United States Region 4 ^ EPA 904/9-78-017
Environmental Protection 345 Courtland Street, NE OCTOBER 1978
Agency Atlanta, GA 30308
v>EPA Environmental Final
Impact Statement
Trimble County
Generating Station
protection Agency
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EPA 904/9-78-017 NPDES Application Number:
KY0041971
Repos/fo/y Maferia/
Collection
FINAL
ENVIRONMENTAL IMPACT STATEMENT
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for
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Proposed Issuance of a New Source National -SJ?
Pollutant Discharge Elimination System Permit 2*
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Louisville Gas and Electric Company GO ^2 jo •§ J3 c
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prepared by •*•
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia 30308
gional Administrator Date
10/2/78
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UNiTED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION \M
345 COURTLAND STREET
ATLANTA, GEORGIA 30308
October 6, 1978
TO: ALL INTERESTED GOVERNMENTAL AGENCIES, PUBLIC GROUPS,
AND CONCERNED INDIVIDUALS
The enclosed final Environmental Impact Statement for the Trimble
County Electric Generating Station Units 1-4 is hereby submitted
for your review. This document has been prepared pursuant to
Section 102(2) (C) of the National Environmental Policy Act (NEPA)
(Public Law 91-190) .
Louisville Gas and Electric Company has applied for an NPDES
Permit to discharge wastewater from the proposed facility and
has applied for other necessary Federal and State permits and
approvals. This document has been prepared by the Environmental
Protection Agency to also serve the NEPA requirements of other
Federal agencies.
The final Environmental Impact Statement has also been placed in
the public libraries listed below and it is available for review
at the EPA Region IV Library.
Capitol Regional Library (Frankfort, Kentucky)
Carroll County Public Library (Carrollton, Kentucky)
Duerson-Oldham County Public Library (LaGrange, Kentucky)
Jeffersonville Township Public Library (Jeffersonville, Indiana)
Lexington Public Library (Lexington, Kentucky)
Louisville Free Public Library (Louisville, Kentucky)
Madison-Jefferson County Public Library (Madison, Indiana)
Northern Kentucky Regional Library (Covington, Kentucky)
Public Library of Cincinnati and Hamilton County (Cincinnati, Ohio)
Trimble County Library (Milton, Kentucky)
University of Louisville Library (Louisville, Kentucky)
The 30-day period required for a public review of the final EIS
before administrative action can be taken begins on the date
that the EIS was made available to EPA, Office of Federal
Activities, or the date of this letter, whichever is later.
bring this notice to the attention of all persons who
e Interested in this matter.
ohn C. White
Regional Administrator
Enclosure
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Summary Sheet For Environmental Impact
Statement
Trimble County Generating Plant
Louisville Gas and Electric Company
Kentucky
( ) Draft
(X) Final
U.S. Environmental Protection Agency, Region IV
345 Courtland Street N.E.
Atlanta, Georgia 30308
1. Name of Action; (X) Administrative ( ) Legislative
2. Description of Action; This Environmental Impact
Statement (EIS) was prepared by the Region IV office of the
Environmental Protection Agency (EPA) as the lead Federal
Agency. The purpose of this Statement is to fulfill the
requirements of the National Environmental Policy Act (NEPA)
and the EPA January 11, 1977 regulations: Preparation of
Environmental Impact Statements for' New Source NPDES Permits
(40 CFR 6.900). NEPA requires all Federal agencies to assess
the impacts that would occur following a major Federal action
that has been determined to result in a significant impact
on the human environment.
Louisville Gas and Electric Company, the Applicant, proposes
to construct a new 2,340 megawatt (MW) coal-fired steam electric
generating station between Ohio River Miles 570-572 or 0.5
mile upstream from Wises Landing, Kentucky. The project would
increase the Applicant's electrical generating capacity. This
capacity has been projected to be required by the Applicant.
The facility would replace old units scheduled for retirement
over an 8 year period starting in 1979, as well as provide for
the increasing demand for power in the Applicant's service area.
The proposed project requires commitment of a 860 acre
site for construction of two 495 MW generating units, one
operational in 1983 and the other in 1985, and two 675 MW
generating units, one operational in 1987 and the other in 1989.
Other major components of the station would be two 735 foot
high stacks, two natural draft cooling towers, a switchyard,
two onsite disposal ponds, a barge unloading facility, and water
intake and discharge structures. The project also requires
two ravines adjacent to the generating site totalling 1440
iii
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acres to be used for solid waste disposal. Also proposed is
a new 9 mile long corridor to accommodate two 345-icV transmission
lines. The corridor would cross the Ohio River at the site and
extend west into Clark County, Indiana and connect to a 138-
kV line, 3 miles west of New Washington, Indiana.
No construction has commenced for this new facility pending
issuance of the EPA NPDES Permit to discharge wastewater, the
Corps of Engineers' Section 10/404 Construction Permit and other
necessary Federal and State approval certificates and permits.
Neither the NPDES Permit nor the Corps Construction Permit can
be issued until 30 days after this Final EIS is received by
the EPA Office of Federal Activities. The Applicant has
scheduled construction to begin upon receipt of these permits.
3. Major Environmental Impacts
(A) Construction
This project would represent the commitment of approximately
2,300 acres near Wises Landing to industrial land use from
previous uses, mostly agricultural. The lower portion of a
tributary (Corn Creek) to the Ohio River would be relocated.
This represents a loss of good aquatic habitat. The project
also represents a loss of significant acreage of fertile
agricultural land and good habitat. Increased air pollution,
mostly as fugitive dust, is expected on and near the site for
the duration of the construction period. Pollutants would also
be contributed to the Ohio River during this period from general
site runoff and from construction of the barge facilities
and water intake and discharge structures along the riverfront.
There would be increased noise from construction activities
and increased vehicular use of roadways leading to the
construction areas. The construction work force is expected
to peak at about 695 individuals, and cause significant
socioeconomic changes in surrounding communities. The demand
for goods and services created by the daily influx of workers
and by worker relocations would significantly affect local
communities. No archaeological sites worthy of mitigation were
discovered during survey work.
The proposed transmission line in Indiana is required to
integrate the Trimble County Generating Plant with the
Applicant's system and to complete the 345-kV system loop.
The 9 mile long transmission corridor will occupy 34.5 acres
of which about half is woodland requiring clearing. Work on
the corridor will result in localized short term air pollution
and may cause siltation where stream crossings are required.
IV
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The estimated total construction costs to the Applicant for
the new generating station and transmission system are $1,354
million.
(B) Operation
Operation impacts will occur for the life of the facility, about
36 years. Most significant will be the impact to air quality
within the Ohio River Valley area resulting from sulfur dioxide,
nitrogen oxides, and particulates emitted by the facility.
Visible water vapor plumes emitted from the cooling towers'would
at times extend 3.1 miles from the plant. Emissions from the
stacks will to varying degrees contribute to acidic sulfate
formation. Coal usage by all four units is projected to be
about 112,500 tons (75 barge loads) per week.
The projected enormous quantities of solid wastes generated
during operation are a major consideration. Besides the acreage
for ponds on site, a gradual but complete elimination of 1440
acres of pasture and woodland vegetation in the ravines would
occur over the life of the facility.
The large quantity of water (68,541 gallons per minute, maximum)
withdrawn from the river would result in loss of numerous small
aquatic organisms as a result of entrainment by the plant.
The discharge of heated wastewater and plant service water
(40,900 gallons per minute maximum) would have a minor impact
on aquatic life in the river.
Citizens of Trimble County will experience significant long-
term impacts as a result of plant operation. Increased noise,
traffic congestion, and other adverse environmental impacts
attendant on a large industrial development would irreversibly
alter the rural setting of the site and nearby communities.
Expansion of the tax base from the assessment of the facility
and the revenue obtained from management spending would be
significant. The anticipated 350 operational personnel would
directly stimulate business, especially retail trade and the
housing industry although only a fraction of the operational
personnel are expected to seek housing within the county.
Secondary impacts would result from inducement of satellite
development. Although most of the goods and services required
by the project would originate in Louisville, development of
non-agricultural business would be significantly stimulated.
A major secondary impact of this facility would result from
the Trimble County Generating Plant's use of almost all of
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the available sulfur dioxide air quality deterioration increment,
This could preclude another industry with a similiar type and
magnitude of air emissions from locating in the immediate area.
4. EPA Position on Mitigation of Impacts
The proposed facility would be required to meet all New Source
Performance Standards pertaining to water discharge and water
quality standards under NPDES permitting authority and would
be restricted by New Source Air Emissions limitations under
the Clean Air Act. Impact to terrestrial and aquatic wildlife
has been significantly reduced by changing the onsite disposal
ponds to preserve a wetland creek oxbow. However, the EPA
Region IV has identified several potentially adverse
environmental impacts that require further mitigation. The
following mitigative measures have been developed by the Agency
and the Applicant. The Applicant has agreed to:
Monitor groundwater to detect any contamination and,
if needed, take steps to reduce it
Control site erosion and reduce sediment entering
the Ohio River, Corn Creek, and Barebone Creek
Provide for adequate, environmentally
acceptable waste disposal
Provide for flue gas desulfurization system malfunctions
Restrict use of herbicides on transmission
corridor work
Provide for identification of valuable vegetation and
wildlife habitat along transmission corridors attendant
on the new station
Provide for identification of archaeological
resources along transmission corridors attendant
on the new station
5. Alternatives to the Proposed Action
(A) Alternatives not requiring new capacity
VI
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(B) Alternatives requiring new capacity
(1) Alternative sites
(2) Alternative fuels
(3) Alternative plant system design
(4) Alternative waste treatment and disposal
(5) Alternative electrical transmission
6. Respondents on the Draft Statement
Federal Agencies
Advisory Council on Historic Preservation
Army Corps of Engineers
Department of Commerce
Department of Energy
Department of Health, Education and Welfare
Department of Housing and Urban Development
Soil Conservation Service of the Dept. of Agriculture
State
Kentucky
Department for Natural Resources and Environmental
Protection
Department of Transportation
Department of Fish and Wildlife Resources
Indiana
Indiana State Clearinghouse
Local
Trimble County Water District fl
Trimble County Schools
Interested Groups
Save The Valley
Sierra Club Cumberland Chapter
VII
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Individuals
Mr. Walter Grote
Mr. Fred Hauck
Dr. Harold G. Cassidy
Mr. Harold Alsup
Mr. Stanley B. Wheater
Mr. Milton Rush
Dr. Thomas D. Breitweiser
Mr. C.L. Gossom
Ms. Shirley E. Clark
Mr. Paul Scully
Ms. Mary Clashrian
Mr. Carl J. Zoeller
Mr. Paul Butler
Ms. Gerry L. Hancock R.N.
Mr. George Clark
Mr. L. Paul Venard
Ms. Irene P. Long
Mr. J. Gordon Arbuckle
7. This final EIS was made available t
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TABLE OF CONTENTS
Section Page No,
1. INTRODUCTION 1- 1
1.1 FEDERAL ACTION 1-1
1.2 AGENCY DECISION 1-1
1.3 FEIS FORMAT 1-1
2. STATEMENT OF FINDINGS OF MAJOR ISSUES 2-1
2.1 INTRODUCTION 2-1
2.2 AIR QUALITY ASSESSMENT TECHNIQUES 2-1
2.3 FLUE GAS DESULFURIZATION (FGD) TECHNOLOGY 2- 2
2.4 POTENTIAL GROUND WATER CONTAMINATION 2-2
2.5 POWER PLANT SITING 2-3
2.6 COOLING TOWER INTERACTION WITH STACK EMISSIONS 2- 4
3. SUMMARY OF THE DRAFT ENVIRONMENTAL IMPACT STATEMENT 3- 1
3.1 THE APPLICANT 3-1
3.2 ALTERNATIVES CONSIDERED 3-8
3.3 THE ENVIRONMENT 3-40
3.4 ENVIRONMENTAL IMPACTS OF THE PROPOSED PROJECT. 3-47
3.5 MEASURES TO MITIGATE ADVERSE ENVIRONMENTAL
IMPACTS 3-76
4. AN ANALYSIS OF POTENTIAL PLUME INTERACTIONS BETWEEN
TRIMBLE COUNTY AND CLIFTY CREEK POWER PLANTS 4- 1
4.1 INTRODUCTION 4- 1
4.2 DAMES & MOORE MULTI-SOURCE CRSTER MODEL 4-1
4.3 ANALYSIS TECHNIQUES AND RECEPTOR GRID GEOMETRY 4- 2
4.4 ANALYSIS RESULTS 4-2
5. COMMENTS RECEIVED AND AGENCY RESPONSES 5-1
5.1 INTRODUCTION 5-1
5.2 SUMMARY OF MAJOR CONCERNS AND AGENCY RESPONSES 5- 1
5.3 COMMENT DOCUMENTS AND AGENCY RESPONSES 5- 5
LIST OF APPENDICES
A DRAFT NPDES PERMIT
B REVISED GROUND WATER MONITORING PROGRAM
C EROSION AND SEDIMENT CONTROL PLAN
D STIPULATION
E PUBLIC HEARING TRANSCRIPT
ix
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LIST OF TABLES
Number Title Page No.
1 LOUISVILLE GAS AND ELECTRIC COMPANY 3- 4
PRESENT GENERATING CAPACITY
2 LOUISVILLE GAS AND ELECTRIC COMPANY 3- 5
GENERATION RESOURCE ADDITIONS
1977-1990
3 LOUISVILLE GAS AND ELECTRIC COMPANY 3- 6
GENERATING STATION RETIREMENT PLANS
1977-1990
4 LOUISVILLE GAS AND ELECTRIC COMPANY 3- 7
PROJECTED SYSTEM LOADS AND CAPACITIES,
1976-1990
5 ALTERNATIVE SITES SUMMARY MATRIX 3-13
6 WASTE HEAT REJECTION SYSTEM 3-19
7 ATMOSPHERIC POLLUTION CONTROL SYSTEMS 3-21
8 PLANT WATER USES 3-26
9 INTAKE AND DISCHARGE STRUCTURES 3-28
10 DESCRIPTION OF DISPOSAL POND ARRANGEMENTS, 3-32
TRIMBLE COUNTY GENERATING PLANT
11 RESULTS OF ENGINEERING AND ENVIRONMENTAL 3-33
EVALUATION OF DISPOSAL POND ARRANGEMENTS
12 TRANSMISSION SYSTEMS 3-39
13 KENTUCKY AND FEDERAL AMBIENT AIR QUALITY 3-49
STANDARDS
14 MAXIMUM GROUND-LEVEL POLLUTANT CONCENTRATION 3-52
RESULTING FROM OPERATION OF THE TRIMBLE
COUNTY GENERATING PLANT AS A FUNCTION OF
THE NUMBER OF UNITS IN OPERATION
15 COMPARISON OF THE PROPOSED TRIMBLE COUNTY 3-53
GENERATING PLANT AMBIENT LEVELS TO THE
FEDERAL AND STATE AMBIENT AIR QUALITY
STANDARDS
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LIST OF TABLES (CONTINUED)
Number Title Page No.
16 SUMMARY OF IMPACTS PROJECTED TO RESULT FROM 3-58
CONSTRUCTION AND OPERATION OF THE PROPOSED
TRIMBLE COUNTY GENERATING PLANT
1 RECEPTOR ELEVATIONS 4- 6
1A SOURCE CHARACTERISTICS 4- 7
2 ANNUAL MEAN SULFUR DIOXIDE CONCENTRATION AT 4- 8
EACH RECEPTOR, CLIFTY CREEK
3 HIGHEST 24-HOUR SULFUR DIOXIDE CONCENTRATION 4- 9
AT EACH RECEPTOR, CLIFTY CREEEK
4 SECOND HIGHEST 24-HOUR SULFUR DIOXIDE CONCEN- 4-10
TRATION AT EACH RECEPTOR, CLIFTY CREEK
5 HIGHEST 3-HOUR SULFUR DIOXIDE CONCENTRATION 4-11
AT EACH RECEPTOR, CLIFTY CREEK
6 SECOND HIGHEST 3-HOUR SULFUR DIOXIDE CONCEN- 4-12
TRATION AT EACH RECEPTOR, CLIFTY CREEK
7 ANNUAL MEAN SULFUR DIOXIDE CONCENTRATION AT 4-13
EACH RECEPTOR, TRIMBLE COUNTY
8 HIGHEST 24-HOUR SULFUR DIOXIDE CONCENTRATION 4-14
AT EACH RECEPTOR, TRIMBLE COUNTY
9 SECOND HIGHEST 24-HOUR SULFUR DIOXIDE CONCEN- 4-15
TRATION AT EACH RECEPTOR, TRIMBLE COUNTY
10 HIGHEST 3-HOUR SULFUR DIOXIDE CONCENTRATION 4-16
AT EACH RECEPTOR, TRIMBLE COUNTY
11 SECOND HIGHEST 3-HOUR SULFUR DIOXIDE CONCEN- 4-17
TRATION AT EACH RECEPTOR, TRIMBLE COUNTY
12 HIGHEST 3-HOUR SULFUR DIOXIDE CONCENTRATION 4-18
AT EACH RECEPTOR, TRIMBLE COUNTY
13 SECOND HIGHEST 3-HOUR SULFUR DIOXIDE CONCEN- 4-19
TRATION AT EACH RECEPTOR, TRIMBLE COUNTY
14 HIGHEST 3-HOUR SULFUR DIOXIDE CONCENTRATION 4-20
AT EACH RECEPTOR, CLIFTY CREEK
XI
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LIST OF TABLES (CONTINUED)
Number Title Page No.
15 SECOND HIGHEST 3-HOUR SULFUR DIOXIDE CON- 4-21
TRATION AT EACH RECEPTOR, CLIFTY CREEK
16 HIGHEST 3-HOUR SULFUR DIOXIDE CONCENTRATION 4-22
AT EACH RECEPTOR, COMBINED PLANTS
17 SECOND HIGHEST 3-HOUR SULFUR DIOXIDE CONCEN- 4-23
TRATION AT EACH RECEPTOR, COMBINED PLANTS
18 SOURCE CONTRIBUTION TABLE, TRIMBLE COUNTY 4-24
19 SOURCE CONTRIBUTION TABLE, TRIMBLE COUNTY 4-25
20 SOURCE CONTRIBUTION TABLE, TRIMBLE COUNTY 4-26
21 SOURCE CONTRIBUTION TABLE, TRIMBLE COUNTY 4-27
22 SOURCE CONTRIBUTION TABLE, TRIMBLE COUNTY 4-28
LIST OF FIGURES
Number Title
1 SYSTEM MAP
2 STEAM ELECTRIC SYSTEM CYCLE
3 STATION WATER USE PLAN PEAK FLOW
4 PROPOSED PROPERTY DEVELOPMENT
5 PROJECT LOCATION MAP
6 PROPOSED PLANT SITE
7 LAND USE OF THE PRELIMINARY TRANSMISSION
LINE CORRIDOR, CLARK COUNTY, INDIANA
1 SOURCE & RECEPTOR CONFIGURATION, TRIMBLE
COUNTY AND CLIFTY CREEK
2 RECEPTOR GEOMETRY, TRIMBLE COUNTY AND
CLIFTY CREEK
Page No.
3- 3
3-18
3-27
3-37
3-41
3-42
3-45
4- 4
4- 5
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1. INTRODUCTION
1.1 FEDERAL ACTION
The Louisville Gas and Electric Company (the Applicant) has applied
to the U.S. Environmental Protection Agency (EPA) for a National Pollutant
Discharge Elimination System (NPDES) permit for a proposed four-unit, 2,340
megawatt (MW) fossil-fuel power plant to be located in Trimble County,
Kentucky near the community of Wises Landing. In compliance with its responsi-
bility under the National Environmental Policy Act (NEPA) of 1969, the
Regional Administrator of EPA conducted a review of the proposed project and
determined that the issuing of the NPDES permit for the Applicant's proposed
project would constitute a major federal action. Therefore, before a decision
to issue the permit could be made, an environmental impact statement describing
the probable impacts of the proposed project on the natural and human environ-
ment was required. This report constitutes the Final Environmental Impact
Statement (FEIS).
1.2 AGENCY DECISION
Based on the comprehensive NEPA review of this project, the EPA,
Region IV, intends to issue, with conditions, the water discharge (NPDES)
permit (Appendix A) to Louisville Gas and Electric Company for the Trimble
County Generating Plant, Units 1-4. EPA intends to issue this permit
following the expiration of the 30-day administrative waiting period which
begins upon issuance of the FEIS.
1.3 FEIS FORMAT
The following sections of this document provide: (1) EPA's statement
of findings on the proposed project, (2) a summary of the Draft Environmental
Impact Statement (DEIS), (3) the revised modeling study of the interaction
between the proposed project and the Clifty Creek plant at Madison, Indiana,
(4) comments received by EPA on the DEIS and agency responses, and (5)
an appendix that contains the Draft NPDES permit (Appendix A), a ground
water monitoring plan (Appendix B), an erosion and sediment control plan
(Appendix C), the stipulation regarding impact mitigation signed by the
Regional Administrator and the Applicant (Appendix D), and the transcript of
the public hearing on the DEIS (Appendix E).
1-1
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2. STATEMENT OF FINDINGS ON MAJOR ISSUES
2.1 INTRODUCTION
The agency decisions considered the major issues voiced by other agencies
and the public. The following are the major issues:
1. Air quality assessment techniques
2. Flue gas desulfurization (FGD) technology
3. Potential ground water contamination
4. Power plant siting
5. Cooling tower interaction with stack emissions
The significant environmental impacts identified by EPA during the EIS
process are: (1) the impact to ambient air quality, (2) the potential for
ground water contamination, and (3) the conflict with present land uses in
the area. These impacts are reflected in issues 1, 3, and 4 listed above.
The agency's finding on each of the voiced issues is briefly stated in this
section.
2.2 AIR QUALITY ASSESSMENT TECHNIQUES
The impact from the proposed facility on ambient air quality remains
the most significant impact in the agency's opinion, and it is also the
issue most frequently voiced by the public.
In the course of the EIS process, there were several changes in models
and methodology used to predict the impact of the proposed plant. Comments on
the DEIS identified limitations with the model used to assess potential source
emissions interaction between the proposed plant and the existing Clifty Creek
plant at Madison, Indiana. This issue is important because of monitored
violations of S02 standards in the Madison area and because modeling has
shown the Clifty Creek plant to be exceeding S02 standards without contribu-
tion from the proposed plant. Therefore, the interaction was remodeled with a
multi-source CRSTER model. This remodeling showed that the proposed facility
will not significantly contribute to nor cause a violation of any ambient air
quality standards levels when interacting with the Clifty Creek plant (modeled
at present emissions). This is the same finding as that presented in the
DEIS.
The interaction with Clifty Creek would not be the most significant
impact to ambient air quality from operation of the proposed facility.
The plant is predicted to have maximum contribution to ground level air
pollutant concentrations in the immediate vicinity of the proposed plant
during atmospheric conditions when no other major point sources would
be contributing measurable concentrations of pollutants. No ambient
standards are predicted to be exceeded.
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Several commenters have suggested that EPA Region IV use modeling
methodology which is presently under development. It must be emphasized
that a site specific EIS, on a proposed project for which EPA has a regula-
tory authority, cannot use models which have not been validated. EPA has
ongoing research on new methodology at its Research Triangle Park (RTF)
laboratories. The Monitoring and Data Analysis Divison within the Office
of Air Quality Planning and Standards at RTP is working on the Ohio River
Valley situation and is evaluating the latest developments in predictive
methodology.
2.3 FLUE GAS DESULFURIZATION (FGD) TECHNOLOGY
It is evident that generating stations such as that proposed, which
will utilize abundant high sulfur content coal resources, along with flue
gas scrubbing to remove specified amounts of sulfur prior to emission,
will be the chosen technology by many utilities for years to come, if and
until alternative coal cleaning processes become economically competitive.
The EPA has been involved in the development of scrubber technology for
about 10 years. It firmly believes FGD's are proven and suitable for a
station of the size proposed for Wises Landing. The Applicant will retain
sufficient flexibility in selecting specific FGD devices to take advantage
of further improvements in efficiency and reliability of scrubbers.
2.4 POTENTIAL GROUND WATER CONTAMINATION
Solid waste from the power plant operation could significantly degrade
ground water quality in the Wises Landing area without adequate safeguards.
The Applicant's disposal plan for these wastes has undergone critical review
atid modification. After additional assessment following the DEIS concern
on this issue, and following a meeting of EPA, state, and concerned local
groups, EPA believes that the plant will have minimal effect on ground water
quality.
The bottom ash pond and the much smaller pond for use as an emergency
fly ash and scrubber sludge hold-up prior to sludge fixation will be lined.
There are enough deposits of sufficiently impermeable clays on the site
for this purpose which should significantly reduce the amount of leaching
compared to ponds not lined. Ground water monitoring wells 1-4 are located
at the S-SW pond dikes and screened properly to detect leachate, should it
occur, long before any change to water quality at the municipal well field
at Wises Landing could be detected.
The Applicant's plan to dispose of flue gas scrubber wastes and all
of the fly ash waste in two ravines (designated RA and RB) immediately
adjacent to the generating site is viewed as acceptable. The concern
for ground water contamination results from the fact that portions of
the ravine walls have cracks or fractures in the rock that are suspected
to be contiguous with the shallow aquifer. The extent of this karstifi-
cation, as it is called, is not totally known nor is the direction or amount
of ground water flow in the area of these ravines. The Commonwealth of
Kentucky will require this detailed information from the Applicant under its
solid waste disposal permitting authority prior to disposal operations.
2-2
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The entire proposal to utilize the ravines as they presently exist
is totally dependent upon the success of the proposed sludge/fly ash stabili-
zation technique. The Applicant has indicated that a commercially available
process will be used. There has been ample demonstration, elsewhere, of
the acceptability of the chosen process, specifically, the low permeabilities
of the stabilized sludge. This information and information on the nature of
the proposed coal, leads EPA to believe the process will work at the Trimble
County site.
The sludge must "seal" the cracks in the walls of the ravines, and it
must resist rewatering in the long-term even in direct contact with water in
order to prevent leaching through the two possible avenues. These are
subflow of ground water under the ravine floors westwards toward the Ohio
River and lateral seepage through the cracks in the ravine walls.
If this cannot be accomplished, the Applicant is then forced by agree-
ment with the EPA and by regulatory requirements of Kentucky to seek alterna-
tive disposal methods.
Potential surface water quality degradation from sludge disposal in
the ravines is covered by the NPDES permit enforcement authority.
2.5 POWER PLANT SITING
While the alternative site evaluation in the Draft EIS was not challenged,
the location of a plant outside the Applicant's service area was a complaint.
It should be pointed out that the Applicant proposed the site. There
are many economical and technical factors which the Applicant considered.
The Applicant's main environmental reason for desiring to locate at Wises
Landing is that the Louisville area has been designated as a non-attainment
area for sulfur dioxide. There have been SC>2 and particulate standards
violations which preclude any increased emissions of these pollutants in
that area. There are few, if any, urban centers where a large coal-fired
plant could be sited. Therefore, the Applicant looked outside the immediate
Louisville area. The concern of EPA is for a healthful air quality for both
urban and rural dwellers. The intent of Congress in the Clean Air Act was
very explicit in its assignment of various class areas for allowable air
degradation. The non-attainment provision under this law makes it nearly
impossible for the Applicant to locate any further new capacity in Louisville,
even with the stringent emissions limitations for new sources, and still
retain the economies of scale, which it feels it retains only with a plant
of the size proposed.
The EPA found no violation of any zoning ordinances or existing land
use plans for the area or any conflict with projected future programs.
Land use planning is the mandate of local governments and not EPA.
2-3
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2.6 COOLING TOWER INTERACTION WITH STACK EMISSIONS
The matter of potential adverse impact caused by combined volumes of
water vapor emanating from the cooling towers of the proposed plant and
the Marble Hill Nuclear Station proposed across the river was voiced by
several commenters. The conservative estimate of interaction of the
respective tower plumes indicated that each, under worst conditions, would
cause average humidity increases to 3 percent or less at any location.
Interaction potential of cooling tower plumes is remote.
What is of concern to EPA is the unanswered question of the significance
of radiological activity of airborne particulate emissions from coal-fired
power plants which are in close proximity to nuclear plants. There is
increasing awareness of the condition and an accelerated EPA research effort
to determine the health effects. With consideration of the efficiency of
particulate controls and the type of coal proposed to be utilized at this
plant, EPA believes that the impact will be relatively minor as the plant
is proposed.
Cooling tower water vapor interaction with the stack emissions of
power plants accelerates the formation of sulfate compounds, which are
precursor agents in the lowering of the pH of rainfall. The EPA Office
of Research and Development is currently researching this to determine
the long range effects. It will be extremely difficult to ascertain what
the amount of contribution a specific point source would have to an
acidic rainfall condition many miles away. The new source emissions
limitations on the sulfur dioxide compound is believed to be most important
in avoiding the acidic conditions. EPA currently has no sulfate ambient
standards and consequently is not prepared to apply any such factors to
its regulatory role of new sources.
2-4
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3. SUMMARY OF THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
3.1 THE APPLICANT
Louisville Gas and Electric Company (the Applicant) distributes and
sells electricity to 284,066 ultimate consumers (as of December 31, 1976)
in Jefferson County and portions of Oldham, Bullitt, Meade, and Hardin
Counties, and limited parts of Henry, Trimble, Shelby, and Spencer Counties,
Kentucky (Figure 1). The area served covers approximately 700 square miles
and contains an estimated population of 790,000, exclusive of the Fort Knox
Military Reservation, which the Applicant also serves with electricity.
The Applicant wholly owns one subsidiary, Ohio Valley Transmission
Corporation, an Indiana corporation. This subsidiary exists to own and
operate those facilities located in Indiana that are necessary to the system
operations. Neither Ohio Valley Transmission Corporation nor the Applicant
sells electricity directly to any ultimate consumers in Indiana.
The Applicant presently has transmission interconnections and inter-
connection agreements with Public Service Indiana, Kentucky Utilities Company,
Southern Indiana Gas & Electric Company, The Cincinnati Gas & Electric
Company, Ohio Valley Electric Corporation, Tennessee Valley Authority, East
Kentucky Power Cooperative, and Big Rivers Electric Corporation. These inter-
connections and interconnection agreements provide for various interchanges,
emergency services, and other working arrangements. Power is normally
exchanged via these interconnections for emergency, maintenance, or economy
purposes on an "as-available" basis.
As of December 1977, the net seasonal summer generation capacity of
the Applicant's system is 2,564 MW (Table 1). The bulk of this capacity
is coal-fired, although it does include six combustion turbine units and
eight run-of-the-river hydroelectric units.
The Applicant has one new unit with a capacity of 495 MW under con-
struction at the Mill Creek plant. This unit is scheduled for operation
in June 1980. The new Mill Creek unit, and other units planned through
1990, are described in Table 2.
Several older units will be retired, as shown in Table 3. These units
are scheduled to be retired because they will be obsolete, relatively in-
efficient to operate, costly to maintain, and difficult to retrofit with
equipment that is required to comply with environmental regulations. The
retirement of these units is part of an existing pollutant emissions
compliance agreement between the Applicant and the EPA.
The Applicant forecasts that the net total electric demand of its
customers can reasonably be expected to increase from 1,707 MW (the
adjusted load during the summer of 1976) to 2,482 MW by 1983 and 3,543 MW
by 1990. Table 4 presents the Applicant's projected system loads and
capacities, 1976 through 1990. A preliminary analysis of the actual 1977
summer load data for the Applicant's system generally confirms the demand
forecast for the summer of 1977.
In order to meet the projected future load growth and to maintain
reliable service, the Applicant has determined that it is necessary to
3-1
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add to its system a new generating facility to begin service in 1983. To
this end, the Applicant has proposed to construct a 2,340-MW generating
plant near Wises Landing in Trimble County, Kentucky.
The Applicant has projected the need to commence construction on this
facility to provide the load requirements necessary to compensate for (1)
scheduled retirements at its Paddys Run and Cane Run Stations and (2)
projected increased demand throughout the service area. The construction
schedule and projected online dates for each of the four units as described
in Table 4 will be adjusted if continuing projections of need so require.
The final analysis was made by comparing the composite load of four
major components of the forecast to the composite load growth of recent
history within the Applicant's system. Based on a 1965-1974 data base
and an exponential curve-fit (as commonly used in the industry), the com-
posite load growth shows an overall compound growth rate of 8.5 percent,
which would project forward to 6,288 MW by 1990. However, the growth rate
forecast by the Applicant ranges from 4.1 percent through 6.1 percent and
back down to 4.9 percent by 1990. This is because, for the period 1975
through 1976, some (but less than full) economic recovery was assumed to
occur. This is reflected particularly in the growth rate assigned to the
industrial segment. The composite growth rate for 1976, therefore, was
estimated to be 1.6 percent. From 1976 forward, a gradual increase in
recovery of the economy, particularly in the large industrial sector, was
projected. This is reflected in the 6.1 percent growth rate. However, this
rate is predicted to decline to 4.9 percent (3,543 MW) by 1990. The Applicant
believes that the potential for significant increases in the cost of electric
energy and the sensitivity to, and recognition of, diminishing natural energy
resources, might reasonably be expected to create an economic and moral
pressure for conservation in new growth. Further, retrofitting of existing
residential dwellings with air conditioning is expected to have reached
saturation by this time. Therefore, a slower growth rate should be in
effect by 1990.
The methodology and data on which this determination is based are
described in Sections 1.3 through 1.5 of the DEIS Supporting Report.
3-2
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LOUISVILLE GAS AND ELECTRIC COMPANY
LEGEND
— ELECTRIC —
GENERATING STATIONS
• THERMAL
A HYDRO
• COMBUSTION TURBINE
— MAJOR ELECTRIC LINES
— GAS —
O GAS TAKE POINT
_«» MAJOR GAS LINES
^.^ UNDERGROUND GAS
lJ3 STORAGE FIELD
BARREN
LOUISVILLE GAS & ELECTRIC CO.
TRIMBLE COUNTY GENERATING PLANT
SYSTEM MAP
FIGURE 1
3-3
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TABLE 1
LOUISVILLE GAS AND ELECTRIC COMPANY
PRESENT GENERATING CAPACITY
In Service Net Seasonal Summer
Station and Unit Number Date Type Capability in KWea
CANE RUN #1
#2
#3
#4
#5
#6
CT #11
MILL CREEK #1
#2
#3
PADDY'S RUN #1
#2
#3
#4
#5
#6
CT #11
CT #12
WATERSIDE #7
#8
ZORN CT #11
OHIO FALLS - 8 units
1954 Steam-Coal
1956 Steam-Coal
1958 Steam-Coal
1962 Steam-Coal
1966 Steam-Coal
1969 Steam-Coal
1968 Combustion Turbine
TOTAL
1972 Steam-Coal
1974 Steam-Coal
1977 Steam-Coal
TOTAL
1942 Steam-Coal
1942 Steam-Coal
1947 Steam-Coal
1949 Steam-Coal
1950 Steam-Coal
1952 Steam-Coal
1968 Combustion Turbine
1968 Combustion Turbine
TOTAL
1964 Combustion Turbine
1974 Combustion Turbine
TOTAL
1969 Combustion Turbine
1928 Run-of-River Hydrostation
Total System Steam
Total System Combustion Turbine
Total System Hydro
TOTAL
110,000
107,000
137,000
174,000
183,000
277,000
988,000
16,000
1,004,000
334,000
325,000
425,000
1,084,000
29,000
28,000
63,000
65,000
70,000
67,000
322,000
17,000
26,000
43,000
365,000
17,000
18,000
35 , 000
15,000
61,000
2,394,000
109,000
61,000
2,564,000
Data from latest East Central Area Reliability Coordination Agreement
uniform rating documents.
Source: Louisville Gas and Electric Company, December 1977
-------
TABLE 2
LOUISVILLE GAS AND ELECTRIC COMPANY
GENERATION RESOURCE ADDITIONS
1977-1990
Station and Unit
Member
MILL CREEK #4
Operating
Date
Scheduled June 1980
Type
Steam-Coal
Total Addition
TRIMBLE COUNTY
//I
#2
#3
#4
Planned
Planned
Planned
Planned
June
June
June
June
1983
1985
1987
1989
Steam-Coal
Steam-Coal
Steam-Coal
Steam-Coal
Total Addition
UNDESIGNATED
TOTAL
Planned
June
1984
Combustion
Turbine
Net Capacity of
Unit in KWe
495,
495,
495,
495,
675,
675,
2,340,
65,
2,900,
000
000
000
000
000
000
000
000
000
Source: Louisville Gas and Electric Company, December 1977
3-5
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TABLE 3
LOUISVILLE GAS AND ELECTRIC COMPANY
GENERATING STATION RETIREMENT PLANS
1977-1990
Station and
Unit Number
PADDY'S RUN
CANE RUN
TOTAL
#1
#2
#3
#4
#5
#6
#1
#2
#3
Planned
Retirement Date
June 1979
June 1979
June 1981
June 1981
June 1983
June 1984
June 1985
June 1985
June 1987
Type
S team-Coal
S team-Coal
Steam-Coal
S team-Coal
Steam-Coal
Steam-Coal
Steam-Coal
Steam-Coal
Steam-Coal
Net Capacity of
Unit in KWe
29,000
28,000
63,000
65,000
70,000
67,000
110,000
107,000
137,000
676,000
Source: Louisville Gas and Electric Company, December 1977
3-6
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TABLE 4
LOUISVILLE GAS AND ELECTRIC COMPANY PROJECTED SYSTEM LOADS AND CAPACITIES, 1976-1990
(Note: Parentheses indicate negative numbers)
Peak Load (MWe)a
Capacity Changes
Steam
Combustion Turbine
Hydro
Rerating
Retirements
Firm Purchases (Sales)
Total Capacities
Steam
1
-J Combustion Turbine
Hydro
Firm Purchases (Sales)0
TOTAL (MWe)
Reserve - With Trimble County
Capacity
Percent of Peak Load
Reserve - Without Trimble County
Capacity
Percent of Peak Load
1976 1977 1978
1707b 1778 1862
425°
(4) (8)d
(55) (11)
1969 1969 2386
109 109 109
61 61 61
(10) _(1Q) (21)
2129 2129 2535
422 351 673
25 20 36
422 351 673
25 20 36
1979
1975
(13)d
(57)e
(13)
2316
109
61
(34)
2452
477
24
477
24
1980
2091
495
(17)
2811
109
61
(51)
2930
839
40
839
40
1981 1982
2211 2344
(15)d (15)d
(128)f
2668 2653
109 109
61 61
(51) (51)
2787 2772
576 428
26 18
576 428
26 18
1983 1984 1985 1986 1987 1988
2482 2624 2768 2915 3065 3221
495 495 675
65
(70)8 (67)h (217)1 (137)J
3078 3011 3289 3289 3827 3827
109 174 174 174 174 174
61 61 61 61 61 61
(51) (51) (51) (51) (51) (51)
3197 3195 3473 3473 4011 4011
715 571 705 558 946 790
29 22 25 19 31 24
220 76 (285)
9 3 (10)
1989 1990
3381 3543
675
4502 4502
174 174
61 61
(51) (51)
4686 4686
1305 1143
38 32
Median summer forecast.
Adjusted for temperature and known curtailments.
December 1977 operating date—not available for
1977 summer peak.
Deratings due to sulfur dioxide removal systems.
Retirement Paddy's Run #1 and $2.
Retirement Paddy's Run #3 and #4.
Retirement Paddy's Run #5.
Retirement Paddy's Run #6.
Retirement Cane Run #1 and #2.
j
Retirement Cane Run #3.
kOhio Valley Electric Corporation (OVEC)
sales or purchases.
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3.2 ALTERNATIVES CONSIDERED
INTRODUCTION
The Council on Environmental Quality's and the Environmental Protec-
tion Agency's guidelines for evaluating alternatives indicate five aspects
of a proposed project that need to be addressed:
1. Has the no-action alternative been considered; that is,
is it possible that the Applicant might not require a
new generating station?
2. Is postponing the construction and operation of the
facility environmentally and economically practical?
3. What are the available alternative methods of obtaining
this additional capacity?
4. What are the available alternative sites for locating
the generating facility?
5. What are the available design alternatives for the
generating facility?
The following is a summary presentation of the process by which the questions
were evaluated and of the major feasible alternatives that were considered.
EVALUATION PROCESS
Once the Applicant notified the EPA of its intent to apply for an NPDES
permit for a 2,340-MW fossil-fuel generating plant and the EIS process was
instituted, the Applicant's design firm began its analysis of the engineering
alternatives for a fossil-fuel power plant capable of producing the required
generating capacity. At the same time, an evaluation of the environmental
considerations related to the project was begun by the environmental consultant,
Dames & Moore (hereinafter referred to as the Consultant), retained by the
Applicant to prepare the EIS under the direction of EPA Region IV. The
Applicant submitted a study of the forecasting assumptions and methodology by
which it had determined that its system required a new facility of the size
proposed. This study was reviewed by the EPA, an independent consultant
retained by the Consultant, and the Federal Power Commission. The Commission
and the independent consultant concluded that the forecasting technique and
the results were reasonable. At the same time, the Consultant also retained
another independent consultant to perform an evaluation of alternative sites
for the proposed project. Concurrently, conceptual engineering studies, which
included an evaluation of engineering alternatives, were completed by the design
firm and reviewed by the Consultant and EPA. These studies were then used
to prepare Sections 1.0 through 4.0 of the DEIS Supporting Report.
The following is a description of the results of these evaluations.
3-8
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ALTERNATIVES TO CONSTRUCTING A 2,340-MW GENERATING PLANT
Abandoning the Project
Not providing the additional generating capacity required to meet the
projected increased customer demand within the Applicant's service area would
be detrimental to the service area customers and the regional economy. With-
out additional capacity, it is projected that, by 1985, the Applicant would
not have sufficient reserve capacity to cover a forced outage of one of its
larger units, a maintenance shutdown of one of its larger units, or a combina-
tion of a series of smaller capacity losses within its system. As demand
continued to grow, the system reserve capacity would be further reduced.
The results of such inadequate reserve capacity could be expected to
cause regular brownouts and occasional blackouts within the Applicant's
service area. Residential customers most affected by these incidents would
be those in newer, all-electric homes or apartment buildings. Industrial
customers could decide to cut back production or move from the area, while
commercial customers might be forced to reduce their operating hours. The
results of such actions on the part of these two customer groups would be
employee layoffs, lower levels of productivity, reduced income to commercial
establishments and their employees, reduced commercial services, and, in
general, a severe economic impact within the Applicant's service
area.
Obtaining Required Energy From Other Sources
Three alternative means of obtaining the energy required to meet the
increase in customer demand were evaluated:
1. Purchase of energy from other utilities
2. Uprating of older plants
3. Reactivation of retired plants
Purchase of energy was not found to be a viable alternative primarily
because the energy available for purchase from neighboring utilities on a
long-term basis is not sufficient to meet the projected demand. Also, were
sufficient energy available for purchase, its cost would be higher than that
generated by the Applicant, and this higher cost would be borne by the customer.
Uprating of older plants and reactivation of retired plants were rejected
as viable alternatives for three reasons. First, the generating equipment in
older or retired units is worn and less efficient to operate. The results
are: (1) higher operating and maintenance costs and (2) reduced reliability.
Second, the amount of additional capacity that could be achieved by uprating
older units is relatively minor, compared to the amount required to meet the
projected demand increases within the Applicant's service area. Third,
although the older or retired units could conceivably be modified in order
to achieve the required generating capacity increases, sufficient physical
space is not present on the sites of these plants to support large capacity
additions. Because modern pollution control systems and their waste disposal
requirements were not part of the original plants, the sites of these plants
do not provide sufficient acreage to accommodate them.
3-9
-------
In addition, pollution control devices and their waste disposal re-
quirements are very costly. By attempting to supply the projected increased
demand by constructing a series of new units on older sites, if this were
possible, the result would be excessive duplication of many of the most
costly facilities. This would result in the loss of the economies of scale.
Joint Projects and the Construction of Smaller Facilities
Joint projects are generally a feasible alternative arrangement for
constructing a power plant; such an alternative, however, does not eliminate
the need to construct a new generating plant. Such an option potentially
expands the number of sites available for the location of a plant.
However, at the time the Applicant began planning the proposed project,
it was not a member of a power pool or cooperative agreement (this is still
the case). Such agreements are complex, and their initiation would require
a significant amount of lead time. Further, a coordination of the Applicant's
needs with those of the other members of the agreement would be required, and
the Applicant's ability to modify construction scheduling would be reduced.
The Applicant prefers to rely on internal generation capability to
supply its system's needs rather than on pool or other cooperative agreements.
It claims that such a policy results in lower generation costs and, conse-
quently, lower electrical rates for its customers.
The construction of a smaller facility (990-MW total) could be under-
taken by the Applicant. Such a facility would supply the capacity necessary
to meet increased demand projected for the service area until 1985. After
this time, the projected continued growth would require the construction of
an additional facility. However, the economic costs associated with such an
alternative are far greater than those associated with the construction of a
single, large facility. Additionally, the environmental costs would also be
greater, as another 500+ acres of land would be required for the second
facility. The environmental impacts resulting from the construction and
operation of the second facility would be only somewhat less than those
associated with the larger facility. (Depending on the nature and location
of the site for the second facility, the associated impacts could conceivably
be more significant.)
ALTERNATIVE MEANS OF GENERATING THE REQUIRED POWER
There are four alternative means available to the Applicant of generating
the required power: nuclear, water, oil, and coal. Gas, because of its
shortage, is not a feasible alternative. Other alternative generation means,
such as solar and geothermal, have not been developed to the point where they
are available for use in a large-scale, continuous operation. In Kentucky,
pumped storage is not a viable option because of the geology of the area.
The present estimated lead time required for the planning, design, and
construction of a nuclear power plant is 8 to 10 years. At the time (1974)
that the Applicant began planning for the proposed project, it was anticipating
the need for a new unit by 1981, which eliminated a nuclear plant from
cons ider at ion.
3-10
-------
Furthermore, the economics of nuclear plant development dictate a
unit size of 800 MW or larger. At present, the Applicant's system does
not have the reserve capacity to support the outage of a unit of this size.
The large-scale use of hydroelectric generation in the Ohio River
valley is not feasible because of the lack of suitable sites.
As a fuel for generating electricity, oil is not a viable alternative
in Kentucky at this time. The use of oil as a fuel for electric power
generation is presently being curtailed by government regulations. Further-
more, in a state like Kentucky where there are large coal reserves, it
does not make good sense to burn a fuel that is more costly, less abundant,
and, because most of it is imported from a foreign source, less reliable
than coal.
Coal in varying sulfur contents is available in abundance in Kentucky.
The Applicant proposes to use high-sulfur western Kentucky coal because this
coal is reasonably certain to be available in sufficient quantities for the
36-year life of the facility. Also, western Kentucky coal is presently the
most economical choice, even though expensive flue gas desulfurization equip-
ment is required to control the sulfur emissions that result from the burning
of high-sulfur coal.
Low-sulfur coals from the western states have been ruled out as an
alternative because Kentucky coal is a cheaper and more reliable source of
fuel.
Washing high-sulfur coal improves its Btu output and lowers the amount
of sulfur and other impurities. Washed coal may be used by the Applicant
if it becomes available in sufficient quantities and the cost is not excessive.
ALTERNATIVE SITES FOR A 2,340-MW GENERATING PLANT
Seven candidate sites (out of an initial 17 sites) were evaluated as
potential locations for the Applicant's proposed plant. Of these seven
sites, five were on the Ohio River flood plain. The two remaining sites
(Garrett and LaGrange) were located inland from the river (see Table 5).
The factors considered in the evaluation process were land use, cultural and
recreational features, ecology, aesthetics, water supply, water quality, geology,
natural and man-related hazards, meteorology, and air quality. Certain cost-
related factors associated with site development and plant operation were also
considered. These were land acquisition, cost of transporting coal and other
materials, transmission line costs, cost of developing a cooling water supply,
and cost of site preparation. Another criterion, related to the nature of
the Applicant's service area, was also included in the evaluation of the
seven candidate sites—proximity to the northern portion of the service area.
This area is presently experiencing the fastest growth rate and will there-
fore require a larger portion of the power generated by the proposed project.
Table 5 provides a summary comparison of the seven sites. Maps of the sites,
plus a detailed description of each, are presented in Section 3.4 of the DEIS
Supporting Report.
The Trimble County site was selected by the Applicant as the preferred
alternative on the basis of the following factors: (1) ample acreage avail-
able for plant siting and solid waste disposal, (2) easy access to cooling
3-11
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water supply and barge transportation, (3) nearness of transmission line
tie-in, (4) low sulfur dioxide concentrations in the area, and (5) a loca-
tion in the northern portion of the Applicant's service area.
ALTERNATIVE PLANT SYSTEMS
To design a 2,340-MW power generating plant for the Trimble County
site, the Applicant conducted an engineering alternatives study to design a
plant that would:
0 Operate with a high degree of reliability
0 Be economically feasible
Be in accordance with all applicable federal, state, and
local engineering and environmental regulations
The alternatives analysis considered the following major plant systems and
structures:
1. Cooling system
2. Atmospheric pollutant control system
3. Plant water use system
4. Intake and discharge structures
5. Solid waste disposal system
6. Transmission line facilities
Other plant components, such as the coal handling facilities, barge docking
and unloading facilities, noise reduction devices, etc., were also evaluated.
As the analyses of these plant components were completed by the Applicant
and its design firm, they were submitted to the Consultant and the EPA for
review. On the basis of this review, an assessment was conducted of the
impact of the various alternatives, including the preferred design chosen
by the Applicant. Because the major environmental impacts of the plant will
be associated with the six major systems and structures named above, they
were the focus of the environmental impact analysis. Detailed descriptions of
the alternatives and the proposed plant design are presented in Sections 3.4
and 4.0 of the DEIS Supporting Report. The following is a summary of the major
plant systems and the various alternative designs considered.
Cooling System
The proposed Trimble County Generating Plant will use steam to generate
the electrical energy that the plant is designed to produce. Water will be
drawn from the Ohio River and turned to high-pressure, superheated steam
(thermal energy) in coal-fired steam generators. This steam will then be
sent to the turbine generators, where the thermal energy of the steam will
be converted to mechanical energy, which in turn will be converted to
electric energy in the power generators (see Figure 2). After giving up its
usable heat energy, the steam will be sent to the steam condensers and con-
verted to water; this water will then be reheated and sent to the steam
generators to begin the cycle once again.
3-12
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PAGE NOT
AVAILABLE
DIGITALLY
-------
In order to condense the steam into water, water will be circulated
through the condensers (where heat will be transferred from the steam to the
water), cooled, and then recycled. There are a number of ways the water
cooling process (called waste heat rejection) can be accomplished:
Man-Made Lakes - warm water is discharged to the lake where
the heat dissipates through evaporation
Spray Ponds or Canals - warm water is discharged to a long,
narrow pond or canal from a distribution pipe equipped with
a series of spray modules. These modules "atomize" the water
as it is discharged, allowing its heat to dissipate before
the water enters the receiving pond or canal
Cooling Towers - warm water is sent to a structure in which
the water is broken into films and air is passed through these
films at high flow rates. As the air passes through the water,
it picks up the water's heat load. The heated air is then
discharged to the atmosphere
The engineering, cost, and environmental pros and cons of each of these
alternatives are presented in Table 6. The Applicant proposes to use natural
draft cooling towers for the Trimble County Generating Plant.
Atmospheric Pollutant Control System
When coal is used to fire the steam generators, three major air pollutants
result: sulfur dioxide (S02), total suspended particulates (ash), and nitrogen
dioxide (N02). These pollutants are released to the atmosphere through the
plant's chimneys. The amount of these pollutants that can be so released is
regulated by both federal and state laws (described in this summary under
"Impacts of the Proposed Project"). The amount of these pollutants that is
emitted as a result of burning coal depends on several factors:
The sulfur and ash content of the coal being burned
The number of generating units (a total of four for
the proposed project) that are in operation
The operating level of each unit (i.e., at what level
of design capacity each unit is operating—this
typically varies from as low as 25 percent up to
100 percent)
The regulation of air pollutant emissions from a plant is based on the
maximum amount of air pollutants that would be produced when:
The coal being burned contains the highest sulfur
content that could be expected in the type of coal
that the Applicant has (or will) contracted to buy
for the plant
All four generating units are in operation
Each unit is operating at maximum (100 percent) capacity
3-17
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•H. P. TURBINE
-I P.TURBINE
Powtr to System
H.P.FEEDWMTER HEATERS
L.P. FEEDWATER HEATERS
FEEDMKTER PUMPS
H.P.« HIOH PRESSURE
I.P. * INTERMEDIATE PRESSURE
L.P. > LOW PRESSURE
DATE
DESIGN GUIDE
LOUISVILLE GAS 8 ELECTRIC COMPANY
TRIMBLE COUNTY PLANT SITE
STEAM ELECTRIC SYSTEM CYCLE
SHT OF
FIGURE
2
FORMC-313 1(V74
3-18
-------
TABLE 6
WASTE HEAT REJECTION SYSTEM
System
Advantages
Disadvantages
System
Advantages
Disadvantages
ONCE-THROUGH
COOLING SYSTEM
CLOSED CYCLE
SYSTEMS
Lakei'
Spray Ponds or
Canals
Dry Cooling
Toaers
No effect on present aquatic
habitat.
Requires fewer acrea than
man-made lake, with same
environmental advantage.
Eliminates evaporative losses
of cooling water.
Requires fewer acres, compared
to lakes or canals.
No fogging or icing problems.
Less damaging to aquatic
habitat than once-through
systems.
Causes localized changes in tem-
perature distribution of source
of water.
Relatively high ambient source
water temperatures need to be
lowered artifically.
Federal regulations discourage
once-through cooling systems.
Requires between 2,340 and
11,700 acres; the site has
only 1,000 acres (not includ-
ing ravines).
Tends to cause local fogging.
Has not been used on large
scale in areas that are
geographically and meteo-
rologically similar to the
Trimble County site.
Turbine exhausts at high
temperatures and high pres-
sures; this is inefficient
for cycle operation.
Domestic turbine vendors
restrict their turbine ex-
haust pressures to below those
economically achievable with
present dry tower design.
Mechanical Draft
Toaers
Rectangular
Round
Requires fewer acres than lakes
or canals.
Lower initial cost than round
mechanical draft towers.
Less damaging to aquatic habi-
tat than once-through systems.
Lower cost than natural draft
towers.
Better plume rise and disper-
sion characteristics than
rectangular mechanical draft
towers.
Requires less land than rec-
tangular mechanical draft
towers.
Wet/Dry Mechan- Helps minimize water consump-
iaal Draft tion by limiting evaporation.
Towers
Allows attainment of turbine
back pressures acceptable to
domestic turbine vendors.
Hyperbolic
Natural Draft
Toaer
Disperses plume at a very
great elevation compared to
other tower types.
Trapping of water droplets
in air is minimized.
Does not require more site
area than other tower types,
despite its overall size.
Operating cost generally
lower than other tower types.
Significant ground level
fogging and icing.
Requires more land than round
mechanical draft towers.
Has less desirable plume rise
and dispersion characteristics
than round mechanical draft
towers.
Higher initial cost than
rectangular mechanical draft
towers.
Higher initial cost than round
mechanical draft towers.
More expensive to operate than
round mechanical draft towers.
Has not been used extensively.
Greatest visual ijnpact.
Higher initial cost than other
tower types.
-------
The Applicant intends to burn Alston #1 coal in its proposed Trimble County
Generating Plant. In its raw (untreated) state, this coal contains up to
4.29 percent sulfur and 16.93 percent ash.
In order to keep the amount of air pollutants released by the plant in
conformance with state arid federal regulations, the Applicant must use devices
to control the sulfur dioxide, particulates, and nitrogen dioxide that will be
released by the burning of coal in the plant. Devices to control the sulfur
dioxide are called scrubbers; a variety of devices are available to remove
the particulates (see Table 7). Nitrogen dioxide is controlled by the design
of the steam generators. Each of these types of devices is available in
several different designs. These designs, and their advantages and disad-
vantages, are summarized in Table 7.
The Applicant proposes to use a wet limestone scrubbing system and
electrostatic precipitators in its Trimble County Generating Plant. The type
of nitrogen dioxide removal system to be used in the plant will be determined
by the boiler manufacturer.
Plant Water Use System
The proposed Trimble County Generating Plant will use water for four
main purposes: (1) cooling, (2) plant processes (make-up water for the con-
denser, water for the sulfur dioxide removal system, water to sluice bottom
ash from the boiler furnaces, and water for cleaning and other miscellaneous
uses), (3) domestic consumption and sanitary facilities, and (4) construction
uses (concrete batching plant, drinking purposes, sanitary facilities, fire
protection, hydrotesting, soil compaction, and dust suppression). Plant
construction and operation will produce five types of wastewater:
1. Cooling system wastewater (cooling tower "blowdown")
2. Plant processes wastewater
3. Solid waste disposal area precipitation runoff
4. Site precipitation runoff
5. Domestic and sanitary wastewater
Two alternative sources of water are avilable at the plant site: the
Ohio River and ground water from wells.
Wastewater management options available to the Applicant were the
following:
1. Discharge to the Ohio River
2. Discharge to land surface for ground absorption
3. Disposal ponds (with recycle)
4. Complete use of all wastewater (zero discharge to the environment)
Of the wastewater discharges that will result from the plant, plant process
wastewater has the highest potential for environmental pollution. Early in
the alternative design study, the Applicant decided that all plant process
wastewater would be handled by a zero discharge design. The only wastewater
that would be returned to the environment would be the cooling tower blowdown
and precipitation runoff from the site and solid waste disposal areas.
The only water source large enough to supply the amount required by
the plant for major uses (cooling, plant processes, fire protection, hydro-
testing, and soil compaction) is the Ohio River. The remaining plant water
3-20
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TABLE 7
ATMOSPHERIC POLLUTION CONTROL SYSTEMS
System
Coal Benefici-
ation, (mechanical
washing, magnetic
separation,
chemical
separation)
Advantages
S02 CONTROL
Reduces amount of waste re-
sulting from the removal
process
Solvent Refined
Coal
Flue Gas Desul-
furisation (FGD)
Wet lime or lime-
stone scrubbing
Low in ash and sulfur
Can remove up to 90% of
sulfur from flue gases
Least expensive and most
reliable of FGD processes
now in operation
Double alkali
scrubbing
Reduces scrubber scaling
and plugging problems
Has been used successfully
for industrial boilers
Pis advant ages
Mechanical washing depends on
availability of sufficient
water near mine
Magnetic and chemical separa-
tion still in laboratory testing
stage
Most beneficiated coal would
not allow emissions standards
to be met without other con-
trol methods
Still in development stage
Very expensive and not avail-
able in required quantities
Results in an insoluble waste
product, calcium sulfite/
calcium sulfate, which requires
a large area for disposal
Potential ground water problems
associated with waste disposal
Potential for some scaling or
plugging of scrubber
Waste product contains sodium
salts, with potential for water
pollution
Loss of reactant (sodium salts)
in waste makes the process more
expensive than lime/limestone
scrubbing
Has not been used in this
country at a coal-fired genera-
ting plant larger than 20 MW
3-21
-------
TABLE 7 (Continued)
System
Magnesium Oxide
Scrubbing
Catalytic
oxidation
Advantages
S02 CONTROL (Continued)
Process produces small
amounts of waste, recycles
material used as reactant,
and yields potentially
marketable by-product
Suitable for areas with
limited sludge disposal
space and a potential
market for the sulfur
by-product
If cost can be defrayed by
assumed sales revenue, may
prove to be less expensive
scrubbing method over life
of plant
Disadvantages
Process produces small
amounts of waste, recycles
material used as reactant,
and yields potentially
marketable by-product
If cost can be defrayed by
assumed sales revenue, may
prove to be less expensive
scrubbing method over life
of plant
Erosion, dust emissions,
and other problems
More expensive than lime/
limestone scrubbing
Presently more expensive on
a first cost and operating
costs basis than previous
two methods
May involve problems in
marketing the by-product
because of the large
quantities produced
Process presently undergoing
testing and modification on
large-scale demonstration units
Difficulty in producing high
temperatures for the dry
process
Corrosion and cooler plugging
in acid section of system
Contamination by fly ash may
adversely affect the life of
the catalyst
Capital and operating cost
higher than for lime/limestone
scrubbing
Additional marketing problems
associated with weak sulfuric
acid by-product
Process at demonstration plant
stage
3-22
-------
TABLE 7 (Continued)
System
Sodium scrubbing
Electrostatic
Preoipitator
Wet Scrubber -
Venturi Type
Fabric Filter
(Bag House)
Mechanical
Separators
(Cyclone)
Advantages
S02 CONTROL (Continued)
Process produces small
amounts of wastes, recycles
material used as reactant,
and yields potentially
marketable by-product
If cost can be defrayed by
assumed sales revenue, may
prove to be less expensive
scrubbing method over life
of plant
Presently undergoing full-
scale testing at several
coal-fired facilities
PARTICULATE CONTROL
Up to 99.6% removal of fly
ash, reliable, low operating
and maintenance costs
Disadvantages
Life-time operating and labor
costs are higher than for
lime/limestone scrubbing
CONTROL
Water Injection
Excessive energy consumption,
large volumes of water, pro-
duces waste sludge and
associated disposal problems
Larger space requirements,
limited design temperatures,
and higher maintenance costs
Low operating efficiencies,
necessitating the supplementary
use of one of the other kinds
of precipitators. Hence,
higher capital and operating
costs
High loss in thermal efficiency
makes this method expensive in
times of rising fuel costs and
energy resource scarcity
3-23
-------
TABLE 7 (Continued)
System
Flue Gas Recircu-
lation
Over-Fire A-ir
Advantages
CONTROL
Easily adapted to coal-
firing
Produces lowest NOX levels
Easier to control than
over-fire air
Like flue gas recircula-
tion, has been used ex-
tensively to control
steam temperature
NOX is reduced with rela-
tively little capital cost
Disadvantages
Much higher capital cost
3-24
-------
requirements will be supplied by wells. Of the wastewater management options,
the only one that satisfied the criteria established by the Applicant was a
combination of plant process wastewater recycle, cooling tower cold side blow-
down to the Ohio River, and site precipitation runoff to the Ohio River.
The alternative water sources and wastewater management options evaluated
by the Applicant are described in Table 8. The Applicant's proposed water use
design is indicated in the table by asterisks. A diagram of the plant's water
use plan, which indicates maximum water use requirements, is presented on
Figure 3.
Intake and Discharge Structures
Water being drawn into or discharged from a power plant can affect the
ecosystem of the source or receiving water body. The design of the intake
and discharge structures can affect the degree of impact that the plant's
intake and discharge operations can have. State and federal standards define
the intake velocity of the intake structure and also the degree of impact
that an intake structure may have on the aquatic environment. The size of
the discharge plume and its thermal and chemical content are also regulated.
Careful intake and discharge structure design and location are necessary to
ensure that these regulations are complied with. Table 9 presents the intake
and discharge alternatives evaluated by the Applicant. Asterisks indicate
the Applicant's proposed design.
The Applicant proposes to use an offshore conventional intake structure
and a subsurface, offshore, multi-port discharge structure.
Solid Waste Disposal System
Operation of the proposed Trimble County Generating Plant will result in
the production of two kinds of solid waste: a sludge-type waste from the wet
limestone sulfur dioxide removal system and ash from coal combustion.
Scrubber waste is produced when sulfur dioxide is removed from the steam
generators'exhaust (flue gases). It consists of the solids precipitated
during the reaction between the limestone slurry in the scrubbers (one for
each unit) and the sulfur dioxide in the flue gas. These solids and the
exhausted limestone slurry are collected in the bottom of the scrubber and
combined with a clarifier or thickener to form a sludge-type waste.
Ash, a nonburnable component of coal, is produced when coal is burned
in the steam generator boiler furnaces. Two kinds of ash result when the
coal is burned: "bottom" ash and "fly" ash. Bottom ash, which has a larger
particulate size than fly ash, falls to the bottom of the boiler furnaces
during the combustion process. Fly ash, which is a very fine particulate
matter, leaves the furnaces with the flue gases and is collected by the pre-
cipitators (two for each unit).
The amount of these solid wastes that will be generated by the proposed
plant is determined by the following four factors:
1. The amount of ash and sulfur in the coal
2. The sulfur dioxide removal efficiency of the scrubber
3-25
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TABLE 8
PLANT WATER USES
System
Advantages
Disadvantages
WATER SOURCES (Major Water Uses)'
Deep Veils
Ead-ial Wells
*River> Water1
Water is usually of better
quality than river water
and requires less pretreat-
ment before use.
No impact on aquatic life.
Can extract greater quan-
tities of ground water than
deep wells.
Water quality better than
for river water.
No impact on aquatic life.
Water quantity required
can be met.
Major plant water require-
ments , even with maximum
water reuse, are too great
for this type of source.
Water quality is not as high
as with deep wells.
Initial cost is extremely
high.
Quantity required is uncer-
tain for life of plant due
to plugging problems.
Impingement/entrainment of
aquatic life.
WASTEWATER DISCHARGE
Cold Side Cooling
Tower Blowdown
Discharge to
disposal pond
^Discharge to
river
Site Runoff
Routing runoff
from retention
basin to disposal
pond
*Discharge from
retention basin
to river
Plant Process
*Discharge to
disposal pond
Adequate receiving body.
Release of runoff is
controlled and monitored
to ensure quality is
acceptable for discharge.
No pollutants from plant
processes allowed to enter
environment.
Slowdown would quickly over-
flow any feasibly sized pond
on site.
More expensive discharge
structure.
Requires a pond larger than
area available can accommodate,
Requires additional pumping
and transport equipment.
aSmaller water requirements will be supplied by deep wells.
Applicant's proposed design.
3-26
-------
BY DATE
CHECKED BY
FILE
REVISIONS
BY DATE
o
c
33
> 2
»
si I
CONDENiEBS
OHIO RIVER-
NORMAL POOL ELEV. 420
LOW WATER ELEV. 417'
•7 "F MAX TEMP
YEARLY PEAK
101 V ORT BULB
9Qt WET BULB
IOO » RELATIVE HUMIDITY
CONSTRUCTION SCWAQE TMEATHI
WASTEWATER TO BOTTOM ASH I
AFTER POND IS CONSTRUCTED
-------
TABLE 9
INTAKE AND DISCHARGE STRUCTURES
Sy»t«a
Disadvantages
I
N>
00
INTAKE STRUCTURE
LOCATION
Shoreline
Offshore*
INTAKE STRUCTURE
DESIGN
Conventional*
Perforated Pipe
DISCHARGE CONDUIT
AND STRUCTURE
Direct Discharge
Less pump discharge piping
required.
Can be located near cella
supporting the coal barge
unloader for protection
from river traffic and
debris.
Minimum length of piping
to the cooling towers.
Proven reliability.
Less complicated than
conventional structure.
Lower construction and
operating costs.
No impingement of fish.
Shorter bridge required
because pump ia located
onshore .
Less head loss; ability
to discharge at higher
flood levels than In-
direct discharge line.
Deep excavation required to
provide low velocity through
trash racks.
More costly because of depth
of required cut.
Approach canal could trap and
destroy fish.
Reduced river velocities, caused
by mooring cella and unloading
facilities, could result in
increased siltation around
Intake structure.
Impingement and entralnment
of aquatic life.
personnel.
Depth of river at design
low water may not be
adequate.
Large amount of siltation could
cause heavy silt intake and
clogging of the system. Regular
back flushing with water or air
and dredging of the area could
Less thermal dispersion because
of location of discharge port
near unloading facilities.
Applicant's proposed design.
Indirect Dis-
charge*
Open Channel
Conduit
Buried Condui t *
Discharge port away
from riverfront
facilities.
Less coatly.
No interference with
surface operations.
Greater head loss; more
costly.
no visual impact, pro-
tection from external
conditions , ability to
Pumping
Gravity Flow*
Above Surface
Oiecharge
B&lotJ Surface
Die charge *
Offehore
Discharge*
ttaarehore
Discharge
Ability to discharge
under any river flow
conditions.
Setter reliability
than pumping.
Lower operation and
Better mixing and
thermal dispersion.
Less noticeable.
Helps provide access
for dilution water
around entire pe-
riphery of thermal
plume and improve
dispersion.
More costly.
Discharge is not possible
during extreme flood con-
ditions.
Bypass line and additional
emergency outlet B required •
Can result in occasional
fogging; more extensive
end treatment to ensure
energy dissipation; less
mixing and thermal dis-
persion.
Could cause high surface
velocities.
Reduced river velocities
as a result of mooring cells
and unloading fact lit lee
would result in decreased
dispersion capabilities.
-------
3. The capacity factor/coal use rate of the plant—
that is, the number of hours (per year) of plant
operation at a given percent of capacity and coal
quality (the higher these numbers, the greater the
quantity of solid waste)
4. The ratio of sulfite to sulfate in the limestone
used as a reactant in the scrubber
A total of approximately 7,200 acre-feet of bottom ash will be produced dur-
ing the 36-year life of the plant (approximately 240 acre-feet per year). A
total of approximately 154,200 acre-feet of unprocessed fly ash and scrubber
sludge will be produced during the same period. These amounts are calculated
on the following assumptions:
1. Alston #1 raw (untreated) coal will be burned in the plant
2. Operating characteristics: 60 percent of capacity during
the first 20 years of operation for each unit; 25 percent
of capacity during the last 10 years of operation for each
unit
Scrubber sludge and ash contain chemical compounds that are potentially
harmful to the environment. Therefore, they must be disposed of in a manner
that prevents these components from entering either the surface or ground
water of the disposal area. The traditional method of disposal for ash is a
pond lined with clay or other impervious material to prevent leakage or
seepage. Disposal of scrubber sludge is a relatively new problem for which
several alternatives are available.
One alternative is to dispose of the wet scrubber sludge in the same
manner as the traditional method for disposal of ash: lined, diked disposal
ponds. This alternative would prevent potential contaminants in the sludge
from entering either the surface or ground waters of the site. However,
because of the huge amount of sludge that the plant would produce over its
operating life, the amount of land that would be required for this disposal
alternative is very large. Additionally, this alternative would mean that
the land occupied by the disposal ponds could not be reclaimed once the
plant ceases operation.
A second alternative is to dewater the sludge prior to placing
it in lined disposal ponds. This reduces the volumes of material to be
disposed by removing most of the water, therefore reducing the area
required for the disposal ponds. The disadvantage of this method is
that the disposal areas cannot be reclaimed for future uses.
The third alternative, and the one selected by the Applicant, is to
combine the sludge with a chemical fixation agent in order to create
a material that is stable and relatively nonleachable and impermeable.
This treatment is designed to prevent potentially harmful components
of the sludge from entering the environment. When treated by chemical
fixation, the sludge is transformed into a soil-like granular material
that can be disposed of by traditional landfill methods, covered with
3-29
-------
topsoil, and reclaimed for a variety of purposes. Because the fixation
process allows the material to be landfilled, it can also be compacted.
When so handled, the treated sludge has a high bearing capacity. Thus,
disposal areas of this type can also be reclaimed for structural uses.
This type of sludge treatment process is currently available from
a number of commercial vendors. The Applicant is tentatively proposing
to use the process marketed by I.U. Conversion Systems, Inc., unless a
better system is developed. At such time, the Applicant may reconsider
its choice of vendor.
It should be noted that the previous description of the charac-
teristics of the treated sludge are based on the manufacturer's claims
and on a number of studies of this process that have been conducted at
power plants currently using this disposal method.* While the
stability and handling characteristics have been demonstrated to some
degree, the leachability of the treated sludge has not. The following
table presents data on the structural properties of Poz-0-Tec™, the
name of I.U. Conversion Systems, Inc.'s treated sludge material.
Typical Structural Properties of Poz-0-Tec"
Wet density
Dry density
Moisture content
Cohesion
Unconfined compressive strength
Angle of friction
Permeability coefficient
Allowable bearing capacity
Typical stable fill slope
Compressibility
When compacted and saturated:
Degree of saturation:
Attainment of saturation:
Reliquification potential:
85-100 Ib/cu ft
65-85 Ib/cu ft
25-50 percent moisture
>2,000 lb/sq ft
>25 lb/sq ft
>30°
10"6-10~8 cm/sec
>3 tons/sq ft
2:1 (horizontal to vertical)
Negligible
Incomplete
Years, if ever
None
Field studies are in progress at existing disposal sites to determine the
degree of leaching associated with sludge treated in this fashion, and conse-
quently the degree to which contaminants contained in the untreated sludge
are actually prevented from leaching out of the treated sludge. Data from
laboratory studies of the leachate characteristics of Poz-0-Tec"1 are presented
below:
^A good description of the studies conducted to date is provided in Data
Base for Standards/Regulations Development for Land Disposal of Flue Gas
Cleaning Sludges, Interagency Energy-Environmental Research and Development
Program Report, EPA-600/7-77-118, U.S. Environmental Protection Agency,
Cincinnati, Ohio.
3-30
-------
Material Leachate Characteristics3
(All results except pH in mg/1)
Shake Test
PH
Phenolphthalein alkalinity
Total alkalinity
Hardness
Sulfite
Sulfate
Chloride
Total dissolved solids
Calcium
Arsenic
Cadmium
Chromium
Copper
Iron
Mercury
Manganese
Lead
Zinc
8.5
30
60
400
20
450
150
1000
200
.01
.05
.01
.1
.001
.02
.03
<.03
Runoff Test
8.0
0
30
480
10
480
30
800
240
<.05
<.001
<.02
<.01-.03
<.03
Representative data of Poz-O-Tec™ prepared from a high sulfite sludge.
Fly ash, when combined with scrubber sludge, improves the stability of
the sludge material even prior to the addition of a chemical fixation agent.
The two materials can then be combined with the fixation agent, providing a
more satisfactory means of disposing of the fly ash than the traditional
method (which requires the addition of water to the dry fly ash prior to
its placement in a lined storage pond).
The Applicant evaluated basically two kinds of disposal scheme alterna-
tives for the solid wastes to be produced by the Trimble County Generating
Plant: an onsite disposal pond for the bottom ash and an offsite landfill
type of disposal for the scrubber sludge and fly ash. These disposal schemes
and other disposal alternatives are discussed in detail in the DEIS Supporting
Report. Table 10 provides a description of the alternatives evaluated;
Table 11 provides an analysis of the engineering and environmental advantages
of each alternative. Of the four disposal schemes evaluated, the Applicant
proposes to use Scheme 2. The following paragraphs provide a summary de-
scription of the Applicant's proposed solid waste handling and disposal
schemes.
3-31
-------
TABLE 10
DESCRIPTION OF DISPOSAL POND ARRANGEMENTS, TRIMBLE COUNTY GENERATING PLANT
(Total Expected 30-Year Production of Bottom Ash = 7,200 Acre-Feet;
1-Year Expected Production of Fly Ash/Scrubber Sludge with All Four Units = 5,140 Acre-Feet)
Arrangement
Original Scheme
Bottom ash, emergency fly ash, and scrubber sludge pond to be located in northern half of bottomland portion of site. Corn
Creek to be relocated. Construction in wetlands.
Storage capacity: bottom ash compartment = 7,200 acre-feet (30 years of storage provided)
emergency compartment = 4,200 acre-feet (11 months of storage provided)
Scheme 1
I
U)
Bottom ash pond to be located in northern portion of site bottomland. Emergency fly ash and scrubber sludge pond to be
located in small ravine near center, upland portion of site.
Storage capacity: bottom ash pond = 7,120 acre-feet (approximately 30 years of storage provided)
emergency pond •= 1,244 acre-feet (approximately 3 months of storage provided)
Scheme 2
(Proposed)
Scheme 3
Bottom ash compartment of disposal pond to be located similar to Scheme 1 arrangement. Emergency fly ash and scrubber
sludge compartment to be located on northern end of disposal pond. Corn Creek to be relocated.
Storage capacity: bottom ash compartment = 7,120 acre-feet (approximately 30 years of storage provided)
emergency compartment = 1,500 acre-feet (approximately 3.5 months of storage provided)
Bottom ash pond to be located similar to Scheme 1 arrangement. Emergency fly ash and scrubber sludge pond to be located
north of present Corn Creek. Portion of Corn Creek near northeastern corner of site to be modified.
Storage capacity: bottom ash pond = 7,120 acre-feet (approximately 30 years of storage provided)
emergency pond = 800 acre-feet (approximately 2 months of storage provided)
Scheme 4
Bottom ash pond to be located similar to Scheme 1 arrangement. Emergency fly ash and scrubber sludge pond to be located
in a ravine north of the plant property.
