock Ash Pond History of Construction Compliance Summary

HISTORY OF CONSTRUCTION

CCR Rule Description YES NO Report Reference

Name and address of the owner/operator of the CCR unit ☒ ☐ Section 1.0 – Introduction

Name of the CCR unit ☒ ☐ Section 1.0 – Introduction

Identification number of the CCR unit ☒ ☐ Section 1.0 – Introduction

Location of the CCR unit on most recent United State Geological Survey (USGS) 7½ minute or 15 minute topographical map

☒ ☐ Section 1.0 – Introduction and Appendix A

Statement of the purpose for which the CCR unit is being used ☒ ☐ Section 1.0 – Introduction

Name and size of watershed within which the CCR unit is located

☒ ☐ Section 1.0 – Introduction

Description of the physical and engineering properties of the foundation and abutment materials on which the CCR unit is constructed

☒ ☐ Section 2.0 – Design and Appendix C

Statement of the type, size, range, and physical and engineering properties of the materials used in constructing each zone or stage of the CCR unit

☒ ☐ Section 3.0 – Construction

The method of site preparation and construction of each zone or stage of the CCR unit

☒ ☐ Appendix D

The approximate dates of construction of each successive stage of construction of the CCR unit

☒ ☐ Section 3.0 – Construction

Description of the type, purpose, and location of existing instrumentation ☒ ☐ Section 4.0 – Instrumentation

and Appendix F

Description of each spillway and diversion design features and capacities and calculations used in their determination

☒ ☐ Section 2.0 – Design

Area-capacity curves for the CCR unit ☒ ☐ Section 2.0 – Design

Construction specifications ☒ ☐ Section 3.0 – Construction and Appendix D

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Spurlock CCR Surface Impoundment History of Construction Introduction

East Kentucky Power Cooperative 1-3 Burns & McDonnell August 2016 Rev. 0

HISTORY OF CONSTRUCTION

Provisions for surveillance, maintenance, and repair of the CCR unit

☒ ☐ Section 5.0 – Surveillance and Maintenance

Any record or knowledge of structural instability of the CCR unit ☐ ☒

Detailed Dimensional Drawings Including the Following:

Plan view and cross sections of the length and width of the CCR unit ☒ ☐ Appendix B

Foundation improvements ☐ ☒ Not Applicable

Drainage provisions, spillways, diversion ditches, outlets ☒ ☐ Appendix B

Instrumentation locations ☒ ☐ Appendix F

Slope protection ☒ ☐ Appendix B

Normal operating pool surface elevation ☒ ☐ Appendix B

Maximum pool surface elevation following peak discharge from the inflow design flood

☒ ☐ Section 2.0 – Design

Expected maximum depth of CCR within the unit ☒ ☐ Appendix B

Any identifiable natural or manmade features that could adversely affect operation of the CCR unit due to malfunction or mis-operation

☐ ☒

1.2 Spurlock Ash Pond

The Spurlock ash pond (KYDOW Dam No. 938) is approximately 67 acres1 in size and has an intended

design capacity of approximately 1,750,000 cubic yards2 of CCR material. The Spurlock ash pond is

located directly south of the Ohio River at Mile 413 and is shown on the 2013 USGS 7 ½ minute

topographical quadrangle map found in Appendix A. The ash pond is located within the Cabin Creek –

1 Surface area is measured at elevation 528.0 feet (NAVD 88) per the bathymetric survey found in Appendix E. 2 Intended design capacity as noted in Dames and Moore Subsurface Exploration Program found in Appendix C.

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Spurlock CCR Surface Impoundment History of Construction Introduction

East Kentucky Power Cooperative 1-4 Burns & McDonnell August 2016 Rev. 0

Ohio River watershed (HUC-10: 0509020106). The Cabin Creek – Ohio River watershed is

approximately 131,000 acres in size.