Storage capacity: approximately the same as Scheme 1
-------
TABLE II
RESULTS OF ENGINEERING AND ENVIRONMENTAL EVALUATION OF DISPOSAL POSD ARRANGEMENTS
ENGINEERING
Arrangement
Original
Scheme
Cost
Advantages
Disadvantages
Advantages
$13,339,505 "Adequate storage capacity
Scheme 1
19,450,693
'"Flooding of emergency pond
during period of nonuse not
required
OJ
I
LO
U>
Scheme 2
(Proposed)
13,591,003
"Inadequate capacity in emer-
gency pond
"Most expensive alternative
"High dan required at mouth
of ravine
"Difficult to provide ravine
with impervious lining to
prevent ground water con-
tamination
"Extensive piping required to
transport material to emer-
gency pond in ravine
'Roads and ditches required
on perimeter of emergency
pond
"Gravel underdrain required
in emergency pond
"Inadequate capacity in
emergency pond
"Only 4 acres of bottomland
woods are lost
"Vegetation habitat similar
to that which will be lost
to disposal pond construc-
tion is present in adjacent
areas
"Present Corn Creek habitat
not destroyed
"Oxbou area is preserved
'Only 7 acres of bottomland
woods are lost
Disadvantages
°A total of 236 acres of vegeta-
tion, including 60 acres o£
diverse bottomland hardwood-
vegetation, is lost. An important
wetlands atea is irretrievably
lost
"An established stop-over point for
migrating waterfowl is permanently
lost
"Population levels of species using
area, including opossums, nuskrats,
raccoons, foxes, deer, and many
species of birds, amphibians, and
reptiles will be reduced
"Total of 169 acres of vegetation
is lost. An additional 22 acres
of upland woods vegetation and
habitat is Lost
"Populations of doves, quails,
rabbits, squirrels, foxes and
other furbearers, and deer will
be reduced
°Loss of flooding, adjacent
agricultural fields, the in-
creased human noise and dis-
turbances, and the presence
of physical structures could
decrease the use of the oxbow
and Corn Creek hy waterfowl,
raccoons and other animals
"Oxbow area and Corn Creek may
be degraded as a result of
erosion and air pollution
"Wetland vegetation may be lost
as a result of possible change
in drainage and moisture regime
after Corn Creek is relocated
"total of 173 acres of vegeta-
tion is lost
"Heavily used riparian wildlife
habitat type is lost
"Populations of waterfowl, doves,
quails, furbearers, rabbits,
squirrels, and deer will be
reduced
"Access to oxbow area for wildlife
inhabiting fields, hills, and
ravines to east and northeast of
site is reduced
"The loss of flooding and adja-
cent agricultural fields, the
increased human noise and dis-
turbance, and the presence of
physical structures could also
decrease the use at the oxbow
area by waterfowl, raccoons,
and other animals
"Oxbow area may be degraded as a
result of erosion from con-
struction; oxbow vegetation may
suffer from air pollution as a
result of plant operation
"Aquatic habitat provided by
Corn Creek is lost (long-term)
-------
TABLE 11 (Continued)
ENGINEERING
Arrangement
Scheme 3
Cost
12.657,174
ENVIRONMENTAL
Advantages
Disadvantages
"Inadequate capacity in emer-
gency pond
UJ
I
U>
Scheme
Approximately
same as
Scheme 1
Same as Scheme 1
Same as Scheme 1
Advantages
"Oxbow area is preserved
"Only 8 acres of riparian
hardwood vegetation are
lost
"Somewhat better wildlife
access to oxbow area is
maintained
"Partial alteration of
Corn Creek would mean a
smaller amount of aquatic
habitat would be lost
(long-term); lower portion
of creek would suffer re-
duced productivity during
alteration of upper por-
tion, but would recover
within a shorter period
of time than if that
portion were rechannelized
"Wetland is preserved
"Only 4 acres of bottom-
land woods are lost
Disadvantages
"Total of 177 acres of vegetation
is lost
"Potential (small) change in wet-
lands could occur as a result
of change in water regime
"Populations of waterfowl, doves,
quails, furbearers, rabbits,
squirrels, and deer will be
reduced
"Loss of adjacent agricultural
fields; the increased human
noise and disturbances and the
presence of physical structures
could decrease the use of the
oxbow area by waterfowl, rac-
coons, and other animals
"Productive aquatic habitat
will be lost during rerouting
of upper portion of Corn Creek
"Oxbow area may be degraded as
a result of erosion from con-
struction; vegetation of both
the oxbow and Corn Creek could
suffer from air pollution from
plant operation
"Total of 208 acres of vegeta-
tion is lost: 81 acres in
Ravine RD for emergency
storage and 127 acres for
bottom ash pond.
"An additional 81 acres of up-
land woods habitat is lost
"Project-related activities are
spread out over larger area,
with resulting increase in
potential for disruption of
wildlife and humans in the area
"Oxbow area may be degraded as
a result of erosion from con-
struction; vegetation of both
the oxbow and Corn Creek could
suffer from air pollution from
plant operation
-------
As previously indicated, the proposed Trimble County Generating Plant,
when operated on the parameters indicated previously, is calculated to produce
7,200 acre-feet of bottom ash during the 36-year total operating life of the
plant (note: each unit has a 30-year operating life). Unprocessed fly ash and
scrubber sludge (which the Applicant proposes to combine for storage purposes)
over the life of the plant will amount to approximately 154,200 acre-feet of
material. This means that the Applicant would need a disposal area capable of
storing 161,400 acre-feet of solid waste, if the solid wastes were disposed of
in an unprocessed state.
In addition, the Applicant would have to increase the size of the ash
disposal pond to hold plant process wastewater (approximately 340 gallons per
minute, maximum peak flow) and a yearly average rainfall of approximately
550 gallons per minute. In order to provide the plant process systems with
adequate water, approximately 1,241 gallons per minute of Ohio River water
(maximum peak operating conditions) would have to be added to the pond.
The combined solid waste disposal and plant process water requirements
necessitate a storage area much larger than the area available for storage
even on the 1,000 acres of land originally purchased by the Applicant for the
plant. Two large ravines near the northern portion of the plant's eastern
boundary were calculated to be able to provide up to a maximum of 60,000
acre-feet of storage for solid waste. However, the ground and surface water
pollution potential of ash and scrubber sludge, plus the large amount of
water contained in the scrubber wastes (4,500 gallons per minute, maximum
peak operating conditions) make it imperative to treat the waste solids
(other than bottom ash) in such a way that: (1) their water content would
be reduced before they were stored (and hence allow more water to be reused),
(2) their pollution potential would be eliminated, and (3) the 154,200 acre-
feet of solid waste material would be reduced to an amount that could be
contained by the ravines.
To do this, the Applicant designed a five-part solid waste handling
scheme consisting of the following operations:
1. Bottom ash is sluiced from the steam generators and stored,
along with the plant process water, in a 155-acre compart-
ment (7,120 acre-foot storage capacity) of a 240-acre onsite
disposal pond
2. Fly ash is conveyed pneumatically from the precipitators to
a storage silo (3 days' peak fly ash production capacity).
This stored fly ash is then conveyed pneumatically to a
solid waste process plant located near the two offsite
ravines
3. Scrubber wastes are thickened to produce a sludge (20 percent
solids by weight). This sludge is then pumped to a holdup
pond capable of storing 3 days' peak sludge production.
From the holdup pond, this sludge is pumped to the solid
waste process plant
3-35
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4. The dry fly ash and scrubber sludge are combined and
mixed with a chemical fixation agent. The resulting
solid waste is a stable, nonleachable material suitable
for use as landfill in the offsite ravines. Because
the chemical fixation agent locks in the chemical
components of the combined material, including all of
the water remaining in the scrubber sludge, the resulting
landfill-type of material can be stored without the
necessity of making the sides and bottom of the storage
area impervious. This process will reduce the 154,200
acre-feet of total fly ash and scrubber sludge from the
facility to 58,600 acre-feet.
5. Should the process plant be temporarily inoperable, the second
compartment of the onsite disposal pond will provide
up to 3.5 months of emergency storage for the untreated
fly ash/scrubber sludge (1,500 acre-feet)
The potential impacts of the proposed solid waste disposal system, and
methods to mitigate these potential impacts, are described under the section
entitled Environmental Impacts of the Proposed Project.
Figure 4 presents a schematic diagram of the proposed plant site
development.
Transmission Line Structures
Table 12 presents the alternative transmission line structures evaluated
by the Applicant. The proposed structures are indicated by an asterisk.
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TABLE 12
TRANSMISSION SYSTEMS
System
Eight 138-kV Overhead Lines
Advantages
* Three 345-kV Overhead Lines
Underground Oil-Filled
Pipe-Type Cable
Compared to eight 138-kV lines,
less visual and noise impact
and reduced use of natural
resources
No visual impact
Disadvantages
Increased visual impact over
345-kV lines
Greater use of natural resources
in construction of lines, includ-
ing right-of-way requirements
Increased nuisance to population
during construction
Increased cost to operate lines
Recommended only for relatively
short lines
Limitations on lengths of cable
necessitate line splicing
Additional pumping facilities
required
Cost 12 times greater than for
overhead line
*Applicant's proposed design.
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3.3 THE ENVIRONMENT
INTRODUCTION
For the purposes of assessing the Impact of the proposed project on the
natural and human environment, a series of studies was conducted to determine
the air, land, water, and human characteristics (termed "baseline data") of
the area (termed "environmental setting") likely to be affected by the con-
struction and operation of the proposed Trimble County Generating Plant,
including the transmission line corridors—one in Kentucky and one in Indiana.
The University of Louisville's Water Resources Laboratory was retained by
the Applicant to perform the baseline studies of the aquatic and terrestrial
ecosystem of the proposed plant site and the Kentucky transmission line
corridor (described in Sections 5.2 and 5.3 of the DEIS Supporting Report) and
to provide an environmental overview of the Applicant's service area (Section
2.0 of the Supporting Report). These studies were reviewed and supplemented
by the Consultant. The baseline studies of the air, geological, hydrological,
and socioeconomic characteristics of the plant site and Kentucky transmission
line corridor areas were performed by the Consultant. The Consultant also
performed the baseline study of the Indiana transmission line corridor. The
results of these studies comprise the remaining portions of Section 5.0 of
the Supporting Report. A summary of the major aspects of the environmental
setting of the proposed project follows:
LOCATION AND DESCRIPTION OF THE PROPOSED PROJECT SITE
Plant Site and Kentucky Transmission Line Corridor
Figure 5 shows the location of the proposed plant site in relation to
the state of Kentucky. An aerial photograph of the site is presented on
Figure 6. The site is located on the Ohio River flood plain (River Miles 570
to 572) and adjoining upland area near the community of Wises Landing in
southwestern Trimble County, Kentucky.
The site is principally rural/agricultural in nature and encompasses
2,300 acres. The bottomland portion of the site lies between the Ohio River
on the west and upland (bluff) area on the east. The lower-lying sections
of this portion of the site are subject to occasional flooding. Most of
the bottomland area has been cleared, and a high percentage is used for
crop production. The upland portion of the site, which includes two ravines,
is quite steep. Most of this area is heavily wooded.
Corn Creek runs near the northern site boundary. Barebone Creek lies
to the south of the site and will be crossed by the Kentucky transmission line.
Intermittent streams, tributaries to Corn Creek, drain the ravines. An old,
heavily wooded cutoff channel ("oxbow") of Corn Creek meanders through the
northwestern sector of the site (see Figure 6) creating, along with Corn
Creek, a wetland and bottomland woods area valuable to the wildlife on the
site.
The main approach to the site is via State Route 754, which enters the
flood plain from the southeast and forms the southern boundary of the plant
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LEGEND:
PLANT SITE
BOUNDARY
PROPOSED
BOUNDARY
EXTENSION
-N-
LOUISVILLE GAS & ELECTRIC CO.
TRIMBLE COUNTY GENERATING PLANT
PROPOSED PLANT SITE
FIGURE 6
3-42
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site. County Road 1488 diagonally intersects the flat portion of the site
before it becomes flush with the bluffs to the east.
The air quality of the site and its immediate environs is generally
good. Onsite monitoring of air quality (in 1975) indicated that sulfur
dioxide, total suspended particulates, nitrogen oxide, and carbon monoxide
concentrations are below state and federal ambient air quality standards.
Photochemical oxidant concentrations, however, frequently exceeded the 1-hour
ambient air quality standard during the monitoring program.
No rare or endangered plant or wildlife species were found on the site.
However, the Corn Creek/oxbow area of the site, in combination with the
agricultural fields, provides a highly productive habitat for an abundant
wildlife population. The site is also apparently heavily used by migratory
waterfowl in the spring when the low-lying agricultural fields are flooded.
The population of Trimble County (5,349 in 1970) is relatively stable.
Farming is the primary source of income (58 percent) within the county,
followed by government employment (14 percent). Available housing is not
abundant and is of a somewhat lesser median value than for the state (12,021
versus $12,850 in 1970). Thirty percent of the occupied housing units in
Trimble County lacked some or all plumbing in 1970.
Land use patterns within Trimble County are dominated by farmland (76,691
acres in 1969 out of a total county acreage of 93,440). Tobacco, corn, soy-
beans, and wheat are the primary crops in the county. The major residential
areas in Trimble County are Bedford and Milton. Industrial land uses are
minimal. The minimal resource extraction operations within the county are
limited to sand and gravel dredging in the Ohio River and county streams.
An archaeological and historical/architectural survey of the proposed
Trimble County site was conducted in several phases between April 1975 and
November 1976. Nine archaeological sites and one historical site were
identified on the property in 1975. None were judged to be significant
enough to qualify for nomination to the National Register of Historic Places.
During subsequent surveys, other areas of potential archaeological sites on
the property were investigated, but no significant archaeological findings
occurred.
Two small cemeteries are located within the site boundary. One will
be unaffected by plant development. The other will be affected by the con-
struction of the onsite disposal pond. The local undertaker has agreed to
relocate the graves to the cemetery that will not be disturbed.
Preliminary Transmission Line Corridor
The Applicant has identified its intent to construct a line joining the
proposed Trimble County Generating Plant with one of its lines in northern
Clark County, Indiana. A preliminary mile-wide corridor for this line is
shown on Figure 7, which also shows the various land uses along this pre-
liminary corridor. Because the Applicant has not begun a detailed study of
this proposed line, its actual route could vary significantly from that
depicted on the map.
3-43
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AESTHETIC QUALITIES OF THE PLANT SITE
The proposed plant site is entirely rural in nature and primarily
consists of natural and man-modified natural elements that are visually
distinct from each other. The distinct components of the setting provide
a pleasing variety, with the steep, wooded bluffs and the straight, wide
bank of the river acting as a frame that sets off the flat, cultivated
expanse of the bottomland portions of the site. The band of bottomland
woods on the site provides further visual diversity. The visual diversity,
however, is not unharmonious; the visual components of the site and its
environs blend to form a pleasant rural landscape that is unbroken even
by the presence of Wises Landing.
SENSITIVE AREAS
Within the site and its immediate environs, three sensitive areas
have been identified: Corn Creek, the Corn Creek "oxbow," and the Mahoney
property to the north of the proposed site boundary.
As previously indicated, Corn Creek and the oxbow area are heavily
used by wildlife. While the habitat this area provides is not unique, inso-
far as similar habitat types can be found elsewhere along the river, the
quality of this habitat makes the area worthy of special attention. The
value of the habitat provided by the bottomland woods of the oxbow and Corn
Creek is tied to the surrounding agricultural and upland areas. The variety
of habitat provided by the combination of agricultural, bottomland woods,
streams, and upland wood vegetation types attracts a large number of wildlife
species to the area. These species would not be able to find as varied or
productive an area elsewhere within the project area (i.e., within a 25-mile
radius of the site).
The Mahoney property to the north of the plant site is believed to
contain a unique archaeological site. While this site has not been formally
investigated, Wilson and Janzen (who conducted the Phase I archaeological/
historical investigation of the proposed site), inspected the site and called
it "spectacular." Personnel from the University of Louisville Archaeological
Survey also discovered an in situ site in the highwall along the Mahoney
property; they have classified this site as Early Archaic. This site will
not be impacted by the project.
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3.4 ENVIRONMENTAL IMPACTS OF THE PROPOSED PROJECT
INTRODUCTION
The construction and operation of the proposed Trimble County Generating
Plant will affect the air, land, wildlife, water, and people of the site area.
Impacts to the land and water will be confined to the site and its immediate
environs. Impacts to wildlife will be primarily limited to those species
residing on or near the site; however, migrating waterfowl that presently
use the site as a stopover point will also be affected by the proposed pro-
ject. Impacts on the air and people will be experienced over a larger
geographical area (within roughly a 25-mile radius of the site). Many of
the potential adverse impacts of the proposed project will be reduced by
proposed engineering, construction, and operation practices; some potential
impacts will be eliminated. Many of the impacts of the plant on the people
of Trimble County and other areas (including other counties in Kentucky and
Indiana) will be beneficial; some will not. These potential and projected
impacts on the project area are described in detail in Section 6.0 of the
DEIS Supporting Report. Measures that will be used to reduce or eliminate
potential or projected impacts of the project are described in Section 7.0
of the Supporting Report.
During the EIS process, comments received about the potential impacts
of the project indicated five major areas of public and official concern:
(1) air pollution; (2) potential contamination of local ground water resources;
(3) the valuable wildlife habitat provided by the site, particularly by the
bottomland woods and oxbow area; (4) the disruption of the rural and
aesthetic character of the site; and (5) the potential toxicity to aquatic
organisms of the cooling tower blowdown. As a consequence, these areas were
given special emphasis during the impact analysis process.
Several special studies were conducted in order to estimate as precisely
as possible the impacts of the plant on air and water quality and aquatic
organisms and to provide for measures to reduce these impacts. Several plant
design changes were also made during the course of the study to reduce pro-
jected impacts of the plant on wildlife, water quality, and air quality.
Measures to mitigate (reduce or eliminate) potentially significant impacts
were also developed. The National Pollutant Discharge Elimination System
permit drafted for the project (Appendix A) contains a set of environmental
conditions and required studies that are designed to prevent or to detect and
mitigate potentially significant impacts to the air and water of the site
area. In addition, a Stipulation (Appendix D), signed by the Applicant and
the Regional Administrator, was drawn up to provide a formal mechanism for
ensuring the use of measures to mitigate impacts in areas not covered by the
NPDES permit.
The following is a summary of the projected potential impacts of the
proposed project. Because air pollution and ground water contamination
are the most sensitive issues regarding the operation of the facility,
they are given a more detailed summarization here than other potential
kinds of environmental impacts, which are also more easily summarized.
3-47
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IMPACT OF THE PROPOSED PLANT ON AIR QUALITY
The impact of plant flue gas emissions (which contain the major pollu-
tants sulfur dioxide, total suspended particulates, and nitrogen dioxide)
were determined by computer modeling of the plant emissions; this modeling
included a consideration of the meteorological conditions characteristic
of the plant site region, the topographic characteristics of the plant site
region, and the pollutant levels expected to be already present in the plant
site region at the time Unit 1 of the Trimble County Generating Plant begins
operating.
As noted earlier in this summary, air pollutant emissions from the
proposed plant must be kept at or below levels defined by federal and state
air quality regulations. There are three sets of these regulations: (1)
federal and state Ambient Air Quality Standards; (2) federal and state New
Source Performance Standards; and (3) federal regulations for Prevention
of Significant Deterioration of Air Quality. The second and third set of
standards are designed to ensure that the existing air quality of an area
is not significantly degraded.
To understand the application of these regulations to the proposed plant,
the following background information is necessary. The Ambient Air Quality
Standards are divided into the following two categories:
1. Primary Standards - these standards are intended to protect
public health by applying a "margin of safety" limitation
to the levels of air pollutant concentrations that may exist
in an area
2. Secondary Standards - these define the levels of air pollutants
that must be maintained to protect the public from the known or
anticipated adverse health effects of the pollutants. That is,
concentrations of those pollutants controlled by the Ambient
Air Quality Standards are known or anticipated to be harmful
when they exceed the levels defined by the Secondary Standards
Table 13 presents a list of the Ambient Air Quality Standards. Note that
the standards are based on the average concentration of each pollutant,
measured in micrograms per cubic meter (ug/m-*) during several different
time periods. These standards apply to pollutants measured at ground level,
rather than at the point (stack or chimney) where they are emitted.
New Source Performance Standards were instituted in 1974 and are
designed to control the amount of pollutants added to an area by any new
(constructed after July 1975) major source of air pollution. These
standards govern pollutant emissions as they leave the stack or chimney
of the facility. They are tied to the amount of heat (in British thermal
units [Btu]) generated when the fuel (from which the pollutants result) is
burned in the facility. New Source Performance Standards govern a large
number of emissions; however, for power generating facilities, the regulated
pollutants are sulfur dioxide, particulates, and nitrogen dioxide. These
are limited as follows:
3-48
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TABLE 13
KENTUCKY AND FEDERAL AMBIENT AIR QUALITY STANDARDS
Pollutant
Sulfur Dioxide
Total Suspended
Particulates
Settleable
Particulates
Carbon Monoxide
Nitrogen Oxides
Hydrogen Sulfideb
Averaging
Interval
3-Hour
24-Hour
Annual
Annual Geometric Mean3
24-Houra
3-Month
1-Hour
8-Hour
Annual
1-Hour
Primary
Standard
(pg/m3)
^
365
80
75
260
_
40,000
10,000
100
-
Secondary
Standard
(Ug/m3)
1,300
-
60
150
15°
40,000
10,000
100
14
Photochemical
Oxidants
Nonmethane
Hydrocarbons
1-Hour
3-Hour
(6-9 a.m.)
160
160
160
160
to be exceeded more than once per year.
Kentucky standard only.
°Tons per square mile per month.
Source: Commonwealth of Kentucky, 1974c
3-49
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New Source Performance Standards for Coal-Fired
Steam Electric Generating Facilities
Pollutant Emission Limitation
Sulfur dioxide 1.2 Ib/million Btu's
Particulates 0.1 Ib/million Btu's
Nitrogen dioxide 0.7 Ib/million Btu's
Federal regulations for Prevention of Significant Deterioration of Air
Quality establish what additional amount (increment) of sulfur dioxide and
particulate concentrations, measured at ground level, all New Sources
combined can add to those concentrations already present in any given loca-
tion. (The implications of this regulation are discussed under "Land Use"
in the Impact Summary table.) Under these regulations, all areas of the
United States have been divided into one of two categories:
1. Class I - areas where existing air quality is excellent
(pristine areas)
2. Class II - areas of moderate pollution where additions of
well-controlled emissions would not significantly degrade
existing area quality
Most areas of the United States are presently listed as Class II areas,
including the proposed plant site. The following are the allowable increments
of sulfur dioxide and particulates that may be added to existing pollutant
concentrations in a Class II area by a major new source of air pollutants:
Allowable Increments of Significant Deterioration
of Air Quality (Class II)a
Allowable Increment
Emission
Sulfur dioxide
3-Hour Maximum 512
24-Hour Maximum 91
Annual Arithmetic Mean 20
Particulates
24-Hour Maximum 37
Annual Geometric Mean 19
a
Clean Air Act Amendments, August 1977.
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In determining whether the emissions of the proposed facility would
meet Ambient Air Quality Standards and regulations for Prevention of Signi-
ficant Deterioration, four steps were performed:
1. The existing air quality of the site was measured by an
onsite monitoring program
2. The emission rates of sulfur dioxide, particulates, and
nitrogen dioxide that the plant will release to the
atmosphere were calculated
3. A computer modeling study was conducted to determine (1)
what the maximum ground level concentrations of these
pollutants would be; and (2) the area where they would
occur
4. These concentrations were compared to the onsite monitoring
data to determine if they were within the Ambient Air Quality
Standards; they were then compared to the allowable increases
in pollutant concentrations as defined by the regulations for
Prevention of Significant Deterioration
Tables 14 and 15 present the results of these steps. The air quality
investigation indicated that emissions from the Trimble County plant will
not cause any violations of Ambient Air Quality Standards or New Source
Performance Standards, and will be within the available increment specified
by Prevention of Significant Deterioration regulations. This conclusion is
based on an EPA permitted emission rate of 0.84 pound of sulfur dioxide per
million Btu's of heat input (compared to the 1.2-pound limit specified by
New Source Performance Standards). The Applicant will be required to demon-
strate, by in-stack monitoring, that this emission rate, or lower, will be
maintained throughout the operating life of the plant. Sections 6.3 and
6.4 of the Supporting Report present a full discussion of these steps and
include figures that depict the geographical distribution of the maximum
concentrations of sulfur dioxide, particulates, and nitrogen dioxide pro-
jected to result from the operation of the proposed plant.
The proposed Trimble County Generating Plant site is located approxi-
mately 12 miles downriver from the Clifty Creek Generating Plant in Madison,
Indiana. Because emissions from this plant have caused violations of Ambient
Air Quality Standards near Madison, Indiana, a study was run to determine
what, if any, additional effect the operation of the Trimble County plant
would have on pollution concentrations in the Madison area and, conversely,
what additional pollution concentrations would result in the Wises Landing
area if the Clifty Creek plant emissions interacted with the Trimble County
plant emissions. Although this potential interaction was investigated earlier
and was thoroughly discussed in the DEIS (Supporting Report, page 6-40), EPA
wanted to verify the results using a multi-source model. Dames & Moore's
report is contained in Section 4 of this FEIS.
The analysis of the potential plume interactions between the Trimble
County Generating Plant and the Clifty Creek plant were conducted with a
multiple source CRSTER model. Six modeling runs were performed to determine
the potential for interaction of the plant plumes. An independent run was
conducted for each plant for annual, 24-hour, and 3-hour SC>2 concentrations
using the complete meteorological base year (1964 Louisville Airport data).
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TABLE 14
MAXIMUM GROUND-LEVEL POLLUTANT CONCENTRATION (pg/m3) RESULTING
FROM OPERATION OF THE TRIMBLE COUNTY GENERATING PLANT AS
A FUNCTION OF THE NUMBER OF UNITS IN OPERATION
u>
Ul
ho
UNIT 1
86% efficiency scrubber
no reheat
UNITS 1 and 2
double liner stack
86% efficiency scrubber
no reheat
UNITS 1. 2 and 3
1 double, 1 single
liner stack
90% efficiency scrubber
25°F reheat
UNITS 1. 2. 3 and 4
2 double liner stacks
90% efficiency scrubber
25°F reheat
Annual Avg. Max. 3-Hr. Max. 24-Hr.
2.4
2,7
295
391
3,5
465
471
47
74
80
79
Particulates
Annual Avg. Max. 24-Hr.
0.2
0.2
0.2
0.3
3.1
4.9
5.3
5.2
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U)
I
Cn
W
Nitrogen Dioxide
TABLE 15
COMPARISON OF THE PROPOSED
AMBIENT LEVELS3 TO
Pollutant
Sulfur Dioxide
Total Suspended
Particulates
Averaging
Interval
3-hour
24-hour
Annual
24-hour
Annual
AMBIENT AIR
Primary
Standard
(yg/m3)
365
80
260
75
TRIMBLE COUNTY GENERATING PLANT
THE FEDERAL AND STATE
QUALITY STANDARDS
Secondary
Standard
(yg/m3)
1,300
-
150
60
Baseline
Level
(yg/m3)
331
113
40
123
57
Maximum0
Calculated
471
80
4
5
>1
Total
Ambient
Levels
802
193
44
323
>58
Annual
100
100
80
84
Combination of estimated maximum concentration resulting from operation of the
proposed plant and maximum ambient background concentration.
Baseline values are the maximum measured values from Louisville Gas and Electric
Company's 1975 monitoring program.
Maximum calculated values are those calculated by the EPA Single Source CRSTER model.
-------
On the basis of the model output, 11 days were selected for additional
analysis. Three runs were made on the selected 11-day data set: the first
for Trimble County only; the second for Clifty Creek only; and the third for
both plants combined. A final run was made to determine the contributions
associated with each plant at the time of the predicted maximum interaction,
day 174 period 4.
A comparison of the results of the complete year analysis for each
plant indicates that the maximum impacts of the plants in the study area
result from very different meteorological conditions. In general, the maximum
impacts of the Clifty Creek plant are associated with low windspeeds (1-3 mps)
and unstable conditions, while the maximum impacts of the Trimble County plant
are associated with moderate windspeeds (3-5 mps) and neutral stability.
This result is typical of this type of plant configuration. Essentially, the
analysis shows that the maximum impact of Clifty Creek in the study area can
occur anywhere within the area, since the maximum impact is associated with
low windspeeds which usually imply variable wind directions. The maximum
impact of Trimble County, however, can only occur during northerly air flow
with neutral conditions since the source is located approximately 19 kilo-
meters from the impact area. Any variation in wind direction causes the
plume to miss the area entirely. In addition, the occurrence of unstable
conditions disperses the plume before the impact area is reached. Therefore,
a fairly restrictive set of conditions are needed for the Trimble County plume
to impact the area at all.
Since the primary purpose of the study was to identify any periods during
which Trimble County contributions might exacerbate Clifty Creek impacts in
the area, a comparison of the respective plant impacts for the 11 selected
worst case days was conducted. The comparison indicated that Trimble County
did not contribute significantly to any of the 25 calculated Clifty Creek
violations of the 3-hour S0£ standard. Trimble County's maximum contribution
for any of the 25 periods wasO.lyg/m3 which occurred during one period only.
A similar check was conducted for the highest 3-hour concentrations. This
comparison indicated a maximum contribution from the Trimble County Plant of
48.5 pg/m3, which occurred at the receptor located 1.2 km from the receptor
grid center along the 200° azimuth line.
IMPACT OF THE PROPOSED PLANT ON LOCAL GROUND WATER RESOURCES
The solid waste materials (ash and S02 scrubber sludge) that would be
generated by the proposed plant contain contaminants that, if released to
the local ground water, could threaten the health of persons and animals
using the water for drinking purposes.
Disposal of ash products from coal-fired power plants is traditionally
accomplished by placing the ash in diked disposal ponds. Pond liners such
as compacted clay are the most frequently used method of preventing con-
taminants in the ash from leaching into local ground water aquifers. The
Applicant proposes to dispose of the bottom ash generated by the proposed
project in this manner. In addition to the compacted clay lining, measures
to monitor the ground water aquifer beneath the site will be instituted to
ensure that accidental contamination of this resource would not reach the
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local ground water users (the most significant user of which is the Trimble
County Water District #1, whose wells lie approximately 1 mile from the
southern boundary of the plant site). This ground water monitoring plan
is described in Section 3.5. Because ground water moves slowly through
the aquifer, and because the potential for accidental release of contami-
nants is very low, the monitoring program would provide adequate advance
notice of such contamination to allow corrective measures to be taken.
It should be noted here that the Applicant's design for the facility
includes wells to supply potable water to project personnel. These wells,
located on the plant site, would be the first water supply wells to be
affected by any release of contaminants to the aquifer. Thus, the Applicant
has its own interests, as well as those of others, to consider in this
regard.
The Applicant proposes to dispose of the fly ash and SC>2 scrubber
sludge resulting from operation of the Trimble County plant by placing
it in two ravines to the east of the bottomland portion of the site.
This fly ash and sludge, like bottom ash, contains chemicals that are
known to be harmful to humans and animals.
Sludge liquors typically contain ions of sulfate, sulfite, chloride,
calcium, magnesium, and various chemical species as shown in the following
table.
Levels of Chemical Species in Scrubber Sludge
Liquors and Elutriates for Eastern Coals
Species
Ant imony
Arsenic
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Sodium
Zinc
Chloride
Range in
Liquor (ppm)
0.46-1.6
<0.004-1.8
<0.0005-0.05
41
0.004-0.1
470-2,600
0.001-0.5
<0.002-0.1
0.002-0.4
0.02-0.1
0.002-0.55
<0.01-9.0
0.0009-0.07
5.3
0.03-0.91
<0.005-2.7
36-20,000
0.01-27
470-5,000
Median (ppm)
1.2
0.02
0.014
41
0.023
700
0.02
0.35
0.015
0.026
0.12
0.17
0.001
5.3
0.13
0.11
118
0.046
2,300
(Table continued
on following page)
3-55
-------
Range in
Species Liquor (ppm) Median (ppm)
Fluoride 1.4-70 3.2
Sulfate 720-30,000 2,100
IDS 2,500-70,000 7,000
pH 7.1-12.8
Source: EPA-600/7-77-118
While long—term studies of the potential contaminants in untreated scrubber
sludge have not been conducted to date, some conclusions have been drawn from a
number of tests that have been conducted to date. These conclusions, listed
in the EPA document Data Base for Standards/Regulations Development for Land
Disposal of Flue Gas Cleaning Sludges (EPA-600/7-77-118), are as follows:
1. The total dissolved solids in the untreated sludge liquors
exceed drinking water standards
2. Selenium concentration commonly exceeds drinking water
standards
3. Fluoride concentrations may be high
4. Arsenic, lead, and mercury concentrations (among others)
can exceed drinking water standards in some instances,
although these concentrations are typically below stan-
dards and are readily attenuated by most soils
As described in Section 3.2, the Applicant proposes to treat the solid
waste (fly ash, scrubber sludge) prior to disposal. The treatment process
tentatively proposed is one marketed by I.U. Conversion Systems, Inc. The
process consists of adding a chemical fixation agent to the fly ash and
dewatered sludge. The fixation process is designed to transform the solid
waste into a stable, relatively nonleachable and impermeable material suitable
for disposal by traditional landfilling methods.
As previously indicated in Section 3.2, the leachability and permeability
characteristics of treated scrubber sludge are not definitively known, while
stability characteristics have been fairly well demonstrated. Laboratory
tests have indicated the following characteristics with regard to scrubber
sludge:*
1. The leaching characteristic of limestone scrubber sludge
is strongly dependent on the source of the coal (initial
sulfur content)
1The following information is taken from EPA-600/7-77-118.
3-56
-------
2. Generally, chemical treatment improves leachate quality
3. The concentration of the major chemical species in leachate
from chemically treated sludge has been observed to be
approximately one-fourth to one-half the concentration
in leachate from untreated sludge
4. Contaminant transport occurs primarily during rainwater
runoff
One conclusion can be stated: for a landfill type of disposal, chemical
fixation of scrubber waste is not only desirable, it is also necessary.
Because definitive knowledge regarding the leaching and permeability
characteristics of fixed scrubber sludge is not available at this point in
time, and because there is a potential for contamination of the Wises Landing
aquifer if large amounts of the chemicals present in the solid waste reached
the aquifer, EPA has required the Applicant to include a ground water monitoring
program in its solid waste disposal plan (it should be noted that additional
requirements may be placed on the Applicant by the Commonwealth of Kentucky,
which has solid waste disposal permit authority over the proposed project).
The other engineering safeguards that will be implemented to prevent
potential contamination of the Wises Landing aquifer as a result of solid
waste disposal in the ravines are described in Section 3.5
SUMMARY OF IMPACTS OF PLANT CONSTRUCTION AND OPERATION
To provide an easily readable summary of the projected environmental
impacts of the proposed project, a summary table (Table 16) was developed.
This table lists the environmental components (for example, vegetation) that
will be subject to impacts from the construction and operation of the plant
(Column I) ; the sources of impact (for example, site clearing activities)
(Column II); the project impacts (Column III); the duration and degree of
impact (Column IV); and the studies and/or measures that will be undertaken
to identify and/or reduce these impacts (Column V). Only those impacts that
are considered to be, or have the potential to be, significant are discussed
in this document. All other impacts are discussed in detail in the DEIS
Supporting Report.
The project will not impact any historical or archaeological resources
(see Section 3.3, page 3-43 of this FEIS).
3-57
-------
TABLE 16
SUMMARY OF IMPACTS PROJECTED TO RESULT FROM
CONSTRUCTION AND OPERATION OF THE PROPOSED
TRIMBLE COUNTY GENERATING PLANT
I
II
ENVIRONMENTAL
COMPONENT
AFFECTED BY
PROPOSED PROJECT
AIR QUALITY
SOURCE OF IMPACTS
CONSTRUCTION ACTIVITIES
(CLEARING, GRADING, TRAFFIC,
EQUIPMENT MOVEMENT, ETC.)
III
PROJECTED IMPACTS
OR EFFECTS
INCREASE IN AIRBORNE DUST
IV
DURATION AND DEGREE OF IMPACT
THROUGHOUT 14-YEAR CONSTRUCTION
PHASE.
VARIES FROM LOW TO HIGH IMPACT,
DEPENDING ON NATURE AND EXTENT OF
CONSTRUCTION ACTIVITIES AND
WEATHER CONDITIONS
MEASURES TO MITIGATE
PROJECTED IMPACTS
USE OF DUST SUPRESSION MEASURES,
PARTICULARLY WETTING OF ROAD
SURFACES
CONSTRUCTION EQUIPMENT AND
CONSTRUCTION WORKERS' VEHICLES
INCREASED LEVELS OF NITROGEN
OXIDES, CARBON MONOXIDE, AND
HYDROCARBONS FROM ENGINE
EXHAUST
THROUGHOUT 14-YEAR CONSTRUCTION
PHASE.
LOW TO MODERATE IMPACT
I
w
00
SULFUR DIOXIDE, PARTICULATES
(ASH), AND NITROGEN DIOXIDE
IN FLUE GAS (CHIMNEY) EMISSIONS
RELEASE OF LARGE AMOUNTS OF
THESE POLLUTANTS TO THE
ATMOSPHERE. MAXIMUM GROUND
LEVEL POLLUTANT CONCENTRA-
TIONS RESULTING FROM OPERA-
TION OF THE PROPOSED PLANT
ARE PROJECTED TO OCCUR WITHIN
APPROXIMATELY 1.4 KM OF
THE PLANT SITE
THROUGHOUT 36-YEAR TOTAL OPERATING
LIFE OF PLANT.
MAJOR IMPACT; HOWEVER, GROUND
LEVEL CONCENTRATIONS WILL REMAIN
BELOW FEDERAL AND STATE STANDARDS
FOR FOSSIL FUEL EMISSIONS
RELEASE OF POLLUTANTS AT SUFFICIENT
HEIGHT TO ALLOW RAPID DISPERSION
AND DIFFUSION
USE OF POLLUTION CONTROL EQUIPMENT
(SCRUBBERS, PRECIPITATORS, AND
BOILERS DESIGNED TO CONTROL NITROGEN
OXIDES). THIS EQUIPMENT WILL REMOVE
90 PERCENT OF THE SULFUR DIOXIDE, 99
PERCENT OF THE PARTICULATES, AND
LIMIT THE FORMATION OF NITROGEN
DIOXIDE.
FLUE GAS EMISSIONS WILL BE MONITORED
TO ENSURE THAT THEY REMAIN WITHIN
THE PERMITTED LIMITS.
WHEN THE SCRUBBERS CANNOT BE OPER-
ATED, THE APPLICANT WILL EITHER
CEASE OPERATION OF THE UNIT, BURN
AN ALTERNATE COAL (A 30-DAY SUPPLY
OF ALTERNATE COAL WILL BE STORED
ON THE SITE), AND/OR FOLLOW OTHER
PROCEDURES TO COMPLY WITH PSD LIMITS.
-------
TABLE 16 (Continued)
•I
ENVIRONMENTAL
COMPONENT
AFFECTED BY
PROPOSED PROJECT
AIR QUALITY
(CONT'D)
III
SOURCE OF IMPACTS
SULFATE FORMATION
PROJECTED IMPACTS
OR EFFECTS
INCREASED ACIDITY OF RAIN-
FALL NEAR THE PLANT
IV
DURATION AND DKGREE OF IMPACT
THROUGHOUT 36-YEAR TOTAL OPERATING
LIFE OF PLANT.
MEASURES TO MITIGATE
PROJECTED IMPACTS
COOLING TOWER OPERATION
VISIBLE VAPOR PLUME
to
I
l/l
NO SIGNIFICANT IMPACT EXPECTED, AS
NECESSARY INGREDIENT (SULFUR DIOX-
IDE) WILL BE CONTROLLED. HOWEVER,
NEITHER THIS PHENOMENON NOR THE
FORMATION OF SUSPENDED SULFATES
CAN BE ADEQUATELY ESTIMATED WITH
AVAILABLE TECHNOLOGY
THROUGHOUT 36-YEAR TOTAL OPERATING
LIFE OF PLANT.
LOW TO MODERATE IMPACT. PLUME
WILL RARELY EXTEND MORE THAN 3.1
MILES FROM PLANT; MOST VISIBLE
IN WINTER
GROUND LEVEL FOGGING
THROUGHOUT 36-YEAR TOTAL OPERATING
LIFE OF PLANT.
DRIFT DEPOSITION (WATER
DROPLETS CONTAINING
IMPURITIES FROM RIVER
WATER AND CHEMICALS ADDED
TO PREVENT BIOLOGICAL
GROWTH IN PIPES AND
COOLING TOWERS)
FOGGING WILL OCCUR ABOUT 19 HOURS
PER YEAR WITHIN 0.8 MILE OF PLANT.
BEYOND 3 MILES, FREQUENCY OF FOG-
GING WILL BE LESS THAN 1 HOUR PER
YEAR. INCIDENCES OF FOGGING TO
SOUTH AND SOUTHWEST MAY PRESENT A
HAZARD TO RIVER TRAFFIC BY RE-
DUCING VISIBILITY AT TIMES WHEN
NATURAL FOG WOULD NOT BE EXPECTED
HIGHEST DEPOSITION RATES WILL OCCUR
TO THE NORTH, CLOSE TO THE PLANT.
THE KENTUCKY STANDARD FOR DRIFT
DEPOSITION IS 15 TONS PER SQUARE
MILE PER MONTH. THE MAXIMUM PRO-
JECTED RATE FOR THE PLANT IS 0.12
TONS PER SQUARE MILE PER MONTH
-------
TABLE 16 (Continued)
KNVIKOHMk'HTAL
COMPONKNT
AFf'KCTKD By
PHOPOSKD 1'ROJKCT
GEOLOGY AND
TOPOGRAPHY
II
5VIIHCE OF I Ml'ACTS
GRADING OPERATIONS
SOLID WASTE DISPOSAL IN
RAVINES RA AND RB
SURFICIAL
SOILS
VEGETATION
GRADING OPERATIONS
SITE CLEARING OPERATIONS AND
FILLING OF RAVINES WITH SOLID
WASTE FROM PLANT OPERATIONS
KENTUCKY TRANSMISSION LINE
CONSTRUCTION AND OPERATION
III
rHOJKCFKD IMPACTS
OR KFFKCTS
MECHANICAL STRENGTHENING
AND MATERIAL ARRANGEMENT
OF SITE'S RECENT ALLUVIAL
DEPOSITS
UNDER MAXIMUM WORST-CASE
COAL CONDITIONS, RAVINES
WILL BE COMPLETELY FILLED
SO THAT THE TOP OF THE
FILL WILL BE AT THE SAME
HEIGHT (AROUND 800 FEET
ABOVE MEAN SEA LEVEL) AS
THE PRESENT RIDGE TOPS
DESTRUCTION OF APPROXI-
MATELY 421 ACRES OF CROP-
LAND SOILS
ELIMINATION OF 1,844 ACRES
OF VEGETATION, INCLUDING
APPROXIMATELY 400 ACRES OF
CROPLAND VEGETATION AND 7
ACRES OF VALUABLE BOTTOM-
LAND WOODS VEGETATION, FROM
PLANT SITE
DISRUPTION OF 34.5 ACRES OF
VEGETATION (18.4 ACRES OF
WOODLAND)
IV
nilRATfON AND HKKRKE OF IMPACT
THROUGHOUT 14-YEAR CONSTRUCTION
PHASE
SIGNIFICANT IMPROVEMENT OF THE
SUPPORT, CONTAINMENT, AND DRAIN-
AGE FEATURES OF THE SITE
MAJOR IMPACT, AS A DRAMATIC
CHANGE IN TOPOGRAPHY WILL OCCUR
PERMANENT, MAJOR IMPACT DUE TO THE
HIGH PRODUCTIVITY OF THIS SOIL
PERMANENT, MAJOR IMPACT
LOSS OF CROPLAND VEGETATION
AMOUNTS TO AN ECONOMIC LOSS OF
$3,892,000 (BASED ON 36 YEARS
OF PLANT OPERATION)
EROSION, SEDIMENTATION, AND
ORGANIC AND INORGANIC NUTRIENT
LOSS FROM PLANT SOILS AS A
RESULT OF VEGETATION REMOVAL
DISRUPTION OF SUCCESSIONAL TRENDS
IN IMMEDIATE PLANT AREA
LOW, TEMPORARY IMPACT TO NONWOOD-
LAND VEGETATION
MAJOR IMPACT TO WOODLAND VEGETA-
TION IN TERMS OF TIME (THAT IS,
TIME REQUIRED FOR WOODLAND
VEGETATION TO MATURE)
MKASIIRES TO MITIGATE
PKOJKCTED IMPACTS
STOCKPILING OF TOPSOIL FOR USE IN
REVEGETATION OF OPEN AREAS
LOSS OF RAVINE VEGETATION WILL BE
VERY GRADUAL OVER THE OPERATING LIFE
OF THE PLANT. TREES WILL BE CUT AS
REQUIRED, BUT GROUND COVER WILL NOT
BE REMOVED. TREES WILL NOT BE RE-
MOVED FROM THE RIDGETOPS OR AREAS
IN THE RAVINES NOT REQUIRED FOR
WASTE DISPOSAL
LIMITED USE OF HERBICIDES
-------
TABLE 16 (Continued)
ENVIRONMENTAL
COMPONENT
AFFECTED BY
PROPOSED PROJECT
VEGETATION
(CONT'D)
II
SOURCE OF IMPACTS
KENTUCKY TRANSMISSION LINE
CONSTRUCTION AND OPERATION
(CONT'D)
INDIANA TRANSMISSION LINE
CONSTRUCTION AND OPERATION
IV
CO
I-1
PLANT ATMOSPHERIC EMISSIONS,
INCLUDING DRIFT (SEE AIR
QUALITY)
WILDLIFE
SITE CLEARING OPERATIONS AND
FILLING OF THE RAVINES WITH
SOLID WASTE FROM PLANT
OPERATIONS
PROJECTED IMPACTS
OR EFFECTS
DISRUPTION OF 328.1 ACRES
OF VEGETATION (76.3 ACRES
OF WOODLAND)
POTENTIAL FOR CROP AND
OTHER VEGETATION DAMAGE
LOSS OF 1,844 ACRES OF WILD-
LIFE FORAGE, COVER, LIVING,
BREEDING, AND NESTING AREA,
INCLUDING 7 ACRES OF BOTTOM-
LAND WOODS; REDUCTION AND
POSSIBLE ELIMINATION OF A
WELL-ESTABLISHED STOPOVER
POINT FOR MIGRATING WATER-
FOWL
DESTRUCTION OF SOME NON-
MOBILE SPECIES OF WILDLIFE
(SMALL RODENTS, AMPHIBIANS,
AND REPTILES)
MEASURES TO MITIGATE
PROJECTED IMPACTS
DURATfON AND DEGREE OF IMPACT
MODERATE IMPACT IN TERMS OF LOSS OF
COMMERCIAL VALUE OF TIMBER
LOW, TEMPORARY IMPACT TO NONWOOD-
LAND VEGETATION
MAJOR IMPACT TO WOODLAND VEGETATION ASSESSMENT OF VEGETATION OF FINAL
IN TERMS OF TIME AND AS REMOVAL OF
THIS VEGETATION WILL CONTRIBUTE TO
ONGOING LONG-TERM DESTRUCTION OF
WOODLAND VEGETATION IN INDIANA
LOW POTENTIAL IMPACT
CHRONIC INJURY TO MOST PLANTS
FROM SULFUR DIOXIDE CAN BE EXPEC-
TED DURING LONG-TERM AVERAGE
ANNUAL DOSAGES OF 60 MICROGRAMS
PER CUBIC METER. PRESENT MAXI-
MUM SULFUR DIOXIDE CONCENTRATION
IN THE PROPOSED SITE AREA IS 40
MICROGRAMS PER CUBIC METER.
MAXIMUM ANNUAL AVERAGE CONCENTRA-
TION TO BE CONTRIBUTED BY THE
PLANT WILL BE 3 MICROGRAMS PER
CUBIC METER
PERMANENT, MAJOR IMPACT
THE SITE, PARTICULARLY THE BOTTOM-
LAND WOODS ALONG CORN CREEK AND
THE OXBOW AND THE ADJACENT AGRI-
CULTURAL FIELDS, SUPPORTS AN
ABUNDANT WILDLIFE POPULATION AND
PROVIDES AN ESTABLISHED STOPOVER
POINT FOR MIGRATING WATERFOWL
CORRIDOR WILL BE CONDUCTED TO
IDENTIFY MOST SENSITIVE AREAS ALONG
ROUTE SO THAT THESE CAN BE PROTECTED
LIMITED USE OF HERBICIDES
THE MAJOR PORTION OF THE OXBOW AREA
WILL REMAIN AS IS. BECAUSE THE
RAVINES WILL BE FILLED GRADUALLY,
ONE AT A TIME', LOSS OF THE WILDLIFE
HABITAT IN THESE AREAS WILL BE
GRADUAL. AREA WILL BE MAINTAINED BY
KENTUCKY DEPARTMENT OF FISH AND WILD-
LIFE RESOURCES AS A WILDLIFE REFUGE
-------
TABLE 16 (Continued)
11
ENVIRONMENTAL
COMPONENT
AFFECTED BJ
PROPOSED PROJECT
WILDLIFE
(CONT'D)
SOURCE OF IMPACTS
SITE CLEARING OPERATIONS AND
FILLING OF THE RAVINES WITH
SOLID WASTE FROM PLANT
OPERATIONS
(CONT'D)
III
PROJECTED IMPACTS
OR EFFECTS
REDUCTION OF POPULATION
NUMBERS OF SPECIES ON AND
IMMEDIATELY ADJACENT TO
SITE IF CONSTRUCTION
ACTIVITIES COINCIDE WITH
BREEDING AND NESTING
SEASON
IV
DURATION AW DEGREE OF IMPACT
MEASURES TO MITIGATE
PROJECTED IMPACTS
W
I
FORCED EMIGRATION OF
MOBILE WILDLIFE FROM
SITE INTO ADJACENT AREAS
ANIMALS WILL BE FORCED TO MOVE INTO
AREAS THAT ARE PROBABLY ALREADY
SUPPORTING THE MAXIMUM NUMBER OF
SPECIES CAPABLE OF LIVING IN THESE
AREAS. AS A RESULT, THEY WILL BE
FORCED INTO COMPETITION FOR
SPACE, FOOD, AND OTHER LIFE REQUIRE-
MENTS. THE RESULT WILL BE A DIRECT
OR INDIRECT REDUCTION IN THE NUMBER
OF ANIMALS PRESENTLY IN THE SITE
AREA
HIGHER TRAFFIC LEVELS ON
U.S. 421, SR 754, AND
CR 1488
INCREASED NUMBER OF ROAD-
KILLS
THROUGHOUT CONSTRUCTION AND OPERATING
PHASES
GROUND WATER
QUALITY
INCREASED NOISE, DUST, AND
HUMAN DISTURBANCE
TRANSMISSION LINE ROUTE
CLEARING
SOLID WASTE DISPOSAL IN
RAVINES
MAY CAUSE A DISRUPTION OF
PREDATOR-PREY RELATIONSHIPS,
MATING BEHAVIOR, AND REPRO-
DUCTION
IN WOODLAND AREAS, CREATION
OF "EDGE" HABITAT THAT WILL
SUPPLY FOOD AND COVER TO
ANIMALS RESIDING IN ADJA-
CENT AREAS
POTENTIAL GROUND WATER
CONTAMINATION FROM LEACHATE
THROUGHOUT CONSTRUCTION PHASE;
SHOULD NOT BE AS SIGNIFICANT DURING
PLANT OPERATION
THROUGHOUT LIFE OF TRANSMISSION LINES
THROUGHOUT DISPOSAL PERIOD AND FOR
SOME TIME AFTER DISPOSAL OPERATIONS
ARE CONCLUDED
-------
TABLE 16 (Continued)
ENVIRONMENTAL
COMPONENT
AFFECTED BY
PROPOSED PROJECT
GROUND WATER
QUALITY
(CONT'D)
II
SOURCE OF IMPACTS
III
PROJECTED IMPACTS
OR EFFECTS
SOLID WASTE DISPOSAL
RAVINES
(CONT'D)
IN
IV
DURATION AND DEGREE OF IMPACT
NO IMPACT ANTICIPATED AS RESULT
OF MITIGATING MEASURES TO BE
EMPLOYED
MEASURES TO MITIGATE
PROJECTED IMPACTS
THE APPLICANT IS PROPOSING TO USE
A CHEMICAL FIXATION PROCESS PROPOSED
TO TRANSFORM THE SCRUBBER SLUDGE/
FLY ASH MIXTURE TO BE PLACED IN THE
RAVINES INTO A STABLE, NONLEACHABLE
LANDFILL-TYPE OF MATERIAL. THE
APPLICANT IS RF.QUIRED TO DEMONSTRATE
TO THE EPA, 1 YEAR PRIOR TO THE
STARTUP OF UNIT 1, THAT THIS PROCESS
WILL ACCOMPLISH THE SATISFACTORY
STABILIZATION OF THE WASTE MATERIAL.
IF THIS PROCESS CANNOT BE DEMON-
STRATED TO HAVE LONG-TERM RELIABILITY,
THE APPLICANT WILL BE REQUIRED TO
SELECT A SUITABLE OFFSITE DISPOSAL
AREA, FOR WHICH A COMPLETE
ENVIRONMENTAL IMPACT ANALYSIS
WILL HAVE TO BE PREPARED AND
SUBMITTED TO THE EPA AND THE
COMMONWEALTH OF KENTUCKY
BOTTOM ASH AND EMERGENCY
SCRUBBER SLUDGE/FLY ASH
DISPOSAL POND AND COAL
STORAGE AREAS
POTENTIAL GROUND WATER
CONTAMINATION FROM LEACHATE
THROUGHOUT 36-YEAR TOTAL PLANT
OPERATING LIFE
IF THE RAVINES ARE USED TO STORE THE
STABILIZED MATERIAL AND A LEACHATE
POTENTIAL IS BELIEVED TO EXIST,
GROUND WATER MONITORING OF THE
RAVINES MAY BE REQUIRED
THE APPLICANT WILL LINE THE BOTTOM
ASH AND EMERGENCY SCRUBBER SLUDGE/
FLY ASH DISPOSAL POND WITH A LINER
TO IMPEDE THE DISCHARGE OF LEACHATE
FURTHER, THE APPLICANT WILL IMPLE-
MENT AND MAINTAIN A GROUND WATER
MONITORING PROGRAM. DETAILS OF THE
PROGRAM AS WELL AS QUARTERLY REPORTS
WILL BE SUBMITTED TO THE EPA AND THE
COMMONWEALTH OF KENTUCKY. IF THE
REPORTS DEMONSTRATE THAT SIGNIFICANT
CONTAMINATION (LEVELS IN EXCESS OF
-------
TABLE 16 (Continued)
ENVIRONMENTAL
COMPONENT
AWECTED By
PROPOSED PROJECT
GROUND WATER
QUALITY
(CONT'D)
SURFACE WATER
QUALITY
U)
I
II
SOURCE OP IMPACTS
BOTTOM ASH AND EMERGENCY
SCRUBBER SLUDGE/FLY ASH
DISPOSAL POND AND COAL
STORAGE AREAS
(CONT'D)
RUNOFF FROM SITE AREAS SUBJECT
TO CLEARING, GRADING, AND
OTHER CONSTRUCTION ACTIVITIES
AND TRANSMISSION LINE CONSTRUC-
TION
III
IV
PROJECTED IMPACTS
OK EFFECTS
INCREASED LEVELS OF TURBID-
ITY, SEDIMENTATION, AND
SUSPENDED SOLIDS IN CORN
CREEK, THE OHIO RIVER, AND
STREAMS CROSSED BY THE
TRANSMISSION LINES; POTEN-
TIAL DEGRADATION OF THE
OXBOW AREA
DURATION AND DEGREE OF IMPACT
PRIMARILY DURING FIRST 2 YEARS OF
CONSTRUCTION PHASE FOR PLANT SITE;
DURING TRANSMISSION LINE CONSTRUC-
TION, SHORT-TERM IMPACT ON OXBOW
AREA
LOW TO MODERATE POTENTIAL IMPACT
(NOTE: BACKGROUND LEVELS OF
TURBIDITY AND SUSPENDED SOLIDS
ARE FREQUENTLY HIGH IN OHIO RIVER.
WATER QUALITY OF OXBOW AREA IS
POOR)
MEASURES TO MITIGATE
PROJECTED IMPACTS
DRINKING WATER STANDARDS) IS
PRESENT, THE APPLICANT WILL BE
REQUIRED TO IMPLEMENT MEASURES
TO MITIGATE SUCH CONTAMINATION
AND TO ASSURE THAT NO FUTURE
CONTAMINATION WILL OCCUR
RUNOFF FROM POWER PLANT, COOLING
TOWER, AND LAYDOWN AREAS WILL BE
COLLECTED, STORED, AND TREATED
BEFORE RELEASE TO THE OHIO RIVER.
OTHER APPROPRIATE EROSION AND
SEDIMENTATION CONTROL MEASURES
WILL BE IMPLEMENTED PRIOR TO AND
DURING ALL CONSTRUCTION ACTIVITIES
CONSTRUCTION OF DOCKING AND
UNLOADING FACILITIES AND IN-
TAKE AND DISCHARGE STRUCTURES
RELOCATION OF PREVIOUSLY
ALTERED, LOWER 1,800 FEET
OF CORN CREEK
INCREASED BARGE TRAFFIC
INCREASED LEVELS OF TURBID-
ITY, SEDIMENTATION, AND
SUSPENDED SOLIDS, AMD RE-
SUSPENSIO!] OF CONTAMINATED
RIVER BOTTOM SEDPIEHTS, IN
NEARSHORE OHIO RIVER WATERS
ADJACENT TO AND IMMEDIATELY
DOWNSTREAM OF CONSTRUCTION
AREAS
INCREASE IN TURBIDITY AND
SUSPENDED SOLIDS IN CORN
CREEK AND OHIO RIVER NEAR
NEW MOUTH OF CREEK
INCREASED WAVE ACTION
(RESULTING IN SHORELINE
EROSION) AND TURBIDITY
LEVELS IN OHIO RIVER;
RESUSPENSION OF CONTAMINATED
RIVER BOTTOM SEDIMENTS
DURING CONSTRUCTION OF THESE
FACILITIES
LOW TO HIGH IMPACT, DEPENDING
ON BACKGROUND LEVELS IN THE
OHIO RIVER AT THE TIME
IMMEDIATELY FOLLOWING CONSTRUC-
TION OF THE NEW CHANNEL
MODERATE, SHORT-TERM IMPACT
THROUGHOUT BOTH CONSTRUCTION
AND OPERATING PHASES
NEW CHANNEL WILL BE CONSTRUCTED
DRY, RIPRAPPED, AND THEN OPENED
TO RECEIVE CORN CREEK WATERS
-------
TABLE 16 (Continued)
ENVIRONMENTAL
COMPONENT
AFFECTED BY
PROPOSED PROJECT
SURFACE WATER
QUALITY
W
I
Ul
AQUATIC LIFE
II
SOURCE OF IMPACTS
INCREASED BARGE TRAFFIC
(CONT'D)
POTENTIAL SPILLS OF COAL,
FUEL, OIL, CEMENT, SAND,
GRAVEL, LIMESTONE, CAUSTIC
SODA, ALUM, AND SULFURIC
ACID DURING UNLOADING
OPERATIONS
IMPINGEMENT/ENTRAINMENT OF
AQUATIC ORGANISMS BY THE
INTAKE STRUCTURE
III
IV
POTENTIAL DEGRADATION OF OHIO
RIVER WATER QUALITY FROM LARGE
ACCIDENTAL SPILL OF MATERIAL
DURING BARGE UNLOADING OPERA-
TIONS, PARTICULARLY OF OIL
OR SULFURIC ACID
PROJECTED IMPACTS
OP EFFECTS
DEGRADATION OF WATER
QUALITY
POTENTIAL LOSS OF SOME
AQUATIC ORGANISMS, PARTIC-
ULARLY EGGS, LARVAL FISHES,
AND OTHER FLOATING ORGANISMS
MOVEMENT OF ADULT FISH FROM
THE AREA; DESTRUCTION OF
FIXED MACROBENTHIC, PERI-
PHYTON, AND MOLLUSK POPU-
LATIONS; REDUCTION OF
PLANKTON POPULATIONS; A
GENERAL REDUCTION IN THE
STABILITY AND COMMUNITY
STRUCTURE OF THE AQUATIC
ECOSYSTEM
DURATION AND DEGREE OF IMPACT
LOW TO MODERATE IMPACT, AS THESE
CONDITIONS ALREADY EXIST IN AREA AS
A RESULT OF EXISTING BARGE TRAFFIC,
SAND DREDGING OPERATIONS, AND BACK-
GROUND CONDITIONS; FURTHER, TOTAL
BARGE TRAFFIC INCREASE IS LOW
THROUGHOUT BOTH CONSTRUCTION AND
OPERATING PHASES
LOW TO MAJOR POTENTIAL IMPACT
DEPENDING ON AMOUNT OF SPILL;
HOWEVER, ONLY SMALL SPILLS ARE
ANTICIPATED
THROUGHOUT 36-YEAR TOTAL PLANT
OPERATING LIFE
THROUGHOUT BOTH CONSTRUCTION AND
OPERATING PHASES
MAJOR, RELATIVELY SHORT-TERM IMPACT
TO ALL SPECIES' POPULATIONS EXCEPT
MOLLUSKS
MEASURES TO MITIGATE
PROJECTED IMPACTS
APPLICANT ASSUMES RESPONSIBILITY FOR
CLEAN-UP OF ALL SPILLS TO THE OHIO
RIVER FROM BARGE UNLOADING OR LOAD-
ING OPERATIONS OF OIL, COAL, RE-
ACTANT, OR OTHER CHEMICALS. FEDERAL
OIL POLLUTION PREVENTION PROCEDURES
(40 CFR PART ll"i) WILL BE FOLLOWED
THE APPLICANT WILL CONDUCT STUDIES
TO DETERMINE WHAT, IF ANY, IMPACT
OPERATION OF THE INTAKE STRUCTURE HAS
ON THE AQUATIC ENVIRONMENT. THESE
STUDIES WILL BE CONDUCTED FOR EACH
GENERATING UNIT DURING ITS FIRST
YEAR OF OPERATION. RESULTS OF THE
STUDIES WILL BE SUBMITTED TO THE
EPA. IF THE STUDIES SHOW THAT
SIGNIFICANT IMPACT IS OCCURRING,
MEASURES WILL BE INSTITUTED TO
MITIGATE SUCH IMPACT AND ASSURE
THAT NO FURTHER IMPACT OCCURS
-------
TABLE 16 (Continued)
II
ENVIRONMENTAL
COMPONENT
AFFECTED By
PROPOSED PROJECT
AQUATIC LIFE
(CONT'D)
SOURCE OF IMPACTS
POTENTIAL LARGE INCREASES IN
TURBIDITY, SEDIMENTATION,
SUSPENDED SOLIDS, AND RE-
SUSPENSION OF CONTAMINATED
RIVER BOTTOM SEDIMENTS
FROM CONSTRUCTION ACTIVI-
TIES, BARGE TRAFFIC, AND
REROUTING OF CORN CREEK
(SEE "WATER QUALITY")
W
RELOCATION OF LOWER CORN CREEK
III
PROJECTED IMPACTS
OH EFFECTS
HIGH TURBIDITY AND SUSPENDED
SOLIDS LEVELS MAY INTERFERE
WITH GILL "BREATHING" OF
SOME SPECIES AND WITH
SENSORY RECEPTORS TO LOCATE
PREY. LESS MOBILE SPECIES
MAY DIE
EGGS SPAWNED IN AREA COULD
BE SILTED OVER
ADDITIONAL SUSPENDED SOLIDS
AND RESUSPENDED SEDIMENTS
CAN AFFECT PHYTOPLANKTON,
PERIPHYTON, AND SHALLOW-
WATER AQUATIC PLANTS BY
CLOUDING THE WATER TO SUCH
A DEGREE THAT THE AMOUNT OF
SUNLIGHT REACHING THESE
ORGANISMS IS SUBSTANTIALLY
REDUCED. WHEN THIS OCCURS,
PHOTOSYNTHESIS IS REDUCED
OR PREVENTED AND MANY OF
THE LIGHT-DEPENDENT
ORGANISMS DIE
INCREASED DISSOLVED NUTRIENT
LEVELS FROM RESUSPENSION OF
BOTTOM SEDIMENTS AND FROM
EROSION
PRODUCTIVITY OF LOWER CORN
CREEK WILL BE COMPLETELY
ELIMINATED. SPECIES PARTIC-
ULARLY AFFECTED WILL BE THOSE
THAT USE THE CREEK FOR SPAWN-
ING
REDUCED FOOD AND COVER
AVAILABLE FOR DEVELOPING
YOUNG-OF-THE-YEAR FISHES
IV
DURATION AND DEGREE OF IMPACT
THROUGHOUT BOTH CONSTRUCTION AND
OPERATING PHASES
LOW TO MODERATE IMPACT, DEPENDING
ON EXISTING CONDITIONS IN OHIO
RIVER (NOTE: SEE "WATER QUALITY."
SPECIES PRESENT IN OHIO RIVER ARE
PRIMARILY POLLUTION-TOLERANT
ORGANISMS. FURTHER, THEIR NUMBERS
AND DIVERSITY ARE RELATIVELY LOW.
THUS, LARGE POPULATIONS WOULD NOT
BE SUBJECT TO THESE ADVERSE IMPACTS)
MEASURES TO MITIGATE
PROJECTED IMPACTS
A LONG-TERM (POSSIBLY 10 TO 15
YEARS), MAJOR IMPACT. HOWEVER,
THE PRODUCTIVITY OF THE CREEK
SHOULD EVENTUALLY RETURN TO
LEVELS SIMILAR TO THOSE OF THE
PRESENT CHANNEL, WHICH WAS
ORIGINALLY RELOCATED SOMETIME
DURING THE 1940'S
NEW CHANNEL WILL BE JOINED TO OLD
CHANNEL RATHER THAN DIRECTLY TO THE
OHIO RIVER. DESIGN OF NEW CHANNEL
WILL BE COORDINATED WITH KENTUCKY
DEPARTMENT OF FISH AND WILDLIFE
RESOURCES
-------
TABLE 16 (Continued)
II
ENVIRONMENTAL
COMPONENT
AFFECTED By
PROPOSED PROJECT
AQUATIC LIFE
(CONT'D)
POPULATION
III
SOURCE OF IMPACTS
PLACEMENT OF BARGE FACILITIES
FACILITIES AND INTAKE AND
DISCHARGE STRUCTURES
PEAK PLANT CONSTRUCTION WORK
FORCE (695 PERSONS)
OJ
I
PEAK PLANT OPERATING WORK
FORCE (350 PERSONS)
EMPLOYMENT
PLANT CONSTRUCTION EMPLOYMENT
REQUIREMENTS
PROJECTED IMPACTS
OR EFFECTS
ELIMINATION OF SOME PRESENT
AQUATIC HABITAT
NEW SUBSTRATE PROVIDED FOR
PERIPHYTON, INSECTS, AND
MOLLUSKS
IV
DURATION AND DEGREE OF IMPACT
MEASURES TO MITIGATE
PROJECTED IMPACTS
DURATION OF 14-YEAR PLANT CONSTRUC-
TION PHASE
MAXIMUM OF 35 CONSTRUCTION
WORKERS EXPECTED TO RELOCATE
TO TRIMBLE COUNTY; INCLUDING
DEPENDENTS, A MAXIMUM OF 125
PERSONS EXPECTED TO RELOCATE
AS A RESULT OF PLANT CONSTRUC- NUMBER REACHED IN 1983
TION
MODERATE IMPACT. RELOCATIONS WILL
OCCUR GRADUALLY, WITH MAXIMUM
MAXIMUM OF 190 WORKERS EX-
PECTED TO RELOCATE TO TRIMBLE
COUNTY; INCLUDING DEPENDENTS,
A MAXIMUM OF 678 PERSONS EX-
PECTED TO RELOCATE AS A
RESULT OF PLANT OPERATION.
POPULATION OF BEDFORD MAY
DOUBLE
A MAXIMUM OF 695 NEW JOBS
DURATION OF 36-YEAR TOTAL PLANT
OPERATING LIFE
MAJOR IMPACT. MAXIMUM EXPECTED
RELOCATIONS CONSTITUTE 5.6 PER-
CENT OF COUNTY'S PRESENT POPU-
LATION AND WILL CAUSE AN 11
PERCENT INCREASE OVER CURRENT
POPULATION PROJECTIONS FOR 1989
(YEAR MAXIMUM NUMBER OF RE-
LOCATIONS WILL BE REACHED).
HOWEVER, INCREASE WILL OCCUR
OVER A 6-YEAR PERIOD, ALLOWING
PLANNING BY COUNTY OFFICIALS
THROUGHOUT 14-YEAR PLANT CONSTRUC-
TION PHASE
MAJOR IMPACT, PRIMARILY ON LOUIS-
VILLE CONSTRUCTION LABOR POOL
INDUCED SERVICES-RELATED
EMPLOYMENT REQUIREMENTS
CREATION OF APPROXIMATELY
904 NEW JOBS AS A RESULT
OF CONSTRUCTION WORK DE-
MANDS FOR GOODS AND SERVICES
LOW IMPACT TO LOUISVILLE AREA
-------
TABLE 16 (Continued)
ENVIRONMENTAL
COMPONENT
AVFKCTED sy
PROPOSED PROJECT
EMPLOYMENT
(CONT'D)
ECONOMY
CO
II
SOURCE OF IMPACTS
PLANT OPERATION EMPLOYMENT
REQUIREMENTS
INDUCED SERVICES-RELATED
EMPLOYMENT REQUIREMENTS
PLANT CONSTRUCTION EMPLOYMENT
WAGES
INDUCED SERVICES-RELATED
EMPLOYMENT WAGES AS RESULT
OF CONSTRUCTION PERSONNEL
WAGE SPENDING
OPERATING WAGES
IJI
PROJECTED IMPACTS
OR Kt'FECTS
A MAXIMUM OF 350 JOBS
CREATION OF APPROXIMATELY
455 NEW JOBS IN 5-COUNTY
AREA (TRIMBLE, CARROLL,
OLDHAM, AND JEFFERSON
COUNTIES IN KENTUCKY, AND
JEFFERSON COUNTY IN INDIANA)
OVER $152 MILLION IN WAGES
WILL BE PAID TO CONSTRUC-
TION PERSONNEL. OF THIS,
$107 MILLION WILL CONSTITUTE
DISPOSABLE INCOME
APPROXIMATELY $107 MILLION
IN DISPOSABLE INCOME
APPROXIMATELY $696 MILLION
IN WAGES WILL BE PAID TO
OPERATING PERSONNEL. OF
THIS, $487 MILLION WILL
CONSTITUTE DISPOSABLE
INCOME. NEW GROSS INCOME
IN TRIMBLE COUNTY AS A RE-
SULT OF PLANT OPERATION WILL
BE APPROXIMATELY $5 MILLION
(WHICH IS APPROXIMATELY 12
PERCENT OF PROJECTED 1989
TOTAL EARNED INCOME IN
COUNTY)
IV
DURATION AND DKGRKE OF IMPACT
THROUGHOUT 36-YEAR TOTAL PLANT
OPERATING LIFE
MODERATE IMPACT (DEPENDING ON LOCA-
TION OF WORKER SPENDING)
MODERATE IMPACT
MEASURES TO MITIGATE
PROJECTED IMPACTS
THROUGHOUT 14-YEAR PLANT CONSTRUCTION
PHASE
MAJOR IMPACT TO ECONOMY OF AREAS
(PRIMARILY LOUISVILLE METROPOLITAN
AREA) IN WHICH WAGES ARE SPENT
LOW IMPACT TO LOUISVILLE AREA
THROUGHOUT 36-YEAR TOTAL PLANT
OPERATING LIFE
MAJOR IMPACT TO 5-COUNTY REGION
(INCLUDING TRIMBLE COUNTY) IN
WHICH WAGES ARE EXPECTED TO BE
SPENT
-------
TABLE 16 (Continued)
II
ENVIRONMENTAL
COMPONENT
AFFECTED By
PROPOSED PROJECT
ECONOMY
(CONT'D)
HOUSING
III
IV
SOURCE OF IMPACTS
INDUCED SERVICES-RELATED
EMPLOYMENT WAGES AS A RESULT
OF OPERATING PERSONNEL WAGE
SPENDING
CONSTRUCTION PHASE HOUSING
REQUIREMENTS
U)
I
01
OPERATING PHASE HOUSING
REQUIREMENTS
PROJECTED IMPACTS
OR EFFECTS
APPROXIMATELY $487 MILLION
IN DISPOSABLE INCOME
MAXIMUM EXPECTED CONSTRUC-
TION WORKER RELOCATIONS
(35 PERSONS) MAY STIMULATE
NEW HOUSING CONSTRUCTION
IN TRIMBLE COUNTY
POTENTIAL INFLUX OF MOBILE
HOMES, WHICH COULD RESULT
IN DEGRADATION OF LOCAL
AESTHETICS AND POSSIBLY
POSE HEALTH PROBLEMS (THERE
ARE NO ZONING LAWS OR PUBLIC
SEWERAGE FACILITIES IN
TRIMBLE COUNTY)
NEW-HOUSING CONSTRUCTION
CYCLE WILL BE INITIATED IN
TRIMBLE COUNTY. UP TO 190
NEW HOMES COULD BE REQUIRED,
BUT PROBABLY FEWER AS A
RESULT OF DEPARTURE OF
CONSTRUCTION FORCE
REDUCTION OF AVERAGE AGE
OF HOUSING IN COUNTY.
RAISING OF AVERAGE VALUE
OF HOMES
CREATION OF SERIOUS REQUIRE-
MENTS FOR WATER, SEWAGE
DISPOSAL, AND OTHER SERVICES
DURATION AND DEGREE OF IMPACT
LOW IMPACT TO 5-COUNTY AREA
THROUGHOUT 14-YEAR CONSTRUCTION
PHASE
MODERATE IMPACT ON HOUSING INDUS-
TRY IN COUNTY. IF HOUSING DEMAND
IS SPREAD OVER CONSTRUCTION PHASE,
LOCAL CONTRACTORS COULD HANDLE
THIS INCREASED DEMAND
MEASURES TO MITIGATE
PROJECTED IMPACTS
PRIMARILY DURING FIRST 6 YEARS
OF PLANT OPERATION
MAJOR IMPACT
-------
TABLE 16 (Continued)
KNVfKONMKNTAL
COMPONKNT
AFFKCTED BY
PROPOSED PROJECT
TAXES
U)
I
•0
o
LAND USE
II
SOURCE OF IMPACTS
TAXES DURING CONSTRUCTION
Of PLANT
COUNTY TAXES
STATE TAXES
SALES TAXES
TAXES DURING OPERATION
OF PUNT
COUNTY PROPERTY TAXES
STATE INCOME TAXES
SALES TAXES
PLANT CONSTRUCTION AND
OPERATING PHASES
EFFECT OF REGULATIONS FOR THE
PREVENTION OF SIGNIFICANT
DETERIORATION OF AIR QUALITY
m
PROJECTED IMPACTS
OK KPFKCTS
IV
WHAT I OH AND hKWKE OF IMPACT
MAJOR IMPACT TO THE ECONOMY OF THE
AREA
MEASURES TO MITIGATE
PROJECTED IMPACTS
APPROXIMATELY $769,100 IN
TRIMBLE COUNTY TAXES
APPROXIMATELY $6.4 MILLION
IN KENTUCKY TAXES ON PROPERTY
AND CONSTRUCTION PERSONNEL AND
RELATED SERVICE WORKER WAGES
COULD AMOUNT TO $5.2 MILLION
IN KENTUCKY SALES TAXES ON
SPENDING OF CONSTRUCTION
PERSONNEL AND RELATED
SERVICE WORKER WAGES
MAJOR IMPACT TO THE ECONOMY OF THE
AREA
$50.1 MILLION IN TRIMBLE
COUNTY PROPERTY TAXES
$28.2 MILLION IN KENTUCKY TAXES
ON OPERATING PERSONNEL AND
RELATED SERVICE WORKER WAGES
COULD AMOUNT TO $25.5 MILLION
IN KENTUCKY SALES TAXES ON
SPENDING OF OPERATING PERSON-
NEL AND RELATED SERVICE
WORKER WAGES
2,300 ACRES OF PRESENT
AGRICULTURAL AND WOODLAND
LAND USES DEVOTED TO INDUS-
TRIAL USES
IT IS DOUBTFUL THAT ANY NEW
INDUSTRIES WITH SULFUR DI-
OXIDE COULD LOCATE IN SOUTH-
WESTERN TRIMBLE COUNTY OR
FOR DURATION OF PROJECT
MAJOR IMPACT. SITE OCCUPIES .5
PERCENT OF FARMLAND IN TRIMBLE
COUNTY; HOWEVER, THE SITE BOTTOM-
LAND (APPROXIMATELY 400 ACRES)
CONSISTS OF SOME OF THE MOST
FERTILE SOIL IN THE COUNTY
FOR DURATION OF PROJECT
POTENTIAL MAJOR IMPACT; HOWEVER,
MAJOR INDUSTRIAL DEVELOPMENT IS
EASTERN CLARK COUNTY, INDIANA NOT PROJECTED FOR THESE AREAS
-------
TABLE 16 (Continued)
II
ENVIRONMENTAL
COMPONENT
AFFECTED BY
PROPOSED PROJECT
TRANSPORTATION
III
IV
SOURCE OF IMPACTS
PLANT CONSTRUCTION AND
OPERATING VEHICULAR TRAFFIC
PLANT CONSTRUCTION AND
OPERATION BARGE TRAFFIC
Go
I
SOCIAL STRUCTURE
PLANT CONSTRUCTION AND
OPERATION
PROJECTED IMPACTS
OR EFFECTS
CONSIDERABLE CONSTRUCTION
AND OPERATING PERSONNEL
TRAFFIC AND SOME TRUCK
TRAFFIC. TRAFFIC CONTROL
SYSTEM WILL NEED TO BE
INSTALLED AT INTERSECTION
OF U.S. 42 AND SR 754. SR 754
WILL HAVE TO BE UPGRADED TO A
CLASS AAA WEIGHT CLASSIFICATION.
CR 1488 WILL HAVE TO BE RE-
LOCATED
DURATION AND DEGREE OF IMPACT
THROUGHOUT PLANT CONSTRUCTION AND
OPERATING PHASES
MAJOR IMPACT TO EXISTING TRAFFIC
LEVELS
A TOTAL OF 2 MILLION TONS
OF MATERIAL, EQUIPMENT,
AND COAL WILL BE DELIVERED
TO THE SITE DURING CONSTRUC-
TION PHASE. A TOTAL OF
APPROXIMATELY 256 MILLION
TONS OF COAL AND OTHER
MATERIALS WILL BE DELIVERED
TO THE SITE DURING THE
PLANT OPERATING PHASE.
THIS AMOUNTS TO A TOTAL
AVERAGE BARGE TOW (AT 15
BARGES PER TOW) DELIVERY
RATE OF APPROXIMATELY 41
TOWS PER YEAR DURING CON-
STRUCTION AND 632 TOWS
PER YEAR DURING PLANT
OPERATION
SURROUNDING LOCAL POPULA-
TION, ESPECIALLY THE
RESIDENTS OF WISES LANDING,
HAVE LONG BEEN ACCUSTOMED
TO A LIFESTYLE RELATIVELY
FREE OF NOISE, DUST, HIGH
TRAFFIC LEVELS, AIR POLLU-
TANTS, AND INDUSTRIAL
DEVELOPMENTS. THESE PEOPLE
WILL NOW BE SUBJECTED TO
CONDITIONS THAT NORMALLY
OVER PLANT CONSTRUCTION AND
OPERATING PHASES
LOW IMPACT TO EXISTING AND FUTURE
OHIO RIVER BARGE TRAFFIC LEVELS.
THE CANNELTON AND THE MCALPINE
LOCKS HANDLE AN AVERAGE OF 105
TOWS PER WEEK OR 5,460 TOWS PER
YEAR. THUS, CONSTRUCTION BARGE
TRAFFIC WILL INCREASE PRESENT
TRAFFIC LEVELS BY ONLY .7 PER-
CENT; OPERATION BARGE TRAFFIC
WILL INCREASE PRESENT TOW TRAF-
FIC BY 12 PERCENT (THESE FIGURES
INCLUDE BOTH LOADED AND EMPTY
[RETURNING] TOWS)
THROUGHOUT PLANT CONSTRUCTION
AND OPERATING PHASES
MAJOR IMPACT TO LOCAL RESIDENTS'
QUALITY OF LIFE
MEASURES TO MITIGATE
PROJECTED IMPACTS
APPLICANT WILL BEAR THE COST OF RE-
LOCATING CR 1488
-------
TABLjE K) (Continued)
KNVIHONMKNTAL
C'OM'tJNKNT
AmXTKD BY
!'Ht>rO!',KI)
SOCIAL STRUCTURE
(CONT'D)
PUBLIC HEALTH
II
HOIIHCK OF IN!'AW
PLANT CONSTRUCTION AND
OPERATION
(CONT'D)
POLLUTANTS FROM THE FIR INC.
OF FOSSIL FUEL (COAL)
OJ
HI
!'HO,IKCTKD IMPACTS
OH
TYPIFY MORE URBAN ENVIRON-
MENTS. LOCAL AND COUNTY
SERVICES (SCHOOLS, KOADS.
S EWERAf I E FAC I L IT I ES , ETC . )
WILL BE STRAINED. A DECLINE
IN THE EX 1ST INf: QUALITY OF
SERVICES HAY OCCUR INITIALLY
GROUND LEVEL CONCENTRATIONS
OF SULFUR DIOXIDE, PARTJCU-
LATES, AND NITROGEN DIOXIDE
WILL BE BELOW FEDERAL AND
STATE PRIMARY AMBIENT AIR
QUALITY STANDARDS, WHICH
ARE DESIGNED TO PROTECT THE
PUBLIC FROM ADVERSE HEALTH
EFFECTS OF THESE POLLUTANTS.
NEVERTHELESS, THE COMBINED
EFFECTS OF SULFUR DIOXIDE
AND PARTI CULATES ARE POTEN-
TIALLY MORE HARMFUL THAN
HIGH LEVELS OF SULFUR DI-
OXIDE OR PARTICIPATES ALONE.
CHILDREN ARE MORE SUSCEPTIBLE
THAN ADULTS TO ADVERSE EFFECTS
FROM POLLUTANT EMISSIONS.
HOWEVER, BECAUSE OF THE USE
OF POLLUTION CONTROL DEVICES
AND BECAUSE THE PROJECTED
DISPERSION AND DIFFUSION
CHARACTERISTICS OF THE
PROPOSED PLANT ARE GOOD, HIGH
CONCENTRATIONS OF POLLUTANTS
ARE NOT EXPECTED TO OCCUR.
99 PERCENT OF THE PARTICULATE
MATTER PRODUCED BY COAL FIRING
WILL NOT BE RELEASED TO THE
ATMOSPHERE. AT LEAST 90 PER-
CENT OF THE SULFUR DIOXIDE
WILL BE REMOVED
IV
WHATWN MID IiKC.HKE OF IMPACT
MKASUHKS TO MITIGATE
PWJKCTKD IMPACTS
THROUGHOUT PLANT OPERATION PHASE
-------
TABLE 16 (Continued)
ENVIRONMENTAL
COMPONENT
AFFECTED BY
PROPOSED PROJECT
AESTHETIC
QUALITY
II
SOURCE OF IMPACTS
PLANT AND TRANSMISSION LINE
CONSTRUCTION AND OPERATION
W
I
NOISE
PLANT CONSTRUCTION AND
OPERATION
III
PROJECTED IMPACTS
OR EFFECTS
AESTHETIC CHARACTERISTICS OF
THE SITE WILL CHANGE DRAMAT-
ICALLY. THE SITE WILL BE
TRANSFORMED FROM A RURAL TO
A HIGHLY DEVELOPED INDUSTRIAL
SETTING. VEGETATION REMOVAL,
SITE GRADING, CONSTRUCTION
OF THE PLANT CHIMNEYS, COOL-
ING TOWERS, DISPOSAL AND
RETENTION POND DIKES, BARGE
FACILITIES, POWER BLOCK,
OFFICES, SUBSTATION, THE
FILLING OF THE RAVINES WITH
THE SOLID WASTE LANDFILL,
AND TRANSMISSION LINES WILL
ALTER THE VISUAL CHARAC-
TERISTICS OF THE SITE.
NOISE, DUST, AND GENERAL
ACTIVITY ON AND AROUND THE
SITE WILL FURTHER ALTER ITS
PRESENT CHARACTER
NOISE FROM PLANT CONSTRUC-
TION AND OPERATION WILL BE
A SOURCE OF ANNOYANCE TO
THE RESIDENTS IN THE IMME-
DIATE SITE AREA, PARTICULARLY
WISES LANDING. CONSTRUCTION
NOISE WILL PROBABLY BE MORE
OF AN ANNOYANCE THAN OPERA-
TING NOISE, PARTIALLY AS A
RESULT OF THE FORMER'S
INTERMITTENT NATURE
IV
DURATION AND DECREE OF IMPACT
DURATION OF PROJECT
MAJOR IMPACT ON THE RESIDENTS OF
WISES LANDING, ON PERSONS PASSING
THE SITE ON CR 1A88, SR 754, ON
THE RIVER, AND ON PERSONS RESIDING
IN HOMES OVERLOOKING THE SITE.
THE TOPS OF THE CHIMNEYS AND THE
COOLING TOWER PLUMES MAY BE VISI-
BLE ALONG PORTIONS OF U.S. 421.
TRANSMISSION LINES PASSING THROUGH
AGRICULTURAL AREAS IN INDIANA WILL
HAVE A HIGH VISUAL IMPACT. HOW-
EVER, THE TOTAL NUMBER OF PEOPLE
AFFECTED BY THE PROJECT'S IMPACT
ON THE AESTHETIC CHARACTERISTICS
OF THE AREA WILL PROBABLY BE
RELATIVELY SMALL, EVEN GIVEN THE
LENGTH OF TIME THE PROJECT WILL
BE IN EXISTENCE
THROUGHOUT PLANT CONSTRUCTION AND
OPERATING PHASES
LOW TO MODERATE IMPACT DURING
CONSTRUCTION; LOW IMPACT DURING
PLANT OPERATION
MEASURES TO MITIGATE
PROJECTED IMPACTS
SCREENING BERM ALONG SOUTHERN
BOUNDARY OF PLANT AND DISPOSAL POND
DIKES NEAR NORTHERN BOUNDARY OF
SITE, AS WELL AS REMAINING VEGE-
TATION AND PLANTS FROM REVEGETATION
PROGRAM, WILL REDUCE PROJECT-RELATED
NOISE DURING THE LATTER PORTION OF
PLANT CONSTRUCTION AND DURING PLANT
OPERATION
-------
TABLE 16 (Continued)
KNVfHONMb'NTAL
COMPONENT
.AFFKCTKD BY
PHOPOSKD PHOJKCT
SERVICES
II
'JOUHCK OF IMPACTS
PLANT CONSTRUCTION AND
OPERATING WORK FORCE RE-
LOCATIONS ( A TOTAL MAXIMUM
OF 803 PERSONS FROM 1978
THROUGH 2019 - SEE "POPU-
LATION" UNDER COLUMN I)
111
I'HOJKCTKD IMPACTS
OK KWKCTS
COUNTY GOVERNMENT COULD BE
HARD PRESSED INITIALLY TO
MAINTAIN ADEQUATE LEVEL OF
SERVICES. COUNTY'S CURRENT
SEPTIC TANK SEWERAGE SYSTEM
MAY HAVE TO BE UPGRADED. A
FULLTIME DOCTOR MAY BE RE-
QUIRED IN BEDFORD
IV
WHAT 10H AND HWHKK OP IMl'ACT
THROUGHOUT PLANT CONSTRUCTION AND
OPERATING PHASES
MAJOR IMPACT, ALTHOUGH THIS EVENTU-
ALLY WILL BE LARGELY OFFSET BY THE
TAX REVENUES DERIVED FROM THE PLANT
AND ITS OPERATING PERSONNEL AND BY
CAREFUL PLANNING ON THE PART OF
COUNTY OFFICIALS
MKASURKS TO MITIGATE
I'ftOJKCTKD IMPACTS
u>
I
NEW SERVICE FACILITIES
(BAKERIES, VARIETY STORES,
HAIRSTYLING, ETC.) MAY APPEAR
IN BEDFORD, KENTUCKY. AL-
READY EXISTING SERVICES WILL
PROBABLY BE IMPROVED AND
EXPANDED. CARROLLTON,
KENTUCKY AND MADISON,
INDIANA MAY ALSO EXPERIENCE
SOME SERVICE-RELATED GROWTH
MODERATE IMPACT TO COMMUNITY ECONOMY
AN INCREASED DEMAND WILL BE
PLACED ON TRIMBLE COUNTY
SCHOOL SYSTEM BY APPROXI-
MATELY 56 CONSTRUCTION
PERSONNEL CHILDREN AND
APPROXIMATELY 300 OPERATING
PERSONNEL CHILDREN
THROUGHOUT PLANT CONSTRUCTION AND
OPERATING PHASES
MODERATE TO MAJOR IMPACT
SCHOOLS COULD ACCOMMODATE INCREASED
DEMAND DURING CONSTRUCTION PHASE IF
TEACHER'S AIDES CAN BE RECRUITED TO
SERVE IN THE SCHOOL SYSTEM. TAX
REVENUES DERIVED FROM CONSTRUCTION
PERSONNEL RELOCATIONS WILL HELP
OFFSET IMPACT
DEMAND PLACED BY THE 300 OPERATING
PERSONNEL CHILDREN COULD CAUSE A
SEVERE IMPACT ON COUNTY SCHOOLS,
UNLESS THE PRESENTLY PLANNED 300-
PUPIL ELEMENTARY SCHOOL IS CON-
STRUCTED
-------
TABLE 16 (Continued)
KIWIRONMENTAL
COMPONENT
AFFECTED BY
PKOPOSKD PROJECT
SERVICES
(CONT'D)
I
*j
Ul
II
SOURCE OF IMPACTS
PLANT CONSTRUCTION AND
OPERATING WORK FORCE RE-
LOCATIONS (A TOTAL MAXIMUM
OF 803 PERSONS FROM 1978
THROUGH 2019 - SEE "POPU-
LATION" UNDER COLUMN I)
(CONT'D)
HI
PHOJKCTKD IMPACTS
OR KFt'KCTS
SCHOOL SYSTEM MAY UNDERGO
LONG-TERM IMPROVEMENT AS A
RESULT OF REVENUES DERIVED
FROM PLANT OPERATION AND
PERSONNEL
IV
DURATION AND DEGRKE OF IMPACT
AN OVERLAP OF CONSTRUCTION AND
OPERATING PERSONNEL SCHOOL REQUIRE-
MENTS BETWEEN 1983 AND 1991 COULD
RESULT IN TEMPORARY OVERCROWDING
AND REQUIRE SHORT-TERM ALTERNATIVE
FACILITIES
CAREFUL PLANNING BY COUNTY AND
SCHOOL OFFICIALS WILL HELP REDUCE
THE POTENTIAL IMPACT
MRASUHKS W MITIGATE
I'RO,IKCTKD IMPACTS
-------
3.5 MEASURES TO MITIGATE ADVERSE ENVIRONMENTAL IMPACTS
INTRODUCTION
The Applicant and the EPA have developed a set of measures to reduce
identified adverse impacts of construction and operation of the Trimble
County Generating Plant. These measures focus primarily on control of
noise, dust, water, and air pollution. In addition, discharges from the
runoff retention basin and the solid waste disposal ravines and flue gas
emissions will be monitored.
Several of these mitigative measures have been formally established in
a Stipulation (given as an attachment to this document) agreed to by the
Applicant and the EPA as the prerequisite to approval of an NPDES permit.
Subsequent to this Stipulation, and after additional information was supplied
to the EPA by the Applicant, effluent limitations and permit conditions were
established and a draft NPDES permit was written for the proposed project.
This draft permit is also attached to this document.
NOISE CONTROL
Noise from construction equipment can be mitigated to some extent by
the use of proper muffling devices on all engines. Construction management
must make certain that Occupational Safety and Health Act standards are
met by providing ear protection to workers when and where required.
A site arrangement study conducted by the design engineers included
reduction of boundary noise as a major criterion for placement of various
plant elements. On the basis of this criterion, cooling towers, main
plant buildings, barge unloading facilities, and coal-handling equipment
were located as far from Wises Landing as practical. For most principal
noise sources, measures to reduce the noise will be taken. There will
be individual treatment of exceptional noise-producing equipment. The
main building, which houses the major equipment, will be enclosed with
insulated metal siding. This feature will help considerably in reducing
the level of noise emitted from the plant.
In addition to the design features incorporated into the plant to
reduce the noise emitted, other steps will be taken to attenuate emitted
sounds. After construction of the plant, the site will be landscaped and
vegetated. During the construction phase, a vegetated berm will be con-
structed along Kentucky Highway 754. This berm will significantly reduce
noise emissions from the plant. The natural and planned vegetation located
on the site will absorb some of the noise, thereby reducing the noise level
at and beyond the site boundary.
Dust collectors, discussed under "Dust Control," would also serve to
limit noise emissions from coal unloading and transfer operations.
DUST CONTROL
The Applicant will minimize fugitive dust production on site by: (1)
limiting clearing and grading operations to those areas essential to
3-76
-------
maintain construction sequence and schedule, (2) grassing disturbed areas
as promptly as possible, and (3) using dust control or abatement measures
on roadways or cleared areas.
Dust abatement procedures that could be used during construction
include covering construction roads with a stone and petroleum base and
spraying potentially dusty areas with water. The requirement will be
greatest during summer months when the soil-evaporative stress is greatest.
The effects of construction equipment engine exhaust can be allayed
by routine engine maintenance and tuning.
Control of fugitive dust from the handling and storage of coal and
limestone will require a more extensive program. The primary means of
controlling dust emissions from open bulk-material handling operations is
the use of wet sprays. The sprays are most frequently water; however, in
some circumstances, special surfactants are added to the water or a hydro-
carbon-based liquid is used.
It is assumed that sprays would be used at the unloading facilities
and coal and limestone piles as appropriate. At mechanical transfer points,
the operations would be enclosed and dust-laden air would be filtered
through bag-type filters.
Dusting prevention at the coal and limestone piles is achieved by
management of the material pile. This entails careful compaction of the
pile surface at the time of material storage and, under some conditions,
"skimming" with hydrocarbon-based materials.
At the pug mill, a small quantity of conveying air will need to be
vented. If mixing of the sludge cake with the fly ash and fixation agent
is sufficiently complete, this air could be vented through the mill itself.
Otherwise, a spray for dust suppression will be introduced at the discharge
from the mill.
WATER POLLUTION CONTROL
Measures to protect the water and associated aquatic life from damage
by the plant are the stormwater runoff retention system, sanitary facilities
and waste treatment, and closed cycle plant water system. The following are
additional measures that will be employed.
Erosion Control
The following construction practices will be used to reduce erosion
and provide sediment control during construction.
1. As much natural ground cover as possible will be retained
and protected; areas where cover is removed will be seeded
with fescue (sloped areas) or rye (in areas requiring im-
mediate erosion control)
2. Where possible, work will proceed in small units, exposing
a minimum of surficial area to soil erosion
3-77
-------
3. Structures and final grading and surface protection will be
completed as quickly as possible
4. Where it is necessary to delay completion, temporary seeding
or mulching will be used to control erosion
5. Moderate slopes will be used to reduce the velocity of runoff
and to facilitate the establishment and maintenance of a good
ground cover
6. Runoff will be diverted away from excavations, embankments, and
other exposed surfaces by means of temporary berms, dikes, and
slope drains as required
7. Major earthwork will be scheduled during the summer months. This
period allows the establishment of healthy vegetation and
historically has the least amount of rainfall
8. Impounded water will be used for construction purposes as much
as practicable
9. In the ravine areas, where possible, tree stumps and roots and
ground cover vegetation will not be removed. Tree clearing
will be selective and progressive; the tops of the ridges will
not be cleared
10. Riprapping of vegetation will be used to stablize the banks of
the relocated Corn Creek channel as well as the dikes and banks
along the Ohio
Accidential Leakage and Spillage Control
Leakage and spillage could cause significant short-term deterioration of
the water quality and the elimination of large quantities of aquatic biota
at and downstream of the spill. In order to protect the environment from
accidental spillage of materials (coal, fuel oil, limestone, chemicals)
barged to the Trimble County Generating Plant, the following plans have
been made.
All coast guard regulations dealing with oil transfer facilities and
operation will be complied with; an operations manual for the facility will
be prepared and submitted to the captain of the port of Louisville, Kentucky.
A spill prevention control and countermeasure plan will describe spill
prevention measures.
A floating boom will be used to contain any oil that might be spilled
during barge unloading. A motorized work barge with an oil skimmer will
be used if oil cleanup operations are necessary. Facilities for the un-
loading of chemicals will be designed to minimize the possibility of spills.
A containment system will be built around the oil storage facilities on land.
Tanks and diking will be constructed in accordance with American Petroleum
Institute standards. Dikes will be sized to contain at least 110 percent
of the capacity of the largest tanks and will be provided with concrete
sumps. Any water collected in the sumps will be pumped to an oil separator
for recovery of the oil and reuse of the water.
3-78
-------
Ground Water Protection Measures
In order to prevent contamination of ground water by fuel and chemical
stockpiles and by solid waste disposal, the Applicant will take the following
precautions:
1. Solid waste (fly ash and scrubber sludge) will be rendered as
stable, impermeable, and nonleachable as possible by means
of a chemical stabilization process
Disposal of the stabilized solid waste will be phased. During
the first 2 years of plant operation, a test disposal process
will be used. At the mouth of one of the smaller ravines
leading into Ravine RB, a dam to control runoff will be con-
structed. The sludge/ash mixture will be terraced behind the
dam. Runoff would be monitored and, depending on its con-
dition, either (a) discharged directly to Corn Creek, (b)
treated and returned to Corn Creek, or (c) recycled. Leachate
will also be collected and monitored. The disposal area
will be lined with compacted clay. A blanket of permeable
inert material, such as sand, will be laid over the liner.
This blanket would be designed to drain toward a sump, which
will collect any water entering the permeable blanket. The
water collected in the sump will be periodically pumped out
and tested to monitor its chemical constituents. This test
disposal process will provide data on which to establish the
procedure for developing the remaining disposal areas, in-
cluding the extent of required monitoring of ground water
and runoff and any necessary additional engineering safeguards.
2. In lieu of a satisfactory stabilization process or of proven
long-term reliability, a suitable off-site disposal area will
be selected by the Applicant. A complete environmental analysis
(EIA) of the site will be performed and presented to the EPA and
the Commonwealth of Kentucky. The EIA will include detailed
descriptions of the entire process, including: transport, control
of surface runoff, control of leachate, and a complete delineation
of impact to the natural and human environments
3. All fuel, chemical, and onsite waste disposal areas will have
engineered containments featuring impermeable liners and dikes
of sufficient size to provide protection from flooding, and con-
tainment of spills or runoff water. The waste disposal areas
have a combined 30-year disposal capacity
AIR POLLUTION MITIGATION
Measures to mitigate the emission of pollutants from the plant are
described in Sections 3.4 and 4.2 of the supporting report. These include:
increased stack height, natural draft cooling towers, the S02 scrubber
system, and the electrostatic precipitators.
During periods of lengthy shutdown of the scrubber system on a partic-
ular generating unit, the Applicant proposes to employ one of the following
strategies to control the S02 emissions from the plant so that the plant
continues to meet the allowable emission rate:
3-79
-------
1. Shut down the unit with the malfunctioning scrubber
2. Burn an alternate coal in the unit and/or follow other
operating procedures not presently identified
The Applicant will maintain a 30-day supply for one unit of an alternate
coal on the plant site. This coal may be substituted for the normal plant
fuel to allow continued unit operation while the scrubber system is down.
Fuel oil tanks will be equipped with floating roofs, vapor conserva-
tion vents, and flame arresters.
OTHER MITIGATIVE MEASURES
Navigational Warnings
Navigational lights and required navigation warnings will be provided for
the mooring cells in the Ohio River. Barges moored at the cells will cause
little interference with river traffic. Two barge tows will extend approxi-
mately 200 feet from the mooring cells into the channel; the barges will be
approximately 1,000 feet from the center of the channel.
Measures to Protect Wildlife
The Applicant, the Kentucky Department of Fish and Wildlife Resources
(KDFWR), and the U.S. Fish and Wildlife Service met on June 26, 1978 to
develop measures to mitigate the impact of the proposed facility on aquatic
biota and wildlife. Five measures were jointly agreed upon:
1. Relocating Corn Creek so as to simulate natural stream condi-
tions. The new channel will tie into the existing Corn Creek
outlet. Design specifications of the new channel will be
developed jointly by KDFWR and the Applicant. The intent
should be to establish a channel with riffles, pools, and
meanders (if determined feasible). Only 7 acres of the Corn
Creek slough will be altered/disturbed by the project (as
outlined in the EIS)
2. The Applicant will enter into a cooperative agreement with
KDFWR to manage the property extending from the slough to
the Ohio River (the oxbow area). The property will be
managed for migratory and nonmigratory waterfowl, and other
game and nongame birds. Management of the area will include
a share cropping agreement between KDFWR and a local farmer(s).
In conjunction with this area, waterfowl will not be dis-
couraged from using fly ash ponds. Fly ash ponds in
combination with nearby crops will provide habitat especially
attractive to waterfowl. For plant security reasons, the
oxbow area will be closed to hunting. However, the area
will be open to nonconsumptive public uses such as bird
watching, hiking, nature surveys, and others. The KDFWR
will post the area as a waterfowl refuge and/or no hunting
area
3-80
-------
3. Upland habitat located north of the plant site, in ownership
of the Applicant, will primarily be maintained as is. KDFWR
will have the option to employ various management techniques
to benefit deer and other wildlife populations. Among these
techniques, farming of ridgetops may be undertaken. This
area will be open to bow hunting only and will be posted by
KDFWR
4. Purchase of land (ravines) for solid waste disposal will result
in the acquisition of excess acres adjacent to the ravines.
These acreages will be maintained for wildlife use. Deposition
of waste material into ravines will be performed so as to begin
at the outermost extremities of the ravine, eventually working
towards the generating plant. Waste materials placed in ravines
will be revegetated as soon as possible. Vegetative types uti-
lized will be based on recommendations by KDFWR. As ravines
are filled, the Applicant will retain the option of selling
these areas for farming purposes
5. KDFWR will retain the option of constructing a subimpoundment
on an unused portion of the project site. The purpose of the
impoundment would be to rear fish to a stockable size for
release into the Ohio River
The Applicant assumes responsibility for clean-up of all spills to the
Ohio River resulting from barge loading or unloading operations involving
oil, coal, desulfurization reactants, or other chemicals used at the facility.
Oil pollution prevention procedures as stated in 40 CFR Part 112 will be
followed.
Intake velocity at the intake structure screen will not exceed 0.5
feet per second.
MONITORING PROGRAMS
Ground Water Monitoring
The Applicant will implement a ground water monitoring program. Moni-
toring of the ground water downgradient of the onsite bottom ash and emergency
fly ash and scrubber sludge disposal pond, as well as coal storage areas,
will be performed monthly. Quarterly reports will be submitted to the EPA
and the Commonwealth of Kentucky. Applicable EPA-approved methods will be
used to determine, to the limits of detection, the following constituents
in the ground water: copper, iron, lead, mercury, nickel, selenium,
sulfide-sulfite-sulfate compounds, total dissolved solids, specific
conductance, and pH.
The EPA will be informed of any proposed changes to the monitoring pro-
gram. The EPA may require additional monitoring, if warranted, following
the placement of additional units on the site or following the initiation
of use of new areas for coal storage or ash or sludge disposal ponds. If
leachate is suspected, ground water monitoring in the ravines may be
required.
3-81
-------
Should the quarterly reports demonstrate significant contamination of
ground water, the Applicant will implement measures to mitigate such con-
tamination and to assure that no future contamination will occur. Those
measures acceptable to EPA may include but not be limited to: sealing,
relocating, or altering operations of the ash or sludge disposal ponds
and/or coal storage area.
Water Discharge Monitoring
Water discharged from Ravines RA and RB will be monitored, as will
also water discharged from the runoff retention basins, to ensure that
discharge meets applicable federal and state water quality requirements.
Water discharge monitoring requirements are described in the draft NPDES
permit appended to this report.
Flue Gas Emissions Monitoring
In-stack monitoring will be used to measure flue gas emissions in
accordance with state and federal monitoring regulations.
TRANSMISSION LINE MITIGATIVE MEASURES
Transmission line corridors in Indiana will be selected on the basis
of minimizing clearing and reducing the number of stream crossings. Only
unavoidable crossings will be made. Clearing will be selective. Where
possible, streams will be crossed at narrow points and the line will cross
perpendicularly. Transmission towers will be kept at least 50 feet from
stream banks. Also, vegetation along stream banks will be left as is, if
possible.
The following is a presentation of additional mitigative measures.
Construction Measures
After the initial mechanical clearing of the transmission line right-
of-way, herbicides will be used on woody vegetation only. Maintenance use
of herbicides will be limited to no more than one application in 5 years.
When herbicides are required, their application will be limited to: (1)
periods when the wind speed is less than 5 miles per hour, and (2) areas no
closer than 500 feet from any streams. Clearing within the corridor will
employ the selective basal cutting method rather than rooting and grubbing.
Only "danger" trees bordering the right-of-way will be cut. Necessity for
clearing will vary with terrain, but, on level areas, vegetation of a
height not exceeding 20 feet when mature will be allowed underneath the
lines.
Sensitive man-made or natural areas will be avoided to the maximum
extent possible. When the final alignment is determined (prior to land
acquisition for the Trimble County to Northside [Indiana] Substation), ground
level surveys will be conducted along the corridor to definitively locate
such areas, including archaeological sites potentially eligible for inclu-
sion in the National Register of Historic Places. The archaeological survey
will be closely coordinated with and reviewed by the state archaeologist.
3-82
-------
The vegetative survey will be done along the entire corridor, and this
work also will be coordinated with the state. Wildlife biologists and
foresters with the Indiana Department of Natural Resources could help
locate particular survey areas and suggest mitigative action, if needed.
The Applicant will limit, as much as possible, the number of access
roads to the right-of-way. Also, vegetation which would provide visual
barriers to transmission line corridors will be preserved. Replacement
plantings will also be employed where needed in this respect.
Operation Measures
The Applicant will assume the cost of remedying any adverse effects
on radio or television reception caused by its transmission lines.
3-83
-------
4. AN ANALYSIS OF POTENTIAL PLUME INTERACTIONS
BETWEEN TRIMBLE COUNTY AND CLIFTY
CREEK POWER PLANTS
4.1 INTRODUCTION
Dames & Moore has conducted an analysis of potential plume interactions
from the proposed Trimble County Generating Station and the existing Clifty
Creek Generating Station. The study was conducted for Louisville Gas and
Electric Company to the specifications of EPA Region IV. The purpose of
the study was to quantify the ground level S02 contribution of the proposed
Trimble County plant in the area of the Clifty Creek plant's maximum impacts.
The analysis was performed using the Dames & Moore multiple source
CRSTER model. The model is identical to the latest EPA CRSTER model; however,
the locations of major point sources are not restricted to the center of
the receptor grid system. The receptor grid was specifically located to
quantify the effects of the two plant configuration, considering the results
of previous single source CRSTER modeling efforts and the local terrain
characteristics of the area.
The analysis utilized 1 year (1964) of National Weather Service (NWS)
meteorological surface and upper air data from Louisville, Kentucky. The
data were provided to Dames & Moore for the analysis by Fluor Pioneer Inc.
Emissions information and plant characteristics for both plants were also
provided by Fluor for the analysis. Terrain elevations for each receptor
grid were obtained from the U.S. Geological Survey map for the study area.
The results of the analysis indicate that the effects of the proposed
Trimble County plant will be minimal in the study area. Some significant
ground level S02 concentrations were predicted in the area; however,
these generally occur at different locations than the Clifty Creek impacts.
4.2 DAMES & MOORE MULTI-SOURCE CRSTER MODEL
The Dames & Moore multiple source model MLTCRS was developed to fill
the need for a terrain dependent air quality model acceptable to the EPA
and other regulatory agencies. Therefore, the MLTCRS model was developed
incorporating minimum changes from the original EPA CRSTER model. The
model has been submitted to EPA Region IV for review and approval as an
acceptable air quality model for use in a PSD analysis. An evaluation
of the model was performed prior to submittal to EPA. The model used for
the Trimble County analysis included an additional modification at the
request of EPA Region IV to utilize final plume rise in all calculations
to allow comparison of model results with previous studies.
4-1
-------
4.3 ANALYSIS TECHNIQUES AND RECEPTOR GRID GEOMETRY
The analysis was performed using rural mixing heights as generated by
the EPA pre-CRSTER data processing program. Random numbers generated by
the EPA were used to determine the average flow vectors for the meteoro-
logical data base. The EPA numbers were used rather than generating a
new set in order to assure the comparability of analysis results with
previous model runs, as suggested by EPA Region IV. Final plume rise
was also used for all analysis runs for the same reason.
The receptor grid geometry for the study was selected by Dames &
Moore on the basis of previous modeling studies in the area and local
terrain characteristics. Review of the local terrain and climatological
records for the area clearly indicates that the maximum interaction of
the plumes will occur along the bluff to the north and slightly east
of the Clifty Creek plant. Specifically, the Commonwealth of Kentucky's
CRSTER analysis indicated a maximum plume interaction 1.5 kilometers due
north of Clifty Creek. This result was obtained after summing the Clifty
Creek contribution at this point and the Trimble County centerline contri-
bution at the same distance. While this technique appears reasonable,
some doubt remains as to the effect of the centerline offset between the
two plants (see Figure 1 at the end of this section).
Since the multi-source model does not require sources to be located
at the center of the receptor grid system, the receptor network was placed
in the area of maximum expected interactions by Dames & Moore in order to
resolve the off-centerline question. The receptor grid center was located
from the predicted maximum point on the northern bisection point of the
plume centerlines (Figure 1). Using this geometry and appropriate choices
for ring distances, seven receptors (including the Kentucky maximum) were
located along each of the two plume centerlines at identical distances
from the grid center (see Figure 2 at the end of this section). The ring
distances chosen and terrain elevations for each receptor point are pro-
vided in Table 1, and source characteristics used in the analysis are
provided in Table 1-A at the end of this section.
4.4 ANALYSIS RESULTS
Six modeling runs were performed to determine the potential for
interaction of the plant plumes. An independent run was conducted for
each plant using the complete meteorological base year. The results of
these runs for annual, 24-hour, and 3-hour SC>2 concentrations are presented
in Tables 2-6 and 7-11 (presented at the end of this section) for Clifty
Creek and Trimble County, respectively.
Based on the model output, 11 days were selected for additional
analysis. Three runs were made on the selected 11-day set: the first
for Triable County only; the second for Clifty Creek only; and the third
for both plants combined. Results for the highest and second highest 3-
hour S02 concentrations at each receptor are provided in Tables 12-17
4-2
-------
at the end of this section. A final run was made to determine the contri-
butions associated with each plant at the time of the predicted maximum
interaction, day 174 period 4. The results of this analysis for 3-hour
SC>2 concentration is provided in Tables 18-22.
A comparison of the results of the complete year analysis for each
plant indicates that the maximum impacts of the plants in the study area
result from very different meteorological conditions. In general, the
maximum impacts of the Clifty Creek plant are associated with low windspeeds
(1-3 mps) and unstable conditions, while the maximum impacts of the Trimble
County plant are associated with moderate windspeeds (3-5 mps) and neutral
stability. This result is typical of this type of plant configuration.
Essentially the analysis shows that the maximum impact of Clifty Creek
in the study area can occur anywhere within the area, since the maximum
impact is associated with low windspeeds which usually imply variable wind
directions. The maximum impact of Trimble County, however, can only occur
during northerly air flow with neutral conditions since the source is
located approximately 19 kilometers from the impact area. Any variation in
wind direction causes the plume to miss the area entirely. In addition, the
occurrence of unstable conditions disperses the plume before the impact area
is reached. Therefore, a fairly restrictive set of conditions are needed
for the Trimble County plume to impact the area at all. The source contribu-
tion listing for day 270 (Tables 19, 20, and 21) demonstrates the lack of
Clifty Creek impacts in the area during conditions conducive to Trimble
County impacts.
Since the primary purpose of the study was to identify any periods
during which Trimble County contributions might exacerbate Clifty Creek
impacts in the area, a comparison of the respective plant impacts for the 11
selected worst case days was conducted. Our review of Tables 15 and 17
indicates that Trimble County did not contribute significantly to any of the
25 calculated Clifty Creek violations of the 3-hour S02 standards. In
fact, Trimble County's maximum contribution for any of the 25 periods was
0.1 yg/m3 which occurred during one period only.
A similar check was conducted comparing Tables 14 and 16 for the
highest 3-hour concentrations; however, it should be noted that these
values, although in excess of the 1,300 ug/m3 standard, do not represent
standard violations. The results of this comparison indicate a maximum
contribution from the Trimble County plant of 48.5 yg/m3 which occurred at
the receptor located 1.2 kilometers from the receptor grid center along the
200° azimuth line, which is approximately 0.4 kilometer due south of the
maxima predicted by the Commonwealth of Kentucky analysis.
4-3
-------
-
I-
z
o
u
CD
2
DC
LOUISVILLE GAS & ELECTRIC CO.
TRIMBLE COUNTY GENERATING PLANT
SOURCE & RECEPTOR CONFIGURATION
TRIMBLE COUNTY AND CLIFTY CREEK
FIGURE 1
4-4
-------
32
LEGEND:
POINTS OF EXCEEDENCE
CALCULATED BY THE
STATE OF KENTUCKY
CENTER LINE COMPARISON
POINTS BETWEEN CLIFTY
CREEK AND TRIMBLE COUNTY
LOUISVILLE GAS & ELECTRIC CO.
TRIMBLE COUNTY GENERATING PLANT
RECEPTOR GEOMETRY
TRIMBLE COUNTY AND CLIFTY CREEK
FIGURE 2
4-5
-------
TABLE 1
*JN<>
.of)
.80
1.20
l.oO
. JO
ELEVATION IFF*r AMOVE SEA LEVEL)-- 060.0
HKCfPTOH ELEVAT1UUS (KEKT AH3V? SKA LEVf-L)
U1HECTION
1
2
3
H
5
6
r
B
9
10
11
12
U
10
15
Ih
17
1 6
19
20
21
22
23
2o
25
26
27
2B
29
JO
31
32
33
3o
3s
36
660.
860,
650.
830.
860.
860.
850.
850.
850.
850.
655.
8-30.
850.
840.
640.
600 .
600.
640.
630.
630.
830.
600.
BOO.
620.
820.
830.
830.
6?0 .
830.
640.
840.
850.
660.
860.
860.
660.
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
u
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
u
0
0
0
663.
660 •
660.
660.
870.
660.
870.
6BO.
870.
6 7 1).
661.
860.
640.
830.
320.
HOO.
BOO.
610.
820.
4JO.
B JO.
620.
B20.
770.
790.
630.
630.
840.
840.
840.
850.
6bO.
6SO.
850.
860.
86b.
U
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
860
860
840
t<10
870
900
B 70
flSO
860
840
650
830
63b
610
BIO
740
500
800
BOO
BIO
610
BOO
700
770
7*0
BIO
820
820
790
770
HOO
BIO
BOO
830
660
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.(I
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
d60
350
960
88 0
900
390
490
900
860
630
750
aOO
650
920
550
460
400
050
350
580
490
500
795
795
400
560
550
600
610
B40
320
400
44Q
450
•J60
460
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
670
8SO
890
900
910
900
H90
HfiO
870
860
850
620
570
040
060
030
020
020
050
060
040
570
640
790
810
820
825
615
7SO
BOO
820
600
830
660
850
660
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
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.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
ELEVATION (METE-fS AMOVF SEA LEVEL)— 140. 2
HECEHTOH UEVATIONS 253.
) 253.
J 249.
i 249.
1 234.
' 240.
) 253.
) 253.
* 256.
) 256.
> 256.
) 259.
259.
254.
259.
262.
263.
7
1
1
1
2
2
2
2
2
2
7
1
0
0
9
B
8
9
9
0
0
9
9
7
8
0
0
0
0
0
1
1
1
1
1
7
262
262
265
266
268
265
274
265
262
262
2b6
259
259
254
246
246
225
152
203
2o3
206
206
203
213
230
200
206
209
209
200
234
203
206
203
253
262
.1
.1
.2
.2
.2
.2
.J
.2
.1
.1
.0
.1
.1
.5
.9
.9
.6
.0
.8
.6
.9
.9
.6
.0
.1
.6
.9
.9
.9
.6
.7
.8
.9
.8
.0
.1
262
259
266
268
274
271
271
27o
266
253
228
152
196
209
167
loo
130
137
167
176
109
182
242
202
-------
TABLE 1-A
SOURCE CHARACTERISTICS
Trimble County //I
Trimble County #2
Clifty Creek #1
Clifty Creek #2
Clifty Creek #3
Emission
rate
(gms/sec)
860.00
1172.73
3094.00
3094.00
3094.00
Height
(m)
231.6
231.6
207.9
207.9
207,9
Diameter
(m)
7.76
9.06
4.57
4.57
4.57
Exit
velocity
(m/sec)
30.5
30.5
35.1
35.1
35.1
Temperature
(deg K)
334.11
334.11
421.90
421.90
421.90
Volume flow
(m**3/sec)
1442.49
1966.28
575.74
575.74
575.74
-------
TABLE 2
NAMt '• CLlMY CrttF.K »>UI.LUlANT: SO? EMISSION UN[TS:
MtAN CONC = bE-05
1.13bZ2E-OS
9.70051E-06
Ob 2.790T9E-06
b.71b01t-Ub 3.U6.1HE-06
b.b2802E-06
7.03197E-06
1.19092E-05
l.
-------
TABLE 3
PLANT NAME: CLIFTY C^FEK POLLUTANT:
Yt'AKLY rtAXIMJM 24-riOU* CONC= 3.8743F-04 DINECTION=
EMISSION UNITS: CSM/SEC
7 t)ISTANCE = 2.3 KM OAY=172
HIGHEST 24-HOUR CONCENTRATION AT EACH «ECF.PTOK
.4 KM .8 KM 1.2 KM
1 .6 KM
AIR QUALITY UNITS: (jM/Me*3
2.3 KM
DM
1
2
3
4
b
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
1 .8151E-U4
1 .8998E-04
l.dOlOE-04
1 .7004E-04
1 . 7520t-04
1 . 7355E-04
1 .9203F.-04
2.0902E-04
2.2249E-04
2.3181E-04
2.3736E-04
2.3550E-04
2.2B45E-04
2.1248E-04
1.9144t-04
1 .639Jt-04
1 .3I96E-04
1 .1 791E-04
1 .0964E-04
1.3222E-04
1.5iaoE-04
1 .b5B8E-04
1 .7745E-04
2.0692E-04
2.2297E-04
2.3893t-04
2.4553E-04
2.434 7E-04
2.4b' 7rtE-04
2.4324E-04
2.3200E-04
2. 1931E-U4
2.0 172E -04
1.7300E-04
1 .5411E-04
1.6291E-04
( Ib4)
(Ib4)
(164)
(126)
(233)
(143)
(143)
(143)
(143)
(143)
(U3>
(143)
(143)
(143)
(143)
(143)
(143)
(126)
(174)
(174)
(174)
( 174)
(198)
( I9o)
( 19H)
(198)
(198)
(198)
(19*)
< 1V8)
( 19ri)
(194)
(198)
(198)
( )b8>
( 164)
2
2
1
1
2
2
3
3
3
3
3
3
3
3
3
2
2
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
.0926E-04
. 1729E-04
.923SE-04
.9277E-04
,48bOE-04
.7617E-04
.0671E-04
,3199t-04
.1991E-04
.3410E-04
.4223E-04
.4622E-04
.4371F-04
.4104E-04
.3021E-U4
,9b64E-04
.2942E-04
.3895E-04
164)
164)
164)
160)
160)
160)
159)
1 39)
143)
143)
143)
143)
143)
143)
143)
143)
143)
143)
,3b09E-04 (174)
.Oieit>04 (174)
.328SE-04 (174)
.2225F.-04 (174)
.0421E-04 (198)
.0809E-04 (198)
.4171E-04 (198)
.7470E-04 (19d)
.7916E-U4 (198)
.8437E-04 (198)
.8360E-04 (198)
.B235E-04 (198)
,9b36E-04 (209)
.9011F-04 (209)
.6824E-04 (209)
.3100E-04 (209)
,067bE-04 ( 73)
.6b66t>04 (164)
2.
2.
1.
2.
3.
3.
3.
3.
3.
3.
3.
2.
2.
2.
2.
3.
3.
1.
7,
1.
1.
1.
1.
1.
1.
1.
2.
2.
2.
2.
2.
2.
2.
2.
2.
1.
1503F-04
2377E-04
H7b2F-04
7005F-04
0883F.-04
5260F-04
7710F-04
2129E-04
3509F-04
3680F-04
0849F-04
8294F-04
8408F-04
H740F-04
7377F-04
2bb6p-04
04266-04
17b2F-04
3436F-05
ft94t>F-04
7412F-04
2275E-04
6062F-04
5U5F-04
7b30F-04
9456F-04
1484E-04
30bOF-04
3889f-04
3568F-04
3404F-04
6205F-04
7859F-04
5403F-04
2184F-04
941 1F-04
( 164 )
(164)
(160)
(160)
(Ib9)
(139)
( Ib9)
(143)
(143)
(143)
(143)
(143)
(1 74)
(1 74)
( 143)
(143)
(14J)
(143)
(174)
(174)
(174)
(198)
(198)
(169)
(169)
(198)
(198)
( 19H)
( 198)
(198)
(198)
(?09)
(209)
(209)
( 73)
( 73)
2.1339E-04
2.1301E-04
2.2460E-04
2.9065F-04
3.64H7E-04
3.6168E-04
3.0474F-04
3.4488F-04
3.81 10F.-04
3.4263E-04
2.6667(C-04
1 .7900F-04
1 .8160F-04
1 .9874F-04
1 .7196E-04
1.8867E-04
1.39466-04
9.97P3E-06
2.42S6F-09
6.9644P-07
7.676UE-Ob
1 .8369E-04
2.4835F-04
2.7472F-04
2.9049F-04
2.2540F-04
1.967DF-04
1 .6712E-04
2.1 1 16F-04
2.3790E-04
2.0270E-04
2.0898E-04
2.6567F-04
2.7501E-04
2.6796F-04
2.1902F-04
( 164)
( Ib4)
( 160)
(160)
(159)
( 159)
( 143)
( 172)
(172)
(21b)
(21h)
(174)
(174)
(1 74)
( 139)
(209)
(209)
(209)
( 1 9n )
(209)
(209)
(169)
(169)
(1&9)
( 169)
(169)
(169)
( 169)
( 1 Bl )
(181)
(181 )
(198)
(209)
(209)
( 73)
( 73)
2.0056F-04 (164)
1.975U-04 (164)
2.8772fc-04 (359)
3.U722K-04 (139)
3.4439F-04 (Ibv)
2. 64 9 3F -04 (143)
3.o743fc-04 (1/2)
3. fdlSj- -04 (21b)
3. U93F-04 (215)
3.6087F-04 (237)
3.dbV/h-04 ( 1 /I )
2.6681F-04 (1/3)
1.6582F-04 (201)
1 . /404f -04 (2d2)
1.4bb3F-04 (222)
4. bb 7 IF. -Ob (187)
1.97b2F-Ob (208)
1.2113F-23 (142)
1.0417F-30 ( 1)
4.929br-23 (202)
2.4280F.-Ob (1/8)
1.2bblr-04 (219)
2.7878F-04 (136)
3. 11266-04 (13b)
3.U083f--04 (136)
3.3377F-04 (125)
3./680F-04 (125)
3. 100 IF -04 (12b)
2.2267F-04 (125)
1.V48U-04 (24U)
2. ib02^ -04 ( 1H1 )
2.1477F-04 (Ibl)
1.8636F-04 (20V)
2.5045F-04 (20V)
2.6919K-04 ( 73)
2.4333I--04 ( 73)
-------
TABLE 4
o
NAMt: CLlUr C*EE* POLLUTANT: S02 EMISSION UMTS: <5*/SFC «I« DUALITY UMTS: <5M/M««3
YtAHLY SECOND MAXIMUM 24-HOU« COMC« 3.b934£-04 OIU£CTION« B DISTANCE" 2.3 KM DAY=172
SECOND HIGHEST 24-HOUR CCHCENTHATION AT EACH HECEPTOH
.4 KM .H KM 1.2 KM
1.6 KM
2.3 KM
1
2
3
4
b
b
1
B
9
10
11
12
13
14
1-j
16
17
IB
19
20
21
22
23
24
2b
26
27
28
29
30
31
32
33
34
Jb
it)
,4b70E-04
.5693E-04
.6354E-04
.6Bb3E-04
.7S19E-04
.717VE-04
,b981E-04
1.7068E-04
l./4j7t-04
1.71rs2t-04
1.6/23E-04
1 ,64*bE-04
1 .6194E-04
l.bJ3'it-U4
1 .4368E-04
1 .3622t-04
1 .2991E-04
1 .0592E-04
9.97blt-Ub
1 . 10H4t-04
1.3778E-U4
1 .3349t-.-04
1.7 380t - 04
I . 76*» bt — 04
1 .7b73t-04
1 .97b9E-04
2.101 flE-04
2. 1317L-U4
2.2046E-04
2.217bE-04
2.1273E -04
2.0144E-04
1 » 84 0 7E - 0**
1 ,6294t-04
1 .b33S£-04
1 . J9Sb(- -04
I 12b)
(126)
(126)
(164)
( 12b)
(233)
(160)
(160)
( 1 0(1 )
(160)
(160)
(131)
(131)
(131)
( 131 I
(126)
(126)
(139)
(126)
(19*)
(198)
(198)
(I/*)
( 1 74)
(209)
(209)
<20v)
(209)
(209)
(209)
(20V)
(209)
(209)
( Ib8)
( 19H)
< IbM)
1.4H66E-04 (240)
1.6326E-U4 (240)
1.794HE-04 (233)
1.7b6»E-04 (233)
2.070-JE-04
2.7213E-04
2.746VE-04
3.0192E-04
3.1494E-04
2.9394E-04
2.6033E-04
2.2420E-04
1 .906bt -04
1 .7554E-04
1 . 461 vF-04
1.152U-04
9.9461E-OS
7.B170E-05
b.9rtBOE-05
8. 125911-05
1.1240E-04
1 ,6179fc-04
1.9219E-04
1 .6260E-04
1.4194E-04
143)
159)
143)
143)
159)
1 59)
159)
159)
164)
164)
1S4)
131)
131)
174)
143)
196)
198)
198)
174)
17*)
1/4)
1.7bl7E-04 (209)
1.9b4VE-04 (209)
2.27bOt-04 (209)
2.5b9oE-04 (209)
2.7922E-04 (20V)
2.8312E-04 (198)
2.7466E-04 (198)
2.Sb2oE-04 (198)
2.2223E-04 (198)
1.8419E-04 (209)
1.6127t-04 (Ibe)
1.44blE-04
1.6077F-04
1 ,803bF-04
2.1034K-04
2.9007E-04
2.6820F-04
3.0213E-04
3.0B19F-04
2.3911F-04
2.5479F-04
2.34B1F-04
2.6485E-04
2.b762F-04
2.4B98F-04
2.7043F-04
2.2211F-04
l.SbOOF-04
9.29b3F-()b
3. 1 ?8bF-Ob
2.2213F-Ob
5.4l30F-Ob
1.1164F-04
1 ,4b'3bF-04
1.3667F-04
1.7533F-04
1. /978F-04
1 .89B6E-04
1 .9726F-04
1 .9244F-04
1 ,5>180F-04
2.0438F-04
2.4bOOF-04
2.4947F-04
2.2U24E-04
2. 1 Ub9F-09)
(160)
( 143)
(143)
I Ib9)
(159)
(172)
(172)
(174)
(143)
(143)
(174)
(174)
( 198)
(198)
( 198)
(223)
(198)
(174)
( Ib9)
( 198)
(198)
(240)
(240)
(181)
(181)
(181)
(209)
(198)
(198)
(19tl)
(209)
( IbB)
1.
1 •
1.
2.
2.
2.
2.
3.
3.
2.
2.
1.
1 .
1.
1 •
1.
3.
2.
3.
9.
4.
1.
1.
1.
2.
1.
1 .
1.
2.
2.
2.
1.
2.
£?.
?,
1 .
5H01E-04
b33t>E-04
931bE-04
64'j2e-04
b523E-04
7132E-04
9777F.-04
3852E-04
2563E-04
7H71E-04
3331E-04
4350E-04
4346f>04
6018E-04
04S9E-04
0312E-04
017bF-04
9b34F-04
316/F-04
b260F-04
3S60F-04
6898F-04
( 5)
(233)
(359)
( Ib9)
(160)
(143)
(Ib9)
(143)
(21b)
(172)
(174)
(136)
(136)
(139)
(136)
(139)
(227)
( 198)
(209)
(174)
(169)
(209)
(209)
( 12b)
(12b)
(12b)
(240)
(240)
(240)
(240)
(198)
(209)
(198)
( 1 19)
(209)
( Ib8)
1.6919F-04
1 .4844F-04
2.496BF-04
2.b225K-Ot
2.2428E-04
2.t)4«4h-04
3.0084F-04
3.b934F-04
2.B674K-04
3.2786E-04
3. 191Se -04
2.6169F-04
1.3662F-04
6. /879F-Ob
6.b942t-0b
4.b738i--0b
1.9099F-06
1.2b66F-24
1.04l7t -30
1 .86b'jF-23
2.114,-iE-Ob
1.1969^-04
1. 1306r -04
1 .ObeOF-04
2.8384t-04
2.b866lr-0<»
2.7366t-04
2.66<»1K-04
2.1689K-04
1 . 6869F-04
1 . 71B9K-04
1.7691F-04
1.7297E-04
2.0S03t-Ot
2.->lB9t -04
1 ,633bh -Ot
( b)
(233)
(160)
I 16J)
(14J)
(Ib9)
(143)
(172)
(237)
(171)
(173)
(216)
( 22^ )
(13V)
( 1 4V)
(139)
(18M
(22J)
( 2)
<17d)
(202)
(Ib'b)
(Ibb)
(12b)
(12b)
(136)
(27/1
( 169)
(169)
(181 >
(240)
(240)
( 48)
(198)
(119)
(20V)
-------
TABLE 5
HLAMT NAME: CL1KTY CHEEK POLLUTANT: S02 EMISSION UNITS: GM/SfC AIR QUALITY UNITS: GM/M«»3
MAXIMUM 3--IOUH CONC= 2.4114E-03 DIHKCTION= 24 UISTANCE= 2.3 KM OAY=136 TIME (JEHlOi)= b
HIGHEST 3-HOJK CONCENTRATION AT EACH
HANfiE .4
UIH
1
2
3
4
b
b
7
8
9
10
11
l£
13
1 b
16
17
Id
20
21
22
23
24
2b
26
27
2d
29
30
31
32
33
34
3b
36
1.1371E-03
1 .2124E-03
1.1812E-03
1.1139E-03
1 .0987K-03
1 ,U864t-03
1.0520E-03
1.0279E-03
1.0260E-03
1.0447E-03
1.0560E-03
1.U3V2E-03
1.0100E-03
9.4243E-04
9.3061E-04
9.1b01E-04
8.8S93F-04
8.4bl4E-04
8.6471E-04
1 .0524E-03
1.2122E-03
1.3262E-03
1.3901E-03
1.4114E-03
1 .4031E-03
1.3774E-03
1.3427E-03
1.3031E-03
1 .2b90E-03
1 .2420E-03
1 .2024E-03
1 . 1468t-03
1 . 0549E-03
9.3508E-04
9.7014E-04
1 .Ob7bE-03
KM
(164,
(240,
(240,
(240,
(139,
(139.
(139,
(139,
(143,
(143,
(143,
(143.
(143,
(143,
(139,
(139,
(139.
(139.
(17*,
(174,
(174,
(174,
(174,
(174,
(17*,
(174,
(174,
(174,
(174,
(209,
(209,
(209,
(209,
(139,
(139,
( 164,
4)
6)
6)
6)
4)
4)
4)
4)
b)
b)
b)
b)
5)
b)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
6
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
.6
.2B48E-03
.3061E-03
.1798E-03
.1084E-03
.2302F-03
.2135E-03
.2431E-03
,4bl8E-03
.5096F-03
.b86bE-03
.6288F-03
.6393F-03
.6157F-03
.b881E-03
.5230E-03
.3612E-03
.0557F-03
.3755F-04
.0722F-03
.6129E-03
.H628E-03
.7780E-03
.537bE-03
.3024E-03
.13bbE-03
.0979E-03
.1058F-03
.0903E-03
.0388E-03
.1328F-03
.?934F-03
.3731E-03
.3485E-03
,?120E-03
.027bE-03
.0663E-03
KM
( 164,
(?40,
(240,
(214,
(214.
(160.
(159,
( 159,
(Ib9,
(143,
( 143,
(143,
(143,
(143,
(143,
( 143,
(143,
(143,
(174,
(174,
(174,
(174,
(174,
(174,
(174,
(198,
(198,
(198,
(174,
(209,
(209,
(209,
(209,
(119,
( 73,
(164,
4)
6)
6)
6)
6)
b)
b)
t>)
b)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
S)
b)
b)
4)
4)
4)
4)
4)
4)
b)
4)
1.2
1.3010E-U3
1.2862E-03
1.0870E-03
1.3015F.-U3
1.2669F.-03
1.4b23E-03
l.f21bF-03
1.5667E-U3
1.4730b-03
1 .S921E-03
1 ,87blE-03
2.11H8E-03
2.2727F-03
2.299HE-U3
2.1634F-03
1. 7763E-03
1.3140E-03
7.4J60F-04
b.Hl8bE-U4
1.3bb6E-03
1.3929E-03
8.9311E-04
1 . lb03E-03
1.1869E-03
1.36HOE-03
1.3313F-03
1.2144E-03
1 .2678E-03
1 .3073E-03
1.153b(i-03
9. 2041E-04
1.0113E-03
1.2161E-U3
1.2143E-03
1.0965F-03
9.5600E-04
KM
(164,
(240»
(214,
(214,
(160,
(159,
(159,
(159,
(143.
( 174,
(174,
(174,
(174,
(174,
174,
174,
143,
198,
174,
174,
(174,
(1 74,
(169,
(169,
(169,
( 169,
(169,
(2bO,
(2bO,
(2bO»
(198.
(209,
(209,
(209,
73,
( 164,
4)
6)
6)
6)
b)
b)
5)
b)
4)
b)
b)
5)
b)
b)
b)
5)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
b)
4)
4)
4)
S)
4)
1.6
1.2767E-03
1.1859E-03
1.1925E-03
1.2366E-03
1 .3722E-03
l.b9?7E-()3
1.4699fc-03
I.b0b4£-03
1.7930E-03
1.8719E-03
1.8665E-03
1.4319E-03
1 . 4b2bE-03
1 ,b881E-03
1 .334SE-03
1.230bE-03
6.8408E-04
7.8790E-05
1.940bE-Od
C>.571SE-06
6.l408t-04
1.4648E-03
.8313E-03
.8619E-03
.8820E-03
.5399E-03
.3844E-03
1.2242E-03
1.1312E-03
1 ,2HnbE-0.3
1 .2149F-03
8.9J3bE-(14
9.80b8E-04
1.1965E-03
1.2333E-03
9.6513F-04
KM
(164,
(24D,
(214,
( 160,
(Ib9,
(Ib9,
( Ib9,
(21b,
(21b,
(174,
(174,
(174,
(174,
(174,
(139,
(139,
(209,
(209,
(198,
(209,
(209,
(169,
( 169,
(169,
( 169,
(169,
(169,
( 169,
(240,
(2bU,
(2bO,
(2bU,
(209,
(27r,
(119,
( 7 j,
4(
6)
6)
b)
b)
b)
b)
b)
b)
b)
b)
b)
b)
b)
b)
b)
4)
4)
4)
5)
b)
4)
4)
4)
4)
4)
4)
4)
b)
4)
4)
4)
4)
6)
4)
b)
2.3 KM
1.344bt-03 ( b, b)
1.1672h-03 ( b, b)
1.1509E-03 (214, 6)
l.HB9t-03 (160, b)
1.3799E-03 (Ib9, b)
1.2626E-03 (172. J)
1.477b|--03 (21b, b)
1.4b01E-03 (21b, b)
1.4?b9E-03 (21b. 4)
l.??67£-03 (237. bl
I.b339(--03 (216, b)
1.3169K-03 (216. b)
1.32Dbt-03 (201, 4)
1.3923fc.-03 (222, b)
l.l6blt-()3 (222, b)
3.b6b7t-.-04 (187, 5)
l.b801E-Ob (20», b)
9.b9U2E-23 (142, b)
l.OOOOE-30 ( 1, 1)
3.9437E-22 (21)2, 4)
1.9424h-04 (17b, 4)
1.0121E-03 (219, b)
2.0701E-03 (136, S)
2.4114E-03 (136, b)
2.14bbE-03 (136. S)
I.b418t-03 (13b, b)
I.b94bt-03 (277, b)
1.448bt"-03 (Ib9, 4)
1.3r'46t-()3 (169, 4)
1.0Jti8E-03 (169, 4)
1.0402K-03 (2bO, 4)
I.lb94t-03 ( 66, b)
ti.4l 1 1E-U4 ( b6. S)
1.083dfc-03 (277. b)
1.21b3E-03 (119, 4)
9.8b08E-04 ( 73, b)
-------
TABLE 6
PLANT NAME: CLIFTY c^tt* POLLUTANT: ^02 EMISSION UMTS: Gw/sfC AIH QUALITY UNITS: tiM/M»*»3
»tAMLY SECOND MAXIMUM 3-HOU-? CONC* 1.66blt-03 DlHECTION= 9 OISTANCE= 1.6 KM DAY=174 TIMt PE*100= 5
SECOND HIGHEST
.4 KM
3-HOU3 CONCENTRATION AT EACH WECEPTOW
.B KM 1.2 KM
1 .6
1"
1
2
3
4
b
(,
7
d
9
10
1 1
12
13
1 4
16
1 H
19
20
22
£•3
2b
26
28
?9
C 7
J It
J U
Jl
32
33
34
36
1.11 92E-03
1.12 70E-03
1.0790t-03
1.0286E-U3
9.116 7E-04
9.4416E-04
9.9298E-04
1.003SE-03
9.82blE-04
9.7b93E-04
9.b/12E-04
9. 362bt -04
H.6021E-04
/.bb07t-04
7.009/E-04
'>. /b2bE-04
7.7840E-04
7.4ll*t-04
7.1966E-04
6.6273E-04
7 .818 7E-04
9. 3934 F. -04
1.03(iyE-03
1 . 1 2b 7E-03
1. 17Hbt-03
1. 19lbt-03
1 *2089E-03
1 . 1S03L-03
1 .OB09E-03
* 119701: -04
1.0077E-03
U40.
(164.
(139,
( 139,
(143,
(14J,
(139,
( 139,
( 1 39.
(139,
(139.
(139,
(143,
(126.
(126,
(1/4,
(139.
(139.
(139.
(139.
(209.
(209,
(209.
(209.
(209,
(209,
( 1 74 ,
(1/4,
(1/4,
( 164 ,
( 1 J9,
6)
4)
4)
4) S
6)
6)
D)
b)
4)
4)
4)
4)
4 )
4)
b)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4 )
4 )
4)
4)
4)
4)
4 )
. 1092F-Q3
.197bF-03
.010BE-03
.-J333E-04
.0764E-03
. 1426F-03
. 3486E-03
.4919E-03
.5010F-03
.•J862E-03
.3194E-03
.4007F-03
l.l6b/F-03
1.0034E-03
7./963E-04
b. 3713E-04
3. 3660F-04
4.0679F-04
6.036BE-04
/.0901E-04
6.9241F-04
7.84blF.-04
9,s34bE-04
1 .0408F-03
1 .0044E-03
1.0093F-03
1 .0209F-03
1 . 1667F-03
1.2446E-03
1.33b3E-03
1.2068F-03
9.8263F-04
3.080/O04
(^40, b)
(164, 4)
( 139, 4)
(139, 4)
(160, b)
(214, 6)
(143, 4)
(143, 4)
(143, 4)
Ub9, b)
(164, b)
(164, b)
(164, 3)
(164, b)
(164, b)
(143, b)
(143, b)
(174, 4)
(139, 4)
(??3, 4)
(?23, 4)
(223. 4)
(198. b)
(198, b)
(198, b)
(1/4, 4)
(174, 4 )
(174, 4)
(198, b)
(1/4, 4)
(?33, 4)
(233. 4)
(119. 4)
(?09, 4)
(209, 4 )
(139, 4)
l.lbbOF-03
l.lbbOE-03
1.D100E-03
1 .1414E-03
1.0991E-03
1 .2278E-03
1 .4743E-03
1 ,b407E-o3
1. Ub9E-03
1 .4017E-03
1 .4641E-03
1 .4786K-03
1 .3287E-03
1 .3469F-03
1 .3724E-03
1.364bE-03
1 .2400E-03
5.7019F-04
2.3704E-04
2.2430K-04
7.234/E-04
7. 743HE-04
7.b2??e-04
1.109be-03
1 . 1496E-03
1 .0601E-03
1.01 19E-03
8.8b62E-04
8.99b3E-04
1. 1496F.-03
1.1760E-03
1 .04H1F-03
8.9267E-U4
(240. b)
( 164. 4)
(240. 6)
(160, b)
(214, 6)
(143, 4)
(143, 4)
(143. 4)
(Ib9, b)
(21b» b)
(21b, b)
(21b. b)
(21b, b)
(136, 4)
(136, 4)
(143, 4)
(198, 4)
(143. 4)
(196, 4)
(2?3» 4)
(223, 4)
(169, 4)
(198, b)
(240, b)
(240, b)
(240, b)
(240, b)
(240. b)
(19B. b)
(198, b)
(2bO. 4)
<£!33« 4)
(233. 4)
(119, 4)
(119, 4)
( /3, b)
1 .2bl6F-03
1 .1091E-03
8.7303E-04
1 . I886t-03
1.1231F.-03
1.3424f-03
1.3896E-03
1 . 3/9BE-03
1.66-51F-03
1 .4997E-03
l.lbObE-03
l.llRbE-03
1 . 1 133E-03
1. 1927E-03
1.3328E-03
1. 1441E-03
4.3161E-04
2.B671K-09
7.4/6/E-07
3.870/E-04
1.1286E-03
8.S2tJ/E-04
9,b948(-:-0'»
1.1262E-03
8.4278E-04
9./493E-04
1.0bf2E-03
1.1162E-03
9.84S1E-04
l.l/SOE-03
8.8640E-04
9.7b49E-04
1 .1794E-03
1 .2040E-03
B.2898E-04
( b. b)
( b, b)
(234, 4)
(214, 6)
(160, b)
( 143, 4)
( 14J, 4)
(172, 3)
(174, b)
(21b» s)
(199, 4)
(136, 4)
(136, 4)
( 136, 4)
(136, 4)
(136, 4)
(209, b)
(198, 4)
(209, 4)
(1 74, 4)
(169, 4)
(209. b)
(209, 5)
(12b, 4)
(12b, 4)
(240, b)
(240, b)
(240, b)
(169, 4)
(240, b)
( 66, b)
( 66. b)
(233, 4)
(233, 4)
( 7J, 5)
(164, 4)
1 . 1B331- -03
1 .0489E-03
9. 7J97E-04
1.U1B1E-03
1 . 1234t-03
1 .20411- -03
1 .3907F.-03
1 . J/b3t-03
1.4011t-03
1 .cM)eot-03
1.278c!h-03
1.19b8E-03
1 ,092Vt-03
b.l42-1t-04
b.d607»--04
3.7390t-04
l.b2BOE-Ob
i .()Ob3F.-23
1.0000I--30
1.4924E-22
1 .69l8t-04
9.b7b3t-04
9.0429E-04
1 .1U39K-03
1 .3/B7E-03
1 ,2944h -03
9.4B1 7E-04
9.6944E-04
7 .980 7t-04
1 .1 0/6t-03
7.b4b6t-04
9.0324E-04
1 . 1 7<»^t -03
O.()63bt -04
(164. 4)
(240, 6)
(160, b)
(Ib9. b)
( 14 J, 4)
(Ib*-*, b)
(172, 3)
( 1 74, b)
(237, b)
(210. b)
( 17b, 4)
(211. b)
(222, b)
(139, b)
( 1 39, b)
(139, b)
(187, b)
1^23. b)
( 1.2)
(178, 4)
(202, 4)
(Ib6, 4)
( Ib6, 4 )
( 1 2b, b)
( 1 2b , o )
( 12b, 4)
( 12b, 4 )
(2/7, b)
(240 , })
(240 , b)
(2bO» 4)
( 4B, b)
(233, 4)
(277, 6 )
(166, 3 )
-------
TABLE 7
PLANT NAME: TRIMBLE CNTY POLLUTANT: 502 EMISSION UNITS:
MAXIMJM MEAn) CONC = 3.2795E-06 DIKECTION= 33 DISTANCE= .4 KM
AIR iJUALlTf UiMIlS: bM/M*«J
RANGE
ANNUAL MEAN CONCENTRATION AT EACH RECEPTOR
.4 KM .8 KM 1.2 KM 1.6 KM
2.3 KM
I
I-"
00
01 R
1
2
3
4
S
6
7
6
9
10
11
12
13
10
17
18
19
20
21
22
23
24
2b
26
27
28
29
30
31
32
33
3*
3i>
36
3.21b<»2h:-06
3.1967VE-06
3.08232E-06
3.06*U9E-U6
3.1389bF-Ob
3. 12590fc-06
3.02819t-06
3.U2*36E-Ob
3.02't99E-06
3.03006E-06
3.0823bt-0b
3.0S286E-06
3.069blE-U6
j.ooi iae-06
3.02180E-06
3.0A27bt-06
3.0b2b3E-06
3.07963t'-06
3.oooi4e:-o6
3.00791E-06
3.01100E-06
2. 76794fc'-U6
2.76363E-06
2.91532E-06
2.91029E-U6
2.99271K-06
2.990VOE-U6
2.9053HE-06
2.993U3E-06
3.08877E-U6
3.09033t-06
3. l«llbE-06
3.27954E-06
3.27019E-06
3.2b64lt"-0b
3.23878t-06
3.22819E-06
J.12908E-06
3.082t)9E-06
3.04300E-06
3.09b92E-06
3. 16b58E-06
3.05836E-06
3.U593E-06
3.0b<»b3E-l)6
3.0b398E-06
3.0t261E-06
3.02163E-06
2.88461E-06
2.83672E-06
2.80083E-06
2.69916E-06
2.73507E-06
2.836'tOE-06
2.9325
-------
TABLE 8
*-
PLANT NAMt: TklMMLE CNTY POLLUTANT: S02 EMISSION UNITS! GM/SFC
MAXIMUM 24-hOU* CONC« 4.H041E-05 nlHECTION* 36 UISTANCt= .4 KM DAY* 19
QUALITY UNITS:
HlGMt ST
RANGE .4 KM
01*
1
2
3
4
3
6
7
d
9
10
11
12
13
14
13
16
1 1
Id
19
20
21
22
23
24
d-,
26
27
2b
*!9
30
31
32
33
34
Jb
J6
4.79K3E-03
4. 78fe6E-Ob
4.700bE-Ob
4.6rtblE-Ob
•». 7374E-05
•». 7241E-03
4.6499E-05
"».«i47SE-Ob
4.6S1 IE-Ob
4.66lOE-Ob
4.7102E-05
-».6970E-Ob
4.7202t-0b
4.£'740F-Ob
4.3023E-05
4.3262t-05
4.3490E-03
4. 3625t-03
4 .^Hfe9t-0b
4.280riE-05
4.2667f-0b
3.B217E-Ob
3. 7869E-Ob
3.9190E-05
3.B944E-05
4 . lb93E-Ob
4 . l63bE -03
3 .d7tf OE-U3
4 . 1 739E-05
"».2b77E-Ob
4.2H24E-Ob
4.6706E-03
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
14)
19)
19)
19)
19)
19)
19)
19)
4.77b7E-Ob ( 19)
<..79?6E-Ob ( 19)
4. 602 3t -Ob ( 19)
4 .804 IE-Ob ( 19)
24-rtOUH CONCENTRATION
.8 KM
4. 77w7E — 05
4 . 6994E — 03
4 ,6434E-Ub
4 . bd4 3E — Ob
4.bB70E-05
4.b97*E-Ob
4.5093E-05
4,bbU7t-05
4.499?E-05
4.5227E-05
4.533bE-Ot>
4.b634E-05
4.090VF-05
4.097 7t-0b
4.03H2E-03
3.9445E-05
3.9b83E-Ob
4.ot-()b
4,4b63t'-05
4.5b62E-Ob
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
19)
4.63b3E-Ob ( 19)
4.7377t-03 ( 19)
4.8030E-Ob ( 19)
AT EACH HECEPTO*
1.2
4.67B6F-Ob
4.b905E-05
4.b3BtJF-Ob
4.4803F-Ob
4.4322F-05
4.3621F-05
4.6b23F.-Ob
4.3b37t~-05
4.2606E-05
4.2802F-05
4.1149E-03
4.2312F-05
4.3624E-Ob
4.041 1F-05
3.9182F-05
3.9974E-Ob
3.289lF-Ob
1 ,3bn6F-Ob
3.6b74F-05
3.6739F-05
3.b22bF-Ob
3.2b32F-Ob
2.B930F-05
2.0022E-05
2.3624F-05
2.3992F-Ob
2.b647f-0b
2.68b9F-Ob
2.8lbbF-05
2.77bBF-05
2.h 769F-05
3.3045E-05
3.6073F-05
3.b99bF-Ob
4 . 1 7ifbF-Ob
4.72blt-0b
KM
( 19)
I 19)
( 19)
( 19)
(270)
(270)
(270)
(270)
(270)
(27U)
(270)
( 19)
( 19)
(270)
19)
19)
19)
209)
19)
19)
19)
19)
19)
19)
19)
( 19)
( 19)
( 19)
19)
19)
19)
19)
19)
19)
19)
( 19)
4
4
4
4
4
4
4
7E-05
,Ob93E-Ob
,6S32E-Ob
.061 7E-03
.bO«9E-Ob
.449bE-Ob
.96^0E-Ob
.7740E-Ob
.4279E-05
,4?46E-05
.3937f.-0b
,b() ?3E-Ob
.6790E-05
. ld38F-Ob
. 3979E-05
.1963F-05
.9173F-05
.76U4E-05
. 1 143E-05
.OH22F-03
.llHlH-Ob
. Ort69E-Ob
,b44/F-Ob
. 70M1F-03
.9237F-05
.8520F-OS
.39H9F-05
.bbOOf: -Ob
.6829F-03
KM
( 19)
( 19)
I 19)
(270)
(270)
(270)
(270)
(270)
(270)
(270)
(270)
(270)
(270)
(270)
(270)
(209)
(209)
(209)
( 19)
( 19)
(209)
( 19)
( 19)
( 19)
( 19)
(239)
(239)
(2b9)
( 19)
( 19)
( 19)
( 19)
( 19)
( 19)
( 19)
( 19)
2.3
4.b22bfc -03
4.3322f-0b
4.4060F-05
4.30 7riF -Ob
4. 0501 K -Ob
3.3993f -Ob
3. J2B9K-Ob
3.u698fr -Ob
3.06j7E-Ob
3.0471t-0b
3. Il40h-0b
3.04JJE-Ob
I.b8d2t~0b
1.4l36f--0b
1.442be-0b
1.4609F-Ob
1.4869F-Ob
l.<»446t-0b
1 . 3497K-Ob
1.2227>--0b
1. Ibb4e-0b
1.1646F-Ob
1. J006E-Ob
1.44b4fOb
1 ,64b4f -Ob
1. 72bbF-Ob
1.7017^ -Ob
1 ,3434f -Ob
l.J267F-Ob
1 .4i!43(- -Ob
1 .«318l:-()b
2.7899E-Ob
3.31b4e-0b
4. Irt9rtt- -Ob
4 ,p402h -Ob
4.bO/4K-Ob
KM
( 19)
( 19)
(270)
(270)
(^70)
(270)
( 19)
( 19)
( 19)
( 1 V)
( 19)
( 19)
(270)
(260)
(2bO)
(209)
(209)
<£T09)
(209)
(209)
(2b9)
(239)
(209)
(332)
<3J^>
(33«;)
(332)
(332)
( 73)
( 7 J)
( 19)
( 19)
( 1'y)
( 19)
( 19)
( 19)
-------
TABLE 9
PLANT NAME: THIMBLE CNTY POLLUTANT: sos EMISSION UNITS: GM/SEC AIR OUALITY UNITS:
YtAHlY SECOND MAXIMUM 84-HOU<< CO^C= 4.4336fc-05 I)I^ECTION= « OISTANCE= .6 K* DAY=270
SECOND HIGHEST ?4-HOu
( 85)
( 85)
( 85)
( 85)
I 85)
1 85)
( 85)
1 85)
(870)
(270)
(270)
(870)
3.