1.3 H.L. Spurlock Power Station CCR Production3

The Spurlock Power Station currently consists of four units: Units 1 and 2 (pulverized coal units) and

Units 3 and 4 (circulating fluidized bed units). The CCR handling system on Units 1 and 2 consists of

three major components: a bottom ash removal system that removes heavier ash particles from the bottom

of the furnace, electrostatic precipitators that remove fine ash particles that are carried out of the furnace

in the hot gasses, and a flue gas desulfurization (FGD or “scrubber”) system that is used to remove sulfur

dioxide from the flue gases. The CCR handling system on Units 3 and 4 consists of fluidized beds which

circulate a bed of ash in the furnace providing heat transfer to the internal boiler tubing. In the fluidized

beds, lime is also added to the combustion process to “dry scrub” sulfur from the coal. The sulfur reacts

with the lime to form solids that are removed with the fly ash or bed ash.

1.3.1 Fly Ash3

Fly ash particles from Units 1 and 2 are collected by the use of an electrostatic precipitator (ESP or

“precipitator”). The ESP works by inducing an electrical charge on the fly ash particles in the flue gas

stream. The charged fly ash then collects on plates housed within the ESP. These plates are “rapped”

causing the fly ash to drop into the hoppers below the plates. The fly ash is then transferred pneumatically

from the hoppers to an ash silo where the ash is loaded onto trucks and transported to the Spurlock

Landfill. Should the fly ash system fail, EKPC can re-direct the fly ash to the wet ash sluice system which

serves as a back-up to the dry ash system. As a result, the sluiced fly ash will then be directed to the

Spurlock ash pond.

Fly ash particles from Units 3 and 4 are removed from the flue gas by a series of bag filters. The fly ash is

collected in hoppers, transferred pneumatically to a silo, loaded onto trucks, and then transported to the

Spurlock Landfill.

1.3.2 Bottom Ash3

The bottom ash from Units 1 and 2 collects in hoppers at the base of the furnace and is then sluiced in

water to the Spurlock ash pond. In the ash pond, the bottom ash settles out and the water is pumped to the

primary and secondary lagoons where additional settling occurs. From the secondary lagoon, the water is

3 Description of Plant CCR Production is based on information available at the time of this document revision

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Spurlock CCR Surface Impoundment History of Construction Introduction

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either pulled back into the bottom ash sluicing system or overflowed to discharge through a Kentucky

Pollution Discharge Elimination System (KPDES) permitted outfall which empties into the Ohio River.

The bottom ash from Units 3 and 4 is contained in the fluidized beds. The level of this bed ash is

controlled by continually withdrawing a portion of the accumulated ash through a control device to a silo.

From the silo, the bed ash is loaded onto trucks and taken to the Spurlock Landfill.

1.3.3 Gypsum4

The gypsum produced at Units 1 and 2 from the FGD process is dewatered on drum filters located in the

scrubbers and conveyed to a loading area. In the loading area the gypsum is loaded onto trucks and

transported to the Spurlock Landfill.

1.3.4 FGD Scrubber Sludge4

The FGD process byproduct (scrubber sludge) is sluiced to the Spurlock ash pond.

1.3.5 Boiler Slag4

Boiler slag is collected in hoppers at the base of the furnace, ground up in the clinker grinder, and then

sluiced to the Spurlock ash pond.

4 Description of Plant CCR Production is based on information available at the time of this document revision

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Spurlock CCR Surface Impoundment History of Construction Design

East Kentucky Power Cooperative 2-1 Burns & McDonnell August 2016 Rev. 0

2.0 DESIGN

The Spurlock ash pond was designed by Stanley Consultants in the early 1970’s. A subsurface

exploration program was conducted by Dames & Moore prior to the design and construction of the

surface impoundment. The original Dames & Moore report can be found in Appendix C.

Design drawings dated May 5, 1972 for the proposed ash storage area indicate a design crest elevation of

the perimeter dike of 530.0 feet5, with a maximum berm height of 28 feet. Design drawings can be found

in Appendix B. The as-built top of dike elevation has been surveyed and maintained at elevation 528.0

feet6 resulting in a berm height of 26 feet. The most recent bathymetric survey performed on the unit can

be found in Appendix E. Table 2-1 contains a summary of the dimensions and size of the Spurlock ash

pond.