3.
3.
3.
4.
4.
4.
4.
4.
4.
4.
4.
3.
3.
3.
3.
8.
2.
8.
8.
8.
8.
2.
2.
8.
2.
2.
8.
8.
8.
2.
8.
8.
2.
8.
3.
.8
4405t-05
688BE-05
8183E-05
9b7bt-05
1 703t-05
3452E-05
302VE-05
433bE-05
35
8.7894^-05 (870)
2.8179F-05 (870)
8.8819E-05 U70)
1.4380F-05 (2bO)
1 .c:44if.-05 (t;09)
1.3744F-05 (20v)
1.3832h-05 (2bu)
1.2618H-05 (2bO)
1.U11E-05 (I9b)
1.1032F-05 (198)
1.1315E-Ob (c;5-y)
1.1)8931- -05 (209)
9.b7tbt-0b (209)
1.1920F-05 (2D9)
1.3768I--05 ( 73)
1.3bb7F-05 ( 73)
1.3549fc-05 ( 73)
1.3b94c-05 ( 73)
1.3751H-05 ( 73)
1.2520f--05 (332)
1. 4007 K -Ob (239)
I.b047e>05 (2 = 9)
1.7H79K-05 ( 8b)
2.U918K-05 ( 8b)
2.4b09F -05 ( 85 )
2.5254F-05 ( 85)
3.1367F-05 (270)
-------
TABLE 10
ANT HAMt : TklMHLE CNTV ^OLLOTANT: S02 EMISSION UNJTS: GM/SFC AIH QUALITY UNlTb-*
MAX1MJM .1-HOUK CWC* 1.093b£-04 UIHECTION« 7 DISTANCES 1.2 KM |)Af=270 II Mt H£HIO\) = H
3-HOJM CONCENTRATION AT EACH HECEPTOH
.H KM J.2 KM
1 .0 KM
2.3 KM
1
2
3
4
5
b
J
B
9
10
1 1
12
1 »
14
1 >3
16
1 7
18
19
20
21
22
23
24
23
26
27
28
29
30
31
32
33
34
32
36
9.3722E-05
9.4601E-Ob
9.41Q8F. -Ob
9.b03vt-0b
9.7940E-05
9.S972E-05
9.9lHb£-Ob
9.9577t -05
9.97 J4t-05
9.967U-05
9.9bOOfc'-OS
9.B743E-05
9.7/33E-05
9.4191E-05
9.4274E-05
9.39ll3t-0b
9.299bE-Ob
9.t4 19L-06
9.4lhf)E -05
9.5313E-05
9.5969E-05
9.U387E-05
9.0336E-05
9.394QE-05
9.3632E-05
9,b2b3E-05
9.bObbE-05
9.30S7E-05
9.4903E-05
9.67bbE-05
9.6623E-U5
9.til77E-Ob
9.8392E-05
9.b946E-Ob
9.5093F-05
(333.
(3)3,
19.
19.
1^,
19,
19.
1 w,
19.
19,
19.
( 19.
( 19.
(333.
(333.
(333.
(333.
( bb.
( Bb.
( 8b.
( B5.
( 8b.
( 8b.
( Bb.
( 8b.
( «S»
( 8b,
( 85,
( bb.
( 85,
( Hb.
( 8b.
( 8b.
( 8S,
I Bb,
( 8b.
1)
1)
/)
7)
7)
7)
7)
7)
7)
7)
7)
7)
7)
1)
1)
1)
1)
6)
6)
6)
b)
b)
bl
6)
6)
*>)
b)
b)
b)
b)
b)
b)
6)
b)
b)
6)
9.3909E-05
9.6706F-05
9. 961bE-03
1 .0095E-04
1.0155E-04
U0144F-04
1.0007F-04
9.9920F"Ob
9.9199E-Ob
9.9594E-05
1.0023E-04
I .01 10F-04
8.7792F-05
B. yb9bE-Ob
9.079HE-0'J
8.9720E-05
8.9268E-05
rt .9963F-05
9.4b29F-OD
9.7454F-05
9.5527F-05
9.2430E-05
9.2056F-05
8.224UF-05
B.6235F-05
9.42bOfc'-05
9.4032F.-05
9.5933E-OS
9.5b55F-Ob
9.4996P -Ob
9.5577F-05
9.6035F-Ob
9.7037F-Ob
9.6bllF-Ob
9.b863F-Ob
9.4382E-05
333.
19,
19,
!"*•
19,
19,
19,
19,
19,
19,
19,
( 19,
(333,
(333,
(333,
(333,
(333,
I 85,
( 8b«
( 85,
I 85.
( fl5,
( 93,
( 93,
( 93,
( 93,
( 93,
( 93,
( 93,
( 93,
( 93,
( Hb,
( Hb,
( Hb,
( Hb,
( 85,
1)
n
7)
7)
7)
7)
7)
7)
n
7)
7)
7>
1)
1)
n
1)
1)
fa)
6)
b)
b)
b)
2)
2)
2)
2)
2)
2)
2)
21
2)
b)
b)
b)
b)
fe)
9.4422E-05
9.9339F-Ub
1 .0099E-04
".953bE-Ob
9.9bOlE-Ob
.0054^-04
.093bF-04
.0391t-0<»
.0458E-04
.04POE-04
.(1311E-04
.0130F-04
9. 7008F-Ob
R.94«»OE-Ob
8.4960t-U5
9.0301F-Ob
7.92HBE-Ub
7.9bb3F-05
9.2194E-05
9. lOObf -Ob
9.0739b-05
9.07H9F-05
8.6550E-05
7.4694F-05
7.55MF.-05
7.7794F-05
a.l24HE-Ob
8.4185E-U5
8.6253K-Ob
8.2991F-05
8.U997E-05
fl.6b87F-05
8.6840F-05
8.7133E-05
9.1291F-05
9.19bOE-05
( 19,
( 19.
( IV.
( 19,
(270,
(270.
(270.
( 19,
19,
19,
19.
19.
19,
19.
(333.
(333.
(333,
(277.
( Hb.
( Bb,
( 93.
( 93,
( 93,
(277,
( 93,
( 93.
( 93,
( 93.
( 93,
( 93.
( 93.
( 93.
( 8b.
I 85.
( 85.
( 85.
7)
7)
7)
7)
8)
B)
8)
5)
b)
b)
b)
b)
5)
5>
1)
11
1)
b)
bl
b)
2)
21
2)
b)
2)
2>
21
2)
2)
2)
2)
21
b)
6)
bl
b)
9.6154F-Ob
9.9b31f-0b
9.8414E-05
,0l4b£-04
.0891E-04
,064bE-04
.OH01E-04
. 092
6.7 J78E-05
5.9353£-Ob
5.87b»E-05
6.9049E-05
7.07b3t-0b
8.0722E-05
8.3943F-Ob
8.b07^t-0b
9. 34 35F.-Ob
9.3S88E-05
9,S7MbK-05
9.U420E-05
< 19,
I I9t
( 19,
(270,
(270,
( 19,
( 19,
( 19,
( 19,
( 19,
( 19.
( 18d,
( 1HB,
( 19,
(2bO,
(2bO,
(2bO,
(277,
(277,
(277,
(277,
(27?,
( 93,
(104,
(104,
(259,
(259,
(259,
(104,
I 93,
93,
93,
93,
83,
bb,
Bb,
n
7)
71
B)
B)
b)
*>>
b)
5)
5)
5)
4)
4)
5)
4)
4)
4)
b)
b)
61
b)
b)
2)
3)
3)
4)
4)
4)
3)
2)
21
2)
2)
b)
b)
bl
y
9
I
1
1
1
1
V
1
9
9
I
b
0
«
b
b
b
6
8
7
b
b
b
6
b
b
b
b
b
b
7
a
9
9
8
.blBVt-U5
.7753E-05
.04UK-04
.Ob93t-04
.Os2bt-04
.0203t-04
.02»Ut-04
. 74'«
(270.
(270.
( 19,
( 19,
( bH,
( bB,
( b8.
I 68.
( bd.
( 19,
(18d.
(188,
( Ittrt.
(260,
(260,
(277,
( 2 / 7 ,
(277,
<27/,
(^59,
(2b9,
( 73,
( 73,
( 7.1,
( 73.
( 73,
( /J.
( 73.
( 104,
( 93,
( 93.
( 93,
( a1},
( Hb,
7)
7)
8)
8)
bl
b)
8)
HI
8)
8)
8)
5)
4)
t)
4)
4)
4)
b)
6)
b)
b)
4)
4)
7)
7)
7)
7)
7)
7)
7)
3)
2)
2)
2)
6)
b)
-------
TABLE 11
HLANT NAME: TRIMBLE CNTY ->OLI.UTANT: 502 EMISSION UNITS: GM/SEC /uw QUALIFY UNITS: &M/M«»3
YEARLY SECOND MAXIMUM 3-HOU^ CONC= 1.0606E-04 DIPECTION= 6 DlSTANCE= 1.6 KM DAY=270 TIMF PfcXIO()= 8
HANliE
SECOND HIGHEST
i KM
3-HOU3 CONCENTRATION AT EACH RECEPTOR
.8 KM 1.2 KM
2.3 KM
1
2
3
4
6
7
8
9
10
11
12
13
14
lb
16
17
Id
1 9
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
3b
36
9.2B97E-Ob
9.2085E-05
9.3467E-OS
9.3605E-05
9.bl44E-OS
9.49/5E-05
9.3210E-05
9.3188E-05
9.33blE-Ob
9.3717£-0b
9.508HE-05
9.4Hfl3£-05
9.b480E-Ob
8.4317E-05
8. 7038E-05
ri.974bE-Ob
9.2262E-05
9. 153bE-Ob
B. 7953E-05
8.bb66E-Ob
8.3180E-05
8.175BE-05
8.1754E-05
8.4438E-05
8.5310E-05
8.7660E-OS
8.7b41E-Ub
8.5289E-05
d.b329E-05
8.6873E-05
8.b021E-05
8.4448E-05
0.6439E-05
8.8663E-05
9.0696E-05
9.Z411E-05
( tib,
( 19,
(333,
(333,
(333.
(333,
(333.
(333.
(333,
(333,
(333,
(333.
(333,
( 8b.
( 8b.
( 8b,
( rtb,
(333.
(333,
(333,
(333,
(277,
(277 ,
( 93,
( 93,
( 93,
( 93,
( 93,
( 93,
( 93,
( 93,
( 93,
(333,
(333,
(333,
(333,
6)
7)
1)
1)
1)
1)
1)
1)
1)
1)
1)
1)
1)
b)
6)
b)
b)
1)
1)
1 j
1)
6)
6)
2)
2)
2)
2)
2)
2)
2)
2)
2)
1)
1)
I)
1)
9.
9.
9.
9.
8.
9.
9.
9.
9.
9.
Ob
MOOF-Ob
H095E-Ob
3706F-Ob
r4H9(r_05
471 OE-Ob
52:j3F-Ob
9872E-Ob
0641E-Ob
9774F-Ob
079bE-Ob
9861E-Ob
5363E-Ob
4927E-Ob
7150E-Ob
9491F-05
0388F-Ob
4238F-Ob
2979E-05
8976E-Ob
3501E-05
7b92F-Ob
1921E-05
( 19,
(333,
(333,
(333,
(333,
(270,
(270,
(270i
(270,
(270,
(270,
(270,
(270,
(260,
(260,
( 85,
( Hb,
(333,
(3.33,
( 93,
( 93,
( 93,
( 85,
(277,
(277,
( 85,
( 85,
85,
85,
85,
85,
93,
93,
93,
333,
333 i
7)
1)
1)
1)
1 )
8)
8)
8)
d)
8)
8)
8)
8)
4)
4)
6)
6)
1)
1)
2)
2)
2)
6)
6)
6)
b)
b)
6)
6)
b)
b)
2)
2)
2)
1)
1)
9. 1981E-05
9.0441E-05
H. 7369E-05
9.3H54£-Ob
9.5618E-OS
9.8370E-OS
1 .0316F-0*
1 .0283F-04
1 .0069E-04
1.0081E-04
9.581 3E-05
9.7286F-05
9.47bbE-Ob
B.b39bE-05
8.036SE-05
7.9079E-05
7.9079E-05
7.0013E-05
R.b304E-Ob
8.6495E-05
fl.8422E-Ob
8.2381E-05
7.9034E-05
6.7322E-05
7.3022E-05
7.4090E-Ob
7.7028E-05
7.8790E-05
7.9155E-OS
7.4588E-Ob
7.3886E-05
8.1069£-0b
8. bib 3E -05
7.9034E-05
8.031bF-05
8.9928E-Ob
(333,
(333,
(333,
(270,
( 19,
( 19,
( 19,
(270,
(270,
(270.
(270,
(270,
(270,
(270,
(260,
(260,
(277,
(260,
(277,
(277,
( 85,
(277,
(277,
(259,
(277,
(104,
(104,
104,
104,
104,
277 ,
85,
93.
( 93.
(333,
(333,
1)
1)
1)
8)
7)
b)
b)
8)
8)
8)
8)
8)
8)
8)
4)
4)
6)
4)
b)
6)
6)
61
6)
4)
6)
3)
3)
3)
3)
3)
6)
b)
2)
2)
1)
1 )
9.
8.
9.
9.
1.
1 .
1.
1.
9.
8.
8.
7.
7.
9.
7.
6.
7.
7.
b.
7.
7.
6.
7.
6.
b.
b.
5.
b.
6.
7.
7.
7.
8.
9.
8.
8.
0324E-05
45rtbE-Ob
4139E-Ob
63b2E-Ob
0349E-04
ObOf>E-04
0389E-04
0403E-04
831PE-Ob
7b40E-Ob
4377E-Ob
3466e:-os
7308E-05
OllbE-05
4777E-06
9251E-Ob
bOObE-Ob
1228E-Ob
9326E-05
0314E-Ob
0333E-Ob
8620E-05
3797E-05
7295E-05
2970E-05
8224E-Ob
7322F-Ob
8b4lE-Ob
9449E-05
8223E-OS
7498E-Ob
bObOE-Ob
b366E-Ob
0741E-05
2l46E-Ob
8691E-Ob
(333,
(333,
(270,
( 19,
( 19,
(270,
(270,
(270,
(270,
(270,
(207,
(260.
(260,
(270,
( 16d,
(188,
(277,
( 198,
(198,
(2b9,
(259,
(259,
(104,
( 93,
( 93,
(277,
(277,
(277,
( 93,
(104,
(104,
(104,
( 8b,
( 93,
( 93,
(333,
1)
1)
8)
b)
b)
8)
6)
tt)
8)
8)
3)
4)
4)
8)
4)
4)
b)
3)
3)
4)
4)
4)
3)
2)
2)
b)
b)
b)
2)
3)
3)
3)
b)
2)
2)
1 )
8.7770t-0b (333, 1)
9.20B6E-05 (e;70, H)
9.7934t-05 19, b)
1.04b9F_-0•* 14^-05 ( 68, 8)
6.87()5E-Ob (260, 4)
7.4b76t-0b (260, 4)
8.04H5E-05 (260, 4)
7.7080E-05 (188, 4)
7.4fa30E-Ob (277, 6)
7.36b2E-Ob (19P, 3)
7.1440t:-0b (2b9, 4)
7.2272E-05 (259, 4)
6.8171E-05 (259, 4)
6. Obi 7t-05 1277, 6)
b.lb4«E-Ob (277, 6)
5.9104E-05 (lOb, 3)
6.0940E-05 (105, 3)
b,1044t-0b (lOb, 3)
b.9b89E-Ob (lOb, 3)
b.683lE-05 (lOb, 3)
5.2474E-05 (105. 3)
5.4bl8t-05 (104, 3)
b.lb97h-0b ( 93, 2)
7.fal43E-Ob (104, 3)
7.7872E-Ob (104, 3)
8.9117E-05 ( 3b. b)
8.4582E-05 ( 93. 2)
rf.6b41t-0b (333, 1 )
-------
TABLE 12
NAME: THIMBU CNfY -JouufANT: S02 EMISSION UNITS:
YtARLY MA*|M,J* 3-MUUH CONC* 1.0968--04 DIRECTIONS 7 DISTANCE* 1.2
3-HOJH CONCENTRATION AT EACH RECEPTOR
GM/SEC
KM i)AY =
QUALITY UNITS: UM/M««3
TlMt Pfc'Hl<>0 = 8
HANCiE .4
DIP
1
2
3
it
b
b
7
n
9
1(1
11
£k ' ^
1 13
£ >«
lb
16
17
18
19
21)
d\
22
<-3
24
2b
26
27
28
l2bt.-04
,009f>E-0'*
.OlObt-04
.01 12t -04
.01 17t-04
.Ol44t-04
.0b
7.9340E-Ob
7 ,896b(-.-Ob
7.B494t.-Ob
7.7809t -Ob
H.()4Sbt-Ob
8.393<»t-0b
H.71Mt-Ob
V. 1)26 It -05
9.3132E-Ut>
KM
I lv.
< 19.
19,
19.
19.
19.
19.
19.
19,
19,
19.
1 V.
19.
(2/0.
(2/0.
(2 1(1 .
C 2 7 7 ,
(277.
(277.
(277.
(2 7 / ,
(2 / / »
(2V / ,
(277.
(277.
(277.
(277,
(277.
(2/7,
(277,
(27 /.
( 19.
( 19.
( 19.
( 19.
( 19.
7)
7)
7)
7)
7)
7)
7)
7)
7)
7)
7)
7)
7)
4 )
4)
4 )
b)
b)
01
b)
b)
b)
b)
b)
6)
b)
b)
b)
b)
b)
b)
7)
7)
7)
7)
7)
9
1
1
1
9
g
V
1
9
9
9
7)
b)
it)
b)
U)
b)
8)
7)
b)
b)
b)
4)
b)
b)
b)
b)
b)
b)
b)
b)
b)
b)
b)
2)
2)
b)
b)
b)
b)
7)
7)
7)
1.2
9.8532E-05
1.0037E-04
9.89H6E-Ob
9.9487E-OS
.0314E-04
.0280F-04
.0968F.-04
.Obb^E-04
.0706F-04
.0747E-04
1 ,Ob4"JF.-04
1 ,Ob74F-04
1 .0299K-04
9. 7170F-Ob
H.8l40fc"-Ub
7 . 71b9F -Ob
7.4352F-Ob
7 .6192F -Ob
«.3999F-Ob
«.b621f -Ob
P.bb59F-Ob
H.3972F-Ob
8.1479F.-Ob
7.7693F-Ob
7.b3bbF-Ob
7.494Hh"-Ob
7.4240F-OS
7.bl71F-Ob
7.6282F-Ob
7.4856E-Ob
7.b360E-Ob
7.b968F-Ob
7.Sb99F-Ob
7.430bt-0b
7.2lb3t"-0b
9.281 fK-Ob
KM
( 19,
( 19,
( 19.
(270,
(270,
( 19.
(270.
I 19.
( 19.
( 19.
( 19,
( 19.
( 19.
( 19.
( 19,
( 19,
(277,
(277,
(277.
(277,
(277,
(277,
(277,
(277,
(277.
(277,
(277.
( 19,
( 19.
(277,
(277.
(277,
(277.
(27/.
(277,
( 19.
7)
7)
7)
8)
H)
b)
8)
b)
b)
b)
b)
b)
b)
S)
b)
b)
b)
b)
6)
b)
6)
6)
6)
b)
b)
6)
6)
2)
2)
6)
6)
6)
6)
6)
6)
7)
I .6
9.9107F-Ob
9.8b24E-Ob
9.V3b3E-Ob
.03ME-04
.0799E-04
.0703E-04
.0/30E-04
.0769E-04
.0704E-04
.Ob84E-04
9.0942E-Ob
3.923bE-05
S.4999t-0b
1.0b97F-04
b.3321E-Ob
6.1619E-Ob
7.0167F-Ob
7.73SOE-Ob
8.3l44F-Ob
8.4433F-Ob
8.0793F.-05
7.8399E-Ob
7.6131E-Ob
7. ^SbE-OS
6. /663E-05
6.309vE-Ob
6.2034E-OS
6.3012E-Ob
b.6389F-Ob
7.blS4E-Ob
7.bbb9F-OS
7.3b99E-Ob
7.89-i3E-Ob
7.3920E-Ob
8.0blOE-Ob
9.2b8^F-Ob
KM
( 19, 7)
( 19, 7)
(270, 8)
(270, 8)
(27J. «)
19, b)
19, b)
19. b)
19, b)
19, b)
19, b)
1 74, 4)
(270, 8)
( 19, b)
(277, b)
(277, b)
(277, 6)
(277, b)
(277, b)
(277, 6)
(277, 6)
(277, b)
(277, b)
(277, 6)
(277, b)
(277, b)
(277, b)
(277, b)
(277, t>>
( 19, 2)
( 19, 2)
( 19, 2)
( 19, 2)
( 19, 2)
( 19, 7)
( 19, 7 )
2.3 KM
9.9231t;-0b
9./367t-Ob
1 .0483E-04
1.04b9E-04
1 .028bE-04
1.0212F-04
1 .0134E-04
9.49b6E-Ob
9.b«bbh-05
9.b210E-Ob
9.bb47E-05
9.0433t-0b
b.2b2flt--0b
3.433bE-05
4.0 /87t-0b
b.4b88t-0b
b.rt9«3f.-0b
B.0280t-0b
8 ,3b30t-0b
«. JlbU-OS
/.b403f>0s
b.b39rtt -Ob
b.7784t-0b
b.u8/2F-nb
4,bbc?t>t-0b
4 .^924t-05
b.bb02t-0b
4.429bfc-0b
4.77blh-0b
b.304UE-05
6.0b87t-0b
7.-*5/bt-Ob
7.8700E-Ob
B .09Sat-Ob
7 . 4b74t -Ob
9. 209 Ot -Ob
( 19,
(270,
(27o,
( 19.
( 19,
( b8.
( 68,
( b8.
( 68,
( 68,
( bd.
( !•>«
( b8.
( b8.
(277,
(277.
(277,
(277,
(
-------
TABLE 13
PLANT NAME:
:Ai-»LV SECOMi)
KANCiE
CNTY 301.1UTANT: S02 EMISSION UNITS: GM/SKC AIR OUALITY UNITS! GH/M««3
3-HOIH CONC= l.U6bbE-04 DI»ECTION= 7 DISTANCE= 1.2 KM DAY= 19 TlMl- PErtIOI) = b
SECOND HIGHEST
.4 KM
3-HOLP CONCENTRATION AT EACH RECEPTOR
.8 KM 1.2 KM
1 .b KM
2.3 KM
1
rf
3
4
^
O
7
8
9
10
1 1
12
*• 13
H 14
* Ib
Ib
1 7
Irt
1 v
2i)
21
22
23
24
at>
c O
di
r, ri
29
30
31
32
33
34
3b
3b
7.
7.
7.
7.
B.
8.
7.
7.
7.
7.
-t.
7.
7.
h.
7.
7.
7.
/.
7.
fi.
ft.
6.
b.
b.
b.
b.
b.
b.
b.
6.
•H.
7.
7 .
7.
7.
7.
731bE-Ob
B437F-Ob
7btBE-Ob
B293E-U5
04b3E-Ob
079bE-Ob
9294E-05
945^E-05
9b72t-'Jb
9bb0t-0b
Ob84t-0b
9bCit>t -05
9S04£-Ob
9 7ebt-0b
1497E-05
323HE-Ob
491bE-Ob
Jb36E-05
u330E-Ob
4bl 7F.-OS
b849E-Ob
3079E-Ob
3176E-05
b22bE-Ob
bbblE-Ob
786bt-0b
79P9E-05
b9blt:-0b
bBOBE-Ob
7143E-OS
b44bt-0b
709HE-05
6246E-05
blb3E-05
4423fc -05
b9b7t-0b
(270,
(27u •
(270 ,
(270.
(270.
( 2 7 0 .
(270,
(270,
(270.
(27(J ,
(270.
(270,
(27i),
(?77,
(27 ?,
(2/7.
(270.
(27l».
(270.
(270.
(270.
19.
19,
19,
19,
19,
( 19.
( 19,
( 19,
( 19,
I 19.
(til.
(t 1 7,
(277,
(27(),
(270,
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
ft)
4)
b)
b)
b)
4)
4)
4)
4)
4)
4)
4)
4)
2)
2)
2)
2)
2)
2)
4)
b)
b)
ft)
4)
4)
7.
7.
8.
8.
9.
9.
9.
9.
9.
9.
^.
9.
8.
8.
7.
7.
b.
b.
b.
b.
6.
7.
7.
b.
7.
7.
7.
7.
7.
7.
7.
7.
7.
7.
7.
7.
H667F-Ob
9409E-05
0368E-Ob
&028F-05
2489F.-Ob
7aOOE-Ob
5496E-Ob
6612E-Ob
7117E-Ob
70bbF-Ob
5713E-Ob
4631E-Ob
7333E-Ob
j HfcF -Ob
517bF-Ob
lObBF-Ob
9b24F,-Ob
BHb3E-Ob
7132E-05
i99bfc-0b
b4B9E-Ob
1046E-05
3b20F-Ob
bBl 2E-Ob
Oi;98F-Ob
8412F-Ob
H472E-Ob
9488E-Ob
9101F-05
B238E-Ob
793bF_-Ob
4bl4F-Ob
271 IF-Ob
b!20E-Ob
3193E-Ob
b252F-Ob
(270,
(270,
(270,
(270,
(?70,
( 19,
( 19,
( 19,
( 19,
( 19,
( 19,
(270,
(270,
(?70,
(270,
(277,
(270,
(270,
(270,
( 19,
( 19,
( 19,
( 19,
( 19,
( 19,
( 19,
( 19,
(?77,
(277,
( 19,
( 19,
( 19,
( 19,
(277,
(277,
(270,
4)
4)
8)
B)
b)
7)
7)
b)
b)
b)
b)
8)
B)
B)
4)
b)
4)
4)
4)
4)
2)
2)
2)
2)
2)
2)
2)
b)
b)
,;)
2)
2)
7)
0)
b)
4)
7.B096E-05
fl.0408F-Ob
9.1101E-OS
9.4913E-Ob
9.9320E-05
1 .0232F-04
1 ,Obb6E"04
1.0220E-04
9.9678F-05
Q.99blE-Ob
9.57bOE-Ob
9.8b7bF-05
Q.79b8E-Ob
9.1658E-Ob
8.064bE-Ob
7.38o7F-Ob
6.l772E-Ob
4.8b38E-Ob
6.3993E-Ob
6.<»521E-Ob
7.l7b2E-Ob
7.4402E-05
7.28BbE-Ob
5.4b49E-Ob
6.b729E-Ob
6.8816E-Ob
7.2568F-05
7.4l20E-Ob
7.4465E-Ob
7.1642E-05
b.8l28F-05
7.1807E-Ob
6.9b29E-Ob
6.179bF-Ob
6.b969F-05
7.49S6F-Ob
(270,
(270.
(270,
( 19,
( 19,
(270,
( 19,
(270.
(270.
(270.
(270,
(270,
(^70,
(270,
(270,
(270.
( 19.
(174,
( 19,
( 19,
( 19,
( 19,
( 19,
( 19.
( 19.
( 19,
( 19,
(277.
(277,
( 19,
( 19.
( 19,
( 19,
1 19,
(270,
(270,
4)
8)
8)
7)
b)
8)
b)
8)
B)
8)
8)
8)
8)
8)
8)
4)
b)
4)
4)
2)
2)
2)
2)
2)
2)
2)
2)
6)
b)
2)
2)
2)
2)
2)
4)
4)
7.80b7E-Ob
8.4347E-Ob
9.3S9bE-Ob
1.0087K-04
1.058bE-04
1.02b?E-04
9.8b79E-Ob
9.7370E-Ob
9.b9b2E-Ob
8.80b4E-Ob
7.361BE-05
3.8b28E-Ob
b.0726E-Ob
9.1266E-Ob
4.5302E-Ob
2.6b01E-05
2.4bbOE-Ob
2.4b24E-Ob
4.9b67E-05
4.89S?E-Ob
4.7790E-05
4.b299E-Ob
6.64bbf-05
6.214bE-Ob
b.9b53E-Ob
4. 1 138E-Ob
4.0b48E-Ob
4.052»F.-Ob
b.b4»5E-Ob
b.8883E-Ob
7.1174£-0b
7.30e>6E-Ob
7.4394E-05
7.3897F-Ob
7.1b22E-Ob
7.4421f-0b
(270,
(270,
( 19,
( 19,
( 19,
(270,
(270,
(27o.
( 68,
( 6B,
( 68,
( btt.
( 68,
(270,
(174,
(270,
(270,
( 19,
(174,
( 1 7<» ,
( 1 7<» ,
(174,
( 19,
( 19,
( 19,
(17*,
(17*,
(174,
( 19,
(277,
(277,
(277,
(277,
(277,
(277,
(270,
4)
8)
7)
b)
b)
8)
8)
8)
8)
B)
8)
B)
8)
H)
4)
4)
4)
4)
4)
4)
4>
4)
2)
2)
2)
4)
4)
4)
2)
6)
b)
b)
b)
b)
b)
4)
8.0083E-Ob (270, 8)
9.J41bE-Ob ( 19, 7)
1.0119t-04 ( 19, b)
1.0192E-04 (270, 8)
9.766bE-Ob ( 68, 8)
9.824bE-Ob ( 19, b)
9.49lOK-Ob U70« b)
B.9712E-U5 ( 19. b)
9.1279F-05 (270. b)
9.0l67E-Ob (270. 5)
9.2137E-Ob ( 19, b)
9.<*494E-Ob ( 68, 8)
4.2b91E-Ob (270, 5)
3.1819f--0b (Ib9, b)
3.07«9t-0b (169, 5)
2.72blE-Ob (Ib9, 5)
2.23b2E-Ob ( 19, 4)
2.318bE-Ob ( 19, 4)
2.3810E-Ob ( 19, 4)
2.23b7£-0b ( 19, ^)
2.2bb7t-0b ( 19, ?)
4.jr>90E-Ob (174, 4)
4.0649K-Ob (174. 4)
3.80b2E-Ob (174. 4)
3.6114t-0b (174. 4)
3.491bt-0b (17t. 4)
4.2bBlE-Ob (277. b)
3.4bbOE-Ob (17*. 4)
3.bb84E-Ob ( 19. 2)
4.b763E-Ob ( 19. 2)
b.9209E-Ob (277, 6)
b.b264L-Ob (277, b)
b.9711E-Ob (277, b)
7.169bE-Ob (277, b)
b.*900E-Ob (277, b)
7.3445E-Ob (270, 4)
-------
TABLE 14
CUm CREEK
Y^ API. 1 MAXJMJU 3-HUU* CHNC =
-MILITANT: $02 EMISSION unps:
24 DISTftNr;t = 2.3
UNIT
TIMt
ir b
h 1 v
t t> t
3-HOJW CONCF^TPATION AT EACH
KANOc" ,4 KM .* KM
!>IW
I
2
3
4
w,
tl
^
9
10
1 1
12
1 j
t 14
to is
° 16
I/
Irt
20
21
22
23
2b
2/
2^
30
31
32
3 t
34
3b
1 . 1 JMt -o )
1 . 1 2 7 fit -03
4.43^ If -04
8.44»i5t- -04
H.04 I6K -04
H.87MHt -04
'•».441bl: -04
9.-v2vHh -04
1 . fi 2 6 0 i-. - 0 3
1 ,044 /t-03
1 . Ob60b -03
1 . 0 392t-03
I . 0 1 out -0 J
9 .4^4 3t -04
H M)21t-04
7.4H?9t -04
6. 1 ?'t -04
6. 7b2bt -04
H, 147 It -04
1 .Ub24t -03
1 ! J2>">2t-0 J
1 . 39olt -03
1 .4 03 It -03
1 ..'342/K-03
1 ./"b90l- -0 J
1 .^i)f"«t -03
1 . Ib03t -03
1 . OM09F-U3
9. 99h'it -04
9.0793F -04
9.0979t -04
1 . Ob7bt -03
( 104.
1*34 ,
i b4 ,
1 t>4 ,
i 4 J ,
14.).
14 t.
14 J,
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(143.
1 1 •» 3 «
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( 1/4.
(1/4.
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I 1 /4 ,
(1/4,
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(1/4.
(1/4.
( 1 74.
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(1/4,
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4)
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9
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1
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. 19/bf -03
. 32/bf -04
.04 1 7K-04
, 7204(r'-04
.039JF-03
. -"43IF-03
.4(1 1 OF -03
.•J096F-OJ
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. 7&B1E-03
. o230F-0 1
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. t)62nF-03
. //bOF-03
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.0044E-03
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. 360hF-04
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(164.
(164.
( 1 f-4 «
(143,
( 143,
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(143.
(14J.
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(1/4,
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(174,
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. lbSOE-03
.20696-04
.6963F-04
.0944E-03
,4b23F -03
. /2 151: -03
.4/30E-03
,H7blF-03
.1 188F-03
,272/F -0 J
.2992F-03
. 1634F -03
.7763F-03
. 3140F-03
. /019F.-04
.HlHbF-04
• -3j^nh ^U.*
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,lb03F-03
, ld69F-03
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•2144F-03
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. 32 79f -04
t 7Hf>r>E -04
.9942F-04
.b(J7HF-04
. Jbhlf ->U4
.2490F-04
,b600F-04
KM
(164,
( 1 4 3 .
(143,
(159,
( Ib9,
( Ib9.
Ub9.
( 143.
(174,
( 174,
(174,
(174,
( 174,
(174.
( 1 74,
(143,
( 143.
(174.
( 174,
(1/4,
(174,
(169.
(169,
(169.
( 169,
( 169.
(169.
(169.
(174,
(174.
(174,
(174,
(174,
( 174,
(164,
4) 1
4)
1 .6
,2/b7F-03
,03Hbf-03
b) 6.9S31E-04
b) '
51
b)
b)
b)
41
b)
b)
b)
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b)
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4) <
4)
i. 3rtb8P-04
. 3722E-03
,b9?7f-0 3
.4699E-03
.SOb4E-03
.79JOF-03
.H719E-03
.H665F.-0 J
.4319E-03
.4b2bE-03
.bWrtlE-03
. 332ME-03
. 144U-03
?,21 36E-04
1.3136E-06
4) 6.1909F-10
4) 7.47«,7fc-07
») 3.H707E-04
4)
4)
4)
4)
4)
4)
4)
4)
4)
1 .4646E-03
1 .H313E-03
I.H619E-03
. .8H20F -03
l.b399E-03
I ,3«44£-03
1.2242E-03
1 . I 162E-03
-t.bbHbf -04
4) S.7130E-04
4)
3,b4l4F-04
41 L*.126?F-04
4)
1 . 19bbE-03
4) 9.3467F-04
4) fc.289«E-04
KM
(1^4,
( lt)4.
(143,
{ 1 HO _
I 1 l_ U _
(Ib9,
(Ib9,
(21b,
(21b,
( 1 74,
(174,
(174,
(1/4,
(174,
( 1 3b,
( 1 3t>»
(1/4,
(143.
(174,
(174,
(169.
( 169,
(169,
( 169.
(169,
(169,
(169,
(169,
(169.
( lt.9.
( 16V,
(174,
<27/,
(277,
(277,
(164,
4)
4)
bl
bl
bl
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4)
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4)
4)
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4)
4)
4)
4 1
4)
41
6)
6)
6)
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2.3
1 . )833f. -03
H.«2»7E-04
6.0b9Mt-04
l.Olttlt-OJ
1 .3/V9H-03
1.204U.-03
1.4775E-03
1.4b01f-03
1 .42bVt -03
1.1977h-03
b.47fc)fc)t- -04
b. J232k-04
1 ,3b40t-04
2. 79H4H-Ob
4.96b4t.-0b
b. 17d9e-08
3,rt2rt4t-16
1 .OOOOfc-30
l,0000t-30
1 .OOOOE-30
6.0193E-06
7.09H4E-04
2.070H-03
2.4]14t-03
2. Ubbf -03
I.b4lbf.-03
1 .b94bf -03
1.44Mbf -03
1 . 3246r -03
1 ,03Myfc -03
7.b4l8t-04
4.V77bt -04
b.bb
b)
b)
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4)
3)
4)
4)
4)
b)
1 )
1)
1)
b)
bl
b)
t>l
b)
b)
b)
4)
4)
4)
4)
4)
4)
5)
6)
4)
-------
TABLE 15
H>LMT NA". 39 Ifit -04
b.9^0 .lt-04
6.791 7E-04
7.b3f'9t-0'4
c*.09 r Jc:-04
B.4(?74t.-04
M.44 7UE-04
H . 1 7r>2t -04
7.b737t-04
6 . 7 1 3 (i t - 0 4
b.6291E-04
V.07bOt-04
•» .6B73E-04
4 .033 2L -04
3. 7 lBbt-04
3.0791t-04
1 .9230 b. -04
Ib4,
164,
143.
I 43.
143,
U3,
143,
14 j.
1 1 J,
143,
143,
14J,
174,
143,
164,
Io4,
164,
1 64,
1.4S36E-04 (104,
2.0bS3t-04 (277,
2.629bt.-l)4 (277,
3. 379 bk -04 (277,
3.d93bfc-04 (277,
4.0-130E-04 (<^77.
4.6165E-04 <03t -Ot (d 77,
b.b4B3t — 04 (164,
7«30j9t — U4 (164,
H.0777E-04 (174,
7. U3b^t -04 ( 1 7<»,
4)
4)
b)
b)
4)
4)
4 )
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
b)
4)
4)
4)
4)
4)
6)
6)
6)
6)
6)
6)
6)
6)
6)
4)
4)
4)
4 )
b. 1914K-04
3. 1H68E-04
6.9794K-04
b. 3070F-04
6.9277F-04
9. 9762E-04
1 . 1 426F.-03
1 . 3486F-03
1 .4919F-03
1 . -J010F-03
l.bbB8F-03
1 . THb^F-03
l.b!94F-03
1 .400/F-03
1 . 16b7F-03
1 .0034F-03
7.7963E-04
*>. 3713E-0"*
2. 74&2F-04
8. 2137E-Ob
3. 332bE-Ob
1 . 2b3bF-04
2. 6966F-04
3.7076F-04'
4. 7469E-04
b.307sF-04
4.-»31 1F-04
4. 194bE-04
3 . 4324F.-04
b.244bf-04
7. bbb6F-04
d.V632F-04
8.76b8f-04
6. ^^86^-04
6.9173E-04
6 . -3 0 b H - 0 4
(174,
( 143,
143,
164,
Ib9,
159,
143,
143,
(143,
(Ib9,
(164,
(164,
(164,
( 164,
(164,
( 143,
( 143,
( 174,
(143,
( 143,
( 169,
(169,
(169,
(169,
(169,
(169,
( 169,
( 169,
(277,
(277,
(277,
(277,
(277,
(?77,
( 164,
( 1 74,
4)
b)
b)
4)
3)
3)
4)
4)
4)
b)
b)
b)
b)
b)
b)
b)
b)
4)
4)
4)
4)
<*>
4)
4)
4)
4)
4)
4)
6)
6)
6)
b)
6)
6)
4 )
4)
4.b679K-04
5.6936E-04
6.8604F-04
6.621bE-04
1 .227BF-03
1 .4743F-03
1 .5407E-03
l!4017F-03
1 .4641E-03
1.4786E-03
1 .32fi7t'-03
1.3469E-03
1 ,364bF-03
1.1199E-03
3.7078F.-04
1 .3824F-04
9.9999F-06
2.0668F-04
7.2347E-04
5.0923F-04
3.297bF-04
2.67^8E-04
?.6b96F-04
3.06Q7F-04
3.829BE-04
4.9455E-04
b.b8blt-04
3.9849F-04
S.H8H9t"-04
9.2299E-04
9.0687F-04
6.4678E-04
6 ,bOH9(- -04
(174, 4)
(164, 6)
(164, 4)
(159, b)
(143, 5)
(143, 4)
(143, 4)
(143, 4)
(159, b)
(21b, b)
(21b, b)
(21b, b)
(i?lb» b)
(136, 4)
(136. 4)
(143, 4)
(143, b)
(143, 5)
(143, 4)
(169. 4)
(169, 4)
(169, 4)
(174, 4)
(174, 4)
(174, 4)
(174, 4)
(174. 4)
(174, 4)
(174, 4)
(169, 4)
(Ib9, 4)
(277, 6)
(277, 6)
(277. 6)
(277. 6)
(174, 4)
4.1bl2E-04
6.0065E-04
S.1262F-04
t).015bE-04
1.07blE-03
1.3424E-03
1 .3696F-03
1.3076E-03
1.66blF-03
1 .4997E-03
1 .0845E-03
1.11 8bE-03
(164, 6)
164, 6)
164, b)
143, b)
143, 4)
H3, 4)
143, 4)
174, b)
174, b)
21b, 3)
13b, 4)
136, 4)
1.1333E-03 (13o. 4)
1 .1927E-03
9.3192E-04
7.1B37E-04
2.1749E-04
9.9168E-07
1 .76S1E-11
4.9194E-07
136, 4)
174, b)
174, b)
136, 4)
143, 4)
143, 4)
Ib9, 4)
7.83b()E-06 (174, 4)
2.6231E-04
7.123bE-04
7.1b27E-04
136, b)
13b, b)
136, b)
8.6992E-04 (277, b)
5.3360E-04 (277, b)
4.0620E-04 (277, b)
P.6423F-04 (277, b)
1.5847E-04
2.8584E-04
b.01B2E-04
b. 1B63E-04
8.0909E-04
8.6519E-04
7.9381E-04 (
6. 1 9f33lf-04
174, 4)
174, 4)
Ib9, 4)
Ib9, 4)
174, 4)
174, 4)
174, 4)
1 74, 4)
4.1013E-04 (164. 6)
6.3b47E-04 (164. 6)
b.437BF_-04 (Ib9. 3)
B.02bbE-04 (143, 4)
1.1234E-03 (143, 4)
1.142BE-03 (143, 4)
1.1477K-03 (174, b)
1.37b3E-03 (1 74, b)
1.3901K-03 (174, b)
B.b94BE-04 (21b, 4)
6.9991E-04 (21b, 3)
b.Ob!6E-04 (21b, 3)
1.12BOE-04 (21b, 4)
I.b984t-0b (21b, 3)
6.09B6E-07 (21b. 3)
b.J949E-10 (143, b)
6.6b67t-19 (143, 4)
l.OOOOE-30 ( 19, 2)
l.OOOOE-30 ( 19, 2)
l.OOOOE-30 ( 19, ?)
l.ebd*t~~09 (136, 6)
6.0l86t-03 (13h, 6)
9.4892E-Ob (136, 4)
2.1989E-04 (277, b)
7.04 (277, S)
1.3276E-03 (277, b)
1.2269F-03 (169, 4)
1.2944E-03 (277, b)
7.1010E-04 (277, S)
2.7229E-04 (277. b)
l.b7b6E-04 (Ib9, 4)
4.M343E-04 (169, 4)
b.bOBbE-04 (174, 4)
7.14b2E-04 (174. 4)
7.2213E-04 (174, 4)
b.6707h-04 (174, 4)
-------
TABLE 16
I
IS3
HLANT .NAME: co.itUNKO
ftAHLY MAXIMJM 3-
^OLIUTANT: so2 EMISSION UMTS: r,M/spc AIH QUALITY UNITS:
CONC = 2.41l4c-03 OlHECTIO1^ ?4 DISTANCE= 5.3 KM nAY=13* Tint PErfIOi> = b
HliiHfcST
KANGt
,4
3-MOUW CONCEMTW4TIOM AT EACH HECEPTuR
.d KM 1.2 KM
1 .6 KM
2.3 KM
1
2
J
*
5
6
7
f)
9
10
11
12
13
14
15
16
17
Id
19
20
21
22
23
24
25
2b
27
28
29
30
31
32
33
34
,15
36
1.13Mlt-U3
1.1 2rVfc-U3
9.9453t-04
d.4600E-04
B.U403
1.01U1E-03
9.4247E-04
«.6024t-04
7. 4833k -04
6.1299E-04
7.2200E-U4
9.1 155L-04
1 .0992t-03
1 .2591E-03
1.3729E-03
1 .4367E-03
1 .4579E-U3
1 .4495F.-03
1 ,423bE-03
1 ,3888fc-03
1 .3490fc>0 3
1 .3048E-03
1 .2546t-03
1.1959E.-03
1 . 1264E-03
1.0453(1-03
9,b325E-04
•i. 1 059E-04
1 .()S«4E -03
(164,
(104,
( 1 b4 ,
( 1 b* ,
(143,
(1*3,
(14.J,
(143,
( 143.
(143,
(143,
(143,
(143,
(143,
(143,
(143,
(143,
(1 /•»,
( 1 74,
(1/4,
(1 ?4.
(174.
(174,
(17*,
(17*,
(17*,
(1 74,
(1/4,
(17*,
( 17*,
(1/4.
(1 7*,
(17*,
(17*,
( lb*«
(16*,
4)
4)
4)
4)
a)
5)
5)
5)
b)
b)
5)
5)
3)
5)
b)
5)
3)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
1.2B59F-03
1.1990E-03
B. 9458E-04
B. 5422F-04
9. 7E-04
.7350E-05
.3144E-05
.4433E-05
.8823E-04
.4664E-03
.B332E-03
.8641E-03
.8B43E-03
.5423E-03
.3867E-03
.2263E-03
.11B1E-03
.5d45P-04
. 704
,96*7E-04
.8703E-04
.2704E-03
.0062E-03
,29r<3E-04
(164,
(16*,
(143,
(159,
(159,
(159,
(159,
(215,
(215,
(1/4,
(174,
(174,
(174,
(174,
(136,
(136,
(174,
(277,
(277,
(277,
(16V,
(169,
(169,
(169,
(169,
(169,
(169,
(169,
(169,
(169,
(169,
(174,
(277,
(277,
(277,
(164,
4)
4)
5)
b)
5)
5)
5)
5)
5)
5)
5)
b)
5)
5)
4)
4)
51
6)
6)
6)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
4)
6)
6)
6)
4)
1
B
b
1
1
1
1
1
1
1
B
b
1
3
*
b
b
B
a
tt
7
7
2
2
2
1
1
1
1
1
7
5
b
1
1
6
.1B49K-03
• tf5 ME-04
.'I611E-04
.Ul«lF.-03
.37996-03
.2041E.-03
.4775E-03
.4501E-03
.4269E-03
,1977t-03
.47BBE-04
.3232E-04
.3B40E-04
.4335E-05
< U T67E-05
.45BBE-05
.B9B3F-05
.U2BUE-05
.5630t-05
.3161E-05
.i>403t-0b
.09B4E-04
.0701E-03
.4114E-03
.14551: -03
.541BE-03
.594bK-03
.»527E-03
.3281E-03
.04166-03
.5b2Ht-04
.U23BE-04
.9161E-04
.1555E-03
.2441E-03
. lri»4E-04
(164, 4)
164, 4)
143, 5 )
159, 5)
159, 5)
159, b)
(215, 5)
(2lb, b)
(21b, 4)
(1 74, 5)
(174, 5)
(215, *)
(215, 3)
(277, 6)
(277, 6)
(277, 6)
(277, b)
(277, 6)
(277, b)
(277, <>>
(136, b)
(136, b)
(136, 5)
(136, 5)
(136. b)
(2/7, 5)
169, 4)
( 169, 4)
(169, 4)
( lt>9. *)
(159, *>
(17*, 4)
(277, 6)
(277, 6)
164 , 4)
-------
TABLE 17
PLANT NAME: COMBINED PUNTS ^OLI.UTANT: S02 EMISSION UNITS: GM/SEC AIR OUAUITY UNITS: GM/M««J
YtAKLY SECOND MAXIMUM 3-HOIM CONC= 1.6bblt-03 UIRECTION= 9 DISTANCED 1.6 KM DAY=174 TIME PEH10U= D
SECOND rllUHEST
RANGE .4 KM
(MR
1
2
3
4
5
6
7
8
9
10
11
12
13
!•*
1-3
16
1 7
18
1 9
20
i" ->
JO
31
32
33
34
35
56
b.4507E-04 (174, 4)
5.4710E-04 (174, 4)
5.9211E-04 (143, b)
6.9838E-04 (143. b)
/ . D474E-04 ( 1 64 , 4)
S.4087F -04 ( 164 . 4)
5.9204E-04 (143, 4)
6.7918E-04 (143, 4)
7.53H9t-04 (143, 4)
H.0973E-04 (143, •*>
8.4275E-04 (143, 4}
8.4471E-04 ( 1 4 J , 4)
ri. 1 753E-04 (143, 4)
7.5738F-04 (143, 4)
b.7130H-()4 (143, 4)
5.6292E-04 14J. 4)
5.5411E-04 174, 4)
4.6875E-U4 1^3, 5)
4.n415t-04 Ib4, 4)
3.7257t-04 164, 4)
3.0854F-04 164, 4)
1.9286E-04 lb<», 4)
2.0838E-04 (277. 5)
c'.8686E-U4 (277, 6)
3.4321E-04 (^77, 6)
4. 181 1F-04 (277, 6)
4.b919t-U4 (277, 6)
4.8764E-04 (277, fa)
5.4061E-U4 (277, b)
5.7233E-04 l2b«E-04
1. 1234F-U3
1. 1429E-03
1. 1477E-03
1.37a3E-()3
1.3901E-03
8.b948E-04
b.99yj(->04
b.llblbE-04
1 . 12ttOt -04
3. 1819E-05
3.0789E-05
2. 7251E-05
2.2552E-05
2.3186E-05
2.3810E-Ob
2.2367E-Ob
2.2667E-05
b, b isibE-05
9.4892F-05
2. 1989E-04
7.2122E-04
1 .3276E-03
1 .
-------
TABLE 18
PLANT NAME: TWIMHI.I; Cmr
-'OLIUTANT: S02 EMISSION UMTS: GM/SFC AIM QUALITY UNI1S: 6M/M«»3
E CONTRIBUTION TABLE NO. OF SOUXCF.S: b
INT DAY PtM -}/DH SOUUCE 1 SOURCE 2 SOJHCfc 3 SOJWCe 4 SOURCE b SOURCE b SOURCE 7 SOURCE 6 SOUHCE V SOUkCE 10
3
j
3
J
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
172
1 72
1/2
1 72
1 /2
1 /2
1 J2
1/2
1/2
1 /2
1/2
172
1/2
1/2
172
1/2
1/2
1/2
172
172
1/2
1/2
172
172
1 /4
1 It
1 /4
1 74
1 /4
1/4
174
1/4
1/4
174
1/4
1 ft
174
17*
174
1 74
1 /4
1 /4
174
174
174
1 74
1 /4
1 /4
1 f4
I /4
7 2/lb 0. 0. 2.220HF-102.220«E-102.e20aE-100.
7 3/lb U. U. 1 .30/ 1 .(WjHE-Obl «Oo6fjE-OsO» 0. 0. 0.
H 3/lb 1 ,(l(j01t-Ob9.639?E-060. 0. 0. 0.
H 1/17 2.2bOOt-u71 .blbOE-l/70. 0. 0. 0.
b1 5/19 4,bb39t-083.H071t-Of)0. 0. I). 0.
M 3/^0 1 ,b044E-Obl .4blOE-060. 0. 0. 0.
B 2/21 2.0rib9fc -Ob2.0<» /^F -063 . 0 1 04(- -1 / 3. 0 1 <14E-1 /3 . 0 1 04E-170 .
B 1/27 d .33/bF -Ob2 . 3 1 H9E ~066 .b6M4F-l2b .S6M4F- 1 2b.56H4E-l20 .
8 E-060. 0. 0. 0.
fi/1/ 1.323bt-07b.9939F-080. U. 0. 0.
5/19 1 .32/6t-072.78BbE-OHO. 0. 0. 0.
3/2U 1 .b4»4F-Obb.7<»<»3t-070. 0. 0. 0.
2/21 2.1b27E-Ob9.bbbHF.-072. /2b7E-20d.72B /fc -202 .7267E-20U.
1/27 2.44y3E-Obl.l3b7E-06fl.3433F-l4B.3433E-14B.3433E-140.
a/ 33 3. 04 7 2F. -Obi .blOlt-061 .4B23K-1 U 1 .4ft?3E-l 01 .4823E-100.
3/34 £'.b079E-061.1tt7bt-062.271?e-lU£;.2712t-102.?712E-100.
1 =b/3b 3.9449t-Ob2.12b9E-061.023lF-071.0231E-071.0231E-070.
25/10. U. 0. 0. 0. 0.
23/20. 0. 0. U. 0. 0.
22/30. 0. 0. U. 0. 0.
^l/9o. o. o. o. o. o.
2 2/lb 0. 0. 0. 0. 0. 0.
2 3/lb 0. 0. 0. U. 0. 0.
Z -)/\I 0. U. 0. 0. 0. 0.
23/190. U. 0. 0, 0. 0.
2 3/20 0. 0. 0. U. 0. 0.
22/210. 0. 0. 0. 0. 0.
? 1/27 0. 0. 0. U. 0. 0.
2 2/33 0. U. 0. 0. 0. 0.
Source 1 - Trimble County Unit 1
Source 2 - Trimble County Unit 2
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
u.
0.
0.
0.
0.
0.
0.
0.
n.
0.
0.
0.
0.
n.
0.
0.
0.
0.
n.
0.
0.
0.
0.
n.
0.
n.
0.
n.
0.
0.
0.
n.
n.
0.
0.
n.
0.
n.
n.
0.
0.
0.
0.
0.
0.
n.
0.
0.
0.
n.
0.
(i.
0.
u.
n.
i).
u.
0.
0.
0.
0.
u.
0.
0.
0.
u.
0.
0.
0.
0.
0.
0.
0.
u.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
u.
0.
0.
0.
u.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
(1.
0.
0.
0.
0.
0.
u.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
u.
0.
u.
u.
0.
(J.
u.
0.
0.
0.
0.
u.
0.
0.
u.
u.
0 .
Source 3 - Clifty Creek Unit 1
Source 4 - Clifty Creek Unit 2
TOTAL
b.6fa2bE-10
3.922HE-14
0.
0.
4.bb2«E-33
2.b610E-2b
1.2129E-23
1.4339E-22
4.45«9E-23
1.9167E-22
3.b22vE-Ob
3.234bE-Ob
3.13blE-Ob
2.B14bE-Ob
2.162SE-Ob
4.0b51t-07
4. 1 J3t)E-06
4.bb64E-06
b.9400E-Ob
4.3922E-Ub
9.6192h-0b
1.8802E-05
1.612bE-Ob
1.41S7E-05
1.0b6&E-Ob
1.9229E-07
1 .60b4£-07
3.1093E-Ob
3.bHblE-Ob
4.b57BE-Ob
3.69elE-06
o.3787E-Ob
0.
0.
0.
0.
0.
0.
0.
U.
U.
0.
u.
u.
Source 5 - Clifty Creek Unit 3
-------
TABLE 19
NAME: TRIMULE CNTY
POLLUTANT: so2 EMISSION UNITS: GM/SEC AIR QUALITY UNITS: GM/M»»3
SOURCE CONTHldUTION TABLE NO. OF SOUrttES: b
INT UAY PFK ^/DK SOUHCfc 1 SOUkCE 2 SOJHCK 3 SOJPCE 4 SOURCE b SOURCE 6 SOURCE 7 SOURCE B SOUwrF
SOURCE 10
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
** ^
1 -1
NJ 1
Ul
.1
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
.}
3
3
3
174
174
1/4
1/4
174
174
174
174
174
1 74
1 74
1/4
1 74
1 74
174
174
174
174
1/4
174
1 /4
174
174
1/4
174
174
1 74
1/4
1/4
1 74
1 74
174
1 74
174
174
1 74
174
174
174
1 74
174
1 74
1 74
1 74
1 74
1 74
1 74
1 74
174
1 74
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
S
b
b
5
b
b
s
^
5
b
b
b
b
b
6
6
b
f.
6
b
3/34
5/3b
b/ 1
3/ 2
2/ 3
I/ 9
2/lb
3/lb
5/17
5/19
3/20
2/21
1/27
2/33
3/34
b/35
b/ 1
3/ 2
2/ 3
I/ 9
2/lb
3/lb
b/17
b/19
3/20
2/21
1/27
2/33
3/34
5/35
b/ 1
3/ 2
2/ 3
I/ 9
2/lb
3/lb
b/17
b/19
3/20
?/21
1/27
2/33
3/34
5/35
b/ 1
3/ 2
?/ 3
I/ 9
2/15
3/1&
0.
0.
0.
0.
0.
0.
u .
0.
0.
0.
0.
0.
0.
0.
0.
1).
1 .
1.
1.
1.
1 .
1 .
2.
2.
2.
2.
1.
1 .
1 •
1.
b.
8.
9.
1.
1 .
1 .
2.
a.
b.
6.
b.
4.
3.
3.
0.
0.
0.
0.
0.
0.
0
u
u
0
0
0
u
u
0
0
0
(J
0
0
0
0
721 7F-Ob2
H016t-0b2
b3b9E-l>52
8933F-Ob2
9b37K-Ob2
9918t-0b2
IGttlE-ObO
16U9E-050
04dOF-Ob2
OOH9I--052
v4HBe -Ob2
Bv23e -Ob2
85B3F-052
7762E-Ob2
H09BE-147
82blt£-141
8685E-141
2bb5E-131
6061H-132
9bb*t-132
8bb3F-133
7096F-151
4bl 8F-lSt<
IbO 7F-158
2723E-157
5160F-156
9270F-lbb
1 Bi:OE-lb4
0
0
0
0
0
0
*
•
•
•
•
•
•
•
*
•
•
*
•
•
•
*
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
.34//E-051.13B3F-041.
.4568E
.b049K
.5818E
.6642E
-059.
-058.
-054.
-Ob9.
4421F
276U
7824F
b309F
-Ob9.
-ObB.
-Ob4.
-069.
.7162E-U51.B5391--071.
.
.
.7927E
.73941--
.b5?4E
.5804E
.534lt
.4221E
.9225E
.2036E
.34b7E
.7 12 IE
.1902t
.66ri4E
.9072E
. 1B77E
.81 IbE
.3873E
.1B95E
. lb82E
.3bb()E
.3 39 OF
.
.
•
a
.
.
0.
0.
-054.
-056.
-054.
-Ob3.
-Ob3.
-052.
-144 .
-133.
-138.
-134.
-132.
-135.
-131.
-140.
-Ib2.
-152.
-151.
-Ibb.
-152.
-159.
0.
0.
0.
0.
7.
8.
5188F
2096*:
4/5 7h
5186F
122 OF
4 0 7 1 F
BS1?F
/74?F
6756F
0.
0.
-044.
-046.
-U44.
-04J.
-043.
-042.
-0/4.
-063.
-068.
2843F-Ob4.
b!45E-042.
921 IF
0363F
6 0 4 0 F
V949F
4122F
3286F
7420F
/691h
9b30F
94 79t
-04b.
-191.
0.
-092.
-082.
-081 .
-095.
-092.
-109.
0.
0.
0.
0.
-2b7 .
-1 7b.
0.
0.
0.
0.
0.
0.
0.
o.
0.
0.
0.
0.
0.
0.
0.
0.
1383t-04l .
4421t' -059.
276lE-Obtt.
7824F-Ob4.
5309b -069.
8539E-071 .
0.
0.
5188E-044.
2096E-046.
•+757E-044.
5186E-043.
1?20K-043.
4071E-042.
8512F-074.
7742E-063.
6756E-068.
2843t -1154.
5145E-C42.
V21 1E-045.
0363E-191 .
0.
6040t -092.
9949E-082.
4122E-081.
3286E-095.
7420E-092.
7691L-109.
0.
0.
0.
0.
9530F-267.
9479t.-17«.
0
0
U
0
0
0
0
0
0
0
0
0
0
0
0
0
1 3M3E-04U
4421E-050
27blt-050
7824t-050
5309E-060
8539E-070
0
0
b!88t-040
2096F.-040
4 757E-04U
5186E-040
1220E-040
4071E-040
8512t'-070
7742F -060
6756E-060
2843t-ObO
5145E-040
921 1E-040
0363E-190
0
6040t-090
9949E-080
4122E-080
3286E-090
7420E-090
7691E-100
0
0
0
0
9b30t -260
9479t-170
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0 .
0.
0
0
0
(1
n
0
n
I)
n
n
0
n
n
0
0
0
0
0
0
II
0
0
0
n
a
0
n
0
0
0
0
0
0
n
0
n
0
n
(i
0
(i
0
0
0
0
n
n
0
o
(!
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0 .
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
(1 .
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0 .
0.
0.
0.
0 .
0.
0.
0 .
TOTAL
o.
o.
o.
o.
o.
o.
o.
o.
o.
o.
u.
(I.
u.
0.
0.
J.
3.B220E-04
3.25BbE-04
2.9170E-0*
1 .8822E-04
7.4772E-Ob
4.7636L-05
2. lOBlE-Ob
2. 1609E-05
1.4 0 411-0 3
1.9104F-03
1,3888t-03
1 . 100JE-03
9.80b3t-04
7.64 11E-D4
1 ,4bb3t-06
1.1323t-0b
2.6027E-Ob
1 .2Bb3E-04
7.b434E-04
1 .7763E-03
6.772bE-13
2.0b«bE-14
7.8120F-09
8.9846E-Ori
4.2366E-08
1 ,b98bE-OB
8.22MIF-09
2.9307E-09
0.
0.
0.
0.
2.3bb9E-2S
2.6d44fc-lb
Source 1 - Trimble County Unit 1
Source 2 - Trimble County Unit 2
Source 3 - Clifty Creek Unit 1
Source 4 - Clifty Creek Unit 2
Source 5 - Clifty Creek Unit 3
-------
TABLE 20
HLANf NAME: TKlMtlUE CNfY
! S02 EMISSION UNITS: GM/SfC AtH QUALITY UNITS.' GM/M««3
SOURCE CONTRIBUTION TAbLE NO. OF SOURCES: b
IijT DAY
Q/DH SOUWCE 1 SOUHCE 2 SOJHCE 3 SOURCE 4 SOURCE b SOURCE 6 SOURCE 7 SOURCE b SOUHCF. V SOUHCE 10
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
174
174
174
74
74
74
74
74
74
74
174
174
174
1/4
174
1 74
174
174
1/4
/»
74
74
74
74
74
174
174
174
174
174
174
174
174
174
174
174
270
270
2/0
270
2/0
2/0
270
2/0
2/0
270
270
270
2/0
270
b
6
6
6
6
b
b
6
7
7
7
7
7
7
7
7
7
7
7
r
7
7
ri
8
a
8
8
8
«
B
8
8
8
B
8
8
1
1
1
1
1
1
1
1
1
1
1
1
1
1
3/17
3/19
3/20
2/21
1/27
2/33
3/34
3/33
3/ 1
3/ 2
2/ 3
I/ 9
2/lb
3/lb
3/17
*/19
3/20
2/21
1/27
2/33
3/34
3/3b
b/ 1
3/ d
2/ 3
I/ V
2/lb
3/16
3/17
3/19
3/20
2/21
1/27
2/33
3/34
5/3S
3/ 1
3/ 2
2/ 3
I/ 9
2/lb
3/lo
3/17
3/19
3/2u
?/2 1
1/27
2/33
3/34
3/3b
0. 0. 3.H823t-22b.8923t-225.8823t-220.
0 . 0 . 0 .
0 . 0 . 0 .
t>. 0. 0.
0. 0. 0.
0. 0. 0.
0. 0. 0.
0. 0. 0.
0 . 0 . 0 .
0. 0. 0.
0. 0. U.
0. 0. 0.
u. o. o.
0. U. 0.
0. 0. 0.
0. 0. 0.
o. o. n.
0. 0. 0.
0. 0. 0.
0. 0. 0.
0. 0. 0.
0. 0. 0.
4.4119E-073.1 1HE-071.
3.4036t'-072.4l37K-074.
3.2342F-U72.3241E-071.
2.brt4flE-071.8923E-070.
1 ,b710E-071. -Ibl .
b9bb"E-234.
V744F-2&1.
0.
0.
0.
0.
0.
0.
3t>34E-lbl.
7008F-132.
2003t-101.
6639E-1U1.
9097t-081 .
0.
0.
0.
0.
0.
0.
0.
U.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
266bt>161.
6965E-234.
9744F.-261 .
0.
0.
0.
0.
0.
0.
3634E-181.
7008E-132.
2003t-101.
6639t-10l.
9097t-OHl.
0..
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0. 0.
0.
0.
o.
0.
0.
0.
0.
0.
0.
u.
0.
0.
0.
0.
0.
o.
o.
0.
0.
u.
u.
0.
0.
266bt-lbO.
b9btJt~230.
9744fc-2bO.
0.
0.
0.
0.
0.
0.
3634t-180.
7008L-130.
?003t-100.
6b39t-100.
9097t-080.
0.
0.
0.
0.
y.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
n.
0.
0.
0.
0.
0.
0.
0.
0.
0.
n.
0.
0.
n.
0.
0.
0.
0.
0.
n.
0.
0.
0.
0.
n.
0.
0.
i).
n.
0.
0.
0.
0.
n.
n.
n.
0.
n.
0.
n.
0.
0.
0.
0.
0.
n.
0.
0.
n.
n.
i).
n.
i).
n.
i).
n.
n.
0.
0.
0.
0.
0.
0.
u.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
1).
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
II.
0.
0.
0.
u.
0.
0.
0.
0.
0.
1).
u.
u.
0.
0.
u.
0.
0.
u.
0.
0.
0.
0.
0.
0.
0.
u.
0.
u.
u.
0.
0.
0.
0.
0.
u.
0.
u.
u.
u.
0.
0.
TOTAL
1.76V7t-21
0.
o.
0.
0.
0.
0.
0.
u.
0.
0.
0.
0.
0.
o.
0.
0.
0.
0.
0.
0.
0.
7.5237F-07
S.8173E-07
5.5b"83E-07
4.4771E-07
2.29t)0fc-07
3.6006E-09
1 .281bE-07
3.44i;7E-06
4.0166t-0b
3.7955E-00
4.0821E-06
2.9100E-06
3.7294E-06
0.
0.
0.
0.
0.
0.
0.
0.
0.
U.
0.
U.
0.
u.
Source 1 - Trimble County Unit 1
Source 2 - Trimble County Unit 2
Source 3 - Clifty Creek Unit 1
Source 4 - Clifty Creek Unit 2
Source 5 - Clifty Creek Unit 3
-------
TABLE 21
PLANT NAMF. : THIMHLE CNTY
POLLUTANT: S02
EMISSION UNITS: GM/SfC
SOUHCE CONTRIBUTION TABLE
AIM QUALITY UNITS: GM/M»«3
NO. OF SOUHCES: b
IrJT OAY PErt -I/OH SOUHCE 1 SOURCE 2 SOJrtCE 3 SOJHCF. 4 SOUHCE b SOUKCE 6 SOURCE 7 SOURCE a SOUrtCF 9 SOUKCE 10
3
J
3
3
3
3
3
3
3
3
3
3
3
3
3
J
3
3
3
3
3
J
f 3
^ J
^J 3
3
3
J
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
270
270
270
2/0
2/0
270
270
270
2/0
2/0
270
2/0
2/0
270
2/0
270
270
2/0
270
270
270
270
270
2/0
270
270
270
270
2/0
270
2/0
270
270
2/0
270
270
270
270
270
270
270
2/0
2/0
270
2/0
270
270
270
2/0
270
2
?
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
S
s
b
b
b
b
5
3/ 1
3/ 2
2/ 3
I/ 9
2/lb
3/lb
b/17
5/19
3/20
2/21
1/27
2/33
3/34
3/3b
5/ 1
3/ 2
2/ 3
I/ 9
2/13
3/16
b/17
b/19
3/20
2/21
1/27
2/33
3/34
5/3b
3/ 1
3/ 2
2/ 3
I/ 9
2/lb
3/16
b/17
3/19
3/20
2/21
1/27
2/33
3/34
b/3b
3/ 1
3/ 2
2/ 3
I/ 9
2/lb
3/lb
3/17
3/19
0.
U.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
U.
U.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
3.
3.
3.
3.
3.
3.
1.
9.
2.
2.
2.
2.
2.
3.
1 .
1.
1.
1 .
1.
1 .
b.
1.
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1)
0
0
0
0
0
0
0
0
0
721 7E-034
7714E-054
H144F-034
8040F-034
61V3F -ObJ
b670E-Oa3
1187F-031
4935F-069
66b3F.-Ob2
e766t -053
8780E-053
9895L-Ob3
6849F-Ob2
0027E-Ob3
788bF.-Ob2
8b29E-Ob2
6632P.-052
H7^3H-Ob2
?97bF-Obl
hOOlF-Obl
b882t -06b
«039E-061
m
•
•
•
*
»
•
•
*
*
•
*
•
*
•
•
»
*
*
•
•
•
•
•
•
*
•
•
•
•
•
•
*
•
•
•
*
*
.
.
•
•
*
•
.
.
*
•
.
•
0
0
0
0
0
0
0
0
0
n
0
0
0
0
0
0
0
0
0
0
0
0
i)
0
0
0
0
0
1691E-05S
1 /32E-Obl
2028E-051
1533F-051
69bOE-Obl
8138E-050
Od8<»t-ObO
4889t-060
bH83E-Obl
1480E-053
1 705t-052
326 2E -051
9727F-031
390?E-Ob8
Ob83F-OS3
1049t-0b2
1D70E-053
096?t-0b7
9815F-Obb
9b8UE-Ob4
b24UF-Obn
772*t-060
•
•
•
•
•
•
•
•
•
•
•
•
•
»
•
•
*
•
*
•
•
•
•
•
•
•
•
•
.952RF.
0
0
0
0
0
0
0
0
u
0
0
0
0
0
0
0
0
0
u
0
0
0
0
I)
0
0
0
0
-065
.7904F-071
.9923t
.S47bF
.136HE
•
*
•
.4391F
.6797F
.29924f
-Ottl
-111
-191
0
u
0
-111
-Ub3
-062
-Obi
-Obi
-Ob8
-Ob3
-Ub2
-07J
-1 (j'l
-1 /b
.9?4bF-294
•
•
n
0
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
. 0.
0.
0.
0.
0.
0.
0.
0.
0.
. 0.
. 0.
0.
.952at-06b.
.7904E-071.
,9923E-Oftl.
.b476t-lll.
.13b8t-191.
0.
. 0.
0.
.439le:-lll.
.6/97E-083.
.29946-062.
. 9324E-051 •
.7818F-OS1.
.8306E-058.
.2149E-OS3.
.0010t-062.
.2282E-0/3.
,27b8E-l 07.
.7524E-17b.
.924SE-294.
0.
0.
0
0
0
0
0
c
0
0
0
0
0
0
u
u
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9528E-060
7904t-070
9923E-080
b476E-110
13bbt-19u
0
0
0
4391E-110
h797E-080
2994E-060
9324t-ObO
7B18E-050
8306E-OSO
2l49t-ObO
0010E-06U
2282E-070
2768E-100
7524E-170
924bE-290
0
0
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
n.
0.
0.
0.
0.
n.
(i.
0.
0.
0.
0.
0.
0.
n.
n.
n.
0.
0.
0.
0.
i).
0.
i).
0.
0.
n.
0.
0.
0.
0.
n.
0.
0.
0.
n.
n.
0.
0.
0.
0.
n.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
u.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
u.
0.
0.
u.
0.
0.
0.
u.
0.
u.
0.
0.
(1 .
0.
0.
0.
If.
0.
TOTAL
o.
o.
o.
0.
0.
0.
0.
u.
0.
0.
0.
0.
0.
0.
(I.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
I).
0.
0.
9.6766£-Ob
7.9983E-05
8.0231E-Gb
7.9b72E-Gb
7. si 75t.-0b
7.38()7E-Ob
2.2072E-OS
1 .8982E-Ob
5.5b38E-Ob
6.0 3b7t-0b
6.7383E-Ob
1 .2113E-04
1.1003E-04
J.2SflbE-04
1 .3491E-04
4.bb79E-Ob
4.l)f>71E-U5
Source 1 - Trimble County Unit 1
Source 2 - Trimble County Unit 2
Source 3 - Clifty Creek Unit 1
Source 4 - Clifty Creek Unit 2
3.7790E-Ob
3.7682t-0b
1.1212E-Ob
J.b7b7E-Ob
Source 5 - Clifty Creek Unit 3
-------
TABLE 22
PLANT NAME: THIMBLE CNTY
30UUTAMT: $02 EMISSION UNITS:,GM/SEC AIM QUALITY UNIfs: GM/M»»3
SOURCE. CONThJiauTlON TAHLE NO. OF SOUHCES: b
INT (JAY HEH
SOUHCE 1 SOUHCE 2 SOJHCF 3 SOURCE
bOUHCt b SOUPCt b SOURCE 7 SOURCE b SOUfCE S* SOUnCF 10
.e-
l
ho
co
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
270
2/0
270
2/0
270
2/0
270
270
270
2/0
270
270
270
2/0
270
270
270
270
270
2/0
270
270
270
270
270
270
270
270
270
270
270
270
270
270
270
270
2/0
270
270
270
270
270
270
270
270
27U
27U
2/0
S 3/20 b.«:rt72h.-Obb.78b2t-Ob2.403bF-l42.403bt-142.403bt.-140.
b 2/21 b.Mbblt"-066.b005t -068. 1301F-10H. 1 80 1E-1 08. 1 80 lt-100 .
b 1/27 6.0010F-Of>b. 707SK-06?.260HF-072.2frOdE-072.2bOdE-070.
<•> 2/33 b.3b«Jh-Ob7.l937K-Ob4.0044.0044F. - 064. 0044 h. -ObO.
b 3/34 :.. 7^3rth-Obb.4371E-Oft4.09bSF-Ob4.09MbE-Ob4.098bt-ObO.
5 b/3b b.f>bl)3F-067 ,6bbBt-063.4->l 1 t"-Ub3.4bl !E-Ob3.4bl lE-ObO .
6 a/ 1 2.HbO/K-Ob3.143^t-Ob3.42b7t-Ob3.4?S/t-Ob3.42b7E-UbO.
b 3/ 2 2.8790E-Ub3. 1 324E-OS1 .0349k-0bl .0349t-0bl .0349E-ObO.
62/3 2.9044F -Ub3. 143Ob3.S744t-ObO .
b I/ 9 2.8h)b 7h -Ob3 . 092UE-uSS«4Mbbt-OBb ,4B65E-08b. 486bt-U80 .
6 2/lb 2.7328F.-Ob2.8H24t-Obl.d71SK-131.871bE-131.871bt-130.
6 3/lb 2.6B93E-Ob2.81b3E-OS6.009HF-23b.009aE-23b.009dt-230.
6 5/17 8.104bF-Ob7.b<»05E-ObO. 0. 0. 0.
6 5/19 b.2785E-U6t.b813E-ObO. 0. 0. 0.
f> 3/20 1 . 7032F-Obl .b9M)E-Ob2.<»33lh-l22.4b3dE-122.4b38t.-120.
f> 2/21 1.87b9E-Obl.899HE-Obl.l/d3F-Obl.l783E-08l.l783t-OBO.
6 1/27 l.-yub6t--Obl.9521E-Ob9.b72eE-079.S726F-079.S728F-U70.
6 2/33 2.014b> -Ob2 . 04 70E-OS9. 1044FJ-Ob9. 1044E-069. 1044t-ObO.
fo 3/34 1.7997F — Obl.rtb^bE— Ob8»3ob3H— ObB.3bb3E— Ob8»3bb3E — ObO.
b b/3b 2 • (1 7 b9F — Ob2 • 2 1 7 OE — 0 b4 • 7 Bb Ofc — Ob4 • 7 8b 0 E — 0 b 4 . 7 8bO E — 0 bO .
7 -)/ \ 2«9908h— Ob3.10bSE-Obft»**bllh'""UBb»4bllE~OB6.<*6llE — U80.
73/2 2.9666h -Ob3.019?F.-db2. 10b5F-102. lOhbE-1 02. 106bE-100.
7 ?/ 3 2.992H -Ob1.023?e-Ob6.5320h-12b.b820E-12b.SB20E-120.
71/9 2.9430F-Ob2.929<»h -Obi ,4538t--lbl .4538E-161 ,4b3dE-160.
7 2/lb 2.7400E-Ob2.b665t-Ob3.4234F-2b3.4234E-?83.4234t-280.
7 3/lb 2.657BF -Ob2.bb*5E-050. 0. 0. 0.
7 b/17 6.9b99E -Of>b. 708 7E-ObO. U. 0. 0.
7 5/19 7.3007E-Ob6. 13bOt -UbO. 0. 0. 0.
7 3/20 2.4313E-Os2.3b7U"-Ob6.8023F -lbb.8023E-18b.8023E-lbO.
7 ?/21 2.664btr — 05?.b29Dt — 054.b034K*124.b034E-124.5()34E — 120.
7 i/27 2.b893E-052.6880E-Ob9. 769SF -099. 769bF>099. 769bE-090 .
7 2/33 2.8323E-Ob2.8810K-Obb.ll33K-0/b.ll33E-07b.n33E-070.
7 3/34 ^.S211E-052.b470E-OS7.3334K-077.3b34E-0/7.3b34E-l)70.
7 b/3b 2.892bF-Ob3.019SE-Obl .2834F-Obl.2834E-051.2834E-ObO.
8 b/ 1 3.tK»36E-Ob4.1b<.bE-l)b2.3198E-Ob2.3198E-Ob2.319HE-ObO.
83/2 3.89J8F-Ob4.l4/OE-Ob2.6236F-082.6?36E-Ort2.623bF.-ObU.
82/3 3.904lE-Ob4.132HE-Obl.642bF-09l.b42bE-091.b42bt-090.
81/9 3.B70bK-Ob4.0*40t-Ob2.620hE-l J2.b206E-132.6206t-UO.
8 2/lb 3.b'»b2t-Ob3.734l)E-ubb.242U.-23b.2421t-23fe.2421t-a30.
B 3/lb 3,b96HF-Ob3.f.4«»-*E-ObO. 0. 0. 0.
ri 3/17 l.007bE-Ob6.fl4lVE-(lbO. 0. 0. 0.
8 5/19 4.2649E-Ob3.8062t-060. 0. 0. 0.
8 3/20 1 ,3817F-Obl .4041t-05b.b3b1F-lbb.b'3b3E-16b.S3b3E-lbO.
8 OE-ObO .
8 3/34 1 .Slb8F-Obl ,S-y8lt-Ob2.4900t:-Ob2.4900E-062.'*900E-ObO.
6 b/3b 1 ,7894K-Obl .941 Dt-Obl.2l43K-Ob3.2l43F.-Ob3.2143t-ObO.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
n.
0.
0.
0.
0.
0.
0.
0.
0.
n.
0.
0.
n.
n.
n.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
n.
n.
0.
0.
0.
0.
0.
n.
(i.
n.
n.
n.
0.
0.
0.
n.
0.
0.
n.
(i.
0.
i).
0.
0.
n.
0.
i).
0.
n.
n.
0.
0.
n.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0,
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
U.
U.
0.
0.
0.
U.
0.
0.
0.
0.
U.
U.
0.
0.
0.
1).
0.
U.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
1).
0.
0.
0.
0.
0.
0.
0.
0.
0.
U.
U.
0.
1).
U .
0.
0.
0.
U.
TOTAL
Source 1 - Trimble County Unit 1
Source 2 - Trimble County Unit 2
Source 3 - Clifty Creek Unit 1
Source 4 - Clifty Creek Unit 2
1 ,23b8fc-0b
1.3387F>Ob
2.5b'bbt-0b
2.4tb6t-0b
1.1784E-04
1.62/1E-04
9.11b3E-Ob
7.1l98F.-Ob
b.99b2E-Ob
b.blb2E-Ob
b.b046t-0b
l.b74bE-Ob
9.9b97E-06
3.3992t-0b
3.7302t-0b
4. l<»4Ht;-Ob
b.8431E-Ob
b.!692E-Ob
1.86b4E-04
b.llb/t-Ob
b.9ttb9E-Ob
b.01b9E-Ob
b.8724£-0b
b.406bt-0b
b.2123E-Ob
1.2b79E-05
1 .3437t-Ub
4.7«84E-Ob
5.294lt-05
b. 3HU2t-Ob
b.B669t-Ob
b.28B7t-Ob
9.7624E-03
8.7042E-Ob
b.0487t-0b
B.U373E-05
7.9UbE-Ob
7.3/93E-Ob
7.241 /t-OS
1.8918E-05
8.0711E-06
2.78b8E-OS
3. 13/bt-Hb
J.2613E-Ob
1.3374E-04
Source 5 - Clifty Creek Unit 3
-------
5. COMMENTS RECEIVED AND AGENCY RESPONSES
5.1 INTRODUCTION
A total of 33 separate comment documents were received by EPA regarding
the proposed Trimble County Generating Station project. Some of these
comment documents contained a large number of individual comments and data
for consideration. We appreciate and commend the time and effort that all
individuals have given to responding to the DEIS on this project. The level
of involvement of both the public and private sectors throughout this
particular EIS process has allowed a very thorough assessment to be made of
the project and has exemplified the intent of the National Environmental
Policy Act.
The majority of the comments made concerning the project can be grouped
into four categories of concern: air quality, need for the project, project
siting, and solid waste disposal. The main comments regarding these areas
of concern are summarized by category in the following paragraphs, as are
also the agency's responses to these concerns.
Following this summary are the comment documents received by the
agency. They are presented in the order of their preparation date. The
individual comments contained in each document are indicated by number
in the left hand margin. Following each document are the responses to
these comments.
5.2 SUMMARY OF MAJOR CONCERNS AND AGENCY RESPONSES
AIR QUALITY
The following are the major concerns voiced regarding the effect that
the proposed project would have on air quality:
1. Under certain meteorological conditions, the stack plumes
of the Trimble County and the Clifty Creek power plants
could interact and cause a significant adverse impact
(specifically, a large increase in ground-level S02
concentrations) in an area where the air quality is
already significantly degraded
2. There is no evidence to support the claim of 90 percent
S02 removal efficiency by flue gas desulfurization
devices
3. The amount of moisture that would be added to the area
as a result of the combined vapor plume emissions from
the Trimble County and Marble Hill cooling towers would
have a significant adverse effect on the vegetation of
the area
4. The pollutants contained in the flue gases emitted by
the proposed project would not only degrade the air
quality of the immediate area but would also be trans-
ported over long distances to impact areas not considered
in the DEIS
5-1
-------
5. The peculiar meteorology of the Ohio River valley (the so-called
"corridor effect") was not taken into consideration in assessing
the impact of the proposed project
6. The cumulative impact of the Trimble County plant in combination
with other power plants under construction or planned along
the Ohio River was not considered
From the beginning of the EIS process for the proposed Trimble County
project, EPA has recognized that air quality degradation was one of the
major concerns about the project. Consequently, an exceptional effort to
determine, through modeling, the degree and extent of the proposed project's
impact, both alone and in conjunction with the Clifty Creek plant, was
undertaken during the course of the EIS process. Some of the modeling
studies conducted were performed by Fluor Pioneer Inc. (now Fluor Power
Services, Inc.) under the direction of EPA and Dames & Moore. Additional
modeling of the potential interaction of the Trimble County and Clifty Creek
plants was performed by Dames & Moore and EPA. All the modeling work
conducted to date has led to the conclusion that the Trimble County plant
emissions, both alone and in combination with those of the Clifty Creek plant,
will not exeed the limits defined by existing air quality standards.
Regarding the availability of scrubbers with a 90 percent S02
removal efficiency, EPA is satisfied that, given the state of existing
technology, scrubbers capable of providing this level of removal efficiency
can reasonably be expected to be available for use by the proposed project.
It should be noted that the conditions of the PSD permit granted LG&E for
this project require the Applicant to demonstrate, prior to purchase, that
the scrubbers it intends to purchase will enable each unit to meet the PSD
approved emission limits.
Regarding the amount of moisture that the Trimble County plant alone,
and in combination with the Marble Hill facility, would release to the area,
EPA has reviewed the amount of moisture that would be released and does not
believe that the vegetation of the area would be adversely affected to any
significant degree.
Long-range transport of pollutants from one area to another is recognized
by EPA. However, it is difficult at this time to estimate the degree
of impact that a single source, such as the proposed Trimble County plant,
would have on areas further than 20 to 30 miles from that source. Furthermore,
beyond such distances, the amount of pollution contributed to an area by
the Trimble County plant would be very slight because of dispersion of the plume.
A number of individuals have indicated to EPA that, based on the
behavior of the Clifty Creek plant plume, the meteorology of the Ohio River
valley causes stack plumes to behave differently than those plumes released
in non-valley terrain situations. No models currently approved by the EPA
are designed to model the Ohio River valley specifically. However, the
specific terrain features of the Wises Landing site were taken into account
in the modeling studies. The tall stacks of the proposed Trimble County
plant are expected to keep the plume from falling into the valley in the
manner observed to occur with the Clifty Creek plant plume.
5-2
-------
The current policy of the EPA is to examine the impact of new power
plants on a first-come basis. Therefore, only the potential cumulative
impact of the Trimble County plant and the Clifty Creek plant were considered
in the EIS. It will be the responsibility of other power plants that apply
hereafter for construction permits to demonstrate that the cumulative impact
of their emissions and the Trimble County plant's emissions would not
violate either PSD or ambient air quality standards.
NEED FOR THE PROJECT
The following is a list of the major comments received concerning the
projected need for the proposed Trimble County plant:
1. LG&E has projected the need for the Trimble County plant on
the basis of an exponential growth curve between 1977 and
1989, when a straight line growth curve better fits the
energy demand growth that can reasonably be expected to
occur in this time period. Factors such as conservation
and the escalating cost of electricity can be expected to
significantly depress future growth in the demand for
electricity
2. In the past 11 years, LG&E has experienced a growth of
only 60 MW per year; it is predicting a 273 MW-per-year
growth for 1983 to 1989
3. LG&E has a history of overprojecting the growth of demand
for electricity in its service area
In its evaluation of LG&E's projected need for the project, EPA
relied on reviews by an independent consultant specializing in energy demand
forecasting and the Department of Energy. The former reviewed LG&E's
forecast in terms of its service area and judged the forecast to be reasonable.
The Department of Energy reviewed the project in terms of its relation
to the East Central Area Reliability Coordination agreement (ECAR) region.
The Department of Energy reviewer concluded that, if all generating units
scheduled for construction within the region between 1983 and 1987 were
actually completed on schedule, the reserve margin for the area would
range from 28.1 percent (in 1983) to 27.2 (in 1987), with a peak of 29.1
percent (in 1985). These projections were based on the assumption that all
proposed units throughout the region would be completed on schedule and that
the region would experience an average summer peak load growth rate of
5.23 percent annually from 1978 to 1987.
The Department of Energy reviewer also examined the region on the
basis of peak growth rates of 4 and 6 percent and an assumed delay factor in
the construction schedule of some of the units projected to begin operation
within the region between 1983 and 1987. This examinationn indicated that
reserve margins within the ECAR region would be below the usual industry
reserve margin (15 to 25 percent) in 1987, with or without the proposed
Trimble County units, if the region experiences a 6 percent annual growth
rate and there is no delay in the schedules of any projects. If schedule
delays occur, and the region experiences a 6 percent growth rate, the reserve
5-3
-------
margin for the region would be well below 15 percent from 1983 to 1987, with
or without the Trimble County units.
With a 4 percent annual growth rate within the region, the industry
reserve margin would drop below 25 percent in 1987, even with the Trimble
County units in operation, if some currently proposed units within the
region do not begin operating on schedule. Without the Trimble County
units, regional reserve margins would drop below 25 percent in 1986, assuming
a 4 percent regional growth rate and some scheduling delays.
The Department of Energy reviewer believes there is a strong possibility
that some units currently scheduled to begin operation in the region between
1983 and 1987 will be delayed or not receive permits.
SITING OF PROPOSED PROJECT
A number of individuals commented on the location of the proposed
project. The majority of these asked the following questions:
1. Why should Wises Landing and Trimble County receive the
adverse impacts that would be associated with the project
when the benefits of the project (primarily the electricity
generated by the plant) would go to other areas, particu-
larly Louisville?
2. Why can't the project be located within LG&E's service area?
Four basic factors determined LG&E's selection of the Wises Landing
site over other sites potentially available for the project: (1) the
availability of enough land to accommodate the proposed four units; (2) the
nearby presence of an adequate water supply and transportation routes; (3) a
location in proximity to the growth area of LG&E's service area (the northern
portion of the area); and (4) air quality sufficiently above standards to
enable the proposed plant to operate without violating such standards. Of
the sites evaluated by LG&E, the Wises Landing site was considered to best
meet these criteria. The first, third, and fourth criteria ruled out sites
within Louisville and Jefferson County, where the majority of LG&E's customers
are located.
Power plants require a large amount of natural resources—particularly
land, water, and air—in order to operate. As a result, it is necessary
to locate them in areas where these resources are abundant, rather than in
areas where they are already scarce. Obviously, people living in an area
where natural resources are plentiful do not wish to have those resources
reduced, particularly when they do not perceive the cause of the reduction
to provide any direct benefit to themselves or their environs. Consequently,
the residents of any area in which the proposed project could be located
would undoubtedly feel the project to be highly undesirable. This is why
the EPA can only evaluate the project in terms of the sum of adverse impacts
to an area versus the overall need for and benefits from the project. The
EPA attempts to weigh these factors judiciously in order to properly
protect and defend the public interest. The EIS is designed to spell out
all the factors of adverse and beneficial impacts, including siting alterna-
tives, considered by the EPA in its evaluation of the project.
5-4
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SOLID WASTE DISPOSAL
Much concern was expressed regarding the potential for contamination
of local surface and ground water resources, particularly the Wises Landing
aquifer, as a result of the storing of solid wastes (ash and scrubber
sludge) that would be generated by the proposed project. The presence of
karst features in the ravines proposed to be used for solid waste disposal
and the lack of data regarding the hydrology of the ravines and the nature
and content of the solid waste material to be placed in the ravines were the
key factors cited as the reasons for this concern.
The EPA has recognized throughout the EIS process that the storage
of solid waste without adequate engineering safeguards and monitoring
would present a significant potential for ground and surface water contamina-
tion. Because LG&E initially was unable to identify the treatment method it
would use for the scrubber wastes, EPA used the following approach: (1) it
required that LG&E demonstrate, prior to project operation, that the proposed
treatment method would cause the solid wastes proposed to be placed in the
ravines to be environmentally safe. That is, LG&E would have to demonstrate
that contaminants contained in the wastes would not be able to leach into
the ground water or be carried by runoff into the surface waters of the site
area. A monitoring program both prior to and after the project begins
operation was required. If a satisfactory demonstration of the environmental
safety of the solid wastes could not be made by LG&E, then a more suitable
site, complete with engineered safeguards and a separate EIA, would be
required before the project could begin operation.
After the publication of the DEIS, and because of the degree of
concern expressed by persons commenting on the EIS, the EPA and LG&E met
with representatives of the Kentucky agencies that would ultimately be
responsible for issuing a permit for the disposal of the solid wastes, as
well as with representatives of the Trimble County Water District, which
draws its water supply from the Wises Landing aquifer.
At this meeting, LG&E announced that it now proposes to purchase a
commercial method of treating the scrubber sludge and fly ash that it
proposes to place in the ravines. The chemical constituents of the solid
wastes prior to and after treatment are presented in this FEIS in the discussion
of the components of the proposed project (pages 3-32 and 3.57).
During the meeting, it was determined that, because the Commonwealth
of Kentucky has permit authority over the disposal of solid waste, any
further requirements regarding site testing and solid waste treatment would
be imposed on LG&E by the state as part of the permit process.
5.3 COMMENT DOCUMENTS AND AGENCY RESPONSES
The remainder of this section consists of copies of the comment documents,
including a transcript of the public hearing, received by the EPA during
the period set aside for comments on the DEIS. Following each document are
the agency's responses to the individual comments contained in each document.
Because it was determined that all the oral comments made during the public
hearing are also contained in the written comments on the EIS, no responses
have been attached to the transcript itself.
5-5
-------
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
REGIONAL OFFICE
PERSHING POINT PLAZA, 1371 PEACHTREE STREET, N.E.
ATLANTA, GEORGIA 30309
March 1, 1978
REGION IV 1N REPLY REFER TO:
Mr. John E. Hagan, III
Chief EIS Branch
Environmental Protection Agency
Region IV
345 Courtland St., N.E.
Atlanta, Georgia 30338
Dear Mr. Hagan:
We have reviewed the DEIS for the Trimble County Generating Station
(EPA - 904/9-78-01) in Trimble County, Kentucky.
1 HUD does not have any comments to offer at this time. The design
criteria stipulated in the text indicates that HUD's concern that
impacts the facility will generate in the areas of noise, air and
water quality have been adequately considered.
Thank you for the opportunity to review this statement.
Sincerely,
Charles N. Strauh
Assistant Regional Administrator
Office of Community Planning and
Development
5-6
COMMENT DOCUMENT • A
ATLANTA GEOR G, A - B, RM.N GH AM. A L A B AM A - C O LUMB, A . H O LN A -GREENSBORO. NORTH CAROL.NA -JACKSON. M.SSISSIPP,
JACKSONVILLE. FLORIDA. KNOXV1LLE. TENNESSEE- LOUISVILLE. KENTUCKY
Insuring Offices
Coral Gables, Florida - Memphis, Tennessee-Nashville, Tennessee • Tampa, Florida
-------
RESPONSE TO COMMENT DOCUMENT A
Comment Number Response
1 Comment noted. No response required,
5-7
-------
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
AREA OFFICE
151 NORTH DELAWARE
INDIANAPOLIS, INDIANA 46204
REGION V
300 South Wacker Drive
Chicago, Illinois 60606 ^31X11 13, 1 978
IN REPLY REFER TO:
5.4SE:JFS
Mr. John C. White
Regional Administrator
U. S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30308
Dear Mr. White:
Subject: Draft EIS
Louisville Gas and Electric Company's Trimble County
Generating Plant, Trimble County, Kentucky
(Located 12 miles downstrearr. from Madison, IN)
1 This office has reviewed the draft EIS for the subject project and
has no comments. It is felt the project will not affect any
residential areas.
Sincerely,
Acting Area Director
COMMENT DOCUMENT - B
5-8
-------
Comment Number
RESPONSE TO COMMENT DOCUMENT B
Response
Comment noted. No response required,
5-9
-------
Advisory Council on
Historic Preservation
1522 K Street N.W.
Washington, D.C. 20005
March 14, 1978
Mr. John C. White
Regional Administrator
Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30308
Dear Mr. White:
Thank you for your request of February 7, 1978, for comments on the
Draft Environmental Impact Statement for the Trimble County Generating
Station, Trimble County, Kentucky. Pursuant to Section 102(2)(C) of
the National Environmental Policy Act of 1969 and the Council's
"Procedures for the Protection of Historic and Cultural Properties"
(36 CFR Part 800), we have determined that your draft environmental
statement does not contain sufficient information concerning historic
and cultural resources for review purposes.
For purposes of compliance with Section 106 of the National Historic
Preservation Act of 1966 (16 U.S.C. 470f, as amended, 90 Stat. 1320)
the environmental statement must demonstrate that either of the fol-
lowing conditions exists.
1. No properties included in or that may be eligible for inclusion in
or that have been determined on the authority of the Secretary of the
Interior to be eligible for inclusion in the National Register of
Historic Places are located within the area of environmental impact,
and the undertaking will not affect any such property. In making this
determination, the Council requires:
—evidence that you have consulted the latest edition of the National
Register (Federal Register, February 7, 1978, and its monthly supple-
ments) ;
—evidence of an effort to ensure the identification of properties
eligible for inclusion in the National Register, including evidence
of contact with the State Historic Preservation Officer, whose comments
should be included in the Final Environmental Impact Statement. The
State Historic Preservation Officer for Kentucky is Mrs. Eldred W.
Melton, Director, Kentucky Heritage Commission, 104 Bridge Street,
Frankfort, Kentucky 40601.
COMMENT DOCUMENT
5-10
The Council is an independent -unit of the Executive Branch of the Federal Government charged by the Act of
October 15,1966 to advise the President and Congress in the field of Historic Preservation.
-------
2. Properties included in or that may be eligible for inclusion in
or that have been determined on the authority of the Secretary of the
Interior to be eligible for inclusion in the National Register of
Historic Places are located within the area of environmental impact,
and the undertaking will or will not affect any such property. In
cases where there will be an effect, the Final Environmental Impact
Statement should contain evidence of compliance with Section 106 of
the National Historic Preservation Act of 1966 through the Council's
"Procedures for the Protection of Historic and Cultural Properties"
(36 CFR Part 800).
Should you have any questions, please call Ms. Kathleen Pepi at
202-254-3967.
Sincerely yours,
Myrp F. Harrison
Assistant Director
Office of Review and Compliance
COMMENT DOCUMENT • C, CONTINUED
5-11
-------
RESPONSE TO COMMENT DOCUMENT C
Comment Number Response
A description of the surveys employed to identify the
types of properties mentioned in item 1 is contained in
the Supporting Report to the DEIS, pages 5-192 ff. , page
5-200, and pages 5-211 ff. A description of project
impact on such properties is contained in the Supporting
Report, page 6-21. No properties included in or eligible
for inclusion in the National Register of Historic Places
would be affected by the proposed project.
Please also refer to the attached letter from Mr. John
Hagan dated April 10, 1978.
5-12
-------
April 10, 1978
Ms. i-iyra F. Harrison, Assistant Director
Office of Review and Gcnpliance
Advisory Council .on Historic Preservation.
1522 K Street, N. W.
Washington, D. C. 20005
Dear Ms. Harrison:
This letter is in response to your March 14, 1378, consnents on the Trimble
County Generating Station Draft EIS. It is apparent that you should- have
been sent the Supporting Report to the Draft Statement. It contains the
detailed information which you indicate you need to review. This was an
oversight on our part. However, ay February 7, 1978, transaittal letter
for the Draft Statement i*rri*i-n*A to you that the Supporting Report
would be raade available upon request. This procedure is designed to
reduce paperwork and provide Jfee public with readable EIS's, both CEQ
directives.
Your concern and that o£ the State o£ Kentucky for the protection of
cultural resources is fully warranted since a major habitation was believed
to be somewhere near this site on the Chio River. The investigations into
this matter during the EIS process were designed to insure that this
proposed facility would not adversely iapact a potential Register site
or that proper mitigation Measures were initiated.
I have enclosed all pertinent materials fro* our artiiaeological/bistorical
file on this project. I believe tMs inforaation documents that EPA, Region IV,
has followed proper procedures in cooplying with NEPA and the National Historic
Preservation Act, The material inrlndns the Supporting Report DEES, the
Surveys, an tqpdate of the Register listings and pertinent State consultation
correspondence. To facilitate your review of this material, I suggest looking
first at chapters 2,5,6 and 7 of the Supporting Report followed by the other
enclosed inforaation.
I have instructed my staff to keep the cement period iipen for an
additional two weeks past the April 10 closing date so that you niay make
additional cocments.
5-13
-------
>§s. Myra F. Harrison
Page 2
Thank you far r?1*!*^ *h?< natter to ny attention. I regret that the—
Supporting Report was not initially sent to you. This saterial may be
kept for TOOT file.
Sincerely,
John E. Hagan III, Chief
EIS Branch
l. Supporting
2. Archaeological/Historical Surveys
5. Pertineot CUA i esponrifnce
4. February 1978 F. R. listings
5-14
-------
UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary for Science and Technology
Washington. D.C. 20230
(202)377-34.14. 4335
March 21, 1978
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
This is in reference to your draft environmental impact
statement entitled "Trimble County Generating Station."
The enclosed comments from the National Oceanic and
Atmospheric Administration are forwarded for your
consideration.
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you.
We would appreciate receiving five (5) copies of the
final statement.
Sincerely,
Her
Deputy Assistants-Secretary
for Environmental Affairs
Enclosure: Memo from Mr. Gordon Lill
MAR 2 1 1978
COMMENT DOCUMENT • D
5-15
-------
U.S. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
Hockville. Md. 20Q52
Mt. March 16, 1978
Dr- William Aron
Director, Office of Ecology and Conservation
subject: Comments on DEIS 7802.31 - Trimble County Generating
Station, Ky.
TO: Director, Office of Ecology and
Environmental Conservation, NOAA
The National Geodetic Survey does not have any comments on
subject draft environmental impact statement, other than the
possible impact on monuments of the National Geodetic Control
Ne tworks.
Bench marks, triangulation stations, and traverse stations
have been established by the National Geodetic Survey in
the vicinity of the proposed project. Construction required
for the project could result in destruction or damage to
some of these monuments.
The National Geodetic Survey requires sufficient advance
notification of impending disturbance or destruction of
monuments so that plans can be made for their relocation.
The National Geodetic Survey recommends that provision be
made in the project funding to cover costs of monument
relocation.
a
/jfl^-Kj&J^v^,
Gordon Li11
Deputy Director
National Ocean Survey
COMMENT DOCUMENT - D, CONTINUED
5-16
-------
RESPONSE TO COMMENT DOCUMENT D
Comment Number Response
Comment noted. The Applicant has been given a copy of
this letter.
5-17
-------
Indiana State Clearinghouse
State Planning Services Agency
143 W. Market Street
Indianapolis, Indiana 46204
Clearinghouse Use Only
St. Identification No.
7802361400
Date Received
2-15-78
Review Terminated
AUTHORIZATION TO FILE APPLICATION
TQ. Mr. John C. White, Regional Administrator
U. S- Envi ronmental Protection Agency
PROJECT:
EIS - Tremble County Generating Plant - for Proposed Issuance of a
New Source National Pollutant Discharge Elimination System Permit
EPA
Federal Program Title; Agency and FDA Catalog No.
Amount of Funds Requested
The State Clearinghouse has reviewed the summary notification pertaining to the above
project. With regard to the summary notification, the Clearinghouse makes the following
disposition concerning this application:
The proposed project is in accord with State plans, goals, and objectives at
this time.
Y Refer to the attached comments.
You may now complete and file your formal application with the appropriate Federal Agency.
This form, with comments if any, is to be attached to that application, and the lower por-
tion of this form is to be completed by you, detached, and returned to the State Clearing-
house when the formal application is submitted.
Signature (Mrs.
State Clearinghouse Reviewer
Title
March 22. 1978
Date
Indiana State Clearinghouse
State Budget Agency
212 State House
Indianapolis, Indiana
The formal application for
EPA
Cn.
(Name of Project)
on
Federal Agency
Date
St. Identification No. Q
Si-aMnn was submitted to the
by
Name of Applicant
Signature
5-18
COMMENT DOCUMENT - E
-------
STATEr
STATE BOARD OF HEALTH
An Equal Opportunity Employer
INDIANAPOLIS
Address Reply to:
Indiana State Board of Health
1330 West Michigan Street
Indianapolis, IN 46206
TO:
FROM:
Mr. Roland J. Mross
Federal Aid Director
•Stsrtre-Budget- Agency
Attention Indiana State Clearinghouse
William T. Paynter, M. D.
State Health Commissioner
SUBJECT: A-95 Project Review
State Identification No. 7"£ 02.3^ /4-co
Ke>y/
-------
COMMENT DOCUMENT - E, CONTINUED
HISTORIC PRESERVATION ENVIRONMENTAL REVIEW
The 1966 Historic Preservation Act (P.L. 89-665) directed the Secretary of the Interior to
expand the National Register of Historic Places to include buildings, objects, sites, and
districts significant in the nation's history, architecture, archaeology, and culture. Sites
may be of national, state, or local significance. Section 106 of the 1966 Act as altered
first by Executive Order 11593 (May 13, 1971) and later by the 1976 Land and Water Conser-
vation Act (P.L. 94-422) requires that the State Historic Preservation Officer review all
federally funded, assisted, or licensed projects. The purpose for the review is to identify
properties on or eligible for the National Register so that they will not be adversely affecte;
by proposed construction.
Federal regulations in 36 C.F.R., Part 800 and 36 C.F.R., Part 63 require that federal agencies
or applicants provide adequate information so that significant sites can be identified.
*
In 1977, the Indiana General Assembly enacted P.L. 163 which requires the review of State
funded projects and the transfer of State properties. If historic sites or structures will
be adversely affected, the State agency must obtain a certificate of approval from the State
Professional Review Board for Historic Preservation prior to construction.
Applicants seeking project review by the State Historic Preservation Officer should supply
the following material and information:
__j/_l. A clear and concise narrative outlining the proposed actions (this should include
a description of all construction and earth moving to take place and the estimated
acreage or miles of construction).
2. A description of the existing environment to include past land uses of the site
as well as surrounding land uses.
*
3. A statement regarding known historic sites in or near the project area ( a local
or county historical society may be able to supply this information).
_4. Black and white photographs of the project site(s) where construction will take
place (although photographs of sewage treatment plant and electrical substation
sites are necessary, pictures are not normally needed for such projects as con- -
struction or reconstruction of electrical lines, sewage and water lines, streets,
and sidewalks).
5. Black and white photographs of all man-made buildings, structures, and objects to
be demolished.
6. Descriptions of building exteriors of all pre-1930 structures to be affected by
the project (description should include estimated date or era of construction).
~. A U.S. Geological Survey Quadrangle Section map or a copy of one showing the
project area and the proposed construction (if the construction cannot be shown
clearly, an additional site map should be submitted).
8. The following archaeological information:
(T> A letter from a qualified archaeologist stating that no recorded sites will
be affected by the proposed construction and that an archaeological survey is
not necessary,
OR
b. A letter from a qualified archaeologist stating that an archaeological survey
is necessary and a survey report stating what was found and whether or not th(
site is significant enough to merit listing on the National Register of His-
toric Places. 5_2o
9. A statement as to whether the activity will be funded or undertaken by the State
or whether it will be funded, assisted, or licensed by the federal government (in-
dicate the government agency which is funding, licensing, or sponsoring, the projec
-------
Division of Historic Preservation Comments
1 The Kentucky plant will not directly impact any known Indiana historical, architectural,
and archaeological sites. The Draft E.I.S. indicates that after the transmission
line route in Clark County, Indiana, is selected, there will be an investigation of
cultural resources. This investigation should analyze structures as well as
archaeological resources to be affected. The material must be submitted to the
Indiana State Historic Preservation Officer for review and comment prior to construction.
COMMENT DOCUMENT - E, CONTINUED
5-21
-------
Indiana State Clearinghouse
State Planning Services Agency
M^P-Wf^r'.drket Street
Indianapolis, Indiana 46204
..- — - """"" • "•••
^ -"'
TO : V- --;-, ;'. •••. a.
Please use reverse side or separate sheets for additional comments, if necessary.
Reviewers Signature
Title
Date
33 -
Telephone Number
COMMENT DOCUMENT - E, CONTINUED
5-22
-------
ndiana State Clearinghouse
tate Planning Services Agency
43 W. Market Street
ndianapolis, Indiana 46204
Clearinghouse Use Only
St. Identification No.
'A^ \ \A \V\
Date Received
* r —\ >.
^ \ ._ ' \ •
Suspense Date
~:-,-"~V:
PROJECT REVIEW
TO:'
Date
PROJECT NAME: 'e 2vS^_ -
The attached project s^imma'ry^nbtrficaTion is referred to your agency; for "review and com-
ments. If your agency has an interest in this grant application, please complete this
page. Your cooperation is asked in returning this memo to the Clearinghouse Office, in-
dicating your interest or not, within 10 days of receipt.
Our agency is not interested in this project
Comments submitted herewith
Meeting -desired with applicant
Is this project consistent with the goals and objectives of your agency?
X no Comments--
yes
The Environmental Impact Statement does not adequately describe the proposal's impact
on the flood stages of the Ohio River. Without assurance that it will not raise the
flood stages on the Indiana side of the river, we cannot say that this project is in
accord with our goals and objectives. Any questions should be addressed to the IENR
Division of Water, Room 605, State Office Building, Indianapolis, IN 46204
Is there evidence of overlapping or duplication with other agencies?
yes
no
Comments--
Please use reverse side or separate sheets for additional comments, if necessary.
Reviewers Signatur
3/2/78
Date
Environmental Review Coordinator
Title
317-633-4677
Teleohone Number
COMMENT DOCUMENT - E, CONTINUED
5-23
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RESPONSE TO COMMENT DOCUMENT E
Comment Number Response
1 Comment noted. No response required.
2 Comment noted. No response required.
3 It is noted in the DEIS Supporting Report that the
impact of the proposed project on flood levels would be
"insignificant" (page 6-78). Specifically, the plant
would have no measurable effect on annual flood levels.
For 10-year flood events, the plant would cause less than
a 1-inch rise in flood levels. For a 100-year flood
event, the plant would cause a 1-1/4-inch rise in the
flood level in the site vicinity.
5-24
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
333 Waller Avenue, Lexington, KY 40504
March 23, 1978
John C. White
Regional Administrator
Environmental Protection Agency
345 Cortland Street, N.E.
Atlanta, GA 30308
Dear Mr. White:
Reference: EPA 904/9-78-001
This responds to your invitation to comment on the draft environmental
impact statement for the proposed Louisville Gas and Electric Company,
Trimble County Generating Station, Trimble County, Kentucky. First,
we would like to compliment the effort you have made to produce a more
understandable and usable document by separating supporting material from
the environmental impact statement.
I Our only comment relates to the treatment of Corn Creek. Table 14, on
page 63, seems to indicate that a definite decision has been made
relative to treatment of the relocated segment of Corn Creek. However,
page 79 seems to indicate that some decisions relative to Corn Creek
are yet to be made, though they may be small relative to the total
magnitude of the project. We believe that this point should be clar-
ified in the final statement. If any mitigation will be undertaken
on Corn Creek, it should be displayed in the EI$[^Eq£ ^p
and comment. j,;U
EPA-REGION IV
Sincerely,
Glen E. Murray
State Conservationist
V
Director, Office of Federal Activities (Mail,Code A-104) (5 copies)
EPA, Washington, DC
R. M. Davis, Administrator, SCS, Washington, DC
J. Vernon Martin, Director, TSC, SCS, Fort Worth, TX
COMMENT DOCUMENT • F
5-25
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RESPONSE TO COMMENT DOCUMENT F
Comment Number Response
1 A meeting was held on June 27, 1978 to discuss mitigation
of impacts on site and local wildlife that would result
from the relocation of Corn Creek and other construction
activities. The meeting was attended by members of the
EPA, the U.S. Fish and Wildlife Service, and the Kentucky
Department of Fish & Wildlife Resources, and LG&E. The
agreements reached during this meeting are detailed in
the attached letters from the U.S. Fish and Wildlife
Service, dated July 13, 1978 and the Kentucky Depart-
ment of Fish & Wildlife Resources, dated July 17, 1978.
5-26
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
July 13, 1973
Mr. R. C. Somcrs
Assistant General Superintendent.
Louisville Gas & Electric Co.
P. O. Box 32010
Louisville, KY 40232
Dear Mr. Sorters:
Please find attached a revision of our July 7, 1978
letter to you concerning mitigation proposals for the
coal-fired generating plant in Trimble County, Kentucky.
The revision is being provided in response to your
ohone conversation with Mr. Bob Johnson of this office
or. July 11, 1978. We hope this clears up any questions
you h ad.
Sincerely,
Thomas ?. Talloy '--
Field Supervisor
Attachjv.ent
cc: KDnVR/Frankfort, KY )
Dames & Moore/Cincinnati, OH )
EPA/Atlanta, GAy/^ ) w/attaclyr.er.t
FWS Regional Office/Atlanta, GA )
FWS Area Office/Asheville, NC )
TST/RJ/sj
5-27
-------
REVISED
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Division of Ecological Services
Post Office Box 8U$
Cookeville, TN 3o501
July 7, 1978
Mr. R. C. Somers
Assistant General Superintendent
Louisville Gas & Electric Co.
P. O. Box 32010
Louisville, KY 40232
Dear Mr. Somers:
This is regarding the meeting of June 26, 1978, to discuss mitigation
proposals for the coal-fired electric generating plant in Trimble
County. Kentucky. The meeting resulted in agreements being made which
were acceptable^to Louisville Gas and Electric, Kentucky Department
of Fish and Wildlife Resources (KDFWR) , and the U. S. Fish and Wild-
life Service. It was generally agreed that mitigation of adverse
impacts to fish and wildlife could be facilitated by the following
actions:
1 Relocating Corn Creek so as to simulate natural stream condi-
tions. The new channel will tie into the existing Corn Creek
outlet. Design specifications of the new channel will be
developed jointly by KDFWR and Louisville Gas & Electric. The
intent should be to establish a channel with riffles, pools,
and meanders (if determined feasible). Only seven acres of
the Corn Creek slough will be altered/disturbed by the project
(as outlined in the Draft EIS).
2. Louisville Gas & Electric will enter into a cooperative agree-
ment with KDFWR to manage the property extending from the
slough to the Ohio River (the oxbow area). The property will
be managed for migratory and nonmigratory waterfowl, and other
game and nongame birds. Management of the area will include a
share cropping agreement between KDFVJR and a local farmer(s).
In conjunction with this area, waterfowl will not be discouraged
from using fly ash ponds. Fly ash ponds in combination with
nearby crops will provide habitat especially attractive to
waterfowl. For plant security reasons, the oxbow area will be
closed to hunting. However, the area wilt be open to other non-
consumptive public uses such as bird watching, hiking, nature
surveys, and others. The KDFWR will post the area as a water-
fowl refuge and/or no hunting area.
5-28
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Mr. R. C. Sorters - 2 - Julv 7, 1978
3. Upland habitat located north of the plant site, in ownership
of Louisville Gas & Electric Company, will primarily be main-
tained as is. KDFWR will have the option to employ various
management techniques to benefit deer and other wildlife popu-
lations. Among these techniques, farming of ridgetops may be
undertaken. This area will be open to bow hunting only and will
be posted by KDFWR.
4. Purchase of land (ravines) for solid waste disposal will result
in the acquisition of excess acres adjacent to the ravines.
These acreages will be maintained for wildlife use. Deposition
of waste material into ravines will be performed so as to begin
at the outermost extremities of the ravine, eventually working
towards' the generating plant. Waste materials placed in ravines
will be revegetated as soon as possible. Vegetative types uti-
lized will be based on recommendations by KDFWR. As ravines
are filled, Louisville Gas & Electric will retain the option of
selling these areas for farming purposes.
5. KDFWR will retain the option of constructing a sub- impoundment
on an unused portion of the project site. The purpose of the
impoundment would be to rear fish to a stockable size for
release into the Ohio River.
6. Mitigation agreements 1-5 above will be reflected in the final
EIS.
We appreciate the cooperative attitude and environmental awareness
demonstrated by Louisville Gas & Electric. If you have questions con-
cerning the above agreements, or other matters that may require our
attention, please feel free to contact our office.
Sincerely,
Thomas S. Tal ley-
Field Supervisor
cc: KDFWR/Frankfort, KV
Dames S Moore/Cincinnati, OH
EPA/Atlanta, GA
FWS Regional Office/Atlanta, GA
FWS Area Of f ice/Asheville, NC
TST/RJ/sj
5-29
-------
FISH £. W.:_OU-
COMM1SSSON
BX DISTRICTS
K.-C..T.VC-
COMMONWEALTH OP KENTUCKY
DEPARTMENT OF FISH & WILDLIFE RESOURCES
ARNOLD 1_. MITCHELL, COMMISSSCNER
July 17 , 1978
CAPITAL
FRANKFORT, KY.
PHONE 564-34OO
Mr. R. C. Sonars, Asst. General Superintendent
Louisville Gas & Electric Company
P. O. Box 32010
Louisville, Kentucky 40?32
Re: Mitigation plans for
Power Plant Site,
Trimble County, Ky.
Dear Mr. Sorr.ers:
As directed bv the U. S. Environmental Protection Agency,
a -eating between your agency, the U. S. Fish and Wildlife Ser-
vice (USFWS) and this Department was held on June 27, 1978. At
this Meeting, olant si-e"nitigation was discussed and the following
agreements r.ade by the attending agencies.
Mitigation for loss of fish and wildlife habitats to be
incurred upon construction of the Louisville Gas and Electric
(LGSE) Power Plant near Kises Landing in Trimble County, was
determined to be necessary and legitimate. Specifically, it was
ao'-eec that 1) the relocated portion of Corn Creek would be
ro'ted to a course below the toe of the emergency fly-ash pond
dike and intercept the existing Corn Creek outlet to the Ohio
River in effort to retain as much canopy cover at the mouth as
possible and maintain bank stability. A drawing of the relocated
route has been submitted by the applicant and is acceptable.
The relocated portion of Corn Creek is to be similar in width
and deoth to the old channel. If any riffle areas occur in the
old section, thev should be reconstructed in the new. Riprap
will be olaced in areas where bank stabilization will be a
orobler*." Vegetation cc-nosition, density and importance values
should be determined by the applicant and submitted to this
Department. From the data submitted, recommendations will be
nai« regarding olantincs to buffer and stabilize the denuded
banks'of the relocated/creek. BCOECECU HETTS*
5-30
m JUL201378 !
j { j .__- .. i
3 u
SPA-REGION IV
-------
R. C. Somers
July 17, 1978
Page 2
2) The slough area which lies riverward of the fly ash
ponds will be left intact and free from future encroachment. It
is understood, however, that approximately 7 acres will be utilized
for the emergency fly ash pond.
3) The land riverward of the slough will remain undevelop-
ed. LG&E will enter into a cooperative agreement with this Depart-
ment regarding the management of this area for wildlife. This
Department will manage the area a) if proper access to the area is
provided and b) if a cooperator can be located to sharecrop the area
on a crop percentage basis. If conditions can not be met to manage
the area, if is our desire that the area remain undeveloped with
future management options available. This area will be properly
posted by this Department as a wildlife refuge to exclude hunters.
4) The area upland of relocated County Road 1488 will remain
undeveloped and open to bow hunting only. The area will be appropriate-
ly posted by this Department.
5) The .ravine disposal sites that will be cleared for storage
of fly ash will be covered with a layer of soil approximately 2 feet
deep following deposition and grading. Recommendations regarding the
revegetation of these sites are forthcoming from this Department.
Those lands purchased in addition to and in conjunction with ravine
disposal areas are to remain undisturbed for the life of the project.
Ridge tops in the upland areas that are currently in agricultural uses
should be covered in a cooperative agreement similar to the one mention-
ed previously. If only easements are acquired by LG&E on this property,
this condition will not apply.
6) Subimpoundments, which are currently being evaluated by
this Department, have been used in rearing fish to a stockable size
for introduction into the Ohio River. Since we do not know whether
additional subimpoundments will be necessary to carry out fish manage-
ment practices on the Ohio, we do not propose one at this time. How-
ever, if one is found to be necessary we would like to have the option
of having it built on an unused portion of the Trimble County site.
It is our desire that the aforementioned points be addressed
in some detail in the final EIS and that the necessary cooperative
agreements be drawn up prior to beginning of construction or when
final land acquisition is completed. Thank you for the opportunity
to comment and we look forward to your continuing cooperation.
Yours very truly,
Arnold L. Mitchell
Commissioner
ALM:LES:nc
CC: Carl Kays, Joe Bruna, Bill Graves, Pete Pfeiffer,
Bob Jonson, John Phillips, Ronald Sherman and 4lary Veale
5-31
-------
COMMENTS ON THE DRAFT EIS FOR TRIMBLE COUNTY GENERATING STATION
TO: John E. Hagan, III, Chief, EIS Branch, Environmental Protection
Agency, Region IV, 345 Courtlsnd Street, N. E., Atlanta, GA 30308
FROM: Paul G. Scully, 2328 Kargan Drive, Madison, IN 47250 —
A resident of Jefferson County, Indiana
DATE: March 28, 1973
For the past four years, I have closely followed the planned
proliferation of coal-fired poxcer plants in tha Ohio River Basin
area. I have closely followed the history of the xise of flue gas
desulfurization systems, commonly called scrubbers, throughout this
period, and have utonitorcd the scrubber history through the publi-
cations issued every other month by PEDCO Environmental, Inc..
Cincinnati, Ohio who prepares these reports for the Environmental
Protection Agency.
The Draft Environmental Impact Statement (DEIS) on the Trimble County
Generating Station, hereafter referred to as i.lift LG&E Wise's Landing
Plant, repeatedly ir.okes reference to the use of high efficiency
scrubbers on this proposed plant. On page 71, i'he. statement: is made,
"at least 907U of the sulfur dioxide will be removed", 'i'his is made
In reference to the projected impacts on public haalth front che
cheroical pollutants from.the burning of high r.ulfur coal. I will
not attempt to cite every reference in this document to this subject,
but on page 57 there is again a statement, ''this equipment will
remove 90% of the sulfur dioxide, 99% of the ^articulates and limit
the formation of nitrogen dioxide". Nowhere in this entire document
is therp- any evidence to support the numerous statements referencing
the fact that this iftrge coal-fired power plant would be constructed
on the basis that; AC least 90% of the sulfur dio;d.de could be scrubbed
from tha flue gases.
One who 5.s not familiar with the state of the art on scrubber
technology mjght indeed be easily misled si.nce there is not the
slightest suggestion that there? might be sorcc difficulty involved
ir. achieving such a high level of efficiency for the.se proposed
scrubbers. Ihe evidence clearly shows a much different picture,
that is,one in which not a single large scrubber installation in
the United States has ever been <«ble to attain a sulfur dioxide
COMMENT DOCUMENT • G
5-32
-------
COMMENTS ON THE DRAFT EIS FOR TRIMBLE COUNTY GENERATING' STATION
Page 2
removal efficiency of 90% or more for a period of at least one
year. Yet the entire Air Quality Section of the DEIS relating
to sulfur dioxide emissions indicates that there would be no
violation of The Clean Air Act on the basis that the proposed
scrubber installation would remove 90% or more of the S02.
We are well aware of EPA's efforts to encourage and finance research
and development efforts to solve the S02 problems by scrubber systems.
I sincerely hope that some technology will be developed to solve this
most serious problem, but the cold, hard facts clearly indicate that
it is totally unreasonable to suggest that 90% S02 removal is attain-
able for this proposed plant. We who live in this area surely cannot
be expected to be engulfed with tens of thousands of more tons of
chemical pollution on the basis that LG&E thinks they can achieve
this high level of S0£ removal.
EPA's own PEDCO Report Summary indicates only 32 operational scrubbers
in the United States as of the January 25, 1978 report. These PEDCO
Environmental Reports provide a litany of failures, partial successes,
and absolutely no evidence that anyone;on large 600 megawatt or
greater generators^ has been able to attain 90% S02 removal efficiency.
Yet, the DEIS for 'the Trimble County Generating Station indicates
that the allowable increment for S02 will almost be used up by this
proposed plant provided it does attain this magic 90% number.
A review of the past few years scrubber reports from PEDCO Environmental
suggest that 50 - 60% efficiency might indeed be a more proper figure
and even this in many cases would be quite high. We have all been
encouraged from time to time by some temporary successes such as that
achieved at the Bruce Mansfield Plant in Shippingport, Pennsylvania
where the 300-f million dollar scrubber installation did indeed work
successfully for a few months. However, as we all know, this later
proved to be of short duration and the unit has been plagued with
enormous operational problems on its scrubbers for many, many months
and I believe it is currently operating at 50% at best.
We do not quarrel with the fact that scrubbers have, in face, worked
successfully for short periods of time on small generators. However,
at the LG&E plant we are not talking about 10 megawatt or 60 megawatt
COMMENT DOCUMENT • G, CONTINUED
5-33
-------
COMMENTS ON THE DRAFT EIS FOR TRIMBLE COUNTY GENERATING STATION
Page 3
units, but rather a huge generating station where a series of 595
megawatt generators are planned.
It is interesting to note that almost the entire electric utility
industry, with the exception of Kansas City Power and Light and
Louisville Gas & Electric Company -- have steadfastly maintained
that the scrubber technology available today is not yet reliable
enough to be considered commercially feasible. Mr. H. J. Young,
Senior Vice President, Edison Electric Institute, New York City,
has repeatedly been quoted to the effect that currently available
302 contr°l equipment is not adequately reliable and his statements
have been echoed by many others emphasizing that trouble free
commercial units simply are not yet available. The citizens of
this Ohio River Valley Area should not be subjected to serious
health hazards on the basis that LG&E or EPA hopes that the
technology will get better by the time the plant is built. We are
not dealing with just the benefits of jobs or additional taxes
or many other factors which might speak in favor of this unit,
but rather the primary factor for which the Clean Air Act was
enacted, namely our health.
One might well ask — "Why such a large interest in sulfur dioxide
emissions in this area?" The Ohio River Basin Energy Study --
Preliminary Technology Assessment Roport was released a few months
ago and it is attached for reference.- It brings into sharp focus
the usagnitude of the chemical pollution problem facing the people
of this area. The ORBES Report shows that the S02 emissions from
the local Clifty Creek Plant are more than 357* of all of the total
S02 allowable emissions from the entire 19 Indiana coal-fired power
plants. The 286,000 tons per year of S02 emitted by the plant already
here are indeed greater than the combined emissions from all of the
3 LC&E coal-fired plants in Jefferson County, Kentucky plus all of
the other 100 point sources referenced by the Jefferson County,
Kentucky Air Pollution Board.
The magnitude of this problem can be further emphasized by referring
to page 53 of the DEIS — LG&E Wise's Landing Plant wherein it states
that the maximum combined three hour average concentration of sulfur
dioxide in the Mcdison area would be 2,89S ug/m^ which constitutes a
violation of the Ambient Air Quality Secondary Standard of 1,300 ug/nr*.
. * Pages II-B-3-33 and Il-B-3-35
COMMENT DOCUMENT • G, CONTINUED
5-34
-------
COMMENTS ON THE DRAFT EIS FOR TRIMBLE COUNTY GENERATING STATION
Page 4
On page 56 the statement is then made that this gross violation would
have occurred even if the Trimble County Plant were not in operation,
as the concentration contributed by this plant was only 0.1 ug/nr*.
These calculations indicate that even though huge concentrations of
SOo already exist in the Madison area, only an infinitesimal additional
amount would accrue as a result of the Trimble County Plant. In fact,
these statements suggest that a dozen LG&E Trimble County Plants
could be added without adversely impacting the air quality in the
Madison or Jefferson County, Indiana area. Page 56 of this same report
also refers to the maximum 24 hour concentrations which again show
violations of the Ambient Air Quality Standards, but virtually no
contribution from the Trimble County plant. In this instance, their
contribution is about 1/50,000th of the problem -- a figure which is
quite difficult to comprehend. The obvious question to be raised by
the DEIS figures cited on pages 53 and 56 is that if the contribution
of this proposed plant is indeed so small in its impact on areas just
10 miles away, would it not then be practical to have this plant
located south"of Louisville in its own service area where it could
provide jobs, taxes, and so many other benefits to its own customers.
It would be most interesting to hear the response of the Jefferson
~ County, Kentucky Air Pollution Board to this proposal. The facts
clearly suggest that LG&E is lowering its S02 pollutants in the
Louisville area under a mandate from this same air pollution board,
and they are doing this partially by planning to remove or shut down
part of' their existing coal-fired power plant operations by moving
them to the Trimble County site. These figures simply do not add
up and strongly suggest that those of us who live in the area adjaconc
to the Clifty Creek Power Plant are going to be classified as second
class citizens and have even more chemical pollution headed our way.
It is interesting to note that the proposed LG&E plant apparently
would have a by-pass in the scrubber system. The Bruce Mansfield
Plant at Shippingport, Pennsylvania and one of the Kansas City
Power & Light Company units have no by-passes permitted because
they are in areas with heavy S02 pollution. One must ask why
1 this area should not be given the same protection? The only safeguard
1 sue Bested in the DEIS is that LG&E would maintain a 30 day supply ot
loxVsulfur coal in the event of scrubber shutdowns. The history of
COMMENT DOCUMENT - G, CONTINUED
5-35
-------
COMMENTS ON THE DRAFT EIS FOR TRIMBLE COUNTY GENERATING- STATION
Page 5
scrubbers is replete with shutdowns of scrubbers for periods of
much greater duration than one month.
In summary, I can only conclude that a gross injustice would be done
to permit the building of this planned facility on the basis that
either EPA or LG&E hope or think that the scrubber technology will
be improved enough to guarantee a minimum of 90% S02 removal as
suggested in the DEIS. The protection of our health surely demands
more equitable treatment, and the laws enacted by Congress certainly
did not envision large coal-burning plants just 10 miles apart. This
is especially true when one of those plants emits an average of
over 1 1/2 million pounds of S02 per day. We enlist your support.
Paul G. Scully
2328 Hargan Drive
Madison, IN 47250
COMMENT DOCUMENT - G, CONTINUED
5-36
-------
INDIANA - KENTUCKY SULFUR DIOXIDE EMISSION SUMMARY
The report entitled, "Ohio River Basin Energy Study — Preliminary
Technology Assessment Report" has been released s.nd it brings into
sharp focus the magnitude of the problem facing the local populace
as regards the health effects of possible uncontrolled growth of
coal-fired power plants in a relatively restricted area.
The attached pages are taken directly from the OR3ES Report and
represent a summary of the various emissions from all of the coal-
fired power plants in Indiana and Kentucky. The following data is
taken directly from these exhibits:
A. The sulfur dioxide (S02) emissions from the local Clifty
Creek Plant are more than 35% of all of the total S02
allowable emissions from the entire 19 Indiana coal-fired
plants. This one plant emits more than 1/3 of the total
allowable S02 emissions from all coal-fired power plants
in our State. It is clearly the largest single emitter
in the State of Indiana with 257,444 tons of S02 emitted
annually.
B. A comparison of the Clifty Creek SO-? emissions, indicates
that the annual SOo emissions from Clifty Creek are
approximately 30% of the allowable S02 emissions for the
entire 17 coal-fired power plants in the State of Kentucky.
Again, this single plant emits far greater amounts of SOo
than any single' Kentucky coal-fired power plant.
C. The Kentucky summary indicates that the three LG&E coal-
fired power plants located in Jefferson County, Kentucky
will only be permitted a total allowable SOo emissions
of 67,853 tons. The Indiana report shows that the Clifty
Creek Plant here in the Madison area has an allowable
emission of 267,444 tons. Other information from the
Jefferson Count}', Kentucky Air Pollution Board indicates
that the sulfur dioxide emissions from the Clifty Creek
Plant here are in fact greater than all of the total
emissions from all sources (some 100 of them in Louisville
and Jefferson County, Kentucky combined).
In spite of the fact_s from these government figures from the OR3ES
Report,, the Louisville Gas: & Electric Company is still proceeding with
plans for a large 2400 megawatt coal-fired poT?er plant at Wise's
COMMENT DOCUMENT • G, CONTINUED
5-37
-------
INDIANA - KENTUCKY SULFUR DIOXIDE REMISSION SUMMARY Page 2
Landing, about nine miles from the local Clifty Creek or IKEC power
plant. LG&E's answer to the obvious concerns regarding the health
hazard is that they plan to use scrubbers to remove the SC>2 pollutants
from the stack gases. However, a careful review of all of the coal-
fired scrubber installations in the U.S. indicate not a single
successful installation, that is one which has operated successfully
for at least one year. Rather, we find a series of complete failures,
partial failures, and continuing technological problems which are
recognized throughout the land.
In addition to the obvious problems associated with a huge coal-fired
facility just nine miles away, we are also faced with & planned
2,000 megawatt plant at Ghent, Kentucky — approximately 20 miles
up river on the Ohio River. This is now operating at a 1,000 megawatt
level with plans to double the output.
Without attempting to get into the technical matters associated with
coal-fired power plants, it does appear rather obvious that we are
facing a potentially dangerous health problem in this area, and the
local medical society has been very outspoken in opposition to any
more coal-fired power plants in this area. The magnitude of the
problem can perhaps be best understood if one should consider that
even if the proposed LG&E scrubber should x^ork 50% of the time, or be
50% efficient, we would still then have additional sulfur dioxide
pollution which would be approximately equal to the 572,000,000 Ibs.
v;e now receive annually from the local Clifty Creek Plant (286,000
tons per year).
COMMENT DOCUMENT - G, CONTINUED
5-38
-------
Prepared by IMMR for ORBES
EMISSION INVENTORY FOR KENTUCKY POWER PLANTS (1)
2
1
O (j°
O co
M ***
s
3
w
5»J
(_3
O
O
£5
cj
as
H
utility
KEUC
KEUC
K.SPC
GWMU
BRKC
HEi'L
LOOK
LOG!'
LOGii
KKPC
TVA
KEUC
KEiJC
TV A
EKI'C
DIU'C
KEUC
Plant Name
Pincville
Ghent
Dale
Owentboro
lUwativllle
Henderson
I'atiilys Run
Canu Run
Mill Creek
1M^ Sjndy
filiawtifc
IJrown
On:' i>. River
Paraditic
Uurnuide
1U-U1
Tyrone
(County)
(Bell)
(Carrol!)
(Madison)
(Daviess)
(Hancock)
(livmiereon)
(Jeficruon)
(Jefferson)
(Jefferson)
(Lawrence)
(McCj-acV.cn)
(Mercer)
(Mi!l!u-»'berg)
(Mu'.lieiiburg)
(1'ulai.K!)
(V/ebbt<:r)
(Amiertiori)
TOTAL
County
Code
200
580
720
920
158C
2760
1920
I9ZO
1920
21--.0
21C/J
2760
2960
2960
.'•I 60
•1020
'1140
--
AQCR
Cede
101
79
102
77
77
77
7S
78
72
103
72
102
72
72
105
77
102
--
Participate
1.B60
1,088
5.528
1.416
1.505
153
234
2.017
399
IS. 439
9. 790
18,023
6,116
4,? 2 6
17.974
5.U19
2,042
96.789
E,
Part All(2)
(420)
(1,304)
(1.296)
(2,050)
(3,154)
(207)
(1,567)
(5,710)
(1,629)
(8.390)
(6.630)
(11,615)
(1.460)
(10.693)
(3,905)
(14,503)
(251)
(75.334)
•niEslon listim;
SO
2,130
42,682
7,633
69.577
97.700
—
4,764
137.657
63,389
47,577
249.750
76.132
31.512
537,529
33, £ '19
78,706
1,599
1,483.941
itca Mons/ Joa
SO. All
(4,176)
(85.911)
(20,680)
(22.153)
(21,600)
(4.383)
(8,425)
(43.539)
(15,899)
(132,440)
(118.320)
(103,430)
(15.702)
(181,927)
(44,480)
(63,637)
(3,648)
(900.435)
NOx
612
8,877
4,578
16,265
13,284
_-
1.792
15.196
7,917
23.953
71,440
13.483
4,616
103.127
7.407
—
1,588
294,135
HC
10
49
154
221
—
23
290
132
399
710
225
77
1,031
123
—
17
3,461
CO
34
163
513
737
_.
87
752
440
1,331
2,380
749
257
3.439
412
—
53
11,347
Sulfur
Content
1.6
2.5
1.2
3.5
3.5
__
3. '4
3.8
3.8
.9
2.8
1.6
3.2
4.1
2.2
3.5
.8
—
O
«•
O
O
J2S
•-3
t-H
as
(1) Obtained from the Kentucky Division of Air Pollution Control
(2) Allowable emissions under current regulations
-------
TABLE IIB-3.1-11 EMISSIONS FROM ORBES - INDIANA COAL
FIRED POWER PLANTS (a)
Plant Cap.
MWe
Breed
Clifty Creek 1,
Crawfordsville
Edwardsport
Culley
Frankfort
Stout
Johnson St.
Logansport
Gallaghar
Noblesville
Tanner Creek 1
Wabash River
Pritchard
Warrick (Alcoa)
Petersburg
Cayuga 1
Gibson
Hoosier (Ratts)
TOTAL 9
450
304
63
147
415
33
846
30
75
600
100
,098
962
394
731
724
,062
668
244
,946
Loadings Ton/yr .
Particulate Sulfur Dioxide
Actual Allowable Actual Allowable
41,500
88,800
794
348
2,741
763
2,027
540
1,276
192
52,700
3,258
2,895
confident
3,160
3,010
996
7,080
212,080
2,400
11,160
770
372
9,13?
776
2,750
466
5,720
530
3,682
2,270
1,062
4.970
6,490
5,610
3,660
2,540
64,365
62,800
286,200
4,380
7,560
69,540
4,550
84,780
6,080
86,100
3,700
146,900
108,700
29,260
157,800
97,300
120,100
33,200
24,000
1,332,950
62,800
267,444
4,380
7,560
17,130
4,550
16,756
6,110
86.100
3,700
32,640
108,700
26.390
32,280
97,300
120,100
33,200
24,000
761,096
(a) Data from National Emission Data System listing dated April 23, 1077.
COMMENT DOCUMENT - G, CONTINUED
II-S-3-35 5_40
-------
Comment Number
RESPONSE TO COMMENT DOCUMENT G
Response
Please refer to the Summary of Major Concerns and Agency
Responses, pages 5-1 to 5-5 of this FEIS, and to the
response to Comment 4, below.
Please refer to the response to comment 7 of Comment
Document T (page 5-183 of this FEIS). Please also refer
to the Public Hearing transcript statement by
Ms .Louise Grosse of EPA Region V regarding the status of
enforcement on the Clifty Creek plant (pages 36 to 39, of
Appendix E) .
The use or omission of by-pass dampers is not a condition
of compliance or protection but a difference in design
concept. Both of the examples referred to by Mr. Scully,
which do not have by-passes, are systems which remove
both fly ash and S02 by scrubbing. These systems
must have total scrubbing of the flue gas in service at
all times to meet both particulate and SO removal regu-
lations. Otherwise, by-passing would undoubtedly be prohib-
ited or in any event would not be a viable alternative.
In contrast, the Applicant maintains that alternative
methods of operation should be available to provide
optimum use of all of the facilities. Consequently, each
unit will be provided with reliable high efficiency
electrostatic precipitators for the removal of particulate
matter (fly ash) and SO scrubbing equipment designed
for continuous operation but equipped with a by-pass for
use should trouble be experienced with the scrubber.
Because the required particulate removal will be accom-
plished by the precipitator,the S0_ emissions can be met,
while the scrubber is on by-pass, through the burning of
the 30-day supply of an alternate coal which will be
available at the site. This would allow production to
continue without causing permitted emission limits to be
exceeded.
The EPA and the Applicant believe that this is a realistic
approach that will provide the protection and safeguards
desired while permitting optimum use of the generating
equipment.
It is true that some lengthy shutdowns have been experi-
enced and reported in the past. A number of such outages
have been scheduled to make modifications. The industry
has profited from this experience, which has historically
occurred in the development of new technology, and more
reliable systems have resulted.
5-41
-------
RESPONSE TO COMMENT DOCUMENT G, Continued
Comment Number Response
3 (continued) It is EPA1s opinion that, with a well designed S02
removal system provided with reasonable redundacy to
minimize outages, lengthy shutdowns will be rare.
Please also refer to the attached EPA memorandum
dated September 6, 1978.
4 A condition of the PSD approval states that EPA
has the authority to review the Applicant's submittal
of the selected scrubber system prior to its purchase.
If EPA determines that the design parameters of the
system are insufficient to meet the permitted emissions
rate, EPA may disapprove, or allow modification of,
the control parameters of the selected system. The
source must meet the PSD approved emission limits
and protect the air degradation increments as modified
by Congress August 1977.
5-42
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYKt
WASHINGTON. D.C. 20450 S£P !3 12 3^ '/J
SEP 06 1978 DIVISION'
OFFICE OF ENFORCEMENT
MEMORANDUM
Subject: United States of America v. West Penn Power
Company , Civil Action No. 77-1142 (W.D. Pa. 1978)
From: Director
Division of Stationary Source Enforcement
To: Enforcement Division Directors
Regions I-X
On August 21, 1978, Judge William W. Knox of the
United States District Court for the Western District of
Pennsylvania granted a Motion for Preliminary Injunction
against West Penn Power Company in the above captioned
case. The Judge's Order requires West Penn, within 15
months of the date of the Order, tof inter alia, award
equipment bids for the installation of a flue gas desulfuri-
zation system for the control of sulfur dioxide emissions at
the utility's Mitchell Power Station Boiler No. 33 in the
Monongahela Valley Air Basin, Washington County, Pennsylvania.
In a Complaint and Motion for Preliminary Injunction filed
on September 30, 1977, the government averred Boiler No. 33
to be operating in violation of the sulfur dioxide emission
limiting regulation of the Pennsylvania State Implementation
Plan.
In opposition to the government's Motion, West Penn
contended that, inter alia, installation and operation of
scrubbers for the control of sulfur dioxide emissions were
technologically and economically infeasible. The Court,
however, did not agree. In a lengthly opinion, Judge Knox
held that the installation of a flue gas desulfurization
system on Boiler No. 33 to be "...a reliable, effective
method of meeting the requirements of the Pennsylvania State
Implementation Plan and by far the least expensive of the
alternatives open to West Penn" (at page 6). Finding that
the installation of a scrubber at Mitchell Station Boiler
No. 33 would require a capital expenditure of between
$35 and $60 million, depending on the type of scrubber
5-43
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-2-
selected, the Judge felt that both West Perm and its holding
company, Allegheny Power System, have the financial capa-
bility to installka scrubber and remain financially sound.
Furthermore, Judge Knox held that such an expenditure
"...would be a rational economic decision for West Penn to
make in order to comoly with the Pennsylvania SI?" (at page
14).
During eleven days of hearings, expert testimony
was introduced with respect to both the reliability of
scrubbers and the sludge disposal problems associated with
line and limestone nonregenerable scrubber systems. The
Court considered sludge disposal as "...a task being
successfully carried out by every one of the utilities
employing a line or limestone FGD system..." (at page 12).
Acknowledging that sludge disposal does present difficult
problesas, the Court noted the technology forcing aspects of
the Clean Air Act and expressed confidence that, with proper
study by nest Penn, sludge disposal was reasonably possible.
In response to West Penn1 s assertion that scrubbers
were generally unreliable and therefore technologically
infeasihla, the Court noted that all major mechanical
problems associated with scrubbers and experienced earlier
have, to a large extent, been resolved. The Court took
particular exception to the testimony of West Penn' s pre-
ferred expert on the reliability of scrubber technology and
his view that a scrubber is reliable only if it is opera-
tional 100% of the time. Judge Knox rejected such a perfor-
mance standard as "... an impossible standard to meet for
any can aade equipaent" (at page 10). Noting that more than
50 utilities in the country were operating, constructing, or
planning to install flue gas desulfurization systems, the
Court Questioned the wisdom of permitting less of an effort
for sulfur dioxide control by West Penn at its Mitchell
Station.
Judge Knox's Order and accompanying decision (copy
attached) Granting the government's Motion for Preliminary
Injur.ction'are a positive development in the Agency's
efforts cowards recognition of flue gas desulfurization
systeas as aooropriate relief, in the enforcement context.
5-44
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-3-
for violation of sulfur dioxide regulations. Much credit is
due to those individuals in Region Ill's Enforcement Division
who assisted in the preparation of the Agency's case.
Edward E. Reich
Attachment
5-45
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THE SIERRA CLUB
Cumberland Chapter
c/o Bob Wilson
Energy Chairman
University of Louisville
P.O. Box 1055
Louisville, Ky. 40201
March 28, 1978
Mr. Tom Helms, Deputy Director
Div. Air and Hazardous Materials
EPA Region IV
345 Courtland Street
Atlanta, Georgia 30308
Subject: Louisville Gas & Electric Co.
Wises Landing Proposed Plant
Dear Mr. Helms:
We, as representatives of the Sierra Club, believe that our
arguments should carry more than normal weight because we
are not vested interests. Nor are we trying to protect or
enhance our jobs. We don't believe EPA heard us six months
ago at the Kentucky Utilities hearing in Carrollton. We
will therefore try to speak more forcefully.
We insist on our share of the common good. It would seem
that some of you have for saken that goal in trying to pur-
sue individual or corporate gain. My main advantage is
that I can neither be promoted nor fired on the basis of
what I say tonight!
In the past some utilities have reminded us that their
prime job is to furnish adequate supplies of electric energy.
That much is correct, however, they seem to have forgotten
that The Federal Power Act, Sec. 202(a), also says that the
energy supplied must be:
(2) furnished with the greatest possible economy, and
(3) with proper regard for the utilization and conser-
vation of our natural resources.
The Sierra Club contends that LG&E is completely neglecting
the latter two of these three mandates.
Sincerely,
Bob Wilson
Fred Hauck for
The Sierra Club
COMMENT DOCUMENT • H
5-46
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Page 2
WILL FUTURE ELECTRICITY CONSUMPTION GROW EXPONENTIALLY?
In our close study of a number of the larger utility systems
in Kentucky and Indiana we have used regression analyses for
both annual peaks and total consumption. On all of these
systems the correlation coefficients have been better for
straight line growth than for exponential or compound growth.
This means that the growth patterns of the past years tended
to desert the compound patterns established during the 1950's
and 1960's when real dollar kilowatt-hour rates were falling.
We have found, for example, that LG&E's actual peak demand
has grown only 60 Mw for each year since 1966. At this rate
it would take almost 40 years to use the capacity of the
proposed 2340 Mw Wises Landing installation. . . In case you
don't believe your ears, I repeat ... At LG&E•s average
growth rate from 1966 through 1977, the proposed 2340 Mw's
at Wises Landing would last exactly 39 years!
The Sierra Club contends that the rapidly increasing cost of
electricity in real dollars will be likely to depress future
growth below even this 60 Mw straight-line figure. Research
by economists Cicchetti, Chapman and many others indicate
that the probable future doubling or even tripling of real
dollar electric rates, during the next 15 years, will depress
electricity consumption about 20% per person and per unit of
production. Slightly increasing population, and substitution
of electricity for gasoline in the automobile, and for natural
gas in space heating will do well to make up the difference.
Our life styles have already changed substantially since 1974,
and I'm afraid we haven't seen anything yet:
For reference on probable doubling of rates, see the attached
chart, Addendum #1, utilizing data from two Business Week
articles and an American Electric Power I-rospectus. In ad-
dition. West Virginia University has developed a cash-flow
model for the Ohio River Basin Energy Study (ORBES) that in-
dicates that per kilowatt-hour rates will go to more than 9£
in order to support the very rapid growth that many electric
utilities still think is necessary.
The only advantage of using percentage growth figures is that
it makes for easier growth comparisons between utilities.
For example, many systems are still forecasting 6% to 9%
compound growth numbers, and it appears that LG&E is among
them. All of us thought that this tremendous growth was
necessary, even as late as the early 1970's. However, dur-
ing the last 18 months, two utility-related studies have
reduced this high range considerably. First, Alvin Wein-
berg's Institute for Energy Analysis at Oak Ridge, in a very
thorough study, established a range of 3%% to 4 3/4 %. Later,
the Westinghouse Electric Corporation developed a computer
COMMENT DOCUMENT -H, CONTINUED
5-47
-------
Page 3
model based on 4.12% annual consumption increases through
the year 2000. We emphasize that all of these figures are
based on kilowatt-hours of consumption. Peak growth, the
real determinant of capacity, would logically be consider-
ably smaller because of the many peak-trimming devices
thai, will be employed much sooner than some of the utilities
think. For some reason LG&E has not reduced their sights.
The addition of 2340 Mw to their already planned 2772 Mw
for the year 1982, will increase total capacity almost 10%,
resulting in exponential capacity gains of about 8% a year
during a period when consumers will be using every method
at their disposal to reduce consumption because of their,
by then, astronomical utility bills.
5 An easier way to look at LG&E's planned 8% annually compounded
increases, would be as annual increases in megawatts of cap-
acity. These would be as follows:
Capacity in 1982 (Already Planned)
8% for 1983
8% for 1984
B% for 1985
B% for 1986 271 Mw f AVERAGE
8% for 1987 291 Mw \ GROWTH
8% for 1988
8% for 1989 319 Mw / 273 Mw per Year
Total Capacity(if Wises Landing App.) 4686 Mw
All of this in the face of the past 11 years growth of only
60 megawatts per year!
6 A Federal Power Commission Task Force chaired by economist
Duane Chapman, put the matter concisely:
"The past growth of electricity consumption can be attrib-
uted to three factors; an increase in population, an in-
crease in real income per capita, and a decrease in the
price of electrxcity relative to other commodities. It is
the implications of this latter relationship that are gen-
erally ignored by the industry personnel. Since price is
found to be an :mportant determinant of demand, recent
rates of growth of electricity consumption will be main-
tained only if there are substantial price decreases in
the future. No such decreases are anticipated, and con-
sequently current projections of future demand which omit
price effects may seriously exaggerate the need for gen-
erating capacity.-The increased price of substitute fuels
which are also accounted for in this(study's) model, only
partially offset this effect.•
*"Power Generation; Conservation, Health and FUP! Supply',
Federal Power Commissior., March 1975
COMMENT DOCUMENT • H, CONTINUED
5-48
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Page 4
NEW CONSTRAINTS ON ELECTRIC CAPACITY GROWTH
7 A number of 1974 reasons that LG&E may have for believing in
exponential growth no longer exist. Here are some comparisons;
A. Natural gas production (see Addendum #2) was expected to
drop from 23 tcf in 1973 to 11 tcf by 1980. Instead,
industry and government sources are now expecting between
18 and 25 tcf as late as 1985 and probably later!
B. The new Mexican oil finds added to our Alaskan oil are
expected to postpone the oil crunch until at least 1985.
This compares with the previously expected 1980 date.
C. The expected additional 3500 Mw needed at the Portsmouth
enrichment plant has been reduced to less than 500 Mw be-
cause of the use of the proposed Exxon centrifuge method.
This is said to reduce electricity use by more than 93%!
D. Much higher electricity rates will force early use of
such passive energy-saving systems as better summer shad-
ing and ventilation, and encourage the use of many heat-
absorbent materials in winter to utilize solar heat. The
desired temperature difference between indoors and out-
doors will become less year by year.
E. The same higher prices will cause rapid replacement of
resistance space heating by the newer much more efficient
heat pumps. Even many new houses being built today are
using 6" wall insulation with 12" in the ceilings to
circumvent current high heating bills.
F. Recent publications indicate also that alert industry is
reducing energy use. As examples:
New building lighting loads. . . decreased 45%
One GM plant with computer cont. " 20%
1 Large factory's total elec. bill " 33%
G. Population in the general region covered by both ECAR and
ORBES is growing only half as fast as that of the nation
as a whole. Even total national population is growing
only 0.58% annually, fully 1/3 less than the 0.90% esti-
mated immediately after the 1970 census. These figures
alone indicate that all consumer demand in the ECAR region
is likely to grow less than half as fast as planned as
recently as 12 months ago!
COMMENT DOCUMENT • H, CONTINUED
5-49
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Page 5
HEALTH EFFECTS
8 Little has been said by EPA about the long-distance movement
of sulfates east of the Mississippi. More than two years
ago, EPA, ERDA, NOAA and others joined in two manned balloon-
flight experiments originating at St. Louis and moving gen-
erally eastwardly with the wind for 150 to 200 miles. In
these experiments, instruments in both of the balloons and
aboard the ground tracking vehicles, recorded pollutant con-
centrations essentially undiminished throughout both entire
long trips.
More recently, theoretical air-movement studies commissioned
both by the Ohio River Basin Commission and by ORBES were
done by Teknekron, Inc.,of Berkeley, CA. These studies in-
dicate that prevailing winds move polluted air masses up and
parallel to the Ohio River Valley. These air masses are
steadily "enriched" by power plant and industrial plumes as
they move from Paducah to Evansville to Louisville to Madison
to Cincinnati into our Northeast states.
Another study called MAP3S (An Investigation of Atmospheric,
Energy Related Pollutants in the Northeastern United States),
being done by Lawrence Livermore Laboratory, has already
recorded acid rains with pH readings well below 4 in both
Pennsylvania and West Virginial
Because of the Sierra Club's interest in the results of these
studies, copies of them were furnished to Mr. Helm's office
in Atlanta during and after the Kentucky Utility hearings in
Carrollton, with requests for his comments. After many
requests, we received the bureaucratic reply that only SO2
and particulates could be considered and those only
according to the EPA-accepted dispersion models. This would
be fine if only the sulfates and particulates knew they had
to obey those, and only those rules 1
For more documentation of health effects from other sources
I would like to read the following:
From "Environmental Pollution and Carcinogenic Risks" from
the World Health Organization INSERM Synposia Series, Vol. 52,
International Agency for Research on Cancer, Publication #13,
dated November 1975.
"There exists circumstantial evidence that 30% to 90% of
all cancers are dependent, directly or indirectly, on
environmental factors, using the term in its widest
connotation. Some investigators believe that at least
90% of the factors are chemical in nature."
COMMENT DOCUMENT - H, CONTINUED
5-50
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Page 6
From the Federal Register, Vol. 43 #10, Jan. 16 1978 pages
2229 to 2240:
The report of the Advisory Committee to USHEW commissioned
to study the health and environmental effects of increased
coal production and use. They concluded that it is safe
to increase the nations coal use substantially, ONLY:
if (1) compliance with stringent Federal and State air, water
and solid waste policies are required
if (2) universal adoption and successful operation of best
available control techniques on new facilities - are
required.
if (3) compliance with all reclamation standards are required
if (4) compliance with all mine health and safety standards
is required
if (5) judicious siting of coal fired facilities is required
In addition, there are four major areas of uncertainty and
concern requiring further investigation and identification.