Table 2-1: Summary of Spurlock Ash Pond Dike Dimensions and Size

Dike Height (feet) 26.0

Crest Width (feet) 16.0

Dike Perimeter/ Length (feet) 8,750

Side Slopes (upstream) H:V 3:1

Surface Area (acre) 677

Total Volume of Impoundment (cubic yards) 2,293,3808

Design CCR Capacity (cubic yards) 1,750,000

2.1 Foundation

According to the subsurface exploration program documentation found in Appendix C, the existing

subgrade soils (i.e. foundation) for the Spurlock ash pond consists of silty clay and clayey silt. Boring

logs recorded during this exploration can be found in the report along with the physical and engineering

properties of the foundation materials on which the CCR unit was constructed.

5 Original design elevation based on the National Geodetic Vertical Datum (NGVD) of 1929. NGVD 29 Elevation 530.0 feet is equivalent to NAVD 88 Elevation 529.186 feet 6 As-Built elevation based on the North American Vertical Datum (NAVD) of 1988 7 Surface area is measured at elevation 528.0 feet (NAVD 88) per the bathymetric survey found in Appendix E. 8 Volume of Impoundment measured below top of dike at elevation 528.0 feet (NAVD 88) assuming a bottom of pond elevation of 506.0 (NAVD 88)

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2.2 Spillway

The Spurlock ash pond does not utilize an emergency spillway. Instead, transfer pumps with level

indicators are used to monitor the water level in the pond and transport water to the primary lagoon. The

pumps are capable of discharging a combined rate of 4800 gallons per minute. The water level is

maintained to provide sufficient freeboard to withstand a design rainfall event plus minimum freeboard

required by the Kentucky Division of Water. The design rainfall event is determined based on the hazard

potential classification of the surface impoundment at the time of assessment. Water level control settings,

transfer pump curves and transfer pump test data can be found in Appendix B.

In 2016, the Inflow Design Flood Control System was analyzed pursuant to the CCR Rule using the

freeboard 6-hour event and the 100-year 24-hour event. As a part of the Inflow Design Flood Control

System Plan, the water transfer pump capacities were reviewed to confirm the Spurlock ash pond dikes

would not be overtopped during a design rain fall event. A typical cross section indicating the maximum

pool surface elevation following peak discharge from the inflow design flood is shown in Figure 2-1.

Figure 2-1: Spurlock Ash Pond Typical Cross Section

2.3 Bottom of Pond

The existing terrain which the Spurlock ash pond was constructed varied in elevation according to the

subsurface exploration program document found in Appendix C and the design drawings found in

Appendix B. According to these documents, the grade elevations ranged from elevation 502’-0”

(NGVD29) to elevation 510’-0” (NGVD29) in low lying valleys. For purposes of calculating the amount

of CCR material in the pond, an approximate bottom of pond elevation of 506’-0” (NAVD88) has been

used. For purposes of determining the total volume of material that may be removed in the event of pond

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closure, a bottom of pond elevation of 502’-0” (NAVD88) has been used. The area-capacity curves

corresponding to each of these bottom of pond elevations is shown in Figure 2-2.

Figure 2-2: Spurlock Ash Pond Area-Capacity Curve

54.0

56.0

58.0

60.0

62.0

64.0

66.0

68.0

70.0

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

500 505 510 515 520 525 530

Surface

 Arae

 (Acre

s)

Volume (C

Y)

Stage (feet NAVD88)

Ash Pond Storage ‐ History of Contruction 

Volume (CY) ‐ Bottom Elev 502 Volume (CY) ‐ Bottom Elev 506 Surface Area (acres)

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Spurlock CCR Surface Impoundment History of Construction Construction

East Kentucky Power Cooperative 3-1 Burns & McDonnell August 2016 Rev. 0

3.0 CONSTRUCTION

According to as-built construction drawings, the Spurlock ash pond was constructed between the years of

1975 and 1978 with final construction drawings dated May 9, 1978. Much of the information

documenting the construction of the ash pond was not retained over the years. However, the original

subsurface exploration program and construction specifications provide guidance to the recommended

construction practices used at the time. The original subsurface exploration program and construction

specifications can be found in Appendix C and Appendix D respectively.