These are:
1. Air pollution health effects
Current standards are not known to provide adequate
protection to the public from all combustion products.
2. Acid fallout
Precipitation acidity has increased. A major compre-
hensive study is needed.
3. Trace elements
Trace chemicals, heavy metals and radioactivity will
be released to the environment and to the food chain.
More data are needed to evaluate their potential.
4. Reclaiming acid and arid lands
CONSERVATION
9 Has LG&E considered the possible long-range effects of conser-
vation?
Two ardent supporters of the new conservation practices spoke
in Louisville just last Wednesday at the National Rural Electric
Cooperative Association meeting. TVA's David Freeman and lawyer-
economist Robert Marritz. We doubt that LG&E attended, so here
are three interesting and educational verbatim quotations:
"In many parts of the country, utilities are finding to their
consternation that higher rates and pleas for conservation do
result in reduced usage. Reduced usage means reduced revenues,
sometimes to the extent that rate increases need to be considered.
COMMENT DOCUMENT • H, CONTINUED
5-51
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Page 7
"For a growing utility system, conservation will be economically
beneficial in the long run, both to the consumers that practice
it, and to the system itself. Quite often the utility may
benefit as much or more economically than the conserving
customer. . . If the economists ever prevail and force us to
the inflationary action of selling energy at its full marginal
cost, this would simply move the indirect benefits into the
direct benefit column. The full burden and the rewards would
then fall to the individual consumer."
"In Seattle, a 50% drought surcharge resulted in some effective
conservation; for months usage (of electricity) hovered about
7.7% below forecasts."
To impress upon you what the economists call the "price elasticity
of demand", this 7.7% reduction should have been 10% theoretically,
CONCLUSIONS
10 The Sierra Club believes that both EPA and LG&E are seriously
underestimating the effects of price on future electricity
consumption. Instead of boldly challenging the largely unneeded
building program, EPA is hiding behind the skirts of the state
regulatory commissions, and accepting the utility-determined
growth goal as gospel. Have both EPA and the utilities forgotten
that natural gas is still furnishing three times as many BTU's
as is electricity? And further, that natural gas will still
be carrying this same BTU load in 1985 and probably much later?
It would seem prudent for all of us to listen to the conservation-
minded people like David Freeman, Amory Lovins and Robert Marnt^,
We should logically try to spread the energy load (and with it
the pollution load) among as many baskets as possible. The Ohio
River basket is already filled to overflowing.
COMMENT DOCUMENT - H, CONTINUED
5-52
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PROBABLE ELECTRICITY PRICE
( IN REAL 1977 DOLLARS)
INCREASE- 1985 TO 19 90
UNITED STATES AVERAGES
Ratio of Replacement Cost to Historical (Fixed Costs)
Av. of 32 Facilities Gross Assets Net Assets Depj
2.0-2.25* 1.9-2.1* 2.1-2
Cost of S0? Removal I O&M + Fixed Costs)
Apportioned Cost of Replacing Balance of All
Oil & Gas-Fired Plants with Coal or Nuclear
Approx. Markup
(%)
rec
*
.2 50%
20%- 2 5%
15%
Approx. Price Increase
(cents)
1.50
0.7
-------
Million Cub.. * ''
26
i
COMMENT DOCUMENT - H, CONTINUED
I
-------
RESPONSE TO COMMENT DOCUMENT H
Comment Number Response
1 Comment noted. Because the support for this comment
is supplied in the comments listed in the remainder of
the comment document, no response is made here.
2-7 Please refer to the attached letters from the Department
of Energy dated August 2, 1978 and August 31, 1978,
as well as the Summary of Major Concerns and Agency
Responses, pages 5-1 to 5-5 of this FEIS.
8 Sulfates are not regulated under PSD regulations, nor
is it a criteria pollutant regulated by EPA at this
time.
9 Conservation is one of the many factors taken into
account in the compilation of the load forecast published
in the DEIS.
10 Comment noted. No further response required.
5-55
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Department of Energy
Washington, D.C. 20545
Mr. Ted Bisterfeld
U.S. Environmental Protection Agency
Region IV
345 Court!and Street
Atlanta, Georgia 30308
Dear Mr. Bisterfeld:
This is in response to Mr. White's letter of June 16, 1978, requesting
assistance in replying to comments received primarily from Save the
Valley on the draft environmental impact statement (EIS) for the
proposed Trimble County Generating Station at Wises Landing, Kentucky.
I apologize for the delay in this reply.
I sent you under separate cover on July 27, a copy of our final EIS
on the Portsmouth Gaseous Diffusion Plant at Piketon, Ohio, ERDA-1555
(May 1977) for background material. At the request of Save the Valley,
a public hearing was held on the draft of this EIS in April 1977. A
lot of the material in 1555 will assist you in answering the comments
in detail.
The sketchy selected sections of the comments which you sent to us
and the lack of a copy of that EIS (which was not received by DOE),
makes it difficult to grasp the full impact of the comments on which
you have asked us to respond. However, I have taken a cut at most
of them based on what you sent since you wanted something in writing.
In ERDA-1555, we evaluated the environmental impacts of the operations
of the Clifty Creek and tyger Creek Power Plants located at Madison,
Indiana; and Gallipolis, Ohio respectively. This was done since both
plants supply the bulk of the power to the Portsmouth facility and
currently we utilize all the power generated by these plants.
I have to assume that the "federal facility in Ohio" is our Portsmouth
Plant. Therefore, with regard to your No. 114 comment, we feel that
the allegation is an exaggeration since we are complying with the
EPA-established compliance schedule to meet the new regulations.
Further treatment of NPDES Compliance is in Appendix Q, Volume 2 ot
ERDA-1555. We did consider the regional impacts of our continued
5-56
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Mr. Bisterfeld - 2 -
power procurement in ERDA-1555. With regard to Nos. 116, 117, and
118, we cannot speak for EPA but from DOE's standpoint, we are
procuring our power legally and are assisting OVEC in meeting pollu-
tion control standards at their plants. We do not just buy our
power from the Madison facility as I indicated earlier. We really
purchase it from the Ohio Valley Electric Corporation (OVEC). The _
alternative of converting the Portsmouth facility is treated in
ERDA-1555. In addition, the proposed add-on to the facility will
use the less energy consumptive uranium enrichment process as dis-
cussed in our final EIS, ERDA-1549 (September 1977), a copy of which
is enclosed for your information.
Comment No. 115 is not within our province. However, our ERDA-1555
EIS is probably the first to address the power generation issue for
at least two widely separated areas in the Ohio River Valley. Again,
without a copy of the draft EIS, we cannot comment on the completeness
of the discussion of alternate energy sources.
Comment No. 7 seems to deal with defense of facilities and probably
should be referred to DOD. Mr. Cassidy did testify at our -1555
hearing against nuclear plant proliferation (see page 11-114 in
ERDA-1555).
The Minto Wheel (No. 72) suggestion should be looked at by the utility.
If it is a good idea, they may buy it. DOE has done no work on such
an idea. DOE is conducting RD&D on solvent refined coal (No. 119)
and if the utility needs to use that technology to meet the environ-
mental requirements, it would be their option. Upgrading specific
facilities is something that EPA and the utility should consider.
We have no input into the alternative means for generating power or the
demand level by 1981 (Nos. 122 and 123) without more information. The
technologies listed can all be considered by the utility. However, I
seriously doubt that any of them would be available on a commercial
scale.in the time frame given. You may wish to contact BMI as suggested
by the commenter.
With regard to the last comments and extensive discussion by
Harold Cassidy and Fred Hauck (11-13, 24, 47, 103-108, 110, 111)
concerning projection of need for power, this is basically a local
or regional problem. However, I have passed this section on to our
5-57
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Mr. Bisterfeld - 3 -
staff in ERA to see if they want to review it. I will let you know
if they have any comments.
I hope that the two EIS1 and the preceding is helpful to you.
Sincerely,
7
innington, Director
vision of Program Review
and Coordination
Office of NEPA Affairs
Enclosure:
ERDA-1549
-1
5-58
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Department of Energy
Washington, D.C. 20545
August 31, 1978
Mr. Ted Bisterfeld
U.S. Environmental Protection Agency
Region IV
345 Court! and Street
Atlanta, Georgia 30303
Dear Mr. Bisterfeld:
Enclosed is the information discussed with Mr. Pennington during
recent telephone conversations.
Sincerely,
W. H. Pennington, Director
Division of Program Review
and Coordination
Office of NEPA Affairs
Enclosure:
Memo, C. Falcone to H. Pennington,
dated August 25, 1978
5-59
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Department of Enerc
Washington, D.C. 20461
ADGUST 25, 1978
MEMORANDUM FOR HERB PENNINGTON
IASp
FROM: /^CHARLES FALCONE
^r
SUBJECT: ^ COMMENTS ON THE NEED FOR TRIMBLE
COUNTY UNITS 1, 2 AND 3
Louisville Gas & Electric Company (LOGE) has proposed construction of
three coal-fired generating units (Trimble County 1, 2, & 3), one
each for June 1983, June 1985, and June 1987 respectively. These units
have projected capabilities of 495 MW, 495 MW and 675 MW respectively.
LOGE serves an area entirely within the boundaries of the East Central
Area Reliability Coordination agreement (ECAR) and Census Region No, 5.
These areas are nearly the same but do not correspond exactly.
The effects of the proposed Trimble County plant on the reserve margins
of ECAR are shown in Table 1 below, using data submitted April 1, 1978,
to the DOE by ECAR. This data assumes all projected plants are completed
on schedule and summer peak load growth averages 5.23% annually in the
period 1978-1987.
Table 1 - Effect of Trimble County Plant on Reserves
ECAR Growth Rate 5.23% - All Plants on Schedule
1983 1984 1985 1986 1987
With all 3 Trimble Units At Time of Summer Peak
Capability - MW 110,316 115,201 122,290 126,921 132,881
Peak Demand - MW 85,750 90,071 94,760 99,605 104,506
Reserve -MW 24,566 25,130 27,530 27,316 28,375
Reserve - % 28.7 27.9 29.1 27.4 27.2
Without all 3 Trimble Units
Capability - MW 109,821 114,706 121,300 125,931 131,216
Peak Demand - MW 85,750 90,071 94,760 99,605 104,506
Reserve - MW 24,071 24,635 26,540 26,326 26,710
Reserve - % 28.1 27.4 28.0 26.4 25.6
5-60
14391
-------
The DOE has found that industry practice, for predominantly thermal
generating systems, is to provide for projected reserve margins in
the range of 15 to 25 percent of peak load. Table 1 shows that the
ECAR regional projected reserve margins would exceed the upper end of
the usual range, and should be adequate based upon current industry
standards, if all the projected generating units (excluding the
Trimble County units) were to be completed as now scheduled, and if
the currently projected peak demands should not be exceeded.
Table 2 lists the reserve margins for ECAR and Census Region 5 based
upon studies using the DOE General Purpose Forecasting Program (GPFP).
Two cases for computing reserve margins were considered, one in which
construction slippage was assumed and one without slippage.* In all
cases in-service dates for all non-nuclear units were used as stated by
the ECAR companies while the probable nuclear unit in-service dates were
computed using "milestones" in the licensing process. Peak demand
growth rates of 4 and 6 percent were considered, with and without the
Trimble County Plant.
Table 2
Percent Reserve Margins for ECAR/Census Region 5
"With all 3 Trimble Units 1983 1984 1985 1986 1987
Demand growing at 4% annually
Reserve-% without slippage 40.6/37.3 39.3/35.6 37.1/38.3 37.6/38.1 34.7/34.5
Reserve-% with slippage 28.3/26.1 26.9/25.7 26.0/25.5 25,1/25.5 24,4/23.4
Demand growing at 6% annually
Reeerve-% without slippage 25.4/22.5 21.9/18.7 17.7/18.8 15,9/16.5 11,3/11.2
Reserve-% with slippage 14.4/12.4 11.0/10.0 8.2/ 7.7 5.4/ 5,7 2,8/ 2.0
Without all 3 Trimble Units
Demand growing at 4% annually
Reserve-% without slippage 39.9/36.8 38.6/35.1 35.8/37.4 36.4/37.3 32.8/33,1
Reserve-% with slippage 28.3/26.1 26.9/25.7 26.0/25.5 24.5/25.5 23,8/23,4
Demand growing at 6% annually
Reserve-% without slippage 24.8/22.0 21.3/18.2 16.6/18,0 14.9/15,7 9,7/10,0
Reserve-% with slippage 14.4/12.4 11.0/10.0 8.2/ 7.7 4.9/ 5.7 2.3/ 2.0
5-61
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The results of the GPFP study show that ECAR and Census Region 5 would be
below the usual industry reserve margin range in 1987 with or without
Trimble County, assuming a 6% annual growth rate even without slippage.
Assuming construction slippage and a 6% growth rate the reserve margin
would be well below 15% from 1983 to 1987, with or without Trimble County.
Delay of the three Trimble County units beyond 1987 would not cause
significant degradation of ECAR's reliability if ECAR's load growth rate
occurs as projected by ECAR (or at a lesser rate) and all other projected
capacity Is installed as now scheduled. However, EPA has decided not to
permit construction of at least one coal-fired plant now scheduled for the
ECAR region (Patriot No. 1, 650 MW for 1985; Patriot No. 2, 650 MW for
1987). Lack of the Trimble County and Patriot capacity would bring ECAR's
1987 reserve margin down to 24.3 percent. In view of the strong
possibility that other coal-fired units in the ECAR region may be delayed,
or may not at all succeed in obtaining construction permits, and considering
that nuclear units are generally delayed beyond their scheduled completion
dates, it appears imprudent to force cancellation of the Trimble County
units.
*Slippage is our best estimate of delays in the completion of
generating un£ts due to construction problems, modifying the
utility schedules. The amount of slippage used in the GPFP is
based upon th£ point reached in its construction at the time
the GPFP is used in making a study. A unit close to completion
would have a smaller amount of slippage than a unit that has
just started construction. In the GPFP calculations for the
Trimble County analysis the amount of slippage ranged from 0
months to 48 months. The slippage for each unit is based on
available information concerning completion of specific items
such as foundations, boiler erection, setting of steam turbine
in place, etc.
5-62
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FRED HAUCK
Environmental Consultants,
P. 0. Box 391,
or
Route 3, Tower Heights,
Shelbyville, Ky. 40065
March 29, 1978
Mr. Tom Helms, Deputy Director
Div. Air and Hazardous Wastes Materials
EPA Region IV
Atlanta, Georgia 30308
Attn: Mssrs. Howard Z Hagan, Gregory, Perry, etc.
Subject: Air Problems Connected With the
Proposed LG&E Wises Landing
Power Plant
Gentlemen:
I I think Region IV has misjudged the depth of study by the
opposition to LG&E's Wises Landing facility. Dr. Cassidy
and many others in the general Madison-Bedford vicinity
have devoted almost their entire waking hours for the last
two years doing in-depth studies of the power plant residuals
problems in the Ohio River Valley. The effective man-hours
would roughly equal those in your Draft Statement.
2 I have reluctantly come to the conclusion that: EPA is in the
business of granting their permission irrespective of need
or precise plant location. The dispersion modeling used,
based on our experience with your Chicago people, only
slightly resembles actuality in the Valley. It is incred-
ible that your people have not studied the St. Louis results,
the two Teknekron reports and the tentative MAP3S findings.
I thought, by this time, that all of you knew that SO2 leaves
the air only partially because of reactions with the soil,
our clotrfjb, automotive finishes, masonry, etc. The balance
is converted to the more insidious (SO ^ form, to be carried
hundreds of miles, returning to earth in rains with pH's of
sometimes as low as 3.5.
3 Will you study the very complete written material left with
you and diligently try to solve our air problems, or will
you grant LG&E's request in spite of the very doubtful need
of the Wises Landing facility?
Sincerel
.~
'Fred Hauck
COMMENT DOCUMENT -I
5-63
-------
Comment Number
RESPONSE TO COMMENT DOCUMENT I
Response
EPA recognizes the thoroughness of study by a number of
persons on the proposed project. The interest and concern
by all citizens is appreciated by EPA.
This is not a correct conclusion. EPA has considered the
location of the proposed source in relation to other
sources and has evaluated other sites for the plant. The
Department of Energy, with whom we have consulted on the
need for power, has not indicated concern that this plant
may not be needed.
The Chicago office (Region V) of EPA and Region IV EPA
are both aware of verification work presently being
performed on the EPA model predictions already done
in the Ohio Valley. However, both offices are restricted
to the use of approved models and both have recently
agreed to standardize their analyses of future valley
sources.
The studies mentioned are known to EPA. Teknekron's
data is still questionable and, until EPA verifies their
material and methodology, EPA will use its current
models.
Sulfur dioxide can have severe deteriorating capabilities,
especially for vegetation. The damage to crops in close
proximity to power plants having much greater emission
rates than proposed for Trimble County is well documented.
Long range transport of sulfates has been identified as
a problem in certain areas. It is not a criteria pollutant
and until it is, and until EPA has standards for it, sul-
fates will not receive priority weighting in EPA's
regulatory decisions.
EPA is diligently trying to solve the air quality problems
in the valley. Regarding to the second part of this
question, EPA has stated in this impact statement and at
the public hearing at Bedford, March 28, 1978, that the
air quality problems existing in the valley are the result
of existing sources operating well above new source
performance standards.
5-64
-------
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
REGION IV
101 MARIETTA TOWER, SUITE 1403
ATLANTA, GEORGIA 30323
OFFICE OF THE
Principal Regional Official
March 30, 1978
HEW 847-2-78
Mr. John £. Hagan, III
Chief, EIS Branch
Environmental Portection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
Subject: Trimble County Generating Station.
I We have reviewed the subject draft Environmental Impact Statement.
Based upon the data contained in this draft, it is our opinion
that the proposed action may have only a minor impact upon the
human environment within the scope of this Department's review;
except in the areas of financial assistance to local governments
from the influx of construction workers.
Table 14 shows a maximum increase of 695 new jobs for plant con-
struction employment which indicates a major impact on the econo-
my of the area.
2 Table 14 lists the amount of estimated taxes that the State and
local governments will receive during the construction of this
facility. This office's concern is in the areas of (1) Educa-
tion; (2) Health; (3) Law Enforcement; (4) Infrastructure
Needs; (5) General Government Costs, and (6) Welfare and other
social needs. If the amount of taxes estimated in Table 14 is
sufficient to alleviate the higher burden of the local government's
fisc due to the Influx of construction workers, then the Power
Company's liability is zero. This Department still feels that
the impact statement should be conditioned to require the Power
Company to extend financial assistance to mitigate any impact
upon the local government's fisc resulting from the influx of
the project worker and their families who accompany them (but
not persons who migrate to the area to purvey goods and services
to project workers) during the period of project construction.
The assistance is necessary In the previously mentioned areas
of possible additional costs to the extent they are not covered
COMMENT DOCUMENT - J
5-65
-------
Page Two
Mr. John E. Hagan, III
March 30, 1973
by increased tax revenues and fees attributable to the presence
of project workers or increased financial assistance from higher
levels of government. The Power Company and the local governments
should negotiate to establish a maximum liability figure in these
areas to insure the local governments are not overburdened as a
result of this construction.
Thank you for the opportunity to review this statement. Please
note change of address.
Sincerely yours,
•' • / ' -
i / < '•' 7~ <--/"' ' -/ •' --
Philip I. Sayre 'y
Regional Environmental Officer
Region IV, DHEU
cc: Ms. Mary Miller, OEA
COMMENT DOCUMENT - J, CONTINUED
5-66
-------
RESPONSE TO COMMENT DOCUMENT J
Comment Number Response
1 Comment noted. No response required.
2 EPA cannot condition its permit to require LG&E
to extend financial assistance to the local govern-
ment. It can and does encourage LG&E to work with
the local government to mitigate the impact of the
proposed project. LG&E is currently working closely
with the Trimble County School Board to assist them
in planning for an influx of new students as a result
of project construction. Furthermore, LG&E has
arranged to pay a higher rate of tax on the Wises
Landing site, prior to and during construction, than
that which was assessed on the land in its previous
(and still existing) agricultural use. LG&E is, in
addition, willing to coordinate with the city of
Bedford and county officials in planning for the
demands for services that would be placed on the
town and the county as a result of the project.
LG&E has indicated that any financial assistance
that it might wish to provide to local government
would probably have to be approved and regulated
by the Kentucky Public Utilities Commission.
3 Comment noted. No response required.
5-67
-------
OHIO RIVER BASIN COMMISSION
Suite 208-20 36 East Fourth Street
Cincinnati. Ohio 45202 513/684-3831 (FTS)
March 30, 1978
Mr. John C. White
Regional Administrator
U.S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30308
Dear Mr. White:
Thank you for your letter of February 7, 1978 inviting comments
of the ORBC on the Draft Environmental Impact Statement (EIS)
for the Trimble County Generating Station Units 1 and 4.
In my opinion the EIS has been properly coordinated with the
Commission members.
The Commission looks forward to a continuing cooperative effort
with your department and appreciates your action in keeping us
well informed.
Sincerely,
Fred E. Morr
Chairman
CC: (5) Council on Environ-
mental Quality
Uli CD" ^ " J <-* -I
Eugene F. Mooney |°A'*F-®M fV
ATLANTA'
4 1973
COMMENT DOCUMENT - K
5-68
-------
RESPONSE TO COMMENT DOCUMENT K
Comment Number Response
1 Comment noted. No response required,
5-69
-------
DR. BILLY H. STOUT. SUPT,
CECIL FISHER, o. p. p.
CLYDE CROPPER, FEDERAL CORD.
Trimble County Schools
P.O. Box 67 Phone: 502/255-3554
BEDFORD. KENTUCKY 40006
BOARD OF EDUCATION
CAROLE MARTIN, CHAIRPERSON
STEVE THARP, v. CHAIRPERSON
JACK CARDER, MEMBER
JAMES MCMAHAN, MEMBER
GLENN FISHER, MEMBER
March 30, 797*
Mft. John E. Hagan III, Chie.& E1S Branch
Environmental Protection Agenct/ Reg-tew IV
345 Courtland Street W.E.
MJUnta, Go.. 30308
M*.
|J0* thi& latter to become a part ojj -the hearing on -the proposed
County Generating Station. However, 1 Apeak neither. pro on con
;#ie A^nttton. My on£(/ conce/tn pnopoAzd by L.G.SE. mJUL, && stated in
the. EmjAJiomeMt&t Impact Stateme/tt, create, an in^Zax. o£ people into Jiimbte.
County. Because o£ the. anticipated influx. o& people, 7 am trying to obtain
fiinanciat a*&i&tanc.e. through Title. IX which ii> adnini&tefie.d through the.
U. S. VepaMmejvt o& CowtneAce Economic VeveJLopment Mnini&ttiation. Woweve/t,
they cannot ioute. an influx, oi peapte. into the. county. Enclo&e.d i& a
stating thei/i view.
Tke. Txjmbte, County Schoot Sy&tem i& at pteAent in need o£
We cannot accommodate, an additional 20 4 &o
dz&p&tate. that even 5 AtudentA would create, an even mole. Aeuete problem
than now exi&t. Thi& may Aeem kand to believe, but you can wittneA* thi&
by walking through out building*.
The. con&t^uction and operational peA&onneJL will &ind a dejUma wfien the.y
their. &tudent& in ouA. school &y*tejm. The.y wilt &ind teve/ie. crowded
condition* with no Apace, fat their. btudejntA. I be&ieve. the.y need to be. awane.
o& the. condition* be.&or.e. the.y move, into our. community.
We. cannot plan to con&truct additional school AaciJLitieA far. several
y&vu due. to our. financial condition. Ther.e.&or.e, our only hope, far additional
AaciJLtiieA to *erve. the. expected in{lux. o£ AtudejrvU i& through Title IX o£
the. U. S. PepaUhient o^ Commence Economic Development Administration.
COMMENT DOCUMENT • L
5-70
-------
MA. John E. Hagan III, Ckcetf EIS Bftandt
Atlanta, Ga. 3030S
It ^4 #uie t^C the geneAaUng AtaUon wiU. he£p ouJi tax. ba&e., but tk&ie.
x4 no he£p ion. the. ptLteznt. The. ^uMjiHe. may look bought bat the. px.Me.nt look*
dan -in \>-iva o& ouA exiting £a(UJU£i<>A and the. neiuine.** o^ the. pnopo&ed. con-
you.fi oAAiAtance. in obtaining Fede/utd &und& fan c.on&&tu.vtion o& needed
c6 heAe.by
&UUL Stout,
Tumble. County School*
EncJLo&uJie.
COMMENT DOCUMENT - L, CONTINUED
5-71
-------
U.S. DEPARTMENT OF COMMERCE
Economic Development Administration
SOUTHEASTERN REGIONAL OFFICE
X3DQ0X2Q8
210 E. Ninth Street, p. 0. Box 241
Hopkinsville, Kentucky 42240
November 11, 1977
Dr. Billy H. Stout
Superintendent
Trimble County Schools
P. 0. Box 67
Bedford, Kentucky 40006
Dear Dr. Stout:
Per our telephone conversation of this afternoon, I am writing in
regard to your letter to Congressman Snyder, who in turn contacted
our Southeastern Regional Office in Atlanta concerning your need
for a new school building.
I have studied your proposal in light of our Title IX (Special
Economic Development and Adjustment Assistance Program), and have
discussed the matter with the Southeastern Regional Office. For a
number of reasons, your proposal does not appear to qualify.
First, Title IX is not designed primarily to redress economic adjust-
ment problems associated with too rapid growth, but with actual or
impending catastrophic situations that have or will result in
significant unemployment, such as a major plant closing.
However, there are situations, such as the energy "boom towns" in the
West, that may qualify. In such situations, of course, there would
be such an influx of people that the community simply could not cope
with the demands for utilities and other services.
Trimble County does not seem to fit the "boom town" situation, to the
best of my knowledge. It has one of the lowest unemployment rates in
the state, and information obtained from the Kentuckiana Regional
Planning and Development Agency gives that agency1 s population estimate
for 1976 at 5,600 and for 1977 at 5,600. The Bureau of the Census
shows a population of 5,349 for 1970, so there is a slight increase
between 1970 and 1976, but scarcely of massive proportions.
COMMENT DOCUMENT - L, CONTINUED
5-72
-------
U.S. DEPARTMENT OF COMMERCE
Economic Development Administration
SOUTHEASTERN REGIONAL OFFICE
page L
As you doubtless know, Trimble County does not qualify for the
regular EDA program because of its healthy economic situation, and
even if it did, schools other than vocational schools would be
quite difficult to justify under EDA criteria, although we fully
appreciate and sympathize with your situation.
I am sending you a brochure on the Title IX program, and if you
still have questions or believe that the county would qualify, I
will, as I told you on the telephone, be glad to meet with you in
your office for a detailed discussion of the matter.
Sincerely,
William G. Glasscock
Economic Development
Representative,
Western Kentucky
cc: Mr. W. S. Hattendorf
COMMENT DOCUMENT • L, CONTINUED
5-73
-------
RESPONSE TO COMMENT DOCUMENT L
Comment Number Response
Please refer to Comment Document FF and the response to that
comment document, pages 5-319 to 3-320 of this FEIS.
5-74
-------
SAVE THE VALEY
SAVE THE VALLEY. INC.. P. O. BOX 813. MADISON. INDIANA 4725O
MEMORANDUM: COMMENTS ON THE DRAFT Eis FOR TRIMBLE COUNTY GENERATING
To: ENVIRONM!NTIL°DIVISIONA U,S, ENVIRONMENTAL F52TESII0^SfN^L-
PnilRTI AND ^TREET, ;' F , .ATLANTA, bA , 3Q3UG, AT i N I riS, /lONA tLLioJ.
O^UCK^filp^SgiT OF j-lATURAL ^^OURCES AND ENVIRONMENTAL
PROTECTION, CENTURY PLAZA— U,S, \LI SOUTH, IRANKFORT, UY, JJDUI
FROM: HALTER GROTE, MANUFACTURER
ON BEHALF OF; SAVE THE VALLEY, A NON-PROF JT ORGANIZATION OF MILTON, KY,
ANDHADISON, IN, CITIZENS, P,0, BOX 313, i SAD I SON, 1« 4//.-.J.
, ,
ANALYSIS OP THIS DhlS,
DATE: '1ARCH 1973
I HAVE BEEN A MEMBER OF "SAVE THE VALLEY" FROM THE BEGINNING, I HAVE
BEEN AWARE OF THE POLLUTION PROBLEM INCLUDING SULFUR DIOXIDE THAT EXISTS
IN OUR AREA, IT WAS HARD TO BELIEVE THAT LOUISVILLE GAS AND ELECTRIC
WAS PLANNING ON BUILDING A STILL BIGGER POLLUTER A FEW MILES DOWN THE
RIVER FROM THE EXISTING PLANT, NOT ONLY ANOTHER COAL FIRED POLLUTER,
BUT ONE TWICE THE SIZE OF WHAT WE NOW HAVE,
THERE ARE FOUR MAJOR REASONS WHY L G S E HAS DISQUALIFIED ITSELF FOR
WISES LANDING:
1 MAJOR REASON NUMBER ONE:
STACKING THE DECK BY L G a E BY GIVING A CONTRACT FOR THE ENVIRONMENTAL
IMPACT STUDY TO FLUOR PlONEER, INC.
2 MAJOR REASON NUMBER TWO:
TOP OFFICIAL OF L G & E TELLING US HOW SUCCESSFUL THEIR SCRUBBERS
OPERATE AND AT THE SAME TIME "HEDGING" ON VARIOUS PROSPECTUS FOR THE
SALE OF COMMON AND PREFERRED STOCK BY SAYING THAT THE SCRUBBERS WERE
"DESIGNED TO REMOVE" 35?. OF S02, BY SAYING THAT THEY "BELIEVED"
THEIR SCRUBBERS REMOVED, ,, ETC, IN NO CASE DID THEY STATE THE SCRUBBERS
WOULD ACJJJALLY. TAKE OUT 852 OF THE S02,
COMMENT DOCUMENT - M
5-75
-------
PAGE TWO
&JC^_aEASPJUJW1BER THREEi-
3 r,oYER, vICE PRESIDENT OF L G a E TELLING BEDFORD ROTARY CLUB - THREE
MAJOR REASONS FOR CHOSING WISES LANDING, HE DID NOT TELL THE TRUTH AND
MISREPRESENTED L 6 S E.
IAJOR RE/VSOJL-MMrWER FQUR;
4 THE DATA GIVEN TO PETCO ON CANE RUN 2*\ UNIT FOR SCRUBBERS IS NOT
"TRUTHFUL AND CONSTITUTES MISREPRESENTATION,
TO MAJOR REASON NUMB£S_QN£:
SEE NEXT PAGE (PAGE THREE)
COMMENT DOCUMENT • M, CONTINUED
D-76
-------
PACE THREE
(1) COMMENT DOCUMENT - M, CONTINUED
DURING THE PAST FOUR YEARS MANY MOVES HAVE BEEN MADE BY LOUISVILLE
GAS AND ELECTRIC AND F.PA THAT RAISE SERIOUS QUESTIONS IN OUR MINDS, IT
LOOKS TO US THAT THIS IS NOT AN ENVIRONMENTAL IMPACT STUDY AS SUCH, BUT
BY THEIR ACTIONS, AN ATTEMPT IS BEING MADE TO MANEUVER L G & E INTO A
QUALIFYING POSITION, THE FIRST OFFICIAL NOTICE THAT THIS ENVIRONMENTAL
IMPACT STUDY WAS A STEP IN GRANTING THE PERMISSION TO L G £ E, WAS A
LETTER FROM THE ATLANTA OFFICE OF EPA STATINP THAT L G S E HAD GIVEN A
•TJNTATTVF CONTRACT" TO MAKE THE STUDY TO FLUOR PIONEER CORPORATION,
THIS LETTER FROM EPA ARROUSED VERY SERIOUS QUESTIONS IN OUR MINDS AS
TO WHAT WAS GOING ON BETWEEN THE EPA AND L G £ E, THE STATEMENT IN THIS
LETTER THAT THE CONTRACT WAS TENTATIVE IS NOT THE TRUTH, V|E KNEW FOR
SOME TIME THAT ACTUAL WORK AND CONSIDERABLE WORK HAD BEEN PERFORMED ON BOTH
THE AIR AND THE WATER STUDY, V.'E HAD ALREADY LEARNED THAT THE FLUOR
PIONEER CORP, HAD THE CONTRACT TO MAKE THIS VERY SENSITIVE STUDY WHICH
WOULD AFFECT THE HEALTH, SAFETY AND WELFARE OF THE PEOPLE IN OUR AREA,
OUR LAWYER IN PRESENTING OUR CASE TO EPA CITED A COURT DECISION
PERTINENT TO THIS SITUATION - WHEREIN THE COURT SPOKE OF THE DANGER OF
"STACKING THE DECK", IN THE STATEMENT OF DR. CASSIDYj HE POINTS OUT
A HISTORICAL CONNECTION BETWEEN L G S E AND FLUOR PlONEER AND THE FACT THAT
THEY HAD OVER HUNDREDS OF MILLIONS OF DOLLARS OF CONTRACTS FROM L G S E
AND WERE IN LINE TO DO PART OF THE WORK ON THE ttlSES LANDING PLANT, IF
IT WAS BUILT, (A DISPICABLE CONFLICT OF INTEREST.) 1,'HEN A PERSON
STACKS THE DECK IN A CARD GAME, HE LOSES HIS CREDIBILITY AND
TRUSTWORTHINESS, To STACK THE DECK WHEN THE ISSUE IS THE HEALTH OF
A LARGE COMMUNITY OF MEN, WOMEN AND CHILDREN,,THE PEOPLE, OUTRAGED,,
HAVE THE RIGHT TO EXPECT THAT NEVER AGAIN WILL THEY BE EXPOSED TO THE
OFFICIALS OF L G a E. L G £ E BY THIS DASTARDLY DEED, DISQUALIFIED
THEMSELVES, AND UNDER NO CIRCUMSTANCES SHOULD THE PEOPLE HERE BE
EXPOSED TO SUCH TRICKERY BY L G &_E,,
-------
PAGE FOUR
COMMENT DOCUMENT • M, CONTINUED
VfE, BECAUSE OF SUBSEQUENT ACTIONS AND MANEUVERS ON THE PART OF EPA
NOW HAVE A SERIOUS QUESTION AS TO WHETHER OR NOT EPA KNEW THAT ACTUAL WORK
HAD BEEN PERFORMED ON THAT IMPACT STUDY BY THE FLUOR PIONEER CORP,
THAT IT WAS NOT A TENTATIVE CONTRACT, THAT ACTUAL WORK WAS PERFORMED,
V'E WISH TO ASK EPA IF THEY KNEW THAT ACTUAL WORK WAS PERFORMED, THEN
THE FACT THAT THEY HAD DISQUALIFIED FLUOR PlONEER AND THE ADMISSION
THAT THEY MAKE BY SO DOING, THEN WE FEEL THEY HAVE PREJUDICED
THEMSELVES IN HANDLING THIS VlSES LANDING PROPOSAL,
(2)
OFFICIALS OF LG X E TELLING us HOW SUCCESSFULLY THEIR SCRUBBERS WORKED, AND
THEN HEDGING AND QUALIFYING THEIR STATEMENTS WHEN IT CAME TO THE SALE
OF SECURITIES TO PAY FOR THE SCRUBBERS, UE OFFER COPIES OF THEIR
PROSPECTUS FOR THE SALE OF PREFERRED STOCK OF JUNE 15, 1976,,
REFER TO PAGE 13, PARAGRAPH 6 WHICH READS AS FOLLOWS:
"THE S09 REMOVAL SYSTEMS BEING INSTALLED ARE OF THE WET SCRUBBING
4_
TYPE SIMILAR TO THAT DEMONSTRATED SUCCESSFULLY BY THE 65 i.W PADDY'S RUN
UNIT 6 FULL-SCALE DEMONSTRATION SYSTEM INSTALLED IN 1973, BASED ON
THE OPERATING EXPERIENCE OF THAT SYSTEM, THE COMPANY IS OF THE OP I ON I Oil
THAT THE INSTALLATION OF SIMILAR SCRUBBER SYSTEMS ON ITS LARGER UNITS
WILL SUCCESSFULLY CONTROL S02 EMISSIONS, THE TOTAL COST TO INSTALL
THE SEVEN SO? REMOVAL SYSTEMS IS ESTIMATED TO BE MORE THAN 0195 MILLION,
THE QUALIFICATION IN THIS PARAGRAPH THAT "iT IS THE COMPANYS OPIIITO
THAT IT WILL DO IT,, IT DOES NOT SAY THAT IT HILL DO IT,
A SECOND PROSPECTUS OF SEPTEMBER 1976 - COMMON STOCK, PAGE I'l NOTE
PARAGRPAH 5, "THE S02 REMOVAL SYSTEMS BEING INSTALLED ARE OF THE
WET SCRUBBING TYPE SIMILAR TO THAT DEMONSTRATED SUCCESSFULLY BY THE
65 flw PADDY'S RUN UNIT 6 FULL-SCALE DEMONSTRATION SYSTEM INSTALLED
IN 1973, BASED ON THE OPERATING EXPERIENCE OF THAT SYSTEM, THE COMPANY is
OF THE OPINION THAT THE INSTALLATION OF SIMILAR SCRUBBER SYSTEMS ON ITS
LARGER UNITS WILL SUCCESSFULLY CONTROL S02 EMISSIONS, THE TOTAL COST
TO INSTALL THE SEVEN S02 REMOVAL UNITS IS ESTIMATED TO BE MORE THAN
5-78
-------
*\GAIN THE-,WORD "OPINION'7 IS USED,,NOT THAT THE SCRUBBERS HAVE BEEN
SUCCESSFULLY PROVEN, AS THEY TELL US,
THIRD PROSPECTUS, AUGUST 6, 1976,,NOTE PAGE 3, THRID PARAGRAPH,
ESPECIALLY THE UNDERSCORED LINE: "THE SULFUR DIOXIDE SCRUBBER SYSTEMS
ARE DESIGNED TO REMOVE 857U OF AIRBORNE SULFUR DIOXIDE TOGETHER WITH
A PORTION OF ANY PARTICULATE HATTER REMIANING IN FLUE GASES EXITING
FROM ELECTROSTATIC PERCIPITATORS," (AGAIN THEY DO NOT CLAIM THAT THEY
DO,) ALSO IN THIS SAME PROSEPCTUS IS REFERENCE TO A GRANT BY EPA
TO L G & E TO TRY AND SOLVE THE SLUDGE PROBLEM,
(3)
ROYER TOLD THE BEDFORD P.OTARY CLUB THAT THERE WERE THREE MAJOR REASONS FOR
CHOSING WISES LANDING, ENCLOSED IS A COPY OF THE TRIMBLE BANNER, HE
OUTLINED A NUMBER OF COUNTIES SERVED WITH ELECTRIC BY L G & E, INCLUDING
TRIMBLE AND HENRY COUNTIES, 1'flSES LANDING IS IN TRIMBLE COUNTY, V!E KNEW
THAT HE WAS MISREPRESENTING THE ELECTRIC AREA OF L G S E
N'E CONTACTED THE L G £ E OFFICE AT LOUISVILLE, Vfp. FINALLY TALKED TO
THE MAN WHO KNEW THE SUBJECT, VlHEN WE READ OUT THE COUNTIES MENTIONED
BY DvOYER, THIS MAN SAID THAT THOSE COUNTIES WERE FOR GAS DISTRIBUTION,
THAT THEIR ELECTRIC DISTRIBUTION AREA DID NOT EXTEND THE SAME AS THEIR
GAS SERVICE, H£ MAILED US A MAP, WHICH I AM SHOWING HERE, II IS
THE ORIGINAL, WE WANT IT FOR FUTURE USE, ALSO WE HAVE PUBLIC SERVICE
COMMISSION MAPS WHICH SHOW THAT L G S E HAS A HAND FULL OF CUSTOMERS
ALONG THE OLDHAM - JEFFERSON COUNTY LINE AND ALSO A FEW CUSTOMERS
ON THE TRIMBLE - HENRY COUNTY LINE, l''lSES LANDING IS FAR REMOVED
FROM THE ELECTRIC SERVICE AREA OF L G S E,
THE SECOND REASON FOR ROYER CHOSSING VflSES LANDING WAS THE
EXISTING TRANSMISSION LINES, YOU DO NOT NEED TRANSMISSION LIMES
FOR AREAS YOU DO NOT SERVE, EXCEPT FOR A HANDFUL OF CUSTOMERS ALONG
THE COUNTY LINE, APPROXIMATELY 99? OF TRIMBLE AND IJENRY COUNTIES ARE
SERVED BY KENTUCKY UTILITIES AND SHELBY n.URAL ELECTRIC CORPORATION,
COMMENT DOCUMENT - M, CONTINUED
5-79
-------
PAGE 6
WISES LANDING IS ISOLATED, IT IS LIKE BEING ON AN ISLAND SURROUNDED
BY KENTUCKY UTILITIES AND SHELBY RURAL ELECTRIC,
THE THIRD REASON GIVEN BY ROYER WAS: THE OHIO RIVER, IT ALSO FLOWS
THE LENGTH OF OLDHAM AND JEFFERSON COUNTIES, OLDHAM AND JEFFERSON
COUNTIES ARE CLOSER TO THE COAL FIELDS, AND IF THEIR PLANT WAS
BUILT IN OLDHAM COUNTY, IT WOULD BE SO LOCATED THAT THEU COULD ACCOUNT
FOR OVER 802 OF THE DOLLAR SALES,
(4) (REFERRENCE TO MAJOR REASON FOUR)
THE DATE GIVEN TO PETCO ON CANE RUN #H UNIT FOR SCRUBBERS IS NOT
TRUTHFUL AND CONSTITUTES MISREPRESENTATION.
THE PETCO REPOPxT is ISSUED EVERY FEW MONTHS, IT is COMPILES UNDER A
CONTRACT FROM EPA, WHY DOESN'T DOESNT THE PETCO REPORT TELL THE
TRUTH ABOUT THE FAILURE OF THE CAME RUN #-'-! UNIT SCRUBBERS? WHY DOES EPA
PERMIT THIS FALSE REPORTING? THE REPORT INCLUDES A STATEMENT THAT
BECAUSE THE GREEN RIVER WAS FROZEN DURING THE EARLY MONTHS OF 1977,
THEY COULD NOT BARGE THE CALCIUM HYDROXIDE FOR USE IN THE
SCRUBBERS. DR, CASSIDY AND THE WRITER, ABOUT TWO WEEKS AGO, IN A
MEETING WITH EPA IN ATLANTA, ASKED,,"FROM WHAT POINT ON THE
GREEN RIVER DID L G & E BARGE THE CALCIUM HYDROXIDE?" AFTER ASKING
THE QUESTION ABOUT THREE TIMES, ONE OF THE MEN PRESENT SAID,,
"l KNOW WHERE IT IS." WHEN ASKED WHERE, HE SAID, "RIGHT NEXT TO THEIR
PLANT." THIS IS A HUGE PILE OF CALCIUM HYDROXIDE, A BY-PRODUCT
OF AN ACETELINE PLANT THAT HAS BEEN SHUT DOWN BECAUSE THE PROCESS
IS OBSOLETE.
COMMENT DOCUMENT - M, CONTINUED
5-80
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PAGE 7
THIS CLAIM THAT THE FROZEN GREEN RIVER PREVENTED OPERATION OF THE
SCRUBBERS IS DISCREDITED BY THE LETTER OF L G X E, FEBRUARY 11, 1977
TO PAUL J, TRAINA, DlR, ENFORCEMENT DIV, ENVIRONMENTAL PROTECTION
AGENCY, REGION IV, 345 COURTLAND STREET, ATLANTA, GA, 30308, PAGE 2
PARAGRAPH 5,,THIS LETTER STATES:"WITHOUT COMPLETION OF THE
MODIFICATION PROGRAM ON THE CANE RUN #4 SDRSK, THE TEST FOR
COMPLIANCE WOULD NOT BE MEANINGFUL." THIS SENTENCE THAT THE OPERATION
WOULD NOT BE MEANINGFUL MEANS THE SCRUBBERS WERE NOT PERFORMING TO
t
STANDARD AND WOULD NOT BE MEANINGFUL IF THEY WERE USED, SO VAN NESS
TALKING ABOUT THE GREEN RIVER IS A MISREPRESENTATION ,,AN ATTEMPT TO
COVER UP THE FAILURE OF THE SCRUBBERS TO OPERATE AS THEY SHOULD,
AT A PUBLIC MEETING BEFORE THE JEFFERSON COUNTY POLLUTION CONTROL
BOARD, VAN NESS ASKED THE BOARD FOR AN EXTENSION OF COMPLIANCE
DATE FOR CANE RUN #4, WHEN VAN NESS WAS ASKED THE QUESTION, "THE FACT
THAT YOU ARE ASKING FOR AN EXTENSION FOR A COMPLIANCE DATE, IS THAT
NOT AN ADMISSION THAT THE SCRUBBERS HAVE FAILED?" VAN NESS SAID, "YES,"
HE AGAIN, UNDER QUESTIONING, ADMITTED IT BEFORE THE MADISON ROTARY CLUB,
THE SAME SCRUBBERS CANE RUN ?A THAT VAN NESS TIED INTO THE GREEN RIVER
REPORTING,
COMMENT DOCUMENT • M, CONTINUED
5-81
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PAGE 8
5 THE OR3ES REPORT (ll-B-249) STATES THAT IT is UNETHICAL TO BUILD A COAL
FIRED PLANT OUT OF A UTILITIES SERVICE AREA AND TRANSPORT ELECTRIC BACK TO
ITS SERVICE AREA. IT SAYS PEOPLE WHERE THE PLANT IS LOCATED ARE
SUBJECTED TO HEALTH HAZARDS AND DO NOT GET BENEFITS OF THE ELECTRICITY
WHICH IS TRANSPORTED OUT OF THEIR AREA,
6 THE SIGNED STATEMENT OF THE MANY DOCTORS OF JEFFERSON AND
SWITZERLAND COUNTIES SHOULD BE A WARNIGN TO L G £ E THAT IT WOULD,
BY BUILDING ANOTHER MONSTER COAL~FIRED POLLUTER IN OUR AREA, BE
TAKING A TREMENDOUS RISK OF INCURRING SERIOUS CONSEQUENCES IN
CONNECTION WITH THE HEALTH, SAFETY AND WELFARE OF THE PEOPLE IN
THIS AREA,
7 IF EPA CONTINUES THEIR PROMOTION OF L G ?« E S EFFORTS FOR
WISES LANDING, THEY WOULD PUT THEIR STAMP OF APPROVAL ON A
MONSTER POLLUTER, PROMOTED BY UNTRUTHFUL STATEMENTS AND
MISREPRESENTATIONS AND IT WOULD BE A FURTHER INVASION OF THE RIGHTS
OF THE MEN, WOMEN, AND CHILDREN OF THIS AREA, AS TO THEIR HEALTH,
SAFETY AND WELFARE,
COMMENT DOCUMENT • M, CONTINUED
5-82
-------
LOUISVILLE GAS AND E L K C T R I C COMPANY
lHCOR?»O*AYr.O JH KFN1UCKY
P. O. POX 354
LOUISV1LU-., KY. 40201
February 11, 1977
Mr. Paul J. Traina
Director
Enforcement Division
U» S. Environmental Protection Agency
PvCgion IV
345 Co-jrtland Street
Atlanta, Georgia 30308
Dear lir. Traina:
In answer to your letter of January 26, 1977, to our Mr. B. H.
Kilner, concerning the sulfur dioxide emission test of our Cane Run
Unit A" SI)RS syste-.ni, the unit has operated, since start-up, with good
aveiilab5.1ity and reliability; hut it has not met the guarantee for S
-------
l J. Traina -2- February 11, 1577
During this period, maintenance and inspection of the
scrubber will be done along with the following scrubber modifi-
cations:
a. Installation of turning vanes at various lo-
cations in the gas ducts to improve pressure drop
through the system at high boiler loads.
b. Installation of an additional slurry spray
header system in the contactors to improve the SO^
collection, efficiency at maximum boiler load.
c. Replacement of the underbed spray nozzles
with a new type.
The severe cold weather which has occurred in our section of the
country, coupled with the critical energy shortages in the midwest during
the last 45 days, has set back our maintenance nn<3 modification program
for Cane Run Unit 4, as well as the maintenance programs of other units
atr our Cane. Run and Mill Creek Stations. 'Without completion of the
modification program on the Cane Run 4 SDKS, the test for compliance
would not be meaningful. )
We are, to say the least, not happy with the fact that the scrubber
has not met the guarantee at maximum boiler load and arc continuing to
press the vendor to provide the necessary material and equipment for the
jaodification program at the earliest possible (late.
We are extremely confident that through the research and model
testing that has been done and upon completion of the outlined modifi-
cation^prograni, that the scrubber will'be ready for testing by no later
than August 1, 1977. Therefore, \>*e respectfully request that the con-
sent agreement for Cane Run Unit 4 be modified to allow the compliance
test to be started on or imnadiately after August 1, 1977.
Yours truly,
R. P. Van Ness
Manager, Environmental Affairs
RPV/ga /
cc: Messrs. R. T. Offutt, JCAPB V
B. Talbott
J. F. Mayrose
R. I,. Royer
R. C. Soxners
COMMENT DOCUMENT • M; CONTINUED
5-84
-------
RESPONSE TO COMMENT DOCUMENT M
Comment Number Response
1 At the time of initiation of EIS preparation, when LG&E
nominated Fluor Pioneer Inc. (now Fluor Power Services, Inc.)
to be the third party consultant, EPA had serious reservations
about having the Applicant's design firm prepare the EIS for
EPA. That is why EPA asked the public and other agencies for
comments on Fluor Pioneer as EPA's consultant. As a result
of the comments received, EPA disapproved Fluor as the third
party consultant. Dames & Moore was subsequently nominated
by LG&E as the third party consultant. Dames & Moore's
qualifications were circulated to the public and other
agencies for comment on their acceptability as a third
party consultant, and no adverse comments were received.
Dames & Moore was therefore accepted by EPA as its consultant.
All data obtained from Fluor Pioneer and its subcontractors
by Dames & Moore was checked for accuracy prior to inclusion
in the DEIS. All assessments of project impact were made
totally by EPA through the assistance of Dames & Moore.
2 Comment noted. No response required.
3 Inasmuch as the northeastern extremity of LG&E's electric
service area is roughly the Oldham-Trimble County line,
extending slightly into Trimble County, Trimble County was
correctly described as being on the edge of LG&E's north-
easternmost service area. The plant location is described
as northeast of the service area, implying that it is,
therefore, outside such area.
Further on, Mr. Royer made reference to local rural co-ops,
supplied by Kentucky Utilities and East Kentucky Power
Cooperative, as the actual suppliers of power to the
immediate area.
Taken in context, and recognizing that the audience to
which Mr. Royer was addressing his remarks was thoroughly
familiar with the area, the suppliers of electricity thereto,
and the limited nature of LG&E's services in the area, we
find no intent in those remarks to misrepresent LG&E's
interests in Trimble and Henry Counties.
Rather, it appears obvious that the intent was to acknowledge
LG&E's limited involvement in electric service in those
counties, while pointing out, nevertheless, that (1) LG&E
does have other interests in the residents of this area,
5-85
-------
RESPONSE TO COMMENT DOCUMENT M, Continued
Comment Number
3 (continued)
Response
(2) the reliability of electric service in the area would
be enhanced by an adequate power supply in the area,
irrespective of who owned or operated the facilities, and
(3) a power source northeast of its service area would
meet a significant objective of its site selection
criteria.
In any event, EPA was fully aware of the geographic
relationship between the site at Wises Landing and LG&E's
service area, has set same forth in the EIS, and has
appropriately considered this in its analysis.
Mr. Grote's comment, "You do not need transmission lines
for areas you do not serve," is not true. The purpose of
transmission lines is not limited to direct service to
ultimate consumers. Due to the necessity of interconnec-
tions with other utilities and to the economic, engineering,
reliability and other considerations in transmitting
power, transmission circuits must be routed relatively
free of geographic constraints, and transmission circuits
must be routed as required to interconnect power sources,
substations, or combinations thereof, and often extend
well beyond a utility's geographic service area. One of
the major reasons for selecting the Wises Landing site is
that it is very close (i.e., a few span lengths) to the
existing 345 kV Middletown-to-Clifty Creek transmission
line. This close proximity minimizes the expenditures
and right-of-way clearing for additional transmission
facilities.
It is true that the reference to the Green River does
appear in some of the PEDCO reports. PEDCO inadvertently
substituted the Green River instead of the Ohio River in
the report. LG&E actually reported to PEDCO that the
barges transporting calcium hydroxide additive to Cane
Run Generating Station could not move due to the Ohio
River being frozen over during unprecedented cold weather.
With respect to LG&E's letter of February 11, 1977 to
Mr. Paul J. Traina, the letter stated that the Cane Run
Unit $4 SO- removal system was operating reliably
and at design efficiencies at lower boiler loads, but
that the SO. removal system would require, by the
manufacturer, modification as described in detail in the
letter, to insure that the LG&E specified design effi-
ciencies, at maximum boiler load, were attained. Since
meeting the SO,, efficiency requirements, especially
at maximum boiler loading, was in doubt prior to such
5-86
-------
RESPONSE TO COMMENT DOCUMENT M, Continued
Comment Number
4 (continued)
Response
6
7
modifications, LG&E requested a delay to August 1, 1977
of the official performance test and subsequently extended
the request to August 15, 1977, when it became apparent
that the completion of the modifications would require a
longer period of time than anticipated. Actually, the
official performance test for compliance was completed
and compliance certified on August 4, 1977.
At the public hearing of August 10, 1977, in response to
the request by LG&E for the time extension of the compli-
ance date, which was subsequently granted, Mr. Grote
asked "the fact that you are asking for an extension for
a compliance date, is that not an admission that the
scrubbers had failed." Mr. VanNess replied, "yes, as of
this date," since the scrubber is not considered to be in
compliance officially until the performance test is
completed satisfactorily. Actually, the system had
operated for some time in compliance with the Jefferson
County Air Pollution Control Board's emission regulations
of 1.2 Ib per million Btu at various loads.
It is not unusual for major equipment as complex as
these systems to require some modification of the equip-
ment to meet efficiency guarantees.
The region which ORBES refers to is the ORBES study
region, not just the Ohio River valley. In the ORBES
Phase 1: Interim Findings, November 1977, page 142, there
is a list of the assumptions used by ORBES common to all
the senarios, including the Bureau of Mines scenario. It
states that energy production and consumption within the
region are equal through the year 2000 (no power exports).
Power presently planned along the Ohio River is transmitted
distances of 100 plus miles. The Wises Landing site
is about 30 miles from LG&E's system load center.
The health and welfare of all citizens are the concern
of EPA.
Comment noted. No response required.
Comment noted. No response required.
5-87
-------
REF. NPDES No.: KY0041971
Comments on the Draft EIS for Trimble County Generating Station.
April 3, 1978
Preface
The theme of this White Paper is taken from a book by George
Paloczi-Horvath: to an open and logical mind facts rebel against
self-serving interpretations by those who would profit in some way
from exploitation of misinterpretations of the facts.
Often, of course, there are legitimate differences in opinion
based on agreed facts. But in many cases of ecological disagreement
of opinion, the facts are not available. For example, the Draft
Environmental Impact statement [DEIS] points out on page 2-4, that
air quality data are lacking for the Trimble County area. Then
opportunistic speculation may take over, as in the case of flue gas
desulfurization [FGD] technology, where a great deal of money in-
vested in research on a wide variety of processes is at risk and
undoubtedly "tilts" judgment.
At risk, however, is our health — the quality of life of the
citizens who in general have little say about what is done to them
through environmental manipulations. It is in this area that EPA
is supposed to function. They should be our shield against exploit-
ation by any people or organizations that assail our health, whether
through stupidity, cupidity, carelessness or veniality, or even with
worthy motives.
It is true that EPA has an extraordinarily difficult job. They
should not take sides. Their function is to hold a tight rein on the
three horses of progress—or of potential apocalypse: facts, opinions,
and tradeoffs. The problem is complicated because the people in the
regional offices do not seem to have enough money (or imagination?)
to visit the sites that they legislate for long enough to understand
their problems. Instead, they "mddel" the projected results of an
action from maps and books on the bases of premises presumed reason-
able.
We experience this approach in connection with the subject of
this White Paper: the proposed Trimble County Generating Station,
which is locally called the proposed Wise's Landing Station. We are
told that this proposed plant, to consist eventually of two 495 MW and
two 675 MW power generating units, located about 12 miles S of the
Clifty Creek power plant at Madison, Indiana, and about 30 miles NE
of the City of Louisville, would have practically no effect on us at
Milton, Kentucky, and Madison, Indiana.
It must be known that the Clifty Creek station is an uncontrolled
emitter of more than 286,000 tons of SC>2 annually. The City of Louis-
ville and Jefferson Co. Kentucky produce some 280,000 tons of SC-2,
annually. This number may decrease somewhat as the Jefferson County
controls take effect. If the proposed Wise's Landing plant were to
meet EPA "conditions," namely tb.emit at the rate of 0.78 pound of
S02 per million BTU of heat output (Draft Environmental Impact State-
ment [DEIS] p. 53) the plant would release over 70,000 tons of SC>2
annually, adding this to the Valley's burden of pollution. But we
assert on evidence that the burden would be vastly enlarged over this
amount.
Further, wind rose determinations taken over a period of a year
-»•- COMMENT DOCUMENT - N
5—88
-------
-11-
(1974) at Marble Hill, across the river from the Wise's Landing site and
less than one mile down-stream (air-line) report that prevailing winds
are from the SE and S about 22.9% of the time; from the N and NW about
15% of the time, with calms occurring some 18% of the time when measured
in the river valley (Marble Hill Final Environmental Statement, p. 2-20).
It is argued in the DEIS that a study showed that the Clifty Creek
plant is not in compliance with air quality requirements, and that if the
plume from the Wise's Landing plant were to interact with this plant
"this violation would have occurred even if the Trimble County plant
were not in operation, as the concentration contributed by'this plant
was only O.lmg/M ." Thus the argument goes, having a violation already,
a little more pollution does not count. [pp. 55, 56] We take exception
to the statement especially since, as we point out, the modeling used
understates the interaction.
There are two really serious matters at issue here. One is the
modeling procedure, At first, in the Draft Pre-Construction Review,
October, 1976 and again in the Final Determination, March, 1977, the
4 units of the proposed plant "will be in compliance with EPA's regula-
tions..," for PSD of December 5, 1974 (pp. I5ff).
The categorical "will be in compliance" should, in the first place,
be correctly stated as "would be in compliance if conditions were met
...." (see below). As far as we can see, incorrect modeling was used.
The plant would be in a river valley with 300 to 400-ft. banks. The
models used, PTMAX, CRS, PTMTPW, and AQDM appear, as applied, to be
"plains" models. No account is taken of the channeling effect of the
river banks. Indeed, we were told, when we visited the Atlanta office
of EPA, Region IV, that adjustments in the calculations could be made
by lowering effective stack height in instructions to the computer. Our
protests that as residents we continually observed' the plume from Clifty
Creek station following the river and, indeed, sinking into the valley,
were minimized and even, perhaps, ignored.
One small satisfaction came some weeks later when one of the EPA
Region IV staff members had the grace to phone and tell us that he had
been travelling and took the opportunity to stop off at Madison to
look at the situation. On that day, he found, we had a temperature
inversion, or some other meteorological phenomenon such that the Clifty
Creek plume was sweeping down into the town (which lies in the Valley),
and along Main Street, He got a dose of particulates and S02- He said
--perhaps for emphasis--that it took him two hours to get the stuff out
of his lungs, and was having to re-calculate the modeling.
Now, the DEIS acknowledges that there may be a problem here:
"Generally, the service area is characterized by rolling hills.... This
could present a potential air quality problem due to plume impaction
on the hills or to downwash effects. Within the Ohio River Valley,
the flood plain is of varying width but is flanked on either side by
bluffs that typically rise 400 ft, from the valley floor. Air quality
problems associated with plume impaction and downwash effects are
likely to occur along the entire reach of the Ohio River." (p. 2-4)
LEmphasis added.]
We who live here know that there are problems--it's not a question
of "could present" and "are likely". The problems exist most of the
COMMENT DOCUMENT - N, CONTINUED
5-89
-------
-11L-
time, We therefore find ourselves unable to understand the arrogance of
theoreticians in Atlanta (and Washington) who legislate permission for a
power plant on the basis of speculations. We resent it when we see these
speculations tailored to fit preconceived desires: to aid the foisting
of another polluting plant upon us for the benefit of distant customers.
We join the rebellion of the facts!
We may sympathize with the problems of EPA, with respect to fund-
ing, and so on. However, since our hea 1 th is at risk we will not sub-
mit to cavalier treatment by experts at a distance using possibly
legally acceptable decision methods which, however, are empirically
unjustified. This procedure and the attitude it implies is simply
wrong and is surely not what the Congress intended in setting up EPA.
Comes now the DEIS. Statements are a little more cautiousi there
will be no violations, based on a design emission rate of 0.78 Ib. SCu
per million BTU. The modeling used (p. 53) says so.
The values are calculated using "the EPA Single Source CRSTER
model "This model is said to take account of terrain. However, we were
told, it is proprietary and hence not available to us. We remain, there-
fore, properly suspicious of the validity of any hidden modeling, and
especially so in view of the history of this whole process, a- History
to which I must return, below.
The first serious matter, then, is the use of inadequate modeling
procedures which, as we indicate in the Comments, paragraph. 10, and
especially 53ff give what appear to be desired results, namely that
it will be "acceptable" to EPA if the plant were sited at Wise's Landing.
The second serious matter has to do with the basis of calculations.
This is, indeed,normally prior to the modeling process, but we were
told that the decision of what would be needed in the way of SC>2 removal
efficiency was determined from modeling, starting with an "acceptable"
ground-level concentration. That is, plainly speaking, the SC>2 output
is based on a modeling, not on the actual technological evidence of
attempts to clean up stack gases [FGD]. Required emission rate is based
on modeling.
"This conclusion," says the DEIS, p. 53, "is based on a design
emission rate of 0..78 pound of sulfur dioxide per million Btu's of
heat output...." It appears that the proposed plant is expected to
operate with a scrubber efficiency of 90 percent at 100 percent load
using 4.29% sulfur-content coal arid 21 percent excess air (p. 6-37),
(This calculates to 70,879 tons of sulfur dioxide in a 330-day year,
where 35 days of down time is allowed, as an estimate.)
The figures and calculations paint a consistent picture, and so
anyone not familiar with the history of flue gas desulfurization £FGD]
might well be led to think the problem of FGD has been solved. The
operative word here is "design". There is an enormous and unbridged
chasm between "design emission rate" and the actual performance of the
equipment.
Put bluntly, everything is promised--and has been for years--but
there is not a single plant that is over 100 MW size (much less 4 to
6 times as large!) which burns high-sulfur coal such as 4.29% sulfur
(DEIS, p.6-37), and which has operated consistently for a year, (as
COMMENT DOCUMENT • N, CONTINUED
5-90
-------
-IV-
required of a successful industrial process by the National Academy of
Engineering) operating in the world today, as far as we can determine.
There was at one time great enthusiasm in EPA for experimental
results reported for unit #6 of Paddy's Run station of Louisville Gas
& Electric. It turned out, however, that this operation of a 65 MW
peaking unit was atypical. For one thing, by using 80% excess air
it was claimed that the unit was equivalent in emissions to a 100 MW
unit burning 2% S coal, No commerical plant would long operate at
80% excess air. Normally, a plant will use around 20% excess over
stoichiometry in order to make the combustion as efficient as possible
consistent with blowing the least possible heat up the stacks. 80% is
tar and away out of line.
Frequently, Japanese FGD processes are pointed to as examples of
working technology * However, as we point out in our Comments, these
plants burn oil with low sulfur content. We also destructively
criticized the use in the Pre-Construction Review of October 14, 1976,
of a memorandum on the basis of which it was said "EPA has determined
that control devices of 90 percent efficiency are available...." (p. 9)
This memorandum is highly misleading, as we point out in some detail
in our Comments ,
That memorandum was withdrawn from the Pre-Construction Review and
Final Determination of March 25, 1977, but the same misleading statement
was still used (p. 9). In the DEIS we find 90% efficiency scrubbing
still invoked to permit the calculated emissions to conform to EPA
requirements.
We protest that no plant should be begun or even projected for a
site in between and cTo=se to the already present huge polluters: the
City of Louisville, and the Clifty~Creek plant, while there is no
guarantee that scrubbers will operate to the required efficiency, nor
any real likelihood that the problem will be solved for so large an
installation.
The insult to the citizens of this Valley is compounded by the
proposal that a plant this size is needed. Evidence shows the weakness
of this proposal. There is the history of LG&E as an overprojector of
its needs.
The Environmental Action Foundation's 1978 publication Utility
Scoreboard examines the hundred largest electric utilities in this
Country, and presents data taken from the Federal Energy Regulatory
Commission Annual Report; 1976 data were available. At the beginning
of 1976 LG&E projected their power demand to increase by 14.1%. The
actual increase was 2.6%. Thus there was an overprojection in that year
of 11,5%, This placed LG&E in a tie for the 8th place from the top of
the hundred in overprojection. Comparing the annual overprojections
for 1974-1976, inclusive, LG&E averaged 12.5%, and placed 7th from the
top of the list of 100 companies.
Further, with respect to generating capacity, LG&E showed an over-
capacity of 15.4% over and above a normal 20 %-above-peak reserve.
This, incidentally, cost the customers of LG&E $4,772,849.
The optimism of forecasters might not carry too much weight,
COMMENT DOCUMENT - N, CONTINUED
5-91
-------
-V-
since probably understandable, were it not that LG&E is so close to
the top of the list of 100,
Three additional pollution problems need to be addressed. It is
assumed by EPA that the design performance of electrostatic precipitators
will be met. This is by no means a valid expectation. It would seem
generally to be the industry's experience that these precipitators
operate excellently when first installed. However, after a few months
the electrodes become nearly irreversibly coated with fine particles.
Then the efficiency declines, usually into the 80 or even 70 percent.
Further, the moisture released by a plant of this size can become
recognized as a pollutant when it is excessive, appears in an undesirable
location, and harms crops and people. The cooling towers emit over
32,000,000 gallons of moisture per day. To this must be added some
6.9 million gallons issuing from the stacks. Further, a point not
brought forward in the DEIS, Marble Hill's two units would produce
on the average 34,000,000 gallons per day, and there is talk of doubling
the output.of Marble Hill. This moisture, poured into an already
humid valley, will surely affect fruit crops and tobacco, as well as
the inhabitants.
Lastly, the problems surrounding disposal of sludge have not been
solved. The sludge is projected to be "stabilized" and disposed of in
nearby ravines lined with clay> (These ravines apparently have not yet
been purchased.) One criterion for the storage systems (sludge and
bottom ash) is soil conditions "suitable for a stable foundation."
LG&E has received a grant from EPA to help study the general problem
of sludge treatment. This implies that the problem has not been solved.
What we do know, however, is that the foundation rock is laced with
solution cracks--at least if it is like that on the opposite bank of
the River, Such cracks, as much as 10 ft. wide, were encountered at
Marble Hill. We must infer that leachate from such a sludge dump
may well get down into the ground water and find its way to the river--
source of drinking water down-river--and into local wells= Too little
is known to allow the health of citizens to be placed at hazard.
The basic problem seems to be that the City of Louisville, and
Jefferson County, Kentucky, are already so polluted that no further
pollution can be allowed. At the same time, LG&E own a number of
electricity generating plants in that County which are old and in-
efficient. (Some new units are being built.) These are to be retired,
it is said, when a new facility such as that proposed for Trimble
County is built.
The effect of choosing Wise's Landing as a site is to take pollu-
tion out of Jefferson County and foist it on Trimble citizens, and
the Madison, Milton people, while transporting the electricity else-
where—to the LG&E service area (there is a handful of customers at the
edge of Oldham in Trimble County) and excess to some other customer
such as the ERDA plant at Portsmouth, Ohio. This kind of operation
is condemned in the Ohio River Basin Energy Study. (II-B-2-49-50)
"It seems ethically unreasonable to accept the fact that one group of
people will bear the risks and responsibilities (e.g. pollution) of
energy production while another group of people enjoy the benefits
of such energy production." It seems to that writer that this behavior
amounts "*..to creating a class of second-class citizens, a minority
COMMENT DOCUMENT - N, CONTINUED
5-92
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- VL-
who bear the ill effects of what is enjoyed by the majority."
There are other possible sites in the LG&E service area. But what
seems most sensible is to divide up this huge installation into small
units. These can be rather easily controlled and cleaned up. They could
then be dispersed over the service area, so as to meet the needs of the
people who want the power. They would benefit the area of need by
bringing to it tax returns and jobs.
Further, if the plants are as clean as LG&E, and EPA, claim, then
there is real benefit to putting them in Louisville, for they would
displace polluting plants and have the net effect of cleaning the air--
thus perhaps allowing the ingress of more needed industry.
Finally, dispersion of plants is on the face of it desirable for at
least two additional reasons. First, if there is an outage (tornado,
etc.) there is more chance that some installations will survive to pick
up the load — the April 1974 tornado hit the Clifty Creek plant, and
knocked out the whole 1300 MW production for months, but the path of
the tornado was limited, and many installations, if dispersed, would
not likely have been hit.
2 Secondly, dispersion is highly desirable for reasons of national
defense. It seems idiotic to propose a huge new plant about one mile
from a nuke the promoters of which are talking of doubling its size.
This would create a military target of great seductiveness» Its destruc-
tion would at one stroke paralize an enormous area, power-wise (and
apart from the appalling devastation of radioactive material that would
be released). Dispersed plants would be more difficult to knock out,
and thus from a military point of view it seems wrong to propose a
plant at Wise's Landing. We are surprised that no protest from the
military has surfaced:
In conclusion of this Preface, we wish to retain the possibility of
further criticism should a "final" EIS be forthcoming. There is much
more that can be said, and more detail that can be criticized in this
DEIS than has Seen presented. However, in the peculiar actions of EPA
Region IV, they have taken years to prepare their documents--First
Pre^Construction Review, October 14, 1976 (a shoddy document); second
attempt, Pre-Construction Review and Final Determination, March 25, 1977
(not much change, and that for the worse because of deletion of pages
of material and a damning memorandum without substantive change in the
conclusions) and now the DEIS, January 23, 1978. Then it is hurry, hurry,
and we are given minimal time to analyze the four volumes of the DEIS .
This is, of course, not fair, and seems to ignore our rights.
We protest this treatment.
It seems to us that EPA is ignoring, in their quite evident behavior,
the important effect of construction on the course of events. Once
construction has begun, and money has been invested in structures that
are visible—torn up land, buildings, etc.--judgment is tilted, as
Justice Douglas said in a famous case, in favor of the utility [who are
said, for legal window-dressing, to be proceeding at "their" own risk
(whose??)3- This clearly is an abrogation of the rights of the
citizens who are in any case paying the bills. We are forced to ask
whether "ignoring" is the proper word, or whether perhaps, "exploiting"
would better describe the EPA/LG&E behavior.
5-93 COMMENT DOCUMENT - N, CONTINUED
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-Vll-
By every test of economics, defense posture, health and quality of
life, morals and ethics, this "Proposed Issuance of a New Source National
Pollutant Discharge Elimination System Permit" [DEIS, cover sheet] fails.
We demand, in the name of justice to the people of this Ohio River
Valley, that no plant be allowed to be even started, much less built,
at the Trimble County site near Wise's Landing.
COMMENT DOCUMENT • N, CONTINUED
5-94
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-i-
Outline of Comments
Introduction
Paragraph
1 Criticism of PCRi no evidence S07 requirements will be
a tta ined *
2 Criticism of using Fluor Pioneer, Inc. data
3 EPA's position on FPI use
Overall comments
4 DEIS is unsatisfactory
5 Not a proper impact statement
6 Omission of serious impacts
7 Comment on the DEIS as a whole
8 Admonishment of EPA
9 No improvement on PCR SCK removal information
10 No consideration of modern studies of plume dispersion
and travel
11 Failure to take account of Marble Hill
l£ Failure to take full account of moisture emission
13 Effect of starting a plant prematurely
14 FGD problem still unsolved
15 Sludge disposal still not solved
16 Knowing production of toxic materials actionable
Detailed analysis of the DEIS
17 Identification of documents
lo Evidence for lack of objectivity of the "review"
19 LG&E's history of overprojection of need
20 Further evidence of overprojection
21 The likelihood of linear rather than exponential growth
22 A 2340 MW station is not needed
23 Trend toward self-generation of power
24 Alternatives must be considered as a whole
25 Consideration of sites
26 Proper location in City of Louisville
27 Exception taken to comment on S0? concentration
28 No knowledge of NO removal system given
29 Further evidence that DEIS is not independent
30 The EPA FGD claim
31 No evidence that FGD claim can be met
32 Misleading information given by EPA
33 Scrubber system not determined, yet claim made
34 Further misleading information given
35 Additional misleading information
36 More misleading information
37 Summary of misleading information from EPA
38 Continued use of misleading information in DEIS
39 No valid evidence for FGD success on scale claimed
40 It is wrong to move pollution to Trimble County
COMMENT DOCUMENT - N, CONTINUED
5-95
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-ii-
41 Plant size proposed suggests sale of power outside area
42
43
44
45 No proof pollutants (from sludge and ash) can be
contained.
46 DEIS flawed by omission of Marble Hill, and excessive
moisture
47 Moisture released proposed by Wise's Landing plant
(Flaw #1)
48 Moisture released by proposed Marble Hill plant (Flaw #2)
49 Total projected moisture release
50 Humidity of valley
51 Susceptibility of crops to moisture
52 Excessive moisture as a pollutant
53 Prevalence of calms and temperature inversions (Flaw #3)
54 Modern dispersion studies ignored
55 Amount of pollution and model used are important
56 Design is different from operation
57 Even particulate removal may be questioned
58 DEIS seems to accept "design" as equivalent to "opera-
tion"
59 Quotation from ORBES on dispersion programs
60 Uncontrolled plants near ^ta.
61 DEIS ignores "corridor" effect
62 DEIS seems to ignore EPA recommendations
63 No plant should be considered for Wise's Landing
64 Moral failure of DEIS
65 Exaggeration by DEIS
66 No bypass for flue gases recommended
67 Tilting of judgment by investment
68 How will Applicant be responsible for spills?
69 What of people who leave the region?
70 What of tax loss when people leave the region?
71 Reiteration of uncertain performance of precipitators
72 Reiteration of failures of FGD
73 Where will local people get funds to solve fiscal
impacts?
74 How can tax revenues line up with needed expenditures?
75 EPA evidently is doubtful of waste disposal proposal
76 We reserve right to address additional problems
77 Final impressions and requests as our duty
78 Does EPA Region IV favor LG&E?
79 Does LG&E really need a plant this size?
80 Does the mode of operation imply knowledge of failures?
81 Did EPA violate its own rules?
82 What was the reason for hasty release of the PCR?
83 ORBES stricture on the BOM Scenarios
84 We reject being made second-class citizens
85 Why cannot the proposed plant, if clean, not be put in
Jefferson County, Kentucky?
86 Let them not build at Wise's Landing; Royer quotation
COMMENT DOCUMENT - N, CONTINUED
5-96
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-1-
Ref : NPDES No. (KY0041971)
Memorandum: Comments on the Draft EIS for Trimble County
Generating Station
Jot Environment Division, U. S. Environmental Protection Agency,
345 Courtland Street, N.E. , Atlanta, Georgia 30308, ATINi
Ms. Mona Ellison;
And: Kentucky Department for Natural Resources and Environ-
mental Protection, Century Plaza --U.S. 127 South, Frankfort,
Kentucky 40601
From: Harold G. Cassidy, Ph.D., Emeritus Professor, Yale
University (Retired)
On behalf of: SAVE THE VALLEY, a non-profit organization of
Milton, Kentucky, and Madison, Indiana citizens, P. 0. Box 813,
Madison, Indiana 47250. This is only a part of the Save The
Valley contribution to analysis of this DEIS.
Date: March 1978.
Introduction
3 By public notice in the Trimble Banner Democrat, November
11, 1976, comments were solicited on a "Precons true t ion Review
and Preliminary Determination for Trimble County Generating
Units 1, 2, 3, and 4, to be constructed near Wise's Landing,
Kentucky." This document was said to be prepared by the U. S.
Environmental Protection Agency.
Save The Valley responded in December, 1976.
Save The Valley found this " Precons t ruction Review
LPCRj premature and shoddy, with many distortions of fact.
(1) Among the criticisms leveled at the PCR was that we were
forced to conclude that there is no valid and acceptable basis
i or the conclusion that a facility of the size projected Tor
Wise s Landing will operate as required by the EPA limits on
£22 emission." (P. 15 of Save The Valley Comments \ CoTTl
i-ri We sh?wed that "The use by EPA of Fluor Pioneer Inc.
_FPIJ data, without independent analysis and confirmation,
violates EPA's clear obligations under NEPA and invalidates the
entire PCR process" (p. 16 of Co). This was in part because
at the time FPI was hired by LG&E to prepare an impact state-
ment on the Wise's Landing proposal, FPI was involved in per-
formance of design engineering and procurement services for
LG&E's next generating unit which appeared clearly to be the
very one on which they were to prepare the impact statement."
COMMENT DOCUMENT - N, CONTINUED
5-97
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-2-
(p. 17 of Co) (We noted that FPI is historically connected to
Louisville Gas & Electric [LG&E], a fact which was in the hands
of EPA in the form of a brochure, "Experience, qualifications
and capabilities for environmental services" by FPI in which
they.listed a total of $245,428,000 in contracts that had been
received over the years from LG&E.J
(3) We cited the letter of July 10, 1975 from Mr. Jack E.
Ravan, Regional Administrator of Region IV of the EPA, "To All
Interested Government Agencies and Public Groups." This letter
stated that "the Environmental Protection Agency (EPA) has
accepted the responsibility for preparing an Environmental Im-
pact Statement on the proposed project...." The consultant
(FPI) will prepare the data but EPA will have sole authority
for managing and approving the draft and final statements (p. 24
of Co). ^
-.me Counsel for STV raised objections (letters of August 1,
19/5, August 12, 1975 from Mr. J. Gordon Arbuckle, of the legal
firm of Patton, Boggs, and Blow, Washington, D.C. to Mr. David
R. Hopkins of EPA).
On November 14, 1975 the Madison Courier reported that
LG&E had been notified by EPA to cancel its environmental impact
study contract with FPI. In the letter from Mr. Ravan to Mr.
O. C. Kraus of LG&E is the statement "you must reconsider
selection of Fluor-Pioneer as the third party to prepare an
EAS/EIS for your proposed facility at Trimble County, Kentucky
.... (p. 26 of Co) Evidently, the appearance of blatant con-
flict of interest determined this action by EPA, based on the
information partially outlined in paragraph (2) above.
'verall comments on the Draft Environmental Impact Statement
(4) While this DEIS is better written than the PCR which was
presented to us, it still remains a highly unsatisfactory docu-
ment. (See, for example our paragraph 18 below)
(5) There is frequent reference in it to the "Supporting
Report" and "Technical Appendix". These documents fail to
present adequate support for the statements in the DEIS. This
is not surprising since the statements can not logically be
supported. Indeed, parts of these documents read like "design
presentations" to LG&E from a design firm, and merely serve to
dilute the issue without furthering any logical proof that the
proposed power station will in fact not pollute the Valley beyond
allowable limits. Design presentations are not performance
empirical evidence.
COMMENT DOCUMENT - N, CONTINUED
5-98
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-3-
(6) The document omits quite serious impacts which, if given
their proper weight would clearly close off any possible approval
for a plant at the Wise's Landing area (see our paragraphs 11,
46 for example).
(7) The document, considered as a whole, reads like an
"apologia suffering from all the faults of self-justification"
for a position taken prematurely and insecurely (see para-
graph 18).
(8) Referring to paragraph (2), we find that the DEIS has
ignored the spirit of Mr. Ravan's admonishment to LG&E "...you
must reconsider selection of Fluor-Pioneer as the third party
to prepare an EAS/EIS for your proposed facility at Trimble
County, Kentucky...." and has made extensive use of Fluor-
Pioneer data, for example the maps on pages 3-63, 65, 67, 69,
71, 77, 79, 81, 85, 87, 91, 93, 95, 97, 99, 101, 103, 105, etc.,
etc.; Table 6.1.4-2; Figures 6.3.4-4, etc. etc.
We must reiterate our paragraphs (2) and (3) admonish-
ment to EPA« The use by EPA of Fluor Pioneer Inc. data, without
independent analysis and confirmation, violates EPA's clear
obligations under NEPA and invalidates the entire PCR process.
To quote Mr. Arbuckle's letter of January 5, 1977 to Mr. Ravan,
"we find it difficult to understand how EPA can make a deter-
mination on this critical issue before NEPA has been fully
complied with."
(30 We find overwhelming evidence that forces us to re-
iterate that EPA has still not brought forward valid and accept-
able evidence that a facility of the size projected for Wisejs
Landing will operate as required by the EPA limits on SO-, emission.
(See paragraphs 1 above, and 30 to 39.)
(10) The DEIS does not consider modern knowledge of the
dispersion of pollutants in a river valley region such as that
of the Ohio. We specifically refer to the Teknekron studies,
to MAP3S, and to the Argonne Illinois DOE study of January,
1977. These studies, had they been taken cognizance of, as they
should have been in any self-respecting report, would have
emphasized that no power plant such as that proposed for Trimble
County may be built in that place. We cannot understand on any
rational basis how EPA can ignore the well-established corridor
effect in the transport of pollutants, and how EPA can contemplate
under any rational restrictions, issuing a new source NPDES
permit to the LG&E Trimble County Generating Station [StaJ.
The problem is compounded because the CRSTER model said to have
given the results is hidden from us.
(11) We are deeply disturbed by EPA's failure to take account
COMMENT DOCUMENT - N, CONTINUED
5-99
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-4-
of the impact of the proposed Marble Hill nuclear plant [MH]
of Public Service Indiana [PSl] upon the proposed Sta. This
proposed plant is already undergoing "non-safety-related" ex-
tensive work, yet its effect on the proposed Wise's Landing
Sta., only a mile or so away across the River and up-river a
little, is barely mentioned--and in passing. The only acknowl-
edgement given of its existence is as a dot on some of the area
maps, and a listing on p. 2-41.
This omission, when corrected, will show quite clearly
the hazard and the predictable inimical effects of moisture
plume interactions, and thermal plume interactions (for example)
between the proposed Sta. and MH. This omission becomes
especially egregious in its consequences when set beside the
recent Ohio River Basin Energy Study [ORBES ] Resolution of
February 10, 1978. This Resolution states that it has become
apparent to the core team of ORBES "that air pollution problems
must be viewed from a regional, or perhaps interstate, standpoint
as well as from a plant-by-plant standpoint".' This flagrant
omission, when corrected, makes it clear that it is not in the
interest of air quality to locate any power plant at Wise's
Landing;, and that such a plant would inevitably cause unaccept-
able deterioration of an air quality that is already not good.
(12) There is a glaring omission in the DEIS which should
completely disqualify it as not meeting NPDES requirements.
This omission has to do with the emissions of moisture from
cooling towers and chimneys. A poUitant is a substance appearing
in injurious amount at an undesirable place and damaging to
property and persons. We find that the proposed Sta. will ex-
haust to the air of this already humid valley injurious amounts
of moisture, making this a pollutant. The deleterious effect
is exacerbated when the enormous amount of moisture anticipated
from tile proposed MH plant is added. No account appears to be
taken of these effects in the DEIS. Other omissions are also
present, and are discussed below, e.g. paragraph 53.
(13) We must reiterate "that once a plant is built, with the
mass of concrete and intricate machinery, there. in situ, the
citizen can not do much about it in practicaTTferms, whether or
not the plant is a polluter of great magnitude. This has been
the history of the IKEC plant at Clifty Creek...." Presumably
EPA could closedown a polluter, but history does not give us
confidence in EPA in this area of activity. History does indeed
warn that the utility will make every effort to get a plant
started (for example, refer to PSI and MH) on the basis, once
remarked by Justice Douglas, that it tends to "tilt" judgment
in favor of the utility when judgmental matters are at issue,
if money has already been invested in construction.
We must therefore affirm that no plant must be permitted
COMMENT DOCUMENT - N, CONTINUED
5-100
-------
-5-
to be started until it is clear that (a) it will be needed;
(b) it will actually meet EPA requirements as judged by in-
dependent evidence --independent of EPA and the utility. (See
paragraphs 2, 3, and 4, above.)
(14) We find that the DEIS technologies of flue gas desul-
furization [FGD] on the scale of the units proposed for the Sta.
have not been proven on a continuous basis with high sulfur
coal of the kind proposed to be burned, and must state as
strongly as we can that the history of FGD does not give us
confidence that the problems presently facing its use will be
solved by the time a plant might be built, should all the other
objections listed above be met. No plant should be started
when this problem remains unsolved^ and undemonstrated in practice
at the proposed scale.
(15) We find that the requirements for sludge disposal out-
lined in DEIS have not been solved, and that the sludge-disposal
method proposed, given the geology of the area, presents a
hazard to the health of citizens of Trimble and neighboring
count ie s . No plant should be started until it ha a been demonstrated
to the satisfaction of independent observers that~the sludge-
disposal problem has been solvedT " ~~~~
(16) It has been exhaustively demonstrated that SC^ sulfates,
and particulates, severally and together, are injurious to health
of human beings and animals. With this sure knowledge before us,
any group, whether EPA or LG&E that knowlingly permits or
builds a plant, despite clear warnings such as we have repeatedly
given, which generates these pollutants in amounts above the
allowable limits, will be subject to legal action.
Detailed analysis of the DEIS
(17) This document is identified as EPA 904/9-78-001; NPDES
Application Number KY0041971, February, 1978. References to this
document will be made by page number. Single numbers refer to
the DEIS pages; compound numbers refer to the "Supporting Report"
and the "technical Appendix". The analysis will proceed in the
order of the page numeration.
4 (18) Page 2, of "Summary", paragraph 2i "Construction is
scheduled to begin in July, 1978." This unqualified statement
implies that the issue is decided—a foregone conclusion which
makes a farce out of the projected public hearing at Bedford,
Kentucky, March 28, 1978. This attitude on the part of EPA
vitiates any claim of responsibility to the public under NEPA .
This is the sam.e attitude we objected to in commenting on the
Pre -Construct ion Review. We said, p. 7 of Co "The title-page
begins with a premise which we strongly object to» 'To Be
COMMENT DOCUMENT • N, CONTINUED
5-101
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-6-
Constructed* is the statement. That it is baldly stated that
the plant is intended to be constructed immediately vitiates
the whole purpose of the supposedly objective 'Review'."
We do not take this language lightly, especially because
of the correlations with the acts of EPA and LG&E summarized in
paragraphs 2 and 3 above. (Also paragraphs 6 and 7.) Mere
deletion of the offensive expressions in the final EIS without
substantive evidence of a change in attitude will not reflect
attitudinal change.
5 (19) Page 2 of DEIS, paragraph 3 and supporting report
sections 1.3 through 1.5.
The section of the supporting report pages 1-15 and
1-16 is a good discussion of a difficult subject, and is well
written. However, its conclusions, projecting Applicant's
needs for construction of the proposed plant, are wrong. This
is because the premise of exponential growth is almost certainly
rfr •?• ST0**1*1 wil1 ro01'6 likely be linear. A recent publication
. .. j» i FY Scorch031"**- Environmental Action Foundation, January,
19/SJ LUSJ reports that LG&E was eighth from the top (tied with
Consolidated Edison of New York) of the 100 largest electric
compam.es in the Nation in over-projection for the year 1976.
When the demand projections for the period 1974-76 were examined
for accuracy, LG&E rated 7th (the worst would be No. 1 in 100
largest companies) with 12.5% overprojection. These figures
are based on a comparison of the actual peak load for the year,
compared with the peak load projected, and filed, at the beginn-
ing of the year. The 12.1% figure is a. three-year average.
(Examplej LG&E projected 14.1% increase for 1976; actual in-
crease was 2.6%. Overprojection 11.5%.)
This same source [US] lists LG&E was ranking 32nd, with
an excess capacity beyond the accepted 20% reserve margin of
15.4%. This cost the consumer $4,772,849 (1976 figures) extra.
f -v, .LG&E's history of overprojection --shared with most
of the large electric companies of this Country --supports our
analysis of the premises on which LG&E's claims to need for the
Wise s Landing plant are based, namely, that they are gross
o verpro ject ions .
o i- Further» th® information furnished on pages 1 through 8 of
DEIS show the following with respect to "net seasonal summer
IQQO^^Q^f^^S"1 ,^'i39^' Pr°Jecte
-------
-7-
What this means is that even if LG&E's projected ex-
ponential growth were correct (which it is not, of course) the
excess capacity projected for 1990 would be 13% over a normal
20% reserve margin, so the utility has not learned caution
from the 1976 figures detailed in paragraph 20. All this excess
costs money to rate-payers.
We return to this subject below, paragraph 41.
| (21) Page 1-37 of SR. If the moderated exponential growth
projected by LG&E in Figure 1.5-1 were corrected to the logistically
more likely linear growth at this stage of development of the
load area, the projected need for composite electric load would
be of the order of 2750 MW by 1990. (This is without taking
into account the probable effects of new energy sources now
coming along.) Under such conditions, the new construction
needed by LG&E would not exceed 400MW in addition to the Mill
Creek construction now going forward.
(22) Every rational and conservative indicator shows that a
2340MW station will not be needed by LG&E by 1990, as claimed.
f (23) Page 1-42 of SR. Notice is taken of the trend toward
enclosed shopping malls, and this is used to claim increased
likelihood of growth in electrical demand upon LG&E. What is
not mentioned is the trend toward self-generation by large in-
dustrial and commercial (e.g. shopping malls with one million or
more square feet area) installations. Sheldon Novick fEnviron-
ment. 18 (No. 8, October) 1976] points out that during 1975
"residential and small commercial customers were increasing their
demand by about 6 percent per year" while "the large industrial
customers were cutting their demand by 6 percent below that of
1974; industrial demand for all forms of energy declined 7 per-
cent during 1975...." "Calculations published by the Lawrence
Berkeley Laboratory in December 1975 told the story: Even a
commercial development of one million square feet--a shopping
center--could supply its own power, heating and air conditioning
at less cost than that of separate heating and purchased
electricity. Fuel savings of 40 percent more than over-balanced
the additional capital costs of building the small power station
that would be needed...." Incidentally, the small power stations
increase job opportunities.
8 (24) "Consideration of alternatives" can not. be undertaken
category-by-category, but must be examined all together because
they are parts of an interlinked system.
9 (25) This point (paragraph 24) is particularly germane to the
matter of alternative sites, pages 3-9 to 3-48 inclusive. For
example if, as we believe, LG&E has grossly overestimated need
then what may become feasible is the construction of two
COMMENT DOCUMENT • N, CONTINUED
5-103
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-8-
approximately 200MW plants in the locations viiich will be
vacated by the plants projected to be retired, DEIS Table 3.
The force of this suggestion, which draws together alternatives
(3), (6) SR, p. 3-1, with site alternatives examination, SR
pp 3-9ff, is enhanced by three additional considerations « a)
the small plants would be placed in the area close to load
demands; b) the plants would bring taxes into the area where
customers who benefit from the electricity are accepting the
pollution; and c) the small plants would increase the number
of available jobs.
10 (26) A further point which needs strong emphasis is that if,
as LG&E and EPA claim, the power plant will be clean enough
to meet EPA requirements, then there is no impediment to plac-
ing them in the City of Louisville. Indeed, the City would
profit from such location not only through the three returns
listed in paragraph 25 but also because pollution would be
decreased. This would allow new industry to move into the area
to take advantage of the "credit" so released.
11 (27) DEIS p. 17. Strong exception must be taken to the
statement in -line 2 of this page that at the Trimble County site
there is "low sulfur dioxide concentration in the area." It
must be remembered that the City of Louisville produces in
excess of 250,000 tons of S(>2 per year. Studies of the transport
of SOX and sulfates as well as of other pollutants showed long-
range transport of pollutants in a corridor effect along the
trajectory of the Ohio River. [S. J. Gage and L. F. Smith (of
EPA; and P. M. Cukojr and B. L. Niemann of Teknekron, "Interna-
tional Symposium on Sulfur in the Atmosphere" 1977. J Nowhere
are we told the wind directions when this "measurement" of low
S(>2 concentration was made. If it was extrapolated from monitors
set up near Madison east of IKE Clifty Creek plant then we know
already that the statement can not be trusted.
12 (28) DEIS, p. 22 line 14 and 3-56, 57. Once again we find,
as in the PCR, unsupported statements i "The type of nitrogen
dioxide removal system to be used in the plant will be determined
by the boiler manufacturer." Obviously EPA does not know that
regulations will be met if there is no knowledge of the system
that may be used. This DEIS is clearly not an independent document.
Nor does it function properly as an impact statement which would
provide logical and rational evidence that health and property
and the environment would not be damaged by the proposed plant.
13 (?9) DEIS, pp. 27ff , and 3-84ff . That the DEIS does not func-
tion. as an independent impact statement is shown in part by the
section OB "Alternative Solid Waste Disposal Schemes." The title
is correct i these are just schemes. There is no evidence that
the type of disposal proposed will work.
COMMENT DOCUMENT • N, CONTINUED
5-104
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-9-
Further, it is well known that the substructure of the
site is laced with solution channels—a fact substantiated by
the MH excavations--and it must be apparent that unless the
linings of the valley storage dumps for sludge are actually
impervious then there would be serious seepage and consequent
pollution problems both with regard to the wells of local
people and to the River.
Since the DEIS does not present evidence that this dis-
posal system will work, one is forced to ask how EPA can have
the confidence to proceed with permitting this plant. On what
basis can EPA justify placing unknown numbers of local citizens
at risk?
14 (30) DEIS, pp. 53ff, 4-7ff, 6-33ff. The claim that the pro-
posed plant's scrubber system will have an efficiency such that
0.78 pound of S02 per million BTU will be released to the
atmosphere at the tops of the chimneys (total release) would
be more impressive if the EPA required that there be no bypass
in the flue gas treatment installation.
15 (31) Ihe claim that the 0.78 Ib SCU per million BTU can be
reached would be more impressive and convincing if it were
shown that such a level had ever been achieved with high sulfur
coal such as is proposed for the proposed Sta. This, to fulfill
the requirements of the National Academy of Engineering, would
have to have been demonstrated on an installation of at least
100MW actual (not a smaller plant calculated to 100MW as was
the dubious report on Paddy's Run #6) capacity, run for one year.
This is operational efficiency, not "design efficiency." [See
Pedco-Environmental def initions. ~]
(32) There has been much talk about how flue gas desulfuriza-
tion [FGD^J systems are working in existing plants. In the
initial PCR reference was made to the EPA August 6, 1976 memor-
andum from James Herlihy, Technical Support Branch, DSSE. The
PCR referred to this memorandum "EPA has determined that control
devices of 90% efficiency are available (see attached memorandum,
August 6, 1976)." Following our destructive criticism of this
document the memorandum was omitted from the Final Determination
PCR, but our teaching was ignored. It is therefore necessary
to rehearse this criticism.
(33) The first paragraph of this memorandum on which EPA's
claim that control devices of 90% efficiency exist rests indicates
that LG&E's application does not settle on a scrubber system.
This was correct. In the DEIS, see pp. 4-7 to 8, the situation
remains unchanged. It is not possible for EPA to decide that flue
gas SO? will be reduced to 0.78 Ib. S(>2 per million BTU (see *"
paragraph 30) when the scrubber system is not known.' This is no
way to claim a respectable independent impact statement.
COMMENT DOCUMENT - N, CONTINUED
5-105
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-10-
(34) The second paragraph of the above memorandum says that
80% efficient scrubbers have been obtained and that 95% and
higher were possible under special conditions. The unit cited
is the Tennessee Valley Authority's Shawnee Power Station.
This unit is only 10MW [Pedco-Environmental Summary Report of
FGD systems for September-October, 1976, available December 1,
1976, p. 32 and other tables.]. What EPA wishes us to believe
is that a process that works on a 10MW unit, (designated in the
above-cited Pedco report as a prototype but referred to in the
memorandum as a pilot plant) can be scaled up to 675MW and work.
This is impermissible license.
(35) Nowhere in this Herlihy memorandum, on which rests EPA's
claim that FGD control devices of 90% efficiency exist, does it
state that all the presumed examples of such success, cited by
name, are test runs for plants not in operation (perhaps being
built) or are tests on plants of 10 or 23 or 32MW capacity!
(36) Further, some of the presumed successful plants use coal
with a sulfur content as low as 0.8%. One uses 2.9% sulfur
coal on a 10MW plant. LG&E contemplates using coal with a sulfur
content of 3.8% or more. Japanese successes, often cited loosely
are all oil-fired plants. [See, for example, Norman Kaplan,
"Introduction to Double Alkali Flue Gas Desulfurization Technology."
EPA Flue Gas Desulfurization Symposium, New Orleans, LA, March 8-
11, 1976.]
(37) We are forced to find the Herlihy memorandum misleading
since it does not give the size of the power unit, nor the type
of coal burned. Thus reference to it by EPA in the PCR was a
misuse, verging on false teaching (or worse) of those who may
be uninformed.
(38) Nevertheless, we find the same errors promulgated in the
DEIS, for example on pp. 4-35, 39, where it is stated that "The
straight use of limestone, which has been basically successful
now that a better control and understanding of the sulfur dioxide
chemistry exists" has been noted recently in this country in
"various processes which meet the 90 percent requirement...."
(The Japan plants are again referenced without stating that
they burn oil with low sulfur content.) Figures are given for
"Scrubbers operating at 90 percent efficiency...." without
noting that these are "design" calculations--and indeed,
speculations--rather than operational, empirical figures as
should be required before a plant is foisted on the public.
16 (39) There remains no acceptable evidence that a unit burning
approximately 4% sulfur coal at a capacity of 400 to 600 MW and
operating reliably full time for a year has been or can be built.
Claims that such plants can be or have been built must be sub-
stantiated by evidence that the FGD system cannot be bypassed
and that the manufacturer sustains a substantial penalty--say
COMMENT DOCUMENT - N, CONTINUED
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-11-
I00%--for malfunction of failure to meet design specifications
Otherwise the EPA statements amount to gum-beating.
To repeat and add, if plants of thiscleanness can be
built, there are pressing economic and human reasons for placing
them within the City of Louisville itself to replace retired
plants (see paragraph 26). It is morally and ethically wrong
to fob off on the citizens of Trimble County a polluting source
of any kind when the output of that source is all or virtually
all for the benefit of distant customers.
fO (41) This last sentence in paragraph 40 recalls the obvious
teaching in the figures presented in the DEIS, namely that a
plant of the size contemplated at Wise's Landing would in any
case not be needed. The projected size is clearly based on sell-
ing excess power to other areas- -perhaps the plant at Portsmouth.
The figures read: present capacity, all in megawatts, 2,139; to
be retired to 1987, 682; to come on line (Mill Creek), 920; to
be added if Wise's Landing plant were built, 2,340: total 4,717
MW. Projected need (by LG&E) 3543 MW. This leaves 33% excess
capacity. A more rational, straight-line projection (which
may still be an overestimate, see paragraphs 19, 20 and 21)
yields approximately 2750 MW as the capacity expected to be
needed in 1990. The needed new construction (see paragraph 21)
would be around 375 to 400 MW. If the projected plant were to
be built, and the above estimate were correct- -that is, if there
were no hidden intentions by LG&E to sell power elsewhere, a
factor that would vitiate the estimate --then LG&E customers
would have to support a 70% excess capacity. This makes us
suspect that sales outside of the territory are contemplated.
COMMENT DOCUMENT - N, CONTINUED
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-12-
19(45) DEIS, pp. 27-34. There is no evidence that the pro-
posed solid waste disposal system (sludge and ash) has been
thoroughly tested and shown to be acceptable. As remarked
above, excavation at Marble Hill has shown the base rock to
be laced with solution channels (as much as 10 feet wide).
The potential for polluting the River and local wells is too
great to risk without clear evidence that the various pollutants
--heavy metals, acid run-off, for example--can be contained.
20 (46) The DEIS section beginning on p.50 "Impact of proposed
plant on air quality", is grossly flawed by failure to take
into account the projected existence of Marble Hill nuclear
station, now undergoing site preparation, and among the potential
pollutants the excessive moisture that would be released.
These flaws are exposed immediately below since they appear most
obviously at this point in the DEIS, and bear on the summary
table p. 5/ff. (Refer to our general comments, above, para-
graph 12.) ^
(47) Consider the proposed Wise's Landing plant: this is
proposed to take in 150 million tons of water per year from
the River at the total maximum peak intake rate. According to
5-68 evaporation from the proposed cooling towers and from
drift loss would be about 50 million tons per year. What is
not mentioned (flaw #1 in DEIS) is that in addition 10.5 million
tons per year of moisture produced during combustion of the coal
would be exhausted from the stacks (p. 4-41). This means that
the plant would release to the atmosphere 60.5 million tons of
moisture per year.
(48) Flaw #2 in DEIS, with respect to this particular item, is
failure to mention that the nuke at Marble Hill, if it were
?Rer?^n6 would, at 2 units, produce about 2260 MWe, exude about
DU million tons of moisture into the atmosphere across the
river and close to the proposed Wise's Landing plant. (FES,
P»J--i-t JJ-oucfs.)
(50) Thus the total moisture thrown into the air by these
two plants close together would reach some 110.5 million tons
per year. (PSI has intimated plans to double the size of MH,
adding another 50 million tons should this eventuality arise.)
(50) This is a humid valley. The annual average relative
humidity at Louisville ranges from 57% at noon to 79% at mid-
night (DEIS Appendix H-l). We believe that it is unconscionable
to contemplate such release of moisture as disclosed in
paragraphs 46 to 49, to this valley.
(51) Crops such as apples, peaches, pears, tobacco, are
sensitive to blights of many kinds. High humidity facilitates
innoculation by plant diseases such as brown rot on plums,
peaches, necarines and cherries? scab on apples; fireblieht on
pears and apples.
COMMENT DOCUMENT • N, CONTINUED
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-13-
(52) It is our opinion that quantities of moisture continuously
exhausted to the atmosphere must be considered polluting when
excessive in amount relative to the humidity of the locale.
21 (53) A third flaw in the DEIS in this connection concerns
failure to recoftftiz© the prevalano© of calms und tamperstur©
inversions in this valley. A study made by PSI in connection
with the HI impact study is summarized on p. 2-20 of the FES.
The summary wind rose shows that down in the valley (January-
December 1974, 33-ft. level, Satellite Tower along River. From
PSAR, Figure 2.6-18.) there are calms 18.4% of the time. Such
local meteorology can only exacerbate the polluting effect of
excessive moisture.
22(^4) In our overall comments, paragraph 10, above, we pointed
out that the DEIS fails to take account of modern studies of
dispersion of pollutants. We were told by personnel at the
Atlanta office of EPA (Region IV) that "EPA accepts a model
called CRSTER." However, when we asked for details about the
model we were told that it is a "proprietary" model. It appeared
doubtful to us that Region IV even knew what premises the model
uses. In any case, we were not given access to the model. This
forces us to raise questions about the "independence" of the
DEIS.
(55) Two factors are of the essence in connection with the
dispersion problem: (a) amount of pollutant released, (b) dis-
persion modeling methods.
23(^6) (a) With respect to the amounts of pollution to be re-
leased by a proposed plant, design expectation must be dis-
tinguished clearly from operational experiences based on similar
designs.
(57) (a) The caveat of paragraph 56 applies not only to SCK.
but also to particulates, where the technology is somewhat more
advanced. We quote from the "Preliminary Technology Assessment
Report, University of Kentucky, University of Louisville, Ohio
River Basin Energy Study" May 15, 1977 [ORBES], p. II-B-3-5i
In determining existing emission rates, it is
commonly assumed that control equipment operates within
its design specification. This is also questionable
and [a]ffects the reliability of emissions calculation.
In at least one case a major new power plant in the
ORBES with high efficiency precipitators (in excess of
98 percent removal) has had major problems with its
equipment and was several years in reaching a seventy
percent removal efficiency. During this period it has
been reported that permits for the construction of
another nearby power plant and Prevention of Significant
Deterioration (PSD) determinations were made assuming
COMMENT DOCUMENT - N, CONTINUED
5-109
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-14-
that the plant with equipment problems would be
operating within design specifications. [Emphasis
added.]
(58) (a) We see the same error being committed by the DEIS.
We wish to protest the constant acceptance in DEIS of "design"
as equivalent to "operation." This is especially applicable to
SOj removal. An examination of PEDCO Environmental FGD reports
(supported by EPA) shows that none of the presently operating
Cor shut-down for maintenance) FDG installations on a plant
scale (100 MW or over) is living up to design specifications
with a high- sulfur coal such as that proposed for Wise's
Landing.
24(|9) (b) Dispersion modeling methods have already been men-
Dotation
In making PSD determinations the EPA models
ambient concentrations that will result in the plant
vicinity including the effect of other power plants
within a twenty kilometer radius ["Pre- Const ruction
Review and Preliminary Determination for Units 3 and 4
Proposed for Construction at Kentucky Utilities
Company's Ghent Power Station," EPA Region IV Air
Programs Branch, March 1, 1977.] and the background
level. Thus the cumulative local effects of plants
are considered. Based on this type of analysis the
allowable emission rate for the proposed plant is
specified. It is not clear if the consideration of
nearby power plants is limited to a 20 kilometer (12
mile) radius in all determinations. If that is the
case it does not seem to be adequate, according to
the Argonne analysis which indicates maximum 24 hfr]
SC-2 concentrations of over 20mg/M3 at a 20 mile dis-
tance from a 1000 MW power plant meeting NSPS. ["A
Preliminary Assessment of the Health and Environmental
Effects of Coal Utilization in the Midwest. Draft
Volume I Argonne National Laboratory, January, 1977.]
The concentration levels from existing uncontrolled
plants would be several times those amounts. Since the
allowable 24 hour S02 increment is 100mg/M3 it appears
that power plants within 50 to 100 miles or more should
be included in the determination.
(60) (b) It may be noted that the 1300 MW power plant at
Clifty Creek is uncontrolled with respect to SOo, and is about
12 miles distant, about NNW, from the proposed site of the
Wise s Landing plant. Louisville is about 30 miles southwest of
the site. The prevailing winds are from the SE and S, 22.9%
of the time, annual average, along the river Galley. Winds
COMMENT DOCUMENT • N, CONTINUED
5-110
-------
-15-
from the northwest and north occur about 15% of the time
(annual average, summary wind rose MB FES p. 2-20) down the river
valley. The Ghent Kentucky plant is about 38 miles up-river
from the proposed site.
25(61) (b) the DEIS appears to have neglected the modern dis-
persion studies mentioned above and in ORBES, and to have
ignored the important "corridor" effect. This neglect seriously
prejudices the DEIS.
26 (62) (b) One further quotation from ORBES underlines, by im-
plication, the failure of DEIS to take account of EPA's own
recommendations, p. II-B-3-43»
According to EPA, in flat terrains two 1,000 MW
power plants could be located very near each other.
However, in moderate terrains, two 1,000 MW power
plants would have to be located about 28 miles apart
in order to avoid violation of the Class II increments.
In hilly terrain, they would have to be located about
40 miles apart. |"l973 National Emissions Report, U. S.
Environmental Protection Agency National Air Data
Branch, EPA-450/2-76-007, May, 1976.]
(63) Note that Trimble County, Kentucky and Jefferson County,
Indiana, are in a Class II area. Clifty Creek releases more
than 286,000 tons of S02 per year; the City of Louisville and
Jefferson County, Kentucky, release about 280,000 tons total
S02« All these data, together with EPA's own rules, should
preclude consideration of a plant at Wise's Landing.
27 (64) The moral bankruptcy of this DEIS is shown by the first
paragraph at the top of DEIS, p. 56. This says that if the
proposed Wise's Landing plant were not in operation Clifty
Creek would neverthless not be in compliance. Therefore, if the
proposed Wise's Landing station were to go into operation its
contribution would not matter, since the "violation would have
occurred even if the Trimble County plant were not in operation."
So the already dirty air may be further polluted.'
28(65) The third paragraph on p. 56 of DEIS says "Under no
conditions would the Clifty Creek plant, when interacting with
the Trimble County plant, cause a violation of any Ambient Air
Quality Standards in the Wise's Landing area." ^Emphasis added.]
This categorical statement is false on the face of it. No such
statement may legitimately be made with respect to any modeling
scheme unless there is no pollution involved. Temperature in-
versions, channeling effects, corridor effects, and other factors
make modeling depend greatly on contingencies. ORBES says that
"modelling is still a very imprecise science." (P. II-B-3-44.)
COMMENT COCUMENT • N, CONTINUED
5-111
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-16-
29(66) Table 14, p. 57. Merely monitoring flue gas emissions
will not ensure that they "remain within the new source per-
formance standard limits." The behavior would not be ensured,
but might be made more likely by requiring that there be no
bypass for the flue gas stream.
30(67) It is wrong to allow construction to proceed when the
sludge storage problem has not been demonstrably solved
(Table 14, p. 62). By the time that the plant is within one
year of operation Judgment has already been tilted by the
investment (as Justice Douglas pointed out) and pressure will
force the plant's completion whether or not it pollutes.
31 (68) Table 14, p. 64. It is not made clear in what way
Applicant will assume "responsibility for clean-up of all
spills to the Ohio River...." The chemicals are carried
away and may affect people and biota down-stream. Will
Applicant make financial and health restitution?
32(69) Table 14, pp. 68-70. No account is taken of the out-
migration of persons who would be repelled by the appearance
of a power plant and its apurtenances at this site.
33 (70) Table 14, pp. 68070. No mention is made of the loss
in taxes and business spending that would result when people
move out of the area (see paragraph 69).
34 (71) Table 14, p. 71. It needs to be reiterated, since again
claimed here, that it has been the experience of the industry
that 997. removal of -particulates has not been achieved on a
continuing basis. The history of precipitators is that they work
well at first, but after a few months efficiency falls, to
level off around 80 to 70%. See paragraph 57.
35(72) Table 14, p. 71. The same stricture as in pargraph 71
must be applied to SC>2 removal. See paragraphs 58ff.
36(73) Table 14, p. 73. The DEIS does not adequately address
the fiscal impacts--regional and local of the plant. Such
studies have been reported in "Rapid Growth from Energy Projects.
Ideas for State and Local Action." Department of Housing and
Urban Development, Office of Community Planning and Development,
1976 [HUD]]. For example, says HUD, p. 2i "Revenues may appear
too late. The taxes imposed on the energy project come in after
the project is completed. Where is the city or county to get
money to solve problems which are there now?"
37 (74) Table 14, p. 73. HUD further says, p. 2t "Revenues may
be distributed without regard to need. The taxes on the plant
usually go to the county (and the state), while the major impacts
are in the cities where the people live. The cities may get no
COMMENT DOCUMENT • N, CONTINUED
5-112
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-17-
tax money at all from the energy project. Or the project may
be in one county, while the community where workers live is
across the county (or even state) line. How can tax revenues
line up with needed expenditures?"
38(75) It is evident from the "Stipulation" that EPA is doubt-
ful about the efficacy of the ash/ecrubber sludge state of the
art. Monitoring, however, will not remove leachate from local
citizens' wells!
^76) We have not addressed everything that is questionable
in the DEIS, and do not wish to be limited to those items only
which are taken up here.
Impressions and Requests
(77) In concluding this exposure of the failures of the
DEIS--criticisms that it is incumbent on us to offer, since
neither Applicant nor EPA is likely to come forward with such
strictures--we report several impressions and make requests:
40(78) It appears to us that EPA Region IV has favored LG&E
in ways that are improper: first accepting FPI and then, after
being reproached by us on the conflict of interest inherent in
FPI's working on the impact statement for the plant that they
are expecting to design and build, rejecting FPI, yet still,
in the PCR and in this EIS, using quantities of FPI data which
were not independently;*checked,, (That the data were not checked
was our conclusion from the responses we received when two
representatives of STV visited Region IV on March 10, and
inquired about these data.)
41(79) It appears to us that LG&E are on the face of it not in
need of a plant of 2,340 MW capacity. This follows from the
discussion in paragraphs 19f_f_. Adding to this the evidence that
a huge plant will be operated at 20% capacity for 10 or more
years under what must be highly uneconomic conditions, the above
lack of need is confirmed.
We therefore request that EPA rescind the position taken in their
final PCR determination.
42(81) In our reading this PCR violated EPA's own rules in that
there was no prior public hearing and it was foisted on us prior
to the EIS.
COMMENT DOCUMENT - N, CONTINUED
5-113
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-18-
43(82) We are led to wonder whether EPA Region IV, having
privileged information to the effect that new regulations were
due to be released (eventually appearing as the revised and in
many ways more stringent clean air act of 1977) was not trying
to get a permit to LG&E. The impression may be false, but the
sequence of events, the hurried and indeed shoddy PCR released
by EPA all add up to a series of questions in our minds. (These
questions gain substance from the recent Environmental Defense
Fund suit against EPA.)
44(^3) We call attention to a statement in ORBES, p. II-B-2-49i
A second ethically-questionable assumption, unique
to the BOM £Bureau of Mines^] scenarios, is that electrical
power may be transported out of the region in which it
is produced [ORBES, Task 1, "Development of Plausible
Future Regional Technology Configurations," October 18,
1976J (p. Ic 57-le 59). This assumption clearly violates
principles of equal justice under law and equal protec-
tion, especially equal health protection, if one
realizes that any increase in the level of pollutants
in the environment adversely affects the health of
those who are subjected to them. It seems ethically
unreasonable to accept the fact that one group of
people will bear the risks and responsibilities (e.g.,
pollution) of energy production while another group of
people enjoy the benefits of such energy production.
Accepting the BOM assumption that energy will be trans-
ported out of the ORBES region thus seems to amount
to creating a class of second-class citizens, a minority
who bear the ill effects of what is enjoyed by the
majority.
(84) Since the impression is given us that the Wise's Land-
ing plant is proposed for Trimble County so as to get the
attendant pollution out of the Louisville area (Jefferson
County, Kentucky) we are clearly marked out as second-class
citizens. This we reject as violating our right to health
and equal justice.
45(85) Further, if, as EPA and LG&E claim, the proposed plant
will be clean and meet all new source requirements, then there
is no reason for not placing it--perhaps divided up--in place
of plants scheduled to be retired, in the areas where the
power is needed, where jobs and taxes will accrue to the local
citizens. The impression we get, however, is that the
parties know that the plant will not meet specifications,
and so will not be permitted in Jefferson County, Kentucky.
46(86) Finally, we request that EPA persuade LG&E that Wise's
COMMENT DOCUMENT - N, CONTINUED
5-114
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-19-
Landing is no place for their plant. After all, at a Rotary
meeting May 20, 1976, reported verbatim in the Trimble Banner
Democrat of June 3, 1976, Mr. Robert L. Royer, Vice President-
Operations, LG&E, said, referring to the EIS, which was to be
completed in August (1976):
Having described all of that, I think that you
would agree that the easiest thing for us to do would
be not to build a new power plant, in Trimble County
or anywhere else. Considering the cost, the complica-
tions, and the time it will take LG&E and its share-
holders rsic"! to pay the debt, we might prefer not to
build a new power plant at all.
But there are nearly a million people out there
depending on us....etc.
We would like to see LG&E quietly withdraw from their Wise's
Landing proposal. Let them place any actually needed plant
elsewhere, as we have suggested. We shall gladly accept such
a gift of improved health potential at their hands.
COMMENT DOCUMENT - N, CONTINUED
5-115
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RESPONSE TO COMMENT DOCUMENT N
Comment Number Response
1 This comment document consists of two parts:
a. A "Preface," dated April 3, 1978
b. A "Memorandum: Comments on the Draft EIS
for Trimble County Generating Station,"
dated March 1978
All but one comment (Comment 2) contained in the "Preface"
are contained in the "Memorandum." Therefore, with
the exception of Comment 2, which is on page vi of the
"Preface" (page 5-93 of this FEIS), responses have been
made to the numbered comments in the "Memorandum."
2 EPA referred this comment to the Department of Energy
because we assumed that the point of the comment was a
question of reliability rather than national defense.
The Department of Energy, however, did not respond to the
question. The DEIS was also sent to the Department of
the Army for review, and no comments were received from
them on this matter.
To date, we know of no stated concern by the Defense
Department on the siting of power plants within a region.
3 Like the "Preface," this "introduction" summarizes
material presented in detail in following pages. Specific
comments on the DEIS begin on page 5 of the "Memorandum"
(page 5-101 of this FEIS).
4 EPA disagrees. "Scheduled" and "will" are not the same
term. We regret that an inference was made that the
decision to issue an NPDES permit to LG&E is a "foregone
conclusion." Because it is both the lead federal agency
for the EIS and the agency issuing the NPDES permit, EPA
has worked with the Applicant to ensure that the proposed
project design is as environmentally sound as possible.
Where questions concerning environmental compatibility
could not be definitively answered, a series of conditions,
stipulations, and monitoring programs were placed on the
Applicant. These are designed to measure the actual effect,
if any, of the proposed project, should it be constructed.
If any adverse impacts other than those described in the EIS
are revealed by the required monitoring programs, or if any
of the conditions are not met, the Applicant will be re-
quired to modify the project to bring it into conformance
5-116
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RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number
4 (continued)
Response
5-7
9-10
with the imposed conditions or to mitigate or eliminate un-
acceptable impacts. This approach is consistent with EPA's
past and present program of permit issuance and EIS prepara-
tion.
We regret that the language "to be constructed" was taken
to mean "will be constructed." We more seriously regret
that such language lead to the conclusion that the environ-
mental analysis of the proposed project was not objective.
We must point out at this time, furthermore, that the PSD
and the EIS processes are separate federal programs. Each
has its own separate analyses and review procedures and
schedules. Each has its own public hearing. Each is
governed by separate federal laws.
Please see the Summary of Major Concerns and Agency Responses,
pages 5-1 to 5-5; please also see responses to comments 2-7
and 9 of Comment Document H (page 5-55 of this FE1S).
Alternatives were discussed in the DEIS by category for
clarity of presentation. It is not clear what particular
method of analysis is being recommended. We are in agree-
ment that the alternatives to any action have multiple and
interacting consequences.
The alternative of building smaller units (200 MW) to
meet the Applicant's load requirements would be, according
to LG&E," an environmental, siting, and cost nightmare."
In terms of the total environment, the added income from
the additional jobs that would be created would not off-
set the greater environmental costs nor the higher energy
costs to the consumer of such multiple facility construc-
tion.
Regarding the possibility of constructing new units of
200 MW each in place of plants to be retired: new units
cannot be constructed within the physical space currently
occupied by the older units. Not only would new units
be physically larger than the old ones, they would also
come under current environmental legislation that requires
offstream cooling (cooling towers or lakes) and pollution
control devices. Because the older units use once-through
cooling, the acreage required for offstream cooling
facilities was not originally provided. Further, the
pollution control devices, particularly an S02 removal
5-117
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RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number
10 (continued)
Response
11
12
13
system, require additional physical space not available
on the other sites. In addition, these devices result in
amounts of solid waste that would exceed the capacity of
the disposal areas of the original plant site, (it
should be noted that these disposal areas would already
be filled to capacity by the time the original plant is
retired.)
The statement was based on a review of data available
from the Commonwealth of Kentucky and the state of
Indiana for the years 1973 to 1975. Air quality violations
in Madison,Indiana and high air pollutant concentrations
in Louisville, Kentucky were not producing similar ground
level concentrations at monitors located in the site
vicinity, according to these data. On and nearsite
monitoring for the proposed project likewise showed low
S02 concentrations.
Nitrogen dioxide control is a requirement under 40
CFR, Part 60, Standards of Performance for New Stationary
Sources. The determination of compliance with these
requirements is based on performance testing after
initial startup of the source. There is no requirement
for this source to prove compliance with nitrogen dioxide
standards until startup. Design of the boilers to
achieve the required degree of nitrogen dioxide control
is an accepted and proven technology.
During the DEIS review process, several individuals
expressed concern over the potential impact of onsite and
offsite disposal of solid wastes that will be generated
during the operation of the proposed power station. The
major features of the solid waste disposal plan are (a)
an onsite, clay-lined disposal pond for bottom ash, (b)
an onsite emergency, lined, disposal pond for flue gas
desulfurization (FGD) sludge and fly ash, and (c) disposal
of a stabilized mixture of FGD sludge and fly ash
in two ravines north of the power plant site. The
major points brought out in the review comments on solid
waste disposal can be summarized as follows:
a. The process for stabilizing the FGD sludge and fly
ash mixture is still being tested, and there is no
evidence that the stabilized product will be im-
permeable or unleachable as suggested by LG&E.
b. The substructure of a portion of the ravines is
a karst material, subject to solution channeling.
Leachate would have an easy route to the glacial
outwash aquifer (an important ground water resource)
and to the river.
5-118
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RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number
13 (continued)
Response
c. The combination of factors 1 and 2 above presents a
substantial risk to public and private ground water
supplies in the area.
d. Monitoring for ground water contamination does not
preclude ground water contamination and quarterly
ground water monitoring reports would be insufficient.
Before responding to these four points, EPA's regulatory
role with respect to the wastes involved (FGD sludge and
ash) should be made clear. It looks very unlikely at this
time that these wastes will be classified as hazardous
wastes under Section 3001 of the Resource Recovery and
Conservation Act (RCRA). Therefore, the disposal sites
will have to comply with federal standards under Section
4004 of RCRA and/or state solid waste disposal regulations.
These federal standards have not yet been finalized, but,
even after final promulgation, there is no federal
enforcement authority. The only enforcement is through
the states or through citizen suits.
Our response to the review comments follows:
a. The stabilization process for handling FGD sludge and
fly ash now being investigated by LG&E is l.U. Con-
versions Systems, Inc. Poz-0-Tec™ process. The Poz-0-Tecr
process has been implemented at Columbus and Southern
Ohio Electrie's Conesville Station and is planned for
several other generating stations. Test results on
the stabilized sludge indicate permeability approaching
lO"^ cm/sec after curing. However, there is still
insufficient data on water quality impacts from the
Conesville disposal site. Although claims of
a nonleachable stabilized sludge may be over-exagger-
ated, it appears that this type of material, when
properly landfilled, would not generate significant
quantities of leachate. Therefore, impact on ground
water quality would be minimal in comparison to wet
disposal methods or dry disposal of unstabilized
sludge.
b. The presence of karst material in the ravines has to be
viewed with caution even though the stabilized sludge
would be highly impermeable, thus minimizing leachate
generation. Leachate generated could cause serious
ground water degradation if contaminants could move
through solution channels over great distances with
little or no attenuation. This, however, is not
considered to be likely at the Trimble County site.
5-119
-------
RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number
13 (continued)
Response
The karst limestone horizon occurs above elevation
740± at the Trimble County site. The ravines
slated for solid waste disposal will be filled from
the "floor" level, at about elevation 500, to a
maximum fill level of elevation 800. In accordance
with this plan, both ravines will contain approxi-
mately 240 feet of solid waste fill by the time the
level of this karst limestone is reached. By the
time the valley fill reaches this level, there
should be enough data on which to make a determination
as to whether or not an impervious valley liner is
required. Below elevation 740±, the bedrock strata
contain a relatively high proportion of shale which
has inhibited the development of solution channels.
The permeability of this shaly bedrock and its
natural clay soil cover is very low.
c. The land disposal criteria, Section 4004 of RCRA, will
prohibit the endangerment of ground water supplies by
solid waste disposal facilities. While it is true
that regulations cannot guarantee ground water pro-
tection, there are several site-specific factors that
will provide a margin of safety for ground water
supplies: (a) the ravines are approximately a mile
north of many of the private wells and the municipal
supplies at Wises Landing, and ground water flow is
apparently westward, toward the river; (b) as mentioned
previously, leachate generation would be minimal due
to the impermeability of the sludge mixture; (c) con-
taminants from the solid waste disposal sites would
have to move a significant distance to reach water
supply wells, which would allow for some attenuation;
(d) monitoring would pick up any problems before
water supply wells became endangered; and (e) with-
drawals from LG&E's well, onsite, would retard
movement of leachate toward more distant wells.
It is true that detailed test borings and aquifer
flow studies must be conducted in Ravines RA and RB.
However, the information presently available does
not indicate that contamination of drinking water
sources would be likely. Ground water flow patterns
in the upper bedrock strata may experience some
minor alteration when the ravines are filled and
no longer draw seepage. The effect of filling both
ravines is therefore expected to result in a slight
5-120
-------
RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number
13 (continued)
Response
14
15
rise in ground water levels adjacent to the filled
area. New flow patterns in these marginal bedrock
aquifers will still be toward the river bluff, so
it is very unlikely that the chemical quality of
private wells located east of the fill cound be
signficantly affected. Cohesive soils possessing
low permeability characteristics occur on the floor
and sides of both ravines. Ground water seepage
rates through the soil are expected to be almost
negligible, in relation to other sources of re-
charge which affect the major flood plain aquifer.
d. It was stated previously that monitoring would
not preclude contamination of water supplies; how-
ever, it would give timely warning of any problems
and allow for corrective action. Quarterly ground
water monitoring reports, from our view, would
be sufficient considering the relatively slow move-
ment of ground water. However, the state may choose
to impose more frequent monitoring and reporting
requirements. Please refer to the Stipulation
agreement between the Regional Administrator, and
EPA (Appendix D of this FEIS). It should also be
mentioned that the state has indicated that it will
condition its solid waste disposal permit to consider
results of the test boring and aquifer flow studies.
Please refer to the Summary of Major Concerns and Agency
Responses, pages 5-1 to 5-5 of this FEIS, and to the
attached letters from the Kentucky Department for Natural
Resources and Environmental Protection, dated October 12,
1978 and September 27, 1978.
Please refer to response to comment 3, Comment Document
G, page 5-41 of this FEIS. It should additionally be
noted that EPA's authority does not include prohibiting
the installation of a by-pass for the flue gas desulfuriza-
tion system, as indicated in the attached memorandum
(to G.T. Helms, dated November 9, 1977, with attachment).
The "Summary Report - Utility Flue Gas DesuTfurization
Systems - October-November 1977" by PEDCO (attached)
summarizes the status and operational history of scrubbers
nationwide. As an example, LG&E's Cane Run No. 4 is
reported to have operated for 5 months at 90 percent
operability before the supply of lime was interrupted.
After restart, the scrubber was taken down for extensive
modifications.
5-121
-------
RESPONSE TO COMMENT DOCUMENT N
Comment Number
15 (continued)
Response
16
17
18
The Cane Run No. 4 scrubber operated for 5 months at
90 percent operability and was taken out of service not
because of scrubber failure, but because of poor prior
supply planning. In addition, the sulfur content of the
coal being used was 3.5-4.0 percent, which is the approxi-
mate sulfur content of coal to be used at Wises Landing.
The unit rating is 178 MW, which is above the 100 MW
rating specified by the commenter.
If the commentor will take into account that this example
is based on a design made with technology of the early
1970"s, then the prospects for the success of the scrub-
bers at Wises Landing are not as bleak as the picture
painted. The advances in scrubber technology which
have been made in recent years will benefit the Wises
Land ing pi ant.
Please refer to the response to comment 14, above.
With regard to penalties for not meeting design speci-
fications, some vendors of scrubbers are guaranteeing
removal efficiency and the period of operability (see
response to comment 4, Comment Document G, page 5-42 of
this FEIS). Penalties imposed by EPA pursuant to
Section 113(b)(3) of the Clean Air Act provide for
civil penalties of not more than $25,000 per day of
violation. A person who knowingly violates the law
is subject to this same daily fine and/or 1 year of
imprisonment for the first violation.
Please refer to the "Summary of Major Concerns and
Agency Responses," pages 5-1 to 5-5 of this DEIS, as well
as to the response to comments 9 and 10 of this comment
document.
The expected amount of reserve generating capacity
in the year 1980 is 1,143 MW^ which is 32 percent of
the peak load. LG&E plans to have a minimum reserve
margin of 20 percent; but, since generating capacity
is added in discreet blocks covering several years
of load growth, the reserve margin in the year a unit
is placed in-service must necessarily be greater than
20 percent and can be as high as 40 percent.
5-122
-------
Eugene F. Mooney Julian M. Carroll
Secretary COMMONWEALTH OF KENTUCKY Governor
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF ENVIRONMENTAL PROTECTION
DIVISION OF WATER QUALITY
FRANKFORT, KENTUCKY 40601
October 12, 1978
Mr. Theodore Bisterfeld
Environmental Impact Statement Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
RE: Wises Landing - Trimble County SES,
LG & E Draft EIS
Dear Mr. Bisterfeld:
Pursuant to our conversation of October 11, 1978, I would like to
point out that the specific information elements of Secretary
Mooney's letter of September 27, 1978, were developed in conjunc-
tion with, and as a result of, a joint field reconnaissance by
personnel of this Division and the Division of Hazardous Material
and Waste Management.
It is my opinion that the information generated in response to the
solid waste permit application would be adequate to allow the
Division of Water Quality to certify the NPDES permit, and upon
submittal of plans and specifications, issue a state construction
permit.
If you have any questions or desire additional information, please
feel free to contact us.
ncerely,
Robert E. Blank, Director
Division of Water Quality
REB:cw
cc: Adelbert Roark, Commissioner
Eugene F. Mooney, Secretary
Bob Somers, LG & E
Hazardous Material & Waste Management
File
5-122a
-------
Eugene F. Mooney flff jrj «a JUUAN M. CARROL.
GOVERNOR
SECRETARY
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
OFFICE OF THE SECRETARY
FRANKFORT, KENTUCKY toeoi
TEl_es>MOHC 5Oi 564-335O
September 27, 1978
Mr. John C. White, Regional Administrator
US Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Re: Field Reconnaissance of Wises Landing
Dear Mr. White:
This letter is written in response to Mr. Bisterfeld's telephone
request of September 26 regarding information submittals which would
be required for the Louisville Gas & Electric Company's proposed
power plant at Wises Landing.
A solid waste disposal permit will be required and the following
information will be requested from Louisville Gas & Electric as part
of the application process:
1. A detailed description of sludge stabilization process
proposed.
2. A listing of the physical properties of the material to be
landfilled such as Teachability of material, solubility,
friability, etc.
3. The heavy metal content of the ash including a leachate shake
test with particular emphasis on any toxic materials containing
nickel, copper, mercury, cadnium, lead and arsenic.
4. Site characteristics regarding geology, hydrology and soil
permeability.
5-122b
-------
John C. White
Sep tenner 27, 1978
Page Two
5. Site engineering including surface water control and
operating plan.
This information is also necessary to evaluate environmental
impacts. To the extent that specific standards roust be met, the issuance
of a permit would indicate that impacts were mitigated to those levels.
It would not indicate necessarily that all significant impacts had been
raitigated in the permit process.
Sincerely,
EUGENE F. MOONEY
Secretary
EFMrmg
5-122c
-------
ENVIRONMENTAL PROTECTION AGENCY
N:3Y 9 1877
Contingency Plan for FSD Systeas During Oowntiae as a Function of PSD
S. T. HelBS, P.E., Deputy Director
Air & Hazardous Materials Division
Richard 6. Rhoads, Director
Control Programs Developaent Division
fill copy
Edward Jurlcii, Qrlef
Eaforceaent Proceedings Sraaca
Division of .Stationary Scarce Enforcement
5UKART
The Region IV EIS Branch has requested Information as to whether
cr not the PSD approval for new sources usiag FGD systens can be con-
ditioned to require a contingency plan for periods when the FGO systea
is not functioning (see attached aeao fro» Hr. .John Hagan, Chief, EIS
Sraaca). The aalfuactioa contingency plan could consist of a short
tarai supply of low sulfur coal as well as modified operating procedures.
Our aodeliag results indicate that if the power plant which is
required to have a F6D systea operating at 905 removal efficiency were
to experience a FSD salfunction, concentrations substantially higher
tban the a&AQS could be experienced. Under ^iese circunstances a
contingency plan whicij requires use of an alternative low sulfur
fuel would not seat unreasonable.
Soae of the questions which we would like to see addressed follow:
1. Should a sjstea by-pass be addressed 1a a PSO review? How?
2. Is ttere say basis for a PSD requiresent for a malfunction
contingency plas to protect against violations of the MAAQS?
The allowable PSO Increment?
Acne*
Raply rec
BACXSittXJHO
Attached aeao fro* EIS Branch.
5-123
-------
UN! :_DStA,-S - N v [RON MENTAL PROTECTION -3ENCY
''•AS.-I i.NGTON. DC. 2C460
:E C.- EN.-C=CEMENT
SUBJECT: Contingency Plan for FGD Systems During Downtime
as a Function of ?SD
FROM: Director, Division of Stationary Source Enforcement
"'-•: G.r. Helms, P.E. Deputy Director
Air a~d Hazardous Materials Division
-ni~ ~- -" res?°-^3e to your request dated November 9, 1977,
asxir.g whether PSD approvals for new sources using FGD
systems can z-e conditioned to require a contingency plan for
peric-is when the FGD system is not functioning.
?SD 2r-- SI? regulations require the establishment of
emission^limitations which will be sufficient to ensure non-
degradation of air quality and attainment and maintenance of
KAAQS, respectively. in order to assure this at =11 times
it is necessary for the source owner or operator to be in
compliance with all emission limitations at all times. For
this^reason,^the Agency in the April 27, 1977 ?.R. (42 FR
2_.4/'2> prosiuigazed a requirement outlining our position on
SI? malfunctions. In the preamble to those requirements it
is stated, "...the Administrator has determined that the
automatic granting of a regulatory exemption Cperztit in this
case) for these periods cf excess emissions is not a suitable
remedy." From this language, therefore, it would not be
vise to include within the PSD permit a specific exemption
from zhe requirements during periods of "upset" or "naifunction.'
~*fe do, however recognize that some relief should be
afforded during certain upset situations. If the source
were allowed an automatic exemption it would encourage the
source to claim, after every period of excess emissions,
that an exemption is warranted. Therefore, the only enforceable
means available to the Agency in dealing with all emission
exrurEicns-ce they potentially cue to malfunctions or otherwise-
is to issue nonces of violations with the source being
prove that the violation was due to
z~ ucsec or ma If unction.
5-124
-------
In response to the particular items raised in your
memo, I would not recommend specifically addressing the
system by-pass. That is, if a source elected to have a by-
pass capability it could do so, however it would in no way
limit our abilities to enforce tne emission limits during
those periods when the emissions were not routed through the
control device. We would then exercise our enforcement
options to address the sources failure to satisfy the prescribed
emission limit.
While I would not recommend requiring a malfunction
contingency plan, I would alert the source that any inability
on their part to maintain their emissions consistent with
the applicable regulation may result in an enforcement
action initiated by EPA. This would apply to requirements
necessary to attain and maintain the NAAQS as well as' PSD.
To facilitate this enforcement approach it will require
the issuance of a Notice of Violation (NOV) , although this
will not be necessary for NSPS or NESHAPS, for every period
of excess emission ascertained by your Office. After issuance
of the NOV the Region should consider any information developed
by the source which more fully explains the circumstances of
the violation and any good faith efforts of the owner or
operator of the source to comply and in determining whether
further Agency action is appropriate.
If you have any further questions or comments, please
contact Rich Biondi (755-2564) of my staff.
Edward E. Reich
cc: Dick Rhoads, CPDD
Mike Trutna, CPDD
5-125
-------
SUMMARY REPORT - UTILITY FLUE GMb DESULFURIZATION SYSTEMS - OCTOBER - NOVEMBER
Ln
N5
TAOLE
i
2
3
4
5
6
7
6
9
10
11
12
13
m
15
16
17
SUMMARY LIST OF FGD SYSTEMS
STATUS Of- FfcU SYSTEMS
SUMMARY LIST OF FGD SYSTEMS IN THE EARLY PLANNING STAGES
STATUS OF FGD SYSTEMS IN THE EARLY PLANNING STAGES
PERFORMANCE DESCRIPTION FOR OPERATIONAL"FGD SYSTEMS
NU*lHER AND TOTAL MW OF FGU SYSILMS
SUMMARY OF FGO SYSTEMS HY COMPANY
SUMMARY. UF FGD SYSTEMS BY VENDOR
SUMMARY OF N£W ANU RETROFIT FGU SYSTEMS BY PROCESS
SUMMARY OF OPERATING FGO SYSTEMS BY PROCESS ANU GENERATING UNITS
SUMMARY OF SLUUGE DISPOSAL PRACTICES FOR OPERATIONAL FGD SYSTEMS
SUMMARY OF FGO SYSTEMS BY PKOCL6S AND REGULATORY CLASS
SUMMARY OF OPERATIONAL FGD SYSTEMS
SUMMARY OF FGD SYSTEMS UNDER CONSTRUCTION
SUMMARY OF PLANNED FbD SYSTEMS
FGU SYSTLM OPERATIONS THAT HAVE BEEN TERMINATED OR SHUT DOWN INDEFINITELY
TOTAL OF FGD MEGAWATT CAPACITY BY YEAR
FbD SYSTLMS ECONOMICS
FGD PROCESS FLOW DIAGRAMS
DEFINITIONS
1977
PAGE
2
8
38
42
46
256
260
264
268
272
276
281
286
292
298
306
368
APPENDIX A
APPENDIX B
APPENDIX C
PHEPAKLU bY
PEDCO ENVIRONMENTAL INC.
11H99 CHESTER RUAD
CINCINNATI* OHIO
FOR
SOURCE ENFORCEMENT
PREPARED
DIVISION OF STATIONARY
AND
INDUSTRIAL ENVIRONMENTAL RESEARCH LAbORATORY
1 U.S. ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PARK,
NORTH CAROLNA 27711
CONTRACT NO. 66-01-«*l**7
TASK NO. 6
F»EDCo ENVIRONMENTAL
CINCINNATI. OM«O
-------
TABLE b
PERFORMANCE DESCRIPTION FOrt OPERATIONAL FGO SYSTEMS 11/77
Ul
IDENTIFICATION NO.
UTILITY NAI"L
UNIT NAME
UNIT LOCATION
uun HATING
FUEL CHARACTERISTICS
FGP VENDOR
PKOCLS6
NEW CH RETROFIT
START UP DATE
FGO STATUS
EFFICIENCY,
PARUCULATES
LOUISVILLE GAS * ELECTRIC
CANE RUN NO 4
LOUISVILLE KENTUCKY
176 MW
COAL 3,5 - 4.0 PEHCENT SULFUR
AKEK1CAN AIM FiLTf.0
LI Mil SCRUlidING
RETROFIT
'0/76
OPERATIONAL
99 PERCENT GUARANTEE
S02
65 PERCENT GUAKANTEE
WATEH MAKE UP
SLUbGL DISPOSAL
STABILIZED SLUUGE UISPOSED IN UNLINEO POND
UNIT COST
SEE APPENDIX At FGD SYSTEM ECONOMICS
OPERATIONAL
EXPERIENCE
KFFER TO THE BACKGROUND INFORNAT10N SECTION IN TABLE 5 OF THIS REPORT.
FOLLOWING AN EXTENDER OUTAGE TO IMPLEMENT A SLMIES OF MAJOR MODIFICATIONS
TO THE FGD SYSTtil (A CHEVRON-TYPE KIST ELIMINATOR REPLACING THE RADIAL
VANE UNIT* A NEW SPRAY HEADER INCREASING L/G. A JIRECT OIL-FIRCD STACK
GAS REHEAT SYSTEM INSTALLED* ANO IhE CAKBOLINE DUCT LINING REPLACED WITH
PLASTITE tUOSli IHE SCRJBBER WAS RESTARTED JULY 17 AND IN AUGUST* THE
SCRUBBER SUCCESSFULLY COMPLETED TESTING FOR COMPLIANCE UITH FEDERAL ANO
LOCAL S02 REGS. OPEKABILITY FOR OCT. AND NOV. WAS 9t ANO 96* RESPECTIVELY.
152
PEDCo ENVIRONMENTAL
CINCINNATI OHIO
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UAIKGKUUNU INFORMATION
ON
CANL HUN NO.
tMl CAM RUN HOWL,, CATION IS OHERAUu UY THL LOUIaVIUl. OA* ANU LLL.1R1C COMPANY AND LOCATED kN LOulBVULC, KENTUCKY. THC
PLANT CONSISTS or &ix LILCTRIC POUCH err** ,.„.,.....
iv rwwiK 5.TCA1 bLNERATlNl. UNITS HAVING A TOTAL STEAM TuRkHNC MCI GENERATING CAPACITY OF 992-MW,
UHII NO. * IS A COAL.M.ILO STCAM GENERATING l.OIU K M|TI. A CONTINUOUS NET GENERATING CAPACITY OF 170-MW. TMC UNIt MAS A
MAXIMUM PUxL'K GENERATION CAPACITY OF i«in «i
wg— i*. THL UNIT hLAT HAH IS 10,030 UTU/K*H. THE. II01LLH IS CUKHLNTLY BUWNING COAL WITH A
CilOSS HLAT,NG VALUE OF U.SOO DTU/LO AND AVEHAOL SULFUK AND ASH CCNUNT* OF ».^,« PeKCLNI AND U.O-U.O PE«CCNT, KCSPCCTIVFLY.
THt tHISSSON CUNI..OL SV&TtH FOll TH|8 UNIT CONS.ST, OF AN CLtCT.OSI AT ,C I'HLCIPITATON USIM UP8TUCAH OF A WCT SC, SYSTEM CONSISTS OF TWO IULNTICAL PARALLEL SCRUDOIN6 TRAINS DESIGNED AND SUPPLIED OY THE
AMERICAN AIR FILTER (AAH COMPANY. THE WET SCRUUuING SYSTEM UT1LUL* A SLURRY OF CAROIUL LIMC FOR SULFUR DIOXIDE REMOVAL FROM THE
^ FLUC GAS. THE CARblllC LIME IS A WASTE BY-PRODUCT OUTA1MLU FHOM A NEARBY ACETYLENE MANUFACTURING PLANT. THE HYORATCO LIME CON-
jL TAINS 90.0 TO 92.0 PtWCCNT CALCIUM llVOROXIUE, 2.0 TO a.S PERCLNT SILICA, ».„ TO tt.O PERCENT CALCIUM CARHONATE, AND O.I PERCENT
00 MAGNESIUM OXIUI.
LACH SCRUUIUUG TRAIN IS EUUIPI'ED WITH A GUILLOTINL-T YPE HY-PASS UAMPCK ALLOWING I3Y-PASSING OF THE GAS AKOuf.O THE SCRUUOtRS,
tACH SC.tOlllUNG THAIN CURTAINS THL HOLLOWING MAJOK PILCES Of LOUIPMENT* I.U. UOOSTER FAN, UU1.NCH SECTION, FLOODtiU ELIJO*. MOUKC
ULD CONTnCTult, CENIUIFuGAL t'LMlSTLK, AND A J-SttUON MLAClAlvt TANK SYSTLM, THL WASTL DISPOSAL SYSTLM CONSISTS OF A 75-FOOT
01 A«t TCI' THICKENER fOK LIUUIU-SOL U)!i tiLP«l
-------
LOUISVILLE GAS i ELECTRIC
PERIOD HOURS BOILER (HR) SCRUBBERS IHR)
AUG. 76 lH* 710
FGO SYSTEM PERFORMANCE
PERFORhANCE FACTORS <8U
OPERABILITY UTILISATION
90 VO
CANE RUN UNIT NO, •*
Ln
I
(S3
VO
SEP. 76 720
OCT. 76 7«»t
720
600
650
510
90
90
90
73
COMMENTS
OUTAGE TIME DUKING THE MONTH WAS DUE PRIMARILY TO
EQUIPMENT INSPECTIONS, REPAIR/REPLACEMENT OF AUXILIARY
MOTOR PAR.TSi AND DEPLETION OF ABSORBENT SUPPLY BECAUSE
OF A LATE BARGE DELIVERY. THE SCRUBBING SYSTEM HAS
tfEEN GENERALLY OPERATING At APPROXIMATELY 50 TO 80
PERCENT FLUE GAS CAPACITY, SOME MINOR PROBLEMS HAVE
OEEN ENCOUNTERED WITH AUXILIARY EOUIPMENT MOTORS
AND SPKAY I^ZLLS IN THE MOBIuE BED CONTACTOR. THE
SPRAY NOZZLES ARE SPINNER-VANE COMPONENTS ORIGINALLY
CONSTRUCTED OF PLASTIC. OPERATING TEKPtRATuNES ANO
PRESSURES HAVE CAUSED THE PLASTIC HOUSING TO EXPAND
RESULTING IN THE VANES EXTRUDING OUT THE FRONT END.
SUBSEQUENTLY CAUSING A BLOCKAGE OF THE SLURRY FEED.
THE NOZZLES HAVE bEEN REPLACED WITH CERAMIC-
CONSTRUCTED COMPONENTS.
THE SYSTEM WAS IN SERVICE THROUGHOUT THE MONTH. BEING
AVAILABLE TO THL BOILLR ON A 90 PERCENT BASIS. THE
UNIT WAS TAKEN OUT OF SERVICE ON OCTOBER 25 TO IMPLE-
MENT ADDITIONAL MODIFICATIONS TO THE SCRUBBING SYSTEM.
MAJOR SYSTEM MODIFICATIONS INCLUDE INCREASING PUMP
CAPACITY AND DECREASING PRESSURE DROP. THESE TWO
PROBLEMS HAVE HINDERED OPERATION OF THE UNIT AT FULL
LOAD CAPACITY, TO DATE, THE MECHANICAL RELIABILITY
Ibl
PEDCo ENVIRONMENTAL
CINCINNATI OHIO
-------
LOUI&VILLC VAS « ELCCTHJC
I'LKIOO MOUKS UUJLEH (Hit) SCHUUULK6 lMh»
OJ
o
MAR. 77
APR. 77
MAY 77
NOV. 7$
ULC. 76 TM
JAN. 77 7H*
1'l.ltrOKhANCl » AC tilHS (Ml
OPtHAOlLIlY UTILISATION
V6
10
FEU. 77 67*
JAFTCH
RESTART)
(AFTER
RESTART)
(AFTtK
HESTAKT)
(AFTEH
CANt HUN UNIT NO. •»
COMMCNTS
OF THt SYSTEM, AS A FUNCTION Of- SCHVlCt TIME VERSUS
OUTAGt TIHEt HAS ULEN VE«Y GOOD,
1IH, SYSTI..M INCUHI((,!> NO MAJOM HMOUttMS OH UI'SCTS
OUHINO THL RLPOKf I'CIUOU. CAKilIOE I.IMC SUUUKY IS
EMf'UOYEO AS THL SULFUK DlOXiOE AUSOHUCNT.
OUKING JAN.l • s)AN.ll< Tilt. SCKUUULK WAS UTILUEO 90
I'LHCtNl OF Tilt 1IMU THI.N n't OHIO HlVfcH OtCAME IM-
PASSAULt DOU 10 ICC FOUMAT10N AND THIS CAUSCO THE
CESSATION OF UAKCE OEUlVEKlLS OF LIME.
OUHINO FEORUARYt THE SCRUuBEH WAS ONLY OPERATED FOR
TWO «t-HOUH PCH100S TO PREVENT TOTAL FREEZE-UP,
IN MARCH, THE SCK.UuOEK CAwC UACK ON-CINE AT 10 AM,
ON MARCH J«»TH, AND HAS RUN CONTINUOUSLY THROUGH
THE ENO OF THE PERIOD. FROM THE 1HTH THROUGH THE END
OF TMC MONTH, r»itf»L WAS ONE PCKIOD OF SCHUOOCR OY-PASS,
WHEN DC SUPPLY TO THE UY-PASS HAC TO BE REPAIRED.
THE SCRUUUC.R SYbTCM HAN FOR THE FIHST la DAYS IN APRIL.
WITH A RELIABILITY OF 958. FROM THAT TIME (APRIL Id)
THROUGH AN EXPECTED OATE OF JULY 12, THE SCRUliUER
SYSTEM WILL BE DOWN FQK THE FOLLOWING MODIFICATIONS*
i. TO REMOVE OEMISTEK AND REPLACE WITH A CHEVRON TYPE,
155
PEDCo ENVIRONMENTAL.
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LOUISVILLE CAS 4 ELECTRIC
PERIOD HOOKS BOILER (HR) SCRUBBER 1HK)
PERFORMANCE FACTORSU)
OPERABILITY UTILISATION
JUN. 77
JUL. 77 7"»H
Oi
I
36Q
(AFTER
RESTART)
"32«»
(AFTER
RESTART)
90
(AFTER
RESTART)
90
(AFTER
RESTART)
CANC RUN UNIT NO. i*
COMMENTS
2. TO INCREASE L/G BY ADDING A NEW SPRAY HEADER.
3. TO ADD DIRECT, OlL-FlKED REHEAT, AND
<*. TO REPLACE THE LINING IN THE SYSTEM FROM
THE DEMISTER THROUGH THE STACK WITH PLASTITE <»005
TO BE INSTALLED BY GENERAL COATINGS (THE ORIGINAL
LINING WAS bUBULING. bUT HAD NOT YET FAILED* FAIL-
URE SEEMEU IMMINENT WITHIN i«-5 MONTHS).
SYSTEM REMAINED OuT OF SERVICE PENDING COMPLETION
OF SYSTEM MODIFICATIONS,
SYSTEM MODIFICATIONS WERE COMPLETED AND THE
SCRUBBER PLANT WAS PLACED UACrt IN SERVICE ON JULY
17. ON AUGUST i» THE SYSTEM UNDERWENT AND SUCCESS-
FULLY COMPLETED TESTING FOR COMPLIANCE WITH LOCAL
(JEFFERSON COUNTY) AND FEDERAL S03 AIR EMISSION
REGULATIONS. THE ABOVE-MENTIONED MODIFICATIONS
ENABLED THE SYSTEM TO EXCEED THE 85* SU2 REQUIRE-
MENT (JEFFERSON COUNTY) AJJD FEDERAL STANDARD
U.2 LB/MM BTU). ACTUAL TEST RESULTS INDICATED AN
6fe YO 898i S02 REMOVAL EFFICIENCY FOR 3.3 TO 3.<+X
SULFUR COAL, WHICH IS EQUIVALENT TO AN OUTLET
EMISSION VALUE OF 0.6LB/MM BTU HEAD INPUT. ALL
TESTING WAS PERFORMED bV EPA PERSONNEL.
PEDCo ENVIRONMENTAL
-------
LOUISVILLL 6AS ft ELECTRIC
PERFORMANCE FACTORS (X)
HCRIOU HOUKS BOILER (MR) SCKUBbtR (Hl<) OPERA6ILITY UTILIZATION
AUG. 77 7H"* 657 566 9t 9J
SEP. 77 720 529 52<» 99 9*
OCT. 77 7HH 677
NOV. 77 7*0 H63
662
H5H
98
69
CANE RUN UNIT NO, <»
COMMENTS
THE FGO SYSTEM WAS FURTHER TLSTEO USING METHOD 6
BY FEDERAL EPA ANO WAS OFFICIALLY APPROVED To
HAVE ACHIEVED COMPLIANCE, THL SYSTEM PERFORMED
VERY WELL UURING THIS PERIOD,
EPA MAY CONTINUE TO TEST THROUGHOUT JANUARY. NO
KtAL PROBLEMS ENCOUNTERED IN MAINTAINING
COMPLIANCE.
U)
KJ
IS7
PEDCo ENVIRONMENTAL.
riM<~INNATI OHIO
-------
RESPONSE TO COMMENT DOCUMENT N
Comment Number
18 (continued)
Response
19
20
The total capacity committed to DOE's Portsmouth, Ohio
facility via OVEC is 51 MW as shown in Table 4 on page 8
of the DEIS. There are no present plans, either official
or unofficial, for LG&E to provide capacity beyond the
level published in the DEIS.
Although the Trimble County plant is not being built
for bulk power sales to neighboring utilities other
than the aforementioned OVEC, LG&E indicates that it
is very possible that there could be some bulk sales of
capacity on an "as-available" basis.
Please also refer to the letter from the Department
of Energy dated August 31, 1978, which is attached
as part of the response to comments 2-7 of Comment
Document H, page 5-55 of this FEIS.
Please refer to the response to comment 13 of this
comment document.
The figures quoted represent the instantaneous maximum
water usage of the plant and were originally calculated
to determine the effect of plant water use on the total
river flow during short periods. The figures presented
on page 6-68 of the DEIS Supporting Report represent
cooling system emissions only, not total plant emissions.
These values do not represent expected evaporative
water losses during an annual cycle.
Evaporation and drift loss rates for a complete annual
cycle are presented in Table 4.2.3-1 of the DEIS Sup-
porting Report. These loss rates indicate that a total
of 23.3 million tons of water will be released from
the cooling system during a complete annual cycle.
Similarly, the expected moisture release from the plant
stacks is 6.3 million tons per year, based on an average
capacity factor of 60 percent. Thus, the total moisture
emission from the facility is estimated to be 29.6
million tons per year.
Similarly, the estimated evaporative water loss at the
Marble Hill nuclear facility for a complete annual cycle
is 33.8 million tons (MH-ER, Table 3.4-2). Thus, the
total water loss from both facilities is 63.4 million
tons per year. The addition of anticipated emissions
from Marble Hill Units 3 and 4 is premature, since
design plans for these units have not been finalized
at the present time.