3.1 Embankments

The ash pond embankments were constructed using soils available within the footprint of or adjacent to

the pond area. These soils consisted of brown silty clay or brown clayey silt. Table 3-1 summarizes the in-

situ soil properties found in the original subsurface exploration program.

Table 3-1: Native Soil Properties

Material

Unit Weight (pounds per cubic

foot) Friction Angle

(Degrees) Cohesion (pounds per

square foot)

Fill material 125 25 3,270

River bank upper cohesive 128 25 3,500

River bank silty sand 120 32 100

River bank sand 125 35 0

Soft soil upper cohesive* 106 25 450

Soft soil lower cohesive* 112 25 550

Soft soil sand* 125 35 0 * The soft area indicated is between Borings AS-28 and AS-30

3.2 Liner

Design information located in the original subsurface exploration program and construction specifications

indicate the liner for the Spurlock ash pond consists of 18 inches of compacted silty clay fill. For purposes

of the CCR Rule, the Spurlock ash pond is classified as unlined.

3.3 Protective Cover

The outboard slopes of the Spurlock ash pond consist of top soil protected by vegetative cover. The

vegetative cover is maintained to allow for adequate inspection of the dams. The top eight feet of the

inboard slopes are protected by riprap. The crests of the dams are covered with gravel to facilitate access

around the ash pond.

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Spurlock CCR Surface Impoundment History of Construction Instrumentation

East Kentucky Power Cooperative 4-1 Burns & McDonnell August 2016 Rev. 0

4.0 INSTRUMENTATION

The Spurlock ash pond currently utilizes the following monitoring instrumentation; survey monuments,

piezometers, and inclinometers. These instruments were installed by S&ME, Inc. in September 2010. A

detailed instrumentation report and an aerial photograph indicating the locations of the instrumentation at

the unit can be found in Appendix F.

4.1 Survey Monuments

Survey monuments are installed at six locations along the northern exterior slope of the ash pond. These

monuments are used to establish horizontal and vertical control for a location established in the field.

After an initial set of data is collected, subsequent readings can be used to determine if any surface lateral

movement or settlement has occurred.

4.2 Piezometers

Piezometers are installed at three locations along the northern exterior slope of the ash pond. Two

piezometers were installed at each location. Piezometers (standpipe-type) are small diameter observation

wells used to measure the phreatic surface beneath the ground surface. This information can be used to

detect possible seepage, increasing pore pressure in the embankment, or other water-related issues with

the embankment.

4.3 Inclinometers

Inclinometers are installed at three locations along the northern exterior slope of the ash pond.

Inclinometers are used to detect sliding planes below the ground surface by measuring lateral movement

of the subsurface. Inclinometers consist of a hollow tube which an instrument is lowered through to

measure the curvature of the tube. After an initial set of data is collected, subsequent readings can be used

to compare the profile of the hollow tube to the initial profile to determine if unacceptable movement has

occurred.

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Spurlock CCR Surface Impoundment History of Construction Surveillance and Maintenance

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5.0 SURVEILLANCE AND MAINTENANCE

The Spurlock ash pond has been maintained and inspected since it was constructed. The methods for

doing so have evolved over the years. For many years, inspections and maintenance activities involving

the ash pond were completed without formal documentation. Approximately in the year 2000, a

Computerized Maintenance Management System (CMMS) was implemented to schedule, track and

document work tasks including activities at the surface impoundment. In 2010, a new Asset Life

Management (ALM) system was placed in service and existing inspection and maintenance tasks were

uploaded.

5.1 Periodic Inspections

Over the years, inspections performed at the Spurlock ash pond have evolved due to proactive decisions

by EKPC as well as government mandated requirements. Annual inspections have evolved from visual

observations, such as walk-downs and mowing activities, to detailed reports completed by external

experts. Routine inspections have evolved from quarterly, checklist walk-downs to 7-day and 30-day

inspections required under 40 CFR §257.