5-133
-------
RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number
20 (continued)
21
Response
The effect of the moisture release from the Marble Hill
facility is summarized on page 5.1-26 of the MH-ER.
The results indicate that average increases in relative
humidity will be less than 0.2 percent at any off site
location. Downwash effects near the towers may result
in a maximum relative humidity increase of less than 3
percent at any location.
The effects of the Trimble County cooling towers during
downwash conditions are negligible (please see page TA-107
of the DEIS Supporting Report) due to the increased
height of the natural draft cooling tower plume. In
fact, at a distance of 1 kilometer, ground level fogging
is expected to occur only 10.5 hours per year. This
represents an average increase in relative humidity of
only 0.3 percent within 1 kilometer of the towers at any
location.
Beyond 1 kilometer, the effects of the Trimble
County cooling towers are even less. The maximum increase
in relative humidity is 0.8 percent under the plume
centerline, assuming an ambient humidity of 57 per-
cent during the summer months. During the winter,
the maximum expected increase is approximately 6 per-
cent due to the lower ambient temperatures. This
results in an average increase in relative humidity
of 0.2 percent at any location for the entire year.
Because the yearly variations in ambient relative
humidity are larger than the estimated impacts of
both facilities, the annual effects on sensitive
vegetation due to the operation of the cooling
towers will be negligible.
The meteorological data available for use in the air
quality analyses consisted of National Weather Service
hourly data from Louisville for surface data and from
Dayton for upper air data.
The highest predicted ground level concentrations
occurred not during calms, but during unstable
conditions.
5-134
-------
RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number
21 (continued)
Response
22
23
24
25
26
A modification of the modeling algorithm to account for
moisture content of the plume and the resulting changes
in the dispersion characteristics was not available for
the air quality analysis.
The CRSTER model is an acceptable model for use with
power plants. It is not and has not been a "proprie-
tary" model as far as Region IV is concerned. SAVE
THE VALLEY has been offered the opportunity to review
any and all data or information concerning LG&E's
proposed plant (see attached letter to Mr. Arbuckle
dated January 4, 1978).
The amount of pollutants assumed to be emitted for
modeling purposes (PSD) is based on worst case condi-
tions, usually the maximum emission rate (100 percent).
The emission limits specified as part of the approval
are considered limits which, if exceeded, will subject
the owner or operator to enforcement action.
The emissions from the Clifty Creek plant, although
they may result in ground level concentrations which
exceed the National Ambient Air Quality Standards
(NAAQS) for S02 (primarily health related and secondary
welfare related), are not considered as having consumed
any of the air quality increments. Region V is responsible
for requiring Clifty Creek to reduce emissions in order
to attain the NAAQS, while taking into account any
concentrations from sources previously granted approval
to construct in the area.
There is no limiting distance between major point
source interaction investigations as the commenter
implies. The distance involved between the other
plants reduces the modeled concentrations below
significant values for PSD consideration.
The "corridor effect" is not accounted for in EPA
models presently in use. When approved, a technique
which accounts for this characteristic will be utilized,
if appropriate.
Please refer to the response to comment 24, above.
5-135
-------
Mr. J. Gordon Arbuckle, Esquire
Batton, Soggs and Slow
1200 Seventeenth Street, H.W.
Nashington, D.C. 20036
Dear Mr. Arbuckle:
This is in response to your letter of December 12, 1977,
regarding the prevention of significant deterioration (PSO)
p re-construction review and final detersri nation for the Tri stole
County Generating Station Units 1, 2, 3 and 4 near Wises Landing,
Kentucky. In your letter you stated that a de novo review must be
conducted by EPA, "with full opportunity for public cotament on the
AcSninistrator's prelisinary determination and on all information
submitted by the applicant in connection therewith."
Our re-exaarf nation of the proposed ?nses Landing facility was
in order to determine If this source would sect the insmediately ef-
fective PSD requirements of the 1977 Clean Air Act Amendments (P.L.
95-95). Our previous PSO approval of this source was suspended
pending this re-exasrfnation since the company had not conwenced con-
struction prior to P.L. 95-95. The company has proposed no mate-
rial change to the construction that was approved earlier after
public notice and coanent. Consequently, we feel that a new
consent period is not required.
However, we have decided that we will offer your client, Save
The Valley, the opportunity to review aad coanent on the material
we are looking at In our re-exasination. Accordingly, on Decernber
23, 1977, Mr. Cassidy of Save The Valley was notified by phone of
this opportunity, and of our willingness to let hint inspect the
relevant materials at our offices. On Deceaber 27, 1977, you were
similarly notified. As tentatively discussed in those conversa-
tions, we will consider cotsnents sade by the close of business on
January 13, 19flf, in our re-exavi nation.
If you have any questions, please call Hinston Sraith, Chief
of our Trends and Analysis Section at (404/881-3043).
Sincerely yours,
G. T. Hellas, P.E.
Chief
Air Program Branch
5-136
-------
RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number Response
27 The phase quoted by Dr. Cassidy was not intended to imply
that the contribution of 0.1 yg/m3 to the existing problem
"would not matter." It was an attempt to clarify that the
violation projected by the modeling was not caused by the
Trimble County facility.
28 Comment noted and correction made. There were no modeled
violations in the immediate vicinity of the proposed
Trimble County plant.
29 Please refer to responses to comment 14 of this comment
document.
30 Please refer to the response to comment 13 of this comment
document.
31 In all instances of spills (except those resulting from
floods, wars, or acts of God), the discharger bears all
liability for the clean-up and damages resulting from it.
The Applicant must provide a Spill Contingency, Control,
and Counter-Measure Plan prior to placement on the site
of oils or other chemicals subject to spilling. For the
Ohio River, the role of EPA is to coordinate spill clean-
up following notification. Notification is the first
responsibility of the discharger in the event of a spill.
If the discharger is not known or does not notify EPA and
commence clean-up, EPA will utilize the Federal Contingency
Fund for clean-up. When this fund is utilized, the dis-
charger responsible for the spill must make restitution
to the fund. A schedule of criminal and civil fines
exists according to the type of spill.
Restitution for resulting damage can be sought by the
state and local governments or through citizens suits.
It is not provided for in EPA regulations nor does EPA
assess damage.
32 There is a definite possibility that a few individual
households may choose to move from the area due to personal
objection to the appearance of the plant. However, EPA is
aware of no documented evidence of significant numbers of
people emigrating from an area as a result of power plant
construction. In fact, all evidence indicates a signifi-
cant inmigration of households resulting in a net increase
in local population due to the new job opportunities.
5-137
-------
RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number Response
33 It is expected that there would be an increase, rather than
a loss, of taxes and business spending as a result of the
proposed plant. As noted in the previous response, it is
expected that the number of households moving into the area
may offset any outmigration by a considerable margin. This
net inmigration would provide an increased tax and business
spending base.
34 Removal efficiencies of 99 percent for particulates are
commonly achieved for power plants. Emissions above the
permitted limit will subject the owner or operator to
enforcement action.
35 Flue gas desulfurization is considered by EPA to be a
viable and reliable means of sulfur dioxide control for
power plants.
36 It is generally recognized that the full tax benefits
of a power plant are not realized until completion of
the plant. However, partial benefits do begin to accrue
with initiation of construction, through increasing tax
assessments as plant construction progresses and through
direct payments for specific services which are required
by plant construction.
The Applicant has accepted a readjustment of the tax
assessment on the proposed site property and is presently
paying a higher tax rate than what was being paid on the
basis of the property's previous land use. Further, major
service expenditures resulting from initiation of con-
struction, such as road improvements, will be paid for
or reimbursed by the Applicant at the general time that
the costs are incurred. In addition, a great many of
the impacts on local services, such as police and fire
protection, are the result of and proportional to the
movement of plant-related personnel into the area. As
the demand for these services increases with the in-
migration of households, the immediate tax base on
private households will also increase.
To the extent that these additional sources of tax
revenues may not fully match the impacts in the short
run, temporary measures will need to be taken by local
governments. There are a variety of traditional means
by which local governments may meet their immediate fiscal
needs. An excellent summary of many such means is
5-138
-------
RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number
36 (continued)
Response
37
38
39
40
41
provided in Chapters V and VI ("Paying for the Impacts"
and "Sources of Assistance") of the cited reference
("Rapid Growth from Energy Projects: Ideas for State
and Local Action," Department of Housing and Urban
Development, 1976).
The majority of fiscal impacts over the long-term, such
as the increased pressure on schools, road maintenance,
police and fire protection, will fall on Trimble County
as a whole. In this time frame, tax revenues from the
plant will, appropriately, be paid to Trimble County.
In the short run, it is expected that as many as 660
construction workers would commute into Trimble County
from other areas. In this instance, a geographical
imbalance could be construed, in that these commuters
would be contributing to impacts on Trimble County by
consuming public services, but paying taxes elsewhere
in their home county. In this regard, however, it is
noted that there is a net rate of 828 Trimble County
residents who pay taxes in Trimble County while daily
consuming public services elsewhere in other counties
where they are employed ("Commuting Patterns of Kentucky
Counties," Kentucky Department of Commerce, 1973). It
is concluded, therefore, that a new employment base
in Trimble County would actually bring the regional
service costs/tax revenues into a closer balance than
presently exists.
Please refer to the response to comment 13 of this
comment document.
EPA is obligated to proceed with the issuance of a
final EIS and therefore must place a deadline for
the receipt of comments on the DEIS. The comment
period ended officially on April 10, 1978. However,
in order to accommodate the Commonwealth of Kentucky
and the Trimble County Water District #1, EPA kept
the comment period open until September 14, 1978.
Please refer to the response to comment 1, Comment
Document M, page 5-85 of this FEIS.
Please refer to the response to comments 2-7, Comment
Document H, page 5-55 of this FEIS.
5-139
-------
RESPONSE TO COMMENT DOCUMENT N, Continued
Comment Number Response
42 There were no requirements for a public hearing prior to
the PCR (PSD Preliminary Determination). The PSD approval
time frame does not always allow coordination of review
and approval with the NPDES review process (i.e., the
EIS).
43 The PSD approval exceeded the regulatory time limit
during 1976. An extension of the time for the approval
process was approved by LG&E in early 1977 to allow
additional time for public comments. The "more stringent"
requirements did not take effect until approximately a
year after the original review. The re-review in December
1977 did consider the new requirements under the Clean
Air Act Amendments of 1977, for previously approved
plants which had not commenced construction by August 7,
1977. The Wises Landing plant met the new requirements,
also.
44 Please refer to the response to comment 5, Comment
Document M, page 5-87 of this FEIS, and to the Summary of
Major Concerns and Agency Responses, pages 5-1 to 5-5 of
this FEIS.
45 Please refer to the response to comments 9 and 10 of
this comment document.
46 EPA agrees that new facility construction is very expensive,
but LG&E has not withdrawn its permit application for
the proposed facility. EPA1s decision on permit issuance
is stated in Section 1 of this FEIS.
5-140
-------
SUPPLEMENTAL COflHEflTS
Ref; NPDES No. KY0041971
To; Environmental Division, U. S. Environmental Protection
Agency, 345 Courtland Street, N.E., Atlanta, Georgia 30308,
ATTN; Ms. Mona Ellison; and; Kentucky Department for
Natural Resources and Environmental Protection, Century
Plaza, U. S. 127 South, Frankfort, Kentucky 40601.
From; Harold G. Cassidy, Ph.D., Emeritus Professor, Yale
University (Retired)
On behalf of: SAVE THE VALLEY
Date; April 7, 1978
"| (87) We have raised the question whether EPA has not violated
its own rulings by the volume of Fluor Pioneer data that has
been used in this DEIS (See Comment 78). By rough count we find
over 5 times as many data from Fluor Pioneer as are attributed to
Dames and Moore (not including the Technical Appendix).
2(88) We question the independence of the document when in
addition to matters referred to in Comments 78 and 87 we find
in Technical Appendix TA-67 a report by ESSCO prepared for
Fluor Pioneer. Why not Dames and Moore? This seems to indicate
that the DEIS was prepared by Fluor Pioneer?
3(89) In Volume II, p. 7-6 we must protest that "quarterly
reports" on ground water contamination are not sufficient.
The reports should be monthly, or preferably weekly.
4(90) In Volume II, p. 7-6 there should be specified monetary
penalties for non-compliance under each of the pollutants,
gaseous, liquid and solid, so as to protect the public.
5(91) We have had access to "Air Pollution Emission Test,
First Interim Report on Continuous Sulfur Dioxide Monitoring
Program at Cane Run Unit No. 4, Louisville Gas & Electric Co,,
Louisville, Kentucky, December, 1977."
As far as we can determine, this is merely a test of
performance of monitoring equipment. "The operational test
period was conducted August 1-8, 1977." When we asked Mr.
John Tate of the Jefferson County Air Pollution Control Board
5 141 COMMENT DOCUMENT - 0
-------
-2-
whether compliance was achieved by this test he replied that
there were insufficient data collected as listed in this
report to verify compliance.
(92) Now see the PEDCo report dated March 1978 (for December-
January) p. 73. There it is stated categorically (by LG&E,
for EPA disavows willingness to warrant accuracy or completeness
of the information) with respect to Cane Run Ho. 4 operational
experience with FGD system "...the system successfully passed
compliance testing (85% S02 removal) on August 3 and 4, 19/7.
(93) The conjuction of our findings in paragraphs 91 and 92
explains why we are concerned that EPA may be prepared to
subject the citizens of this Valley to potential pollution from
the proposed plant at Wise's Landing. We already have too much
pollution in our River Valley, and it would be a gross mis-
carriage of justice, and an abrogation of our rights, we think,
to add more—especially on the basis of unsupported claims
such as that in the PEDCo Report, p. 73.
(94) Prior to the hearing on March 28 one or more of the EPA
representatives passed through Madison-Milton area and observed
the plume from the Clifty-Creek plant sweeping down into the
Valley and town. One of these gentlemen told me that there was
no theory that was able to describe or predict this behavior.
We cannot understand how EPA can base decisions that
affect our lives on theoretical models that use data from
Standiford Field (for example) and other distant and relatively
flat terrains, applying such modeling to our Valley situation.
It is known, from studies in the Kanawha Valley, for example,'
in the Charleston section, that winds and movement of pollution
in the Valley are strongly influenced by the character of the
Valley.
This is something that we who live here, and observe
wind movement, directions, and pollution from Clifty Creek
(and coming up the River Valley from Louisville) have been
telling Region IV of EPA for two years or more.
COMMENT DOCUMENT - O, CONTINUED
5-142
-------
RESPONSE TO COMMENT DOCUMENT 0
Comment Number Response
Please refer to the response to comment 40, Comment Docu-
ment N, page 5-131 of this FEIS.
Dames & Moore reviewed the ESSCO report prepared for
Fluor Pioneer. Although the report was judged to be
adequate, as far as it went, it was not complete, as
far as the requirements of the EIS. Therefore, Dames &
Moore conducted an additional salt deposition analysis,
the results of which are contained in the DEIS.
Please refer to the response to comment 13, Comment
Document N, pages 5-118 to 5-131 of this FEIS.
Violations of the NPDES permit conditions and limita-
tions for water pollution are subject to a maximum
civil penalty of $10,000 per day of violation. Willful
or negligent violation is subject to a maximum penalty
of $25,000 per day of violation.
For air pollution, the civil penalty pursuant to
Section 113(b)(3) of the Clean Air Act is not more
than $25,000 per day of violation. A person who
knowingly violates the law is subject to this same
daily fine and/or 1 year of imprisonment for the
first violation.
There is no federal enforcement per se for solid
waste storage under the Resource Conservation and
Recovery Act. Any pollution of surface waters
resulting from solid waste storage would be subject
to enforcement under the NPDES permit. For the
proposed Trimble County plant, the Commonwealth of
Kentucky has the sole permitting authority for solid
waste disposal.
The performance testing referred to is the testing,
on August 3 and 4, 1977, accomplished by Scott Environ-
mental Technology, Inc. for LG&E and EPA. The Method 6
Testing Report written by Scott Environmental Technology,
Inc., and submitted in December 1977, was not complete
and in a form that was acceptable to the Company or the
regulatory authorities.
5-143
-------
RESPONSE TO COMMENT DOCUMENT 0, Continued
Comment Number Response
5 (continued) Scott Environmental Technology, Inc. submitted a revised
report March 29, 1978, which included the additional
information required by the regulatory authorities. The
revised report was accepted by the Air Pollution Control
District of Jefferson County, and it was certified that
the system, as a result of the August 3 and 4, 1977
tests, met the compliance requirements.
6 Present mathematical techniques for predicting plume
dispersion do not account for the apparent falling into
the river valley of the Clifty Creek plume. The present
stacks are probably influenced to some extent by the
air flow over the ridge into the valley area. With the
taller stacks at Trimble County, this effect should not
take place.
5-144
-------
TO: Mr. John Hagin III, Chief EIS Branch
Environmental Protection Agency Region IV
3^5 Courtland Street N.E.
Atlanta, GA 30308
Dear Mr. Hagln,
Enclosed you will find 14 signed sheets of opposition to
the issuance of the NPDES permit (KY00419?!) to Louisville Gas
and Electric for the proposed LG&E plant at Wise's Landing near
Bedford, Ky. These 14? people, all residents of Trimble County,
are only some of my neighbors and friends that I was able to
contact since the EPA hearing here on March 28, 1978 and we
would like to make our feelings known to you.
1 There are many people here very concerned about the air
we must breathe and the water we must drink. Afterall, we will
be unable to stop breathing and needing water after this plant
is constructed and we feel It is your job to protect us from
the dangers to our environment which will certainly occur with
such an insult to nature. A federal agency with the title
ENVIRONMENTAL PROTECTION AGENCY should, at the very least live
up to its name.
2 Many of the small family farmers and the so called "little
people" have lost faith in the federal government and its ineffective
agencies. Please prove to us that you are still employees of we
the taxpayers and not the huge utilities who have unlimited funds
to build these monstrosities which will all too soon become
Ineffective.
3 As a registered nurse I am acutely aware of the health
problems we now face due to the polluted air already present
In our valley. To even consider another coal-fired plant is
ridiculous.
4 Also, it is extremely sad to us to see the beautiful topography
and peaceful way of life we have known to be devastated. Alternatives
to coal-fired plants can be realized but when the land, air, water
and people are gone there is nothing. Please give our side of this
issue your thoughtful consideration.
17^ >f fffi fp j] ?.n rp R\
Sincerely, ift £ «* E M fe ffi
" JU EPA-REGIOHIV ^
E i S BRANCH
Geary L. Hancock, R.N.
^&64^~S ^- ft/&/el>U'zS^/&'AJ- «•••
Copied sent to:
Mr. Zeller, EPA
Dr, John Roth, Commissioner,
Bureau of Environmental Quality
KY. Department for Natural Resources and Environmental Protection
5"145 COMMENT DOCUMENT • P
-------
To Environmental rrotsction Agency
>!a believe the luedical evidence regarding the health hazards
frcs episodes of high concentrations of sulfur dioxide is over-
whelming. The clean air act was enacted by congress to protect
you from unnecessary chemical pollution aro it should be ri?;idly
enforced. It siraply does not wake senae to locate huge power plants
10 miles apart. The evidence indicates they should be separated
by distances much greater than this. Therefore we the undersigne-I
object to the construction of the proposed Louisville Gas and
Electric plant at Wise's Landing or any other coal-fired plant
which would be just a few miles away.
J^.
Q ft, I
w*
Cl «
/
COMMENT DOCUMENT • t, CONTINUED
5-146
-------
To Jlnvironraental r rot act ion Agency
\'a believe the medical evidence regarding the health hazards
from episod.es of high concentrations of sulfur dioxide is -over-
whelming. The clean air act was enacted by congress to protect
you frora unnecessary chemical pollution and it should be rigidly
enforced. 'It simply does not make sense to locate huge power plants
10 miles apart. The evidence indicates they should be separated
by distances much greater than this. Therefore we the undersigned
object to the construction of the pjrppoised Louisville Gas and
Slectric plant at Wise's Landing or any other coal-fired plant
which would be just a few miles away.
, >
ifL-rt' n £-
' '
) I
COMMENT DOCUMENT • P, CONTINUED
5-147
-------
COMMENT DOCUMENT • P, CONTINUED
•To Environmental irrotection Agency
.4a believe the medical evidence regarding the health hazards
from episodes of high concentrations of sulfur rtioxide is over-
. The clean air act was enacted by congress to protect
from unnecessary chemical pollution and it should be rigidly
enforced. It siraply does not make sense to locate huge power plants
10 miles apart. The evidence indicates they should be separated
by distances much greater than this. Therefore we the undersigne-l
object to the construction of the proposed Louisville Gas and
Slectrlc plant at Wise's Landing or any other coal-fired plant
whloh would be just a few miles away,
$JJUL~ ^J/^^ ~?3 ^TTy**^. /*v
/ • j r\ c/ /n /} / ~/?j- j^ , •
fflj&aJjO-ftf^d &-**
-------
To .'Environmental .Protection Agency.
\!s believe the medical evidence regarding the health hazards
from episodes of hisjh concentrations of sulfur dioxide is over-
whelming. The clean air act was enacted oy congress to protect
you from unnecessary chemical pollution and it should be rigidly
enforced. 'It simply dees not make sense to locate huge power plants
10 miles apart. The evidence indicates they should be separated
by distances much greater than this. Therefore we the undersigned
object to the construction of the proposed Louisville Gas and
Slectrle plant at Wise's Landing or any other coal-fired plant
which would be just a few miles away.
COMMENT DOCUMENT - P, CONTINUED
5-149
-------
To .inviroMiental rrotection Agency
.-la balieve the medical evidence regarding the health hazards
from episodes of high concentrations of sulfur dioxide is over-
whelming. The clean air act was enacted by congress to protect
you from unnecessary chemical pollution and it should be rigidly
enforced, it simply does not make sense to locate huge power plants
10 miles apart. The evidence indicates they should be separatad
by distances much greater than this. Therefore we the undersigne-i
object to the construction of the proposed Louisville Gas and
Electric plant at Wise's Landing or any other coal-fired plant
which would be Just a few miles away.
COMMENT DOCUMENT - P, CONTINUED
5-150
-------
To jlnvironrnsr.tal rrotaction Agency
•-.'a believe iha nodical evidence regarding the health haza
fros 3pi3on.es of high concentrations of sulfur dioxide is over-
whelrain<>;. The clean air act was enacted by congress to protect
you. fros unnecessary chemical pollution and it should be rigidly
enforced. 'It simply does not make sense to locate hug® power plants
1G siiles apart* - The evidence indicates they should be separated
by distances rauch greater than this. Therefore we the undersigns^
object to the construction of the jjro^osed Louisville Gas and
Slsctrlc plant at Wise's Landing or any other coal-fired plant
which would be just a few miles away.
COMMENT DOCUMENT - P, CONTINUED
5-151
-------
To Environmental rroteotlon .'\r«;ency
?e believe the sedioal evidence regarding the health hazards
from episodes of high concentrations of sulfur dioxide is over-
whelming. The clean air act was enacted by congress to protect
you from unnecessary chemical pollution and it should be rigidly
enforced. It siaply does not wake sense to locate huge power plants
10 miles apart. The evidence indicates they should be separated
by distances auch greater than this. Therefore we the undersigns^.
object to the construction of the proposed Louisville Gas and
Slectrle plant at Wise's Landing or any other coal-fired plant
which would be just a few miles away.
COMMENT DOCUMENT - P, CONTINUED
5-152
-------
To Environmental protection Agency
•'a believe the medical evidence regarding the health hazards
from episodes of hi^h concentrations of sulfur dioxide is over-
whelming. The clean air act was enacted "by congress to protect
you fro?) unnecessary chemical pollution and it should be rigidly
enforced. It simply does not roake sense to locate huge power plants
10 miles apart. The evidence indicates they should be separated
by distances much greater than this. Therefore we the undersigned
object to the construction of the proposed Louisville Gas and
Electric plant at Wise's Landing or any other coal-fired plant
which would be just a few miles away.
f^*
COMMENT DOCUMENT - P, CONTINUED
5-153
-------
To Environmental i-rotection Agency
•Je believe the medical evidence regarding the health hazards
from episodes of high consent-rations of sulfur dioxide is over-
whelming. The clean air act was enacted by congress to protect
you from unnecessary chemical pollution and it should ba rigidly
enforced. It simply does not wake sense to locate huge power plants
10 miles apart. The evidence indit ates they should be separated
by distances much greater than this. Therefore we the undersigns^
object to the construction of the proposed Louisville Gs.s and
Slectric plant at-Wise's Landing or any other coal-fired plant
which would be just/^ few miles away*
^
c
<^v^r
COMMENT DOCUMENT - P, CONTINUE!
5-154
-------
To -Environmental rrotection Agency
'3 believe the medical evidence rasardin5 the health hazards
fro«} episodes of hi^h concentrations of sulfur dioxide Is over-
whelming. The clean air act was enacted by congress to protect
you from unnecessary chemical pollution and it should be rigidly
enforced„ Tt simply does not make sense to locate huge power plants
10 miles aparte The evidence indicates they should, be separated
by distances much greater than this. Therefore we the undersigned
object to the construction of the ££0£osed Louisville Gas and
alectrie plant at -/ise's Landing or any other coal-fired plant
which would be just- a few iciles away*
fl- bi.
COMMENT DOCUMENT - P, CONTINUED
5-155
-------
To Environmental i-rotsotion ;i;?ency
-;!e believe the medical evidence regard ins the health hasards
from episodes of high coneent-rations of sulfur dioxide is over-
whelming. The clean air act was enacted 'oy congress to protect
you froa unnecessary chemical pollution and it should be rigidly
enforced. It simply does not wake sense to locate huge power plants
10 miles apart. The evidence indicates they should be separated
by distances much greater than this. Therefore we the undarsignsi
object to the construction of the proposed Louisville Gas and
Sleotric plant at Wise's Landing or any other coal-fired plant
which would be ,1ust a few miles away.
/»
( I
I V
COMMENT DOCUMENT - P, CONTINUED
5-156
-------
To Environmental rrotsction Agency
-.!3 believe the medical evidence regarding the health hazards
frcs episodes of high concentrations of sulfur dioxide is over-
v.;helrain.«;. The clean air act was enacted by congress to protect
you from unnecessary chemical pollution and it should be rigidly
enforced, 'It simply does not make sense to locate huge power plants
10 "siles apart. The evidence indicates they s'nould be separated
by distances much greater than this. Therefore we the undersignsi
object to the construction of the proposed Louisville Gas and
Electric plant at -/ise's Landing or any other coal-fired plant
which would be just a few miles away*
COMMENT DOCUMENT • P, CONTINUED
5-157
-------
To -Environmental protection Agen
-------
To Jnvironirisrital protection Ag
>v8 believe the medical evidence regarding the health hazards
from episodes of hi?.;h concentrations of sulfur dioxide is over*
whelming. The clean air act was enacted by congress to protect
you from unnecessary chemical, pollution and it should be rigidly
enforced. 'It simply does not- raake sense to locate huge power plants
10 miles apart * The evidence indicates they should be separated
by distances much greater than this. Therefore we the undersigned
object to the construction of the oossl Louisville Gas and
Slectrlc plant at Wise's Landing or any other coal-fired plant
which would bs just a few miles away*
COMMENT DOCUMENT - P, CONTINUED
5-159
-------
RESPONSE TO COMMENT DOCUMENT P
Comment Number _______ _ Response
These comments have been noted and taken into considera-
tion in EPA' s final determination on issuance of the
NPDES permit to the proposed project.
5-160
-------
Paul G. Scully
2328 Hargan Drive
Madison, IN 47250
April 5, 1978
Mr. John E. Hagan, III.
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
At the hearing on March 28th on the proposed LG&E coal-
fired plant at Wise's Landing, there were a number of comments
made regarding scrubbers or the flue gas desulfurization systems.
The Environmental Impact Statement for the Wise's Landing Plant
states on a number of pages that this facility would remove 90%
or more of the sulfur dioxide from the stack gases in order that
the facility could comply with the air quality requirements of
both the State of Kentucky and the EPA.
A number of speakers commented that there was no problem relating
to the technology for removing S02 in these high efficiency limits
stated in the DEIS. Some even made comments that there were hundreds
of these units in successful operation throughout the country.
You may recall that I took strong exception to these statements
based on the bi-monthly reports which monitor all scrubbers in the
U. S. done by PEDCO Environmental, Cincinnati, Ohio. Within the
last week I have received the book entitled, "EPA Utility FGD Survey",
December, 1977 - January, 1978, which is the latest publication
detailing the performance and history of all the scrubbers, both
operational and planned, in the United States used by utilities.
This document fully substantiates the comments I made at the hearing,
namely, that there simply were no successful scrubbers on large
generating stations, that is those that would remove 90% of the S02
which had been in operation for at least one year successfully.
COMMENT DOCUMENT - Q
5-lol
-------
t_ „ „ -2- April 5, 1978
John E. Hagan z F
reports la supplied by the utility representatives or the scrubber
vendors and/or suppliers.
This document shows that there are currently 31 operational
scrubbers In the U.S. as shown on the attached summary. Fifteen
of these units burn low sulfur coal of 1% or less sulfur content
and therefore are not indicative of successful history for high-
sulfur coal in large generating units.
Of the remaining 16 units, one is the LG&E Paddy's Run #6 unit which
is a small 65 megawatt pilot plant and this generator is only
run during peak load periods, that is, it is not a regular operational
unit on a day by day basis.
There are only 14 of the units shown which serve generators of over
300 megawatts and only 12 installed on 400 megawatt or greater
systems.
If we look for the number of units burning high-sulfur coal,
such as LG&E advises will be burned at the proposed Wise s Landing
facility, and also units which are 400 megawatts or greater, (the
LG&E units will be 595 megawatts) we find there are only 6 which
fall into these categories. When we now ask the question how many
of these had S02 design efficiency of 90% or more, we find that
there are only 2. Both of these are the Bruce Mansfield units
owned by Pennsylvania Power Company located at Shippingport, Pennsyl-
vania. These are the units about which so much has been written
because of the tremendous technological and mechanical difficulties
which have been so well documented. Attached is an article describing
some of the mechanical problems associated with this scrubber system,
and of course, the Bruce Mansfield Unit #2 is not yet operational
since it has just been started up after much delay. The Bruce
Mansfield #1 unit has been operating at only 50% capacity because
of its well publicized scrubber problems.
COMMENT DOCUMENT • a, CONTINUED
5-162
-------
John E. Hagan -3- April 5, 1978
In looking at the other units of over 400 megawatts burning
3.5% or greater sulfur coal, we find that one is the Indianapolis
Power & Light unit which is brand new and not yet considered
operational. Another unit is the Kansas City Power & Light
LaCygne #1 unit, which has also been plagued with horrendous
mechanical problems sinee its inception and I should point out
it is also designed to remove 76% of the S02*
It is also interesting to note that the Texas Utility Martin Lake #1,
which is a large generating station of 793 megawatts only has a
design efficiency for SOo removal of 70.5% even though they burn
1.0% low sulfur coal. The Montana Power Cols trip #1 and #2 units
also burn 0.8% low sulfur coal and are 360 megawatt units. Please
note again that these units have only 70% S(>2 removal design
efficiency.
The Philadelphia Electric Eddystone IA facility, which is only
a 120 megawatt unit burning 2.3% coal did have a 90% S02 design
efficiency, but the history of this unit is one of a series of
mechanical problems since its inception in 1975. The unit has
never approached efficiency anywhere near 90% on a continuing basis.
The month by month detailed reports of each one of these scrubber
systems is available in the referenced EPA document. This latest
report simply confirms that there is no scrubber unit which has
yet been operated successfully for a period of one year burning
high sulfur coal and removing 90% of the sulfur dioxide. In
view of this, it is rather incredible that any utility would be
given a permit which would be based on a promise that such flue
gas removal efficiencies could be attained. Such high efficiency
calculations simply should not be permitted until the technology
has been proven. To do otherwise is to simply risk the health
of thousands of people in this valley who are already subjected
to enormous amounts of SC^ pollution.
Very truly yours,
Paul G. Scully
2328 Hargan Drive
Madison, IN 47250
COMMENT DOCUMENT - Q, CONTINUED
5_163
-------
ouu^ce oi inrormatlon: ———*«.
IPA_Publication p>^ 600/7-78-051 *
NAME OF FACILITY CN - NEW R - RETROFIT)
R Arizona P.S. * Cholla 1
N Col. & Southern 0. - Conesville 5
R Duquesne Light - Elrama
R Duquesne Light - Phillips
N ^ Indy Power & Light - Petersburg 3
i
R g Kansas City P & L - Hawthorn 3
R Kansas City P & L - Hawthorn 4
N Kansas City P & L - LaCygne 1
R Kansas P & Light- Lawrence 4
N Kansas P & Light - Lawrence 5
R Kentucky Util. - Green River 1-2-3
R LG&E - Cane Run 4
R LG&E-Paddys Run 6 (C>
N Mlnntonka -MR Young 2
FGD SYSTEM COAL % DESIGN FGD START
CAPACITY % EFFICIENCY VENDOR UP
MW SULFUR SOo REMOVAL PROCESS DATE
115
400
510
410
530
140
100
820
125
400
64
178
65
450
0.5
4.7
1.0 - 2.8
1.0 - 2.8
3.0 - 3.5
0.5 - 3.5
0.5 - 3.5
5.0
0.5
0.5
3.8
3.5 - 4.0
3.5 - 4.0'
0.7
C01
58.5
89.5
(B) 83.0
(§) 83.0
80.0
70.0
70.0
76.0
75.0
65.0
80.0
85.0
80.0
75.0
Research
Cottrell - 3
Univ. Oil - 1
Chemlco - 1
" 1
Univ. Oil- 1
Comb. Engr.-l
II II n
Babcock-W - 3
Comb. Engr. - 3
ii " - 3
Am. Air
Filter - 1
ii ii ii i
Comb. Engr. - 1
ADL/Comb Equip 4
IMENT DOCUMENT • Q, CONTI1
10-73
01-77
10-75
07-73
03-78
11-72
08-72
02-73
12-68
11-71
09-75
08-76
04-73
09-77
fUED
-------
'Page 2
PGD SYSTEM COAL % DESIGN FGD START
CAPACITY % EFFICIENCY VENDOR UP
NAME OF FACILITY (N - NEW R - RETROFIT) MW SULFUR SOo REMOVAL PROCESS DATE
N Montana Power - Cols trip 1
N Montana Power - Cols trip 2
R Nevada Power - Reid Gardner 1
R Nevada Power - Reid Gardner 2
N Nevada Power - Reid Gardner 3
R NIPSCO - D H Mitchell 11 (S)
H
N w Northern States Pwr - Sherburne 1
N Northern States Pwr - Sherburne 2
N Penn Power - Bruce Mansfield 1
N Penn Power - Bruce Mansfield 2
R Phila Electric - Eddys tone 1A
N S. Carolina P.S. Winyah 2
N Springfield Util. Southwest 1
R TVA - Shawnee 10A
360
360
125
125
125
115
710
710
825
825
120
280
200
10
0.8
0.8
0.5
0.5
0.5
3.2 - 3.5
0.8
0.8
4.7
4.7
2.3
1.0
3.5
2.9
COMJ
70.0
70.0
85.0
85.0
85.0
90.0
5.0
5.0
92.0
92.0
90.0
35.0
92.0
®
IENT DOCU
ADL/Comb EqujLp 4
ii H 4
ii ii 4
•• «• 4
.. 4
Davey Power
Gas 5
Comb. Engr 3
ii H 3
Chemico 1
Chemico 1
United Engr 2
Babcock-W 3
Univ. Oil 3
II II 0
MENT - Q, CONTIN
11-75
07-76
04-74
04-74
07-76
06-77
03-76
04-77
04-76
10-77
10-75
07-77
04-77
04-72
UED
-------
FGD SYSTEM COAL % DESIGN FGD START
NAMP rnr TTA^TT,^ / CAPACITY % EFFICIENCY VENDOR UP
KAKfc Of FACILITY (N - NEW R - RETROFIT) MW SULFUR SO? REMOVAL PROCESS DATE
R TVA - Shawnee 10 B
R TVA - Widows Creek 8
N Texas Util. Martin Lake 1
10
550
793
2.9
3.7
1.0
®
80.0
70.5
Univ. Oil 3
TVA 3
Research 3
Cottrell
04-72
05-77
10-77
Ul
a\
Sicrubber Process Code; (See FGD VENDOR PROCESS)
1 Lime Scrubbing
2 Magnesium Oxide Scrubbing
3 Limestone Scrubbing
.,f
4 Lime/alkaline Flyash Scrubbing
*^
5 Wellman Lord/Allied Chemical
'•A
••° ?
T% 5
Footnotes;
@ Experimentally Controlled
@ Based on 2% Sulfur Coal
© Used for peak loads only
@ Demonstration Unit - EPA & NIPSCO to
recover sulfur
COMMENT DOCUMENT - Q, CONTINUED
-------
SCRUBBERS
costly clean-air systems
that work.. .sometimes
Numerous utilities—and a handful of manufacturers—have installed
SO2 scrubbers. Some wish they hadn't,
and most have experienced maddening problems.
By John H. Sheridan
The dirt and gravel road leading into
Pennsylvania Power Co.'s Bruce Mans-
field plant in Shippingport, Pa., is
crawling with heavy-duty construction
equipment engaged in completing what
will eventually be a 2.500-megawatt
power generating complex on the Ohio
River.
A few hundred yards from the guard
house at Gate 16, the road winds past a
small church cemetery which is virtu-
ally in the shadow of the massive coal-
fired utility station. The cemetery seems
incredibly out of place, but an ardent
environmentalist might find it an ap-
propriate reminder of the reason for the
maze of equipment and ductwork link-
ing the boiler house to a 950 ft chimney
that towers over the busy site.
The ductwork, big enough that you
could drive a tractor-trailer through
it, is part of a $250 million air quality
control system. The heart of the sys-
tem is a group of "scrubber" trains
to remove fly ash and sulfur dioxide
INDUSTRY WEEK, October 24. 1977
(SO2) from the exhaust gases.
Environmentalists, citing studies that
indicate a link between SOa emissions
and human illness and mortality, have
been pressing for more widespread use
of scrubbers—also called flue gas desul-
furization (FGD) systems—on coal-
fired powerplants. Environmental Pro-
tection Agency (EPA) and state regula-
tions have forced FGD installations at
many existing and new utility plants,
although present air pollution rules
allow use of low-sulfur coal as an option
in many cases. (One exception is Wyo-
ming, which has set such tight SOz
emissions limits that scrubbers are
needed even with low-sulfur coal).
As part of his energy plan. President
Carter recommended use of scrubbers
on all new coal-fired plants, even those
that burn low-sulfur coal.
Sludge valley. But the capital cost is
staggering. At Bruce Mansfield, the air
quality control system represents about
one-third of the $750 million capital in-
vestment in the first two generating un-
its. Unit No. 2 was started up this sum-
mer, with a third 825-megawatt unit ex-
pected to come on line in 1980.
A major cost element of the Ship-
pingport project—requiring a $90 mil-
lion outlay—is the sludge disposal sys-
tem to handle the gray, toothpaste-like
material which the scrubbers produce.
The sludge, after chemical fixation
treatment, is pumped through a seven-
mile pipeline to a 1,330-acre valley,
once the water course of Little Blue
Run, a small Ohio River tributary. Little
Blue Run stopped running when en-
gineers from Dravo Corp. built a 400-ft
high dam to create an impounding basin.
Over a 25-year period, the valley will be
filled with sludge at the rate of nearly 3
million tons a year.
But the capital cost burden and the
enormousness of the undertaking are
only part of the reason most utilities
cringe at the thought of building FGD
systems. Since the Clean Air Act was
COMMENT DOCUMENT - Q, CONTINUED
5-167
-------
passed in 1970. an intense environmen-
tal debate has centered on the question:
Do scrubbers wt>rk'~!
Perhaps the best answer is: Sort of.
Some of the time. If you're willing to
devote a small army of technicians to
maintenance, operation, debugging.
and redesign. And if you don't mind
swapping one environmental problem
for another.
Acceptance? Research sponsored
by EPA and [he electric utility industry
has advanced the state of the art in the
last half-dozen years. But most utility
engineers contend it still falls short of
being "commercially proven" technol-
ogy. The most common reason they give
for deciding to install scrubbers is. "We
didn't have much choice."
As evidence that scrubbers are win-
ning "acceptance." EPA cites the fact
that 122 FGD systems are either
planned, under constructibn. or in oper-
ation in the U. S. Sam Ruggeri. senior
chemical engineer at American Electric
Power Service Corp., Canton, Ohio,
calls that "the EPA's Scrubbers Num-
bers Game."
"Through the years," he says, "the
EPA has stated that scrubbers work and
they keep trying to prove their point by
citing numbers of 'commercial' scrub-
bers. To the EPA. once a scrubber has
been ordered it becomes commercial:
even when, as has happened over and
over again, the scrubber is finally built
and has massive malfunctions.
"There are," Mr. Ruggeri points out,
"over 1,000 electric utility boilers in the
United States, but only 122 scrubbers
[most still in the planning stage] by
EPA's count. What about the other 900-
plus units? Most scrubber installations
result from acts of desperation rather
than sound engineering judgment."
At hearings earlier this year, on a
Sierra Club petition to tighten sulfur
emissions standards for new pow-
erplants, a spokesman for the environ-
mental group cited the Bruce Mansfield
plant as evidence that scrubbers work.
He pointed out that its lime-magnesium
oxide slurry absorption system removes
92% of the sulfur from the gas.
'Yes, but...' Keith ("Sam") Work-
man confirms that the system has been
known to achieve that level of effi-
ciency. But the Bruce Mansfield plant
superintendent adds an important qual-
ifier: "Only under carefully controlled
test conditions."
Removal efficiency under normal
Air pollution controls at the Bruce
Mansfield plant (far left) cost $250
million. A structural maze (second
from left) links the Shippingport
boiler house to a 950-ft chimney.
Ductwork in the scrubber system
(second from right) is large enough to
accommodate a tractor-trailer.
Sludge produced by the scrubber
system will fill a dammed-up valley
(far right).
COMMENT DOCUMENT • Q, CONTINUED
5-168
October 24. 1977. INDUSTRY WEEK 67
-------
day-to-day operating conditions may be
an entirely different story. But Mr.
Workman, a serious-mannered site boss
who sports a handlebar moustache,
shrugs when asked what the typical re-
moval efficiency is. He doesn't even
offer a ball park guess.
There are several reasons for that.
"Our stack monitoring equipment
hasn't worked," he explains. Moisture
and particles—the "carryover"—in the
exhaust gas have fouled the monitoring
apparatus in the stack. That is just one
of the headaches his crews have had to
contend with since the turbines first
rolled on the No. 1 generating unit in
December 1975. Scaling deposits,
equipment plugging, corrosion, erosion,
and mist eliminator breakdowns have
also been part of the frustrating struggle
to keep the FGD system on line.
Balancing act. To avoid many of
these problems, and to achieve efficient
SOt removal, it is necessary to maintain
a delicate chemistry balance in the sys-
tem. And that presents a chemical en-
gineering challenge that hasn't yet been
completely licked.
Connecting each boiler to the tall
stack is a series of six scrubber trains,
each housing two venturi-design scrub-
bing vessels which constrict and speed
up the gas flow. In each vessel, a lime-
magnesium oxide slurry reacts with the
rush of hot combustion gases to form a
mix of calcium sulfate, calcium sulfite,
and fly ash: the sludge.
To produce the proper reaction, the
pH level (acid-alkalai) must be carefully
controlled, Mr. Workman points out. If
the slurry becomes too acidic, corrosion
occurs and SCh removal is inhibited. If it
becomes too alkaline, sludge deposits
cause scaling and plugging of the sys-
tem.
"But pH control is difficult," Mr.
Workman notes. "In fact, pH meas-
urement is difficult." To monitor the
pH level, 12 devices known as pH cells
were designed into the system. "But
they've hardly worked at all. We've had
trouble with foreign materials breaking
them. And they will scale up and give
you a false reading."
To cope with that, it has been neces-
sary to take "grab samples" to test for
pH and add lime manually, even though
the system is designed for automatic
lime feed.
Mist puzzle. With modifications, Mr.
Workman is hopeful that the pH cells
will eventually function properly. But
M INDUSTRY WEEK. October 24. 1977
he's less optimistic about solving what
he calls "the mist eliminator problem."
Mist eliminators are baffle-like struc-
tures in a chevron design that a layman
might compare to filtering devices.
They cause the gases to make a series of
90-degree bends, slamming into the bar-
riers in their path. The idea is to trap
moisture in the gas and let it drip back
down into the slurry. If excessive mois-
ture escapes from the first vessel it will
cause a buildup of material on the
rubber-lined housing of the induced
draft fan and lead to a malfunction.
The mist eliminator for the second
vessel prevents moisture from escaping
with the stack emissions. If the exhaust
gas is too moisture-laden, it will cause a
violation of particulate emissions
standards—and it makes for difficult
community relations, particularly when
a cold front happens to be passing by.
"The cold front inhibits evapora-
tion," Mr. Workman explains.-Thus,
the moisture—containing entrapped
calcium sulfate. free lime, and fly
ash—precipitates in the surrounding
area. "It lands on the neighbors' houses
and cars and when the liquid evapo-
rates, it leaves a white film. The
neighbors don't like that worth a
damn."
Several mist eliminator designs have
failed structurally and Bruce Mansfield
engineers have spent several million
dollars replacing and redesigning them.
Replacement of four mist eliminators
this summer added $240,000 to the es-
calating maintenance budget, notes
Dale Billheimer, production engineer.
He hopes the new ones will last—well,
perhaps six months or longer. "We re-
ally haven't had enough operating ex-
perience to be sure how long they'll
last," he says.
Another problem has been scaling,
which impairs the operation of the mist
eliminators and—untended—can even-
tually block the gas flow. One way to
prevent scaling is to spray the unit with
fresh water. But that aggravates the
exhaust moisture problem and dilutes
the magnesium salts in the system. "If
you don't maintain the right magnesium
level, then you're not getting the SOz
removal you need," Mr. Workman
says.
"It's a vicious circle," he adds, with a
hint of exasperation. "And I'm not sure
there is a solution."
A matter of degree. Disagreement
over whether or not scrubbers work is a
little like the argument over whether a
glass of water is half-empty or half-full.
"I'd be a fool to say that all the scien-
tists and engineers won't be able to
eventually develop a_ scrubber system
that will efficiently remove SO2," Mr.
Workman says. "But I don't think the
technology is fully developed yet. My
guess is that, with the exception of the
mist eliminator problem, we can even-
tually work out the problems. But I'm
not positive about that."
While most utility company engineers
are far from satisfied with the present
state of the art of FGD systems, at least
two firms—Kansas City Power & Light
and Louisville Gas & Electric Co.
(LG&E)—have gone on record saying
the technology is adequately developed
to warrant its use. Some in the industry
suggest, however, that practical finan-
cial considerations influence that advo-
cacy position.
"If they say their systems don't work,
then the regulatory commissions won't
let them include the scrubbers in their
rate base," one FGD critic maintains.
In fact, the Kentucky Public Service
Commission (PSC) did inform LG&E
that it would not issue a "certificate of
convenience and necessity" for scrub-
ber installations until the utility proved
its FGD system could operate reliably
on a unit larger than 100 megawatts
(MW) for more than one year. Without
that certificate, notes Robert Van Ness,
LG&E's manager of environmental af-
fairs, it could be difficult obtaining rate
approval after an FGD system is in-
stalled.
LG&E has achieved 99% SO* re-
moval on its 70 MW Paddy's Run boiler,
which has been on line since April 1973.
But that is a peaking unit that is needed
only during periods of high electricity
demand. A scrubber started up a year
ago on a 190 MW unit. Cane Run No. 4,
has been fairly successful, Mr. Van
Ness says.
Brownouts ahead? One advantage
at Cane Run No. 4. however, is that a
bypass is built in. If the scrubber breaks
down, the combustion gas can bypass
the SOs removal system and the
generating station doesn't have to be
shut down. "It is a matter of getting
variances from the air pollution control
board and EPA," Mr. Van Ness notes.
Many utilities have, however, been
prohibited from building bypasses into
their systems.
Without a bypass, a scrubber shut-
COMMENT DOCUMENT - a, CONTINUED
5-169
-------
down translates into a boiler shutdown.
And if that occurs during a period of
peak electrical demand, it can mean
brownouts. So far. scrubber problems
haven't been blamed for power curtail-
ments. American Electric Power's Mr.
Ruggeri says. "But when we get 122
operational scrubbers, that will be a
very real prospect."
There is a solution, of course: build-
ing in "redundancy." backup scrubber
units to be used when others are shut
down for repair or maintenance.
"It's our opinion that you must build
redundancy." says J. James Rosen,
general director, engineering research
department. Detroit Edison Co. "Prob-
ably 20% additional FGD capacity is
needed—and that increases your capital
costs significantly." Another approach
would be to design a powerplant with
additional reserve generating capacity.
A demonstration scrubber at a 170
MW Detroit Edison unit has been taken
out of service as an 862 removal device
because maintenance requirements
were considerably greater than antici-
pated.
Reliability. Often, the argument over
whether scrubbers work comes down
to: how much of the time do they work?
Proponents cite "availability" statistics
in the 90%-plus range—but there are dif-
ferent ways of calculating availability.
On a peaking unit, such as LG&E's
Paddy's Run station, availability statis-
tics aren't meaningful since the boiler
may be in use only 10% of the time.
A survey earlier this year of 24 opera-
tional systems showed availability dur-
ing the first quarter ranging from 20% to
100%. with 80% to 90% a common
range.
The 20% figure was for one module at
Commonwealth Edison Co.'s Will
County No. 1 station. It was the first big
scrubber on line in the U. S.. explains
Bob Lundberg. general staff engineer
for the Chicago-based utility. Operating
since 1972. the unit has had a long his-
tory of technical and chemical prob-
lems.
Historical availability of the unit has
been "about 25%." Mr. Lundberg
notes. Like the Detroit Edison system.
it was scheduled to be taken out of ser-
vice this summer as an SOz control de-
What happens in a scrubber?
The scrubber system at Pennsylvania
Power Co.'s Bruce Mansfield station,
designed by Chemical Construction
Corp.. is equipped with six scrubber
trains for each boiler. This schematic
illustrates the passage through one
train. Flue gases from the boiler (1)
enter the first-stage venturi vessel (2)
from the top and pass down through
the center cone, colliding with a
water-lime spray which removes
flyash and about 70% of the SOa. The
heavier droplets precipitate to the
slurry at the bottom of the vessel (4)
and the gases rise through a set of
mist eliminators (3) which trap finer
droplets of moisture. An induced
draft fan (5) propels the gases to the
second-stage absorber-scrubber
vessel (6) where additional 862 re-
moval occurs. A second-stage mist
eliminator (7) captures liquid "car-
ryover" (moisture) in the exhaust gas.
The gas, which is cooled during
scrubbing, must be reheated in an
oil-fired reheat burner (8) before exit-
ing through the stack (9). Without re-
heating, the buoyancy of the exhaust
plume would be inadequate for
proper dispersion, causing precipita-
tion problems in the area. The slurry
from the scrubber vessels is pumped
to a thickener tank and churned into
30%-solid sludge. The sludge is then
processed through the addition of
Calcilox, a Dravo Corp. hardening
agent, before being pumped to the
disposal site, which is a dammed-up
valley.
Second-stage SO2
absorber/scrubber
First-stage
adjustable
venturi for
fly ash/SO2
removal
eliminators
Coal
Mist
eliminators
Induced
draft fan
Slurry to recycle/sludge disposal
INDUSTRY WEEK, October 24. 1977
COMMENT DOCUMENT - Q, CONTINUED
5-170
-------
The question really is not whether scrubbers work.
The question is: How do they work?"
vice, while continuing to be used for fly
ash control. "We've been trying to
make it work on Illinois coal and we
haven't been able to," Mr. Lundberg
says. "But it wasn't a total loss. Other
people have learned from our experi-
ence. We've learned from it, too. We
won't make all the same mistakes
again."
Water pollution. Some of the FGD
Scrubber scorecard
In a press release earlier this year,
the Environmental Protection Agency
(EPA) noted that the number of
scrubber systems installed, being
built, or planned by electric power
companies has reached 122—nearly
triple the number cited in the fall of
1973.
For a clue to the state of the art of
scrubber technology, Sam Ruggeri,
senior chemical engineer at Ameri-
can Electric Power Service Corp.,
suggests it is useful to examine the
status of the 44 systems EPA was
pointing to four years ago. "Where
are they now?" Mr. Ruggeri asked—
then answered his question. Here is
his breakdown:
• Fifteen have become "opera-
tional," achieving varying degrees of
success. ("One consumed itself and
is being replaced.")
• Five are about to start up or are in
start-up.
• One was delayed by a fire in the
scrubber.
• Two were converted from SO2
scrubbers to particulate scrubbers
for use with low-sulfur coal.
• Four were only test units and have
been shut down.
• Two were "failures" and were
abandoned.
• One was shut down due to lack of
regeneration facilities but has since
been restarted.
• One is being reevaluated and may
not be installed because of sludge
disposal complications.
• Two were canceled and never built.
• Eleven still have not been finally
committed "and may never be con-
structed."
systems which have achieved reasona-
bly good success, he points out, have
been able to "overboard" some of the
water contaminated by contact with
slurry. They discharge it to a river or a
lake. This eliminates some of the dis-
solved solids and allows the addition of
fresh water to the system, which avoids
problems that occur when the slurry be-
comes saturated with chemicals. At
saturation levels, solids build up in the
system and scaling occurs.
In arid regions, the water balance can
be maintained by discharging a bleedoff
stream to an evaporation pond. But in a
typical eastern industrial city, over-
boarding may mean discharging into a
stream or lake. Presto: a conflict with
water pollution laws.
Commonwealth Edison was not per-
mitted to overboard. And to keep its
mist eliminators clean, it had to resort to
a fresh water spray. "But then we
couldn't keep the right Water balance in
the system, and that caused scaling."
One argument against scrubbers is
that they aggravate energy demand, typ-
ically requiring 5% or more of the pow-
erplant's electricity output. "If you are
building generating capacity to meet a
5% or 6% yearly increase in electrical
demand, and someone tells you to in-
stall a piece of apparatus that consumes
10% of your power output, you're giving
away two years of growth," Mr.
Lundberg observes.
Industrial boilers. To a limited ex-
tent, FGD systems have been used on
industrial-sized boilers for SO2 control.
Caterpillar Tractor Co. achieved 80% to
85% availability with a dual alkali sys-
tem at its Joliet, 111., and Mossville, 111.,
plants—and a removal efficiency of 90%
or better when the systems were operat-
ing. (In a dual alkali system, the chemi-
cal reagent is regenerated; the sludge
produced is basically gypsum and can
be used as landfill.)
Based on its four years' experience,
Caterpillar "does not subscribe to the
philosophy of post-combustion desul-
furization as the best method" of meet-
ing sulfur emissions standards, Bill
Compton, staff engineer, told an EPA
hearing panel in May. Problems were
encountered meeting particulate emis-
sions standards and "the availability of
hardware which can withstand the
chemical and physical demands on a
continuous basis are not now availa-
ble," he said. "Many system compo-
nents have proved to be unreliable."
General Motors Corp. has also used a
double alkali system on a boiler at its
Chevrolet Plant in Parma, Ohio. An
evaluation prepared this year for EPA
by Arthur D. Little Inc., Cambridge,
Mass., concluded that the developmen-
tal system "did not generally perform in
accordance with design criteria. It did,
however, show substantial improve-
ment over time."
Because of many outages for mechan-
ical modifications, total scrubber avail-
ability over the two-year test period
was 77.9%, "excluding four long-term
planned shutdowns."
Alternatives. Double alkali, lime,
and limestone slurry FGD units are
called "throwaway" systems because
of the sludge they produce. Less well-
advanced are "regenerable" scrubber
technologies which will produce usable
byproducts—sulfuric acid and elemen-
tal sulfur—instead.
Farther down the road are advanced
front-end coal-cleaning technologies,
such as solvent coal refining and deep
cleaning to remove sulfur and impurities
prior to combustion. Also in the de-
velopmental stage is a technique called
fluid bed combustion, in which coal is
burned on a limestone bed. Particles in
the bed absorb the sulfur during com-
bustion and eliminate the need for a
scrubber.
Most experts expect, however, that
throwaway systems will be the primary
SO2 control strategy for the next ten
years or longer.
As Sam Workman and his engineering
compatriates continue groping for a
scrubber that satisfies all the major
criteria, the controversy over the state
of the art is bound to continue.
"The question really is not whether
scrubbers work," says Detroit Edison's
Mr. Rosen. "The question is: How do
they work? And what is the impact of
applying them to a powerplant—the
waste disposal problem, the energy
penalty, and the tremendous capital
costs, especially if you build in redun-
dancy?" •
COMMENT DOCUMENT - Q, CONTINUED
5-171
October 24, 1977, INDUSTRY WEEK 73
-------
RESPONSE TO COMMENT DOCUMENT Q
Comment Number Response
Please refer to the responses to comments 3 and 4,
Comment Document G, pages 5-41 to 5-42 of this FEIS, and
comment 15, Comment Document N, pages 5-118 to 5-131.
5-172
-------
DR. BILLY H. STOUT, SUPT.
CECIL FISHER, D. P. P.
CLYDE CHOPPER, FEDERAL CORD.
Trimble County Schools
P. 0. Box 67 Phone: 502/255-3554
BEDFORD, KENTUCKY 40006
BOARD OF EDUCATION
CAROLE MARTIN, CHAIRPERSON
STEVE THARP, v. CHAIRPERSON
JACK CARDER, MEMBER
JAMES MCMAHAN, MEMBER
GLENN FISHER, MEMBER
April 5, 797*
Mr. John E. Hagan III, Chle.& EIS Branch
Ewu/z.owienta£ Protection Agency Region II/
345 Courtland Stteet, W. E.
Atlanta, Ga. 3030*
Peat Mt. Hagan:
Enclosed >c6 a copy otf the letter I lecexued £tom the U. S.
ment OjJ ConwieA.ce Econom>tc
am having dt^^cu^tt/ /tn
o& people due to
It
people tfatt we wit££ haue an
We caw ajtxtuUpate a££ o^ t^ie thing* that the. tztt&i mwtion* because
-it M*W stated In you*, impact &tudy. Why then, can't we lece-ive 4ome
xd to he£p a& cont>ttiu.ct additional &adUti&t>? The.
adcke64e4 W>zJLh to the. vexy co/te ojj the pn.obim& that we xja Tumble.
County mJUL encoantet.
4c/ioo£ 4t/4t0n doeA not /iaue the .Ata^ o-t jj/tnancei to conduct
a compie.hejti>lve. economic adju&An&nt Attategy. HoweveA, It doesn't take.
a compx.eJie.nAlv e. plan to 4ee oufi needi.
You*. he£p and
lt> appreciated.
SlncefreZy,
Bill Stout, Superlntende.nt
Trimble. County School^ |p
EPA-REGION IV
E I S BRANCH
ATLANTA. GA.
Enclosure.
T 10V
5-173
COMMENT DOCUMENT R
-------
U.S. DEPARTMENT OF COMMERCE
Economic Development Administration
210 E. Ninth Street, P. 0. Box 241
Hopkinsville, Kentucky 42240
March 29, 1978
Dr. Billy H. Stout
Superintendent
Trimble County Schools
P. 0. Box 67
Bedford, Kentucky 40006
Dear Dr. Stout:
Thank you for your March 27 letter regarding possible Economic
Development Administration Title IX assistance for new public school
facilities in Trimble County.
I have discussed your letter with Mr. W. S. Hattendorf, Deputy
Regional Director and Title IX Coordinator for the EDA Southeastern
Region, and we have concluded that you have, at best, a marginal Title
IX situation.
First, neither Mr. Hattendorf nor I are aware of any instances where
Title IX funds have been used for elementary or secondary school
construction, although this may have happened somewhere in the country.
Second, you do not state that the generating station will be built in
the county, and if so, how many of the 685 projected workforce are
construction workers and how many permanent employees. Also, will the
685 workers all locate in Trimble County, or will they be dispersed
over a broader area, with considerable reliance on commuting to and
from work?
Further, what other "boomtown" effects do you anticipate, such as over-
loading of water/sewer facilities, a housing shortage, or transportation
deficiencies? Title IX should be used, insofar as possible, to address
the expected range of problems, rather than just one specific problem
area such as schools.
In conclusion, if the generating plant is committed to construction in
your county, and if other than school problems will result, it might be
that you need to develop a comprehensive economic adjustment strategy
to chart the remedial efforts needed to overcome the anticipated problems.
COMMENT DOCUMENT - R, CONTINUED
5-174
-------
page 2
If, after you have read the enclosed Draft Title IX Guidelines, you
would like to meet to discuss the matter in more detail, please let
me know and we can arrange a meeting.
Sincerely, ^
William G. Glasscock
Economic Development
Representative,
Western Kentucky
Enclosure
cc: Mr. W. S. Hattendorf
COMMENT DOCUMENT • R, CONTINUED
5-175
-------
RESPONSE TO COMMENT DOCUMENT R
Comment Number Response
Please refer to Comment Document FF, page 5-319 of this
FEIS.
5-176
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, B.C. 20240
ER 78/141
APR 51978
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
Thank you for your letter of February 7, 1978, transmitting
copies of the EPA's draft environmental impact statement for
the Trimble County Generating Station, Units 1-4, Trimble
County, Kentucky.
Our comments are presented according to format of the
statement or by subject.
Mineral Resources
I Although the Bureau of Mines has no information on presently
active mineral recovery operations in Trimble County, sand
and gravel have been produced in the past in the study area.
The proposed project will have a positive effect on mineral
industries in the area since construction minerals will be
immediately tapped followed by the supply of western Kentucky
coal as fuel to the station. We find that the draft state-
ment adequately describes mineral resources.
Groundwater Sampling Program
2 We suggest that the groundwater monitoring program should be
made more explicit and thorough. At a minimum, we recommend
each well sampled should be pumped long enough to withdraw
several times as much water as that contained with the well
casing, gravel pack, or annulus and the distribution system
between the aquifer and the point of collection (Rainwater,
F.H.. and Thatcher, L.L., 1960, Methods for collection and
analysis of water samples: U.S. Geological Survey Water-Supply
Paper 1454, p. 20). After completion of such a withdrawal
period, easily repeated field tests of properties such as pH,
specific conductance, and temperature will reveal whether the
characteristics of the discharge have stabilized sufficiently
for sampling or whether^additional pumping is needed.
5-177 COMMENT DOCUMENT - S
-------
Mitigation Measures
3 Although on page 2-51 of the draft statement the hazards of
potential groundwater contamination of karstic aquifers are
discussed, we recommend that the final statement should speci-
fy the mitigation measures to be employed when herbicides are
used along transmission right-of-ways that cross karstic
terrain.
4 Although project plans have been modified to avoid destruc-
tion of Corn Creek, significant impacts remain unmitigated.
The final statement should include measures to mitigate
habitat destruction resulting from the relocation of a portion
of Corn Creek, loss of cultivated crop lands, pasture land,
upland woods, and miscellaneous floral communities. We believe
that mitigation measures for project-incurred resource losses
and public use of these resources can best be accomplished
through the development of a fish and wildlife management and
public access plan. The plan should provide intensified
management of the habitat remaining after project completion
and the rehabilitation and enhancement of habitat areas severe-
ly altered by the project. We suggest that the final statement
should include an adequate description of the applicant's
mitigation plan for fish and wildlife resources. While the
plan is being developed, we recommend that State and Federal
fish and wildlife agencies should participate in a review
and recommendation capacity. We also suggest that all pertinent
sections of the final statement should mention the proposed
fish and wildlife management plan.
Fish and Wildlife Coordination Act
5 The draft statement provides adequate information regarding
impacts to fish and wildlife and their habitats. As outlined
in the draft statement, the project will significantly and
adversely impact fish and wildlife resources within the project
area. It is anticipated that construction and completion of
the project will require the acquisition of a Corps of Engineers
permit to dredge and/or deposit materials into waters of United
States CSection 404, P.L. 92-500). Relative to this action,
there is Inadequate information concerning measures to minimize
harm for a full understanding of how the proposed action may
COMMENT DOCUMENT • S, CONTINUED
5-178
-------
affect fish, and wildlife resources. Accordingly, the current
review of this statement does not preclude additional and
separate evaluation and comment by the Fish and Wildlife
Service pursuant to the Fish and Wildlife Coordination Act
C16 U.S.C. 661, et seq.). In evaluating such a permit appli-
cation, the Fish and Wildlife Service may concur, with or
without stipulations, or object to the proposed work plan,
depending upon project effects which may be identified and
evident at that time on fish and wildlife resources.
We hope that these comments will be helpful to you in the
preparation of a final statement.
.Sincerely,
/0-7 ^
Larry E. Meierotto
SECRETARY
COMMENT DOCUMENT - S, CONTINUED
5-179
-------
RESPONSE TO COMMENT DOCUMENT S
Comment Number Response
1 Comment noted. No response required.
2 Comments noted. The Ground Water Monitoring Plan
(Appendix B to this FEIS) has been revised to include
these suggestions.
3 Please refer to the response to comment 1, Comment
Document F, page 5-26 of this FEIS.
4-5 Please refer to the response to comment 1, Comment
Document F, page 5-26 of this FEIS.
5-180
-------
THOMAS D. BREITWEISER, INC.
KINO'S DAUGHTERS' HOSPITAL
MADISON, INDIANA 4725O
TELE. 265-2623
THOMAS D. BRBITWEISBR, M.D.
RADIOLOGIST
April 6, 1978
MELVIN J. SKILES, M.D-
RADIOLOGIST
John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N. E.
Atlanta, Ga. 30308
Attention: Ms. Mona Ellison
Dear Mr. Hagan:
The Jefferson and Switzerland County Indiana Medical Society wishes to
object to the proposal of the Trimble County Generating Station and the
issuance of the Draft Environmental Impact Statement.
The Jefferson-Switzerland Counties Medical Society is an organization of
physicians which opposes any additional air pollution in our area. This
medical society is concerned only about human health and has no economic
interest in electric power generation.
We are concerned about very common human illnesses such as lower respiratory
illnesses (especially in childred), acute and chronic bronchitis, asthma and
a large number of heart and lung illnesses. Death in the persons with heart
and lung diseases is a major concern.
For many years we in this area have been exposed to excessive pollution
levels from the Clifty Creek (IKEC) Power Plant. In recent years we have
seen an additional huge power plant built at Ghent, Kentucky; we are now
experiencing the prospect of a huge new power plant to be built at Wise's
Landing in Trimble County; and we have scheduled hearings on a new power
plant in Mexico Bottom; and more are rumored for this area.
1 The health hazards and the ambient air quality violations from the existing
Clifty Creek Plant are gross, and they are listed on page 53 and page 56 of
the Draft Environmental Protection Agency Statement for the proposed Wise's
Landing plant. These levels of air pollution which are given are very
significant for human health.
2 The Environmental Protection Agency is whom we depend upon to enforce air
quality standards. The Environmental Protection Agency has not enforced
these standards which are violated by the Clifty Creek (IKEC) Plant. We
do not understand why there is any consideration of any new pollution sources
in this area by the Environmental Protection Agency.
-1-
5-181
COMMENT DOCUMENT - T
-------
.fir. >JOhn E. Hagan, III 4-6-78 -2-
Chief, EIS Branch
Environmental Protection Agency
Atlanta, Ga. 30308
3 If the Environmental Protection Agency is going to uphold the air quality
standards and our right to health, the proposed power plant at Wise's Landing
for Louisville Gas and Electric Company should never have been considered.
However, if it is, the Jefferson-Switzerland Medical Society would suggest
that the following be provided:
<4 (1) A source should be provided to us whereby the hour-by-hour climatologic
and air pollution data from the Clifty Creek (IKEC) plant can be obtained,
at our expense, by which we may better study the health hazards to the people
in our area.
5 (2) The Environmental Protection Agency should publish what pollution
levels of sulfur dioxide would result if scrubber devices on a new pollution
source should fail. These failures are evidently expected according to the
Draft Environmental Statement for the LG&E Plant at Wise's Landing.
Q (3) We suggest that the Environmental Protection Agency consider air pol-
lution effects of river winds which tend to channel wind upstream and down-
stream. (Final Draft Environmental Impact Statement 3.2.1.3 Energy Research
and Development Administration, May 1977.)
/There is a question of ethics here for the Environmental Protection Agency.
If this agency is charged with protecting our health, why do they propose
multiple new air pollution sources while allowing existing air pollution
violations?
OThere also is a moral question of human rights. Why should one particular
location and people bear the health effects of air pollution (from Portsmouth,
Ohio; Louisville, Kentucky; Frankfort, Kentucky; Indianapolis, Indiana and
more)? After all, our nation is still founded on the idea of a republic
with the proposition that large population areas should not exploit small
population areas.
9We suggest that all of us look these gift horses in the mouth. These
Environmental Protection Agency hearings which have occurred and which are
planned entice us with "proposed" small increments in air pollution and
huge economic and social benefits. Ask yourself, if the health hazards
are so slight and the monetary benefit is so great, why are so many power
companies in such a headlong rush to surround us with huge power plants and
so anxious to spend their money to condemn our land for power lines to ship
it back to the big cities?
Sincerely,
Jefferson-Switzerland County Medical
Sn/* i p1~v /i
Thomas D. Breitweiser, M. D., Spokesman
TDB/paa
COMMENT DOCUMENT - T, CONTINUED
5-182
-------
RESPONSE TO COMMENT DOCUMENT T
Comment Number Response
Please refer to the Public Hearing transcript statement
by Ms. Louise Grosse of EPA Region V regarding the status
of enforcement on the Clifty Creek plant (pages 36 to 39
of Appendix E of this FEIS).
EPA is required to consider any project for which it
receives a permit application.
The EPA is required to perform a complete analysis of
any project for which it receives a permit application,
once it determines that the project would have a signifi-
cant impact on the natural and human environment.
The state of Indiana is charged with compiling monitored
data. Indiana residents should ask to see these data.
If there is no ongoing adequate monitoring program, such
could be requested of the state. American Electric Power
Company, Incorporated, maintains a monitoring system
around the Clifty Creek plant. It has released the data
from this system to Teknekron to use in the EPA-funded
ORBES study. The data is consequently now available to
the public.
If a scrubber is removing 90 percent of the sulfur
dioxide from the flue gas, and the 90 percent removal is
necessary to comply with the 3 hour increment, then total
failure of the scrubber could produce 3 hour concentrations
of approximately 5,000 ug/m^. This example assumes a
worst case situation with maximum output (no reduction
in load or emissions due to scrubber failure) and worst
meteorology.
Please refer to the response to comment 25, Comment
Document N, page 5-135 of this FEIS.
All major emission sources within the jurisdiction of
EPA Region IV are either meeting emissions limitations
or are on an approved compliance schedule. However,
outside Region IV, in Indiana, there are sources, the
Clifty Creek plant for one, which are not on an approved
compliance schedule because of several pending legal
matters. Please also refer to the response to comment 1
of this comment document.
To say that the EPA proposes new emissions is not correct.
The applicants for federal permits propose the facilities
and their emissions.
5-183
-------
RESPONSE TO COMMENT DOCUMENT T, Continued
Comment Number Response
8 The health and welfare of all citizens is the concern
of EPA. The agency is not aware of "the idea of a
republic with the proposition that large population
areas should not exploit small population areas" in
environmental laws. The Clean Air Act has provided
for citizens by establishing ambient air quality
standards and limits on air quality deterioration
from new sources. More deterioration of air quality
can occur in rural areas than in urban areas without
exceeding established increments or standards because
the air in rural areas is normally not significantly
degraded, when measured in terms of existing standards
for air quality. This is a primary reason why utilities
propose to build new plants outside metropolitan areas.
Please also refer to the Summary of Major Concerns and
Agency Responses, pages 5-1 to 5-5 of this FEIS, and to
the following response.
9 The siting of power plants involves the consideration
of many factors. The generation and distribution of
electric power must be planned on a regional basis.
Although the consumption of power is relatively higher
in the urban portions of the region than in rural
portions, the limitation on both land and air quality
increments in urban areas is more severe due to other
urban activities. Therefore, in order to supply the
entire regional system with needed power, utilities
propose to build the additional capacity in those
parts of the region where the land and air quality
increments are available.
The Trimble County area is an integral part of the
larger regional system. This interdependency is
indicated by at least one fact: that more Trimble
County residents depend on neighboring cities for
employment (835 outcommuters) than are employed
within the county itself (753 locally employed).
Trimble County will share most of the direct benefits
of the proposed plant in terms of tax revenues and a
more local employment base. In turn, this county has
a greater abundance of available land and air quality
increments to share than do the already more developed
portions of the regional system.
5-184
-------
TACKET RURAL ROUTE 1 • BEDFORD KENTUCKY 40006 • 502 • 268-3377
April 6, 1978
Mr. John E. Hagan III
Chief £13 Branch
Environmental Protection Agency Region IV
34-5 Courtland Street N.E.
Atlanta, Georgia 30308
Re: Louisville G&B and Electric Company
Trimble County Generating Station
Trimble County, Kentucky
Hearing on March 28, 1978, Permit No. I#oo4l971
Dear Mr. Hagan:
My name is L. Paul Venard, resident of Trimble
County and live on a family farm 3/4 mile
upriver from property controlled by Louisville
Gas and Electric Company.
1 I was at the hearing and listened to everyone and
watched which is almost as Informative. The
impression was that it was a thing that had to be
done, the words by C.A. Perry were "we haven't
decided yet", the feeling was that we who love the
land more than the buck don't have a chance. Louisville
Gas and Electric had wielded its influence properly,
had come up with the right numbers and promises.
That was It*
2At the very least, the sentiment expressed by your
Mr. Zeller was in no way impartial. Testimony was
given saying that the IKE plant 10 miles upriver in
Indiana would be polluting less in the next few years.
Then the Louisville Gas and Electric spokesman went
into his spiel. The question of the emissions came
up and the figure, when combined, with IKE, was too
high according to some guide lines but would be
"acceptable11 with the new lower IKE emissions. At
this time Zeller interjected "looks like good news".
You could have knocked me over with a feather. This
IB justice, this is impartiality? No* this is a
farce I
COMMENT DOCUMENT - U
5-185
-------
John E. Hagan III 2
Environmental Protection Agency
April 6, 1978
3 None of the testimony given by proponents could
say one good thing that the proposed plant would
do for the land or the people of the county. The
only thing that was swaying the two ardent
supporters was the promise of a few pieces of
silver - greed, a despicable lever to gain support
from farm folk who don't realize how rich they are,
that their quality of life is superior to 90$ of
the US population.
The important thing here in Trimble County is the
land and its beauty, its productivity plus the land,
air, and water all around the 1,000 acres Louisville
Gas and Electric already controls. Will LG & E be
permitted to destroy our precious valley?
The local newspaper came out with some astounding
news, the low lifes want our farm and all our neighbor's
farms as well. Why? For the most paradoxical of
reasons. LG & E says because of the clean air
standards. There will be so much fly ash, lime, etc.
from the scrubbers, they need our properties for a
garbage dump.
How can this be progress? if you think you can condone
this, please visit our beautiful farm and then see if
you can condemn.
Fred Hauck of Sierra Club presented evidence in a
sound, logical paper that, to anyone not predisposed
to LG & E opinion, would be evidence that the plant
shouldn't be built or is there a secret national
policy to approve such facilities as long as the
promised air and water pollution numbers fall within
agreed upon limits. Where is the consideration for
the land?
"Land IB the only thing in the world that amounts to
anything, for 'tis the only thing in this world that
lasts and don't you be forgetting it. 'Tis the only
thing worth working for, worth fighting for, worth
dying for". Gerald O'Hara told this poignant truth
to his daughter Katie Scarlett O'Hara, as I now have
told you.
There are no reasons except a venal greed and corporate
convenience why our valley - indeed the nation's heart-
land, the inspiration for the aong Beautiful Ohio, why
should its peaceful historic banks, which have survived
nearly intact till now, be decimated?
COMMENT DOCUMENT - U, CONTINUED
5-186
-------
John E. Hagan III 3
Environmental Protection Agency
April 6, 1978
The Utilities apparently are satisfied the people
want electricity at any price and they are thus
mandated to produce it. The Hell with who or what
gets in their way. The majority of the people don't
want the country fouled either, they want the Utilities
to do what we all have to, more with leas; to be more
efficient, not less; to be compact, not collossal.
I propose to you and any thinking man that for
exactly this reason laws should be passed to prohibit
expansion by Utilities or any large industrial complex
into the countryside, moat especially that land that
was first settled, that is also most productive, that
is so scenic and viewed and appreciated by so many
people.
Any fool can waste, turn