5.1.1 7-Day Inspections

Pursuant to 40 CFR §257, EKPC performs inspections at the Spurlock ash pond at intervals not to exceed

seven days. These inspections are performed by a qualified person and are intended to inspect for any

appearances of actual or potential structural weakness and other conditions which are disrupting or have

the potential to disrupt the operation or safety of the CCR unit.

5.1.2 30-Day Inspections

Pursuant to 40 CFR §257, EKPC monitors all instrumentation at the Spurlock ash pond at intervals not to

exceed 30 days. During this inspection, a qualified person records readings using the instrumentation

identified in Section 4.0. As a best practice, a licensed Professional Surveyor in the Commonwealth of

Kentucky performs a differential level loop through the survey monuments identified in Section 4.0

during this inspection.

5.1.3 Annual Inspections

Pursuant to 40 CFR §257, EKPC performs annual inspections at the Spurlock ash pond at intervals not to

exceed one year. These inspections are performed by a qualified professional engineer and are intended to

ensure that the design, construction, operation, and maintenance of the CCR unit are consistent with

recognized and generally accepted good engineering standards.

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5.1.4 5-Year Structural Stability Assessment

Pursuant to 40 CFR §257, EKPC has implemented the procedures to perform a structural stability

assessment at the Spurlock ash pond once every five years. This assessment is to be performed by a

qualified professional engineer and is intended to document whether the design, construction, operation,

and maintenance of the CCR unit are consistent with recognized and generally accepted good engineering

practices for the maximum volume of CCR and CCR wastewater which can be impounded therein. This

assessment includes but is not limited to the following: a visual inspection, a structural stability

assessment, a safety factor assessment, and a hazard potential classification assessment.

5.2 Maintenance and Repair Procedures

Per current practices, a list of recommended remedial actions is generated following inspections or

assessments performed at the Spurlock ash pond. These remedial actions are entered into the ALM system

as a work order to be completed at the Plant level. The status of the tasks and work orders are tracked

within ALM.

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Spurlock CCR Surface Impoundment History of Construction Structural Instabilities and Remedial Actions

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6.0 STRUCTURAL INSTABILITIES AND REMEDIAL ACTIONS

Throughout the life of the Spurlock ash pond, no known structural instabilities have been identified.

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Spurlock CCR Surface Impoundment History of Construction Review and Revisions

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7.0 REVIEW AND REVISIONS

The initial History of Construction document will be placed in the CCR Operating Record by October 17,

2016. Pursuant to the CCR Rule, if there is a significant change to any information compiled in the

history of construction document, the relevant information must be updated and the revised document will

be placed in the CCR Operating Record. The History of Construction document will be reviewed as part

of the Annual Inspection of the CCR unit. All revisions will be placed on the CCR public website within

30 days following placement in the facility’s CCR Operating Record and will remain on the CCR public

website until the CCR unit completes closure in accordance with §257.102. A record of revisions made to

this document is included in Section 8.0.

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Spurlock CCR Surface Impoundment History of Construction Record of Revisions

East Kentucky Power Cooperative 8-1 Burns & McDonnell August 2016 Rev. 0

8.0 RECORD OF REVISIONS

Revision Number

Date Revisions Made By Whom

0 8/5/2016 Compiled History of Construction Burns & McDonnell

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APPENDIX A – USGS 7½ MINUTE TOPOGRAPHICAL QUADRANGLE MAP

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APPENDIX B – DESIGN DRAWINGS

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APPENDIX C – GEOTECHNICAL EVALUATION

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APPENDIX D – CONSTRUCTION SPECIFICATIONS

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APPENDIX E – BATHYMETRIC SURVEYS

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APPENDIX F – INSTRUMENTATION REPORTS

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Burns & McDonnell World Headquarters 9400 Ward Parkway

Kansas City, MO 64114 O 816-333-9400 F 816-333-3690

www.burnsmcd.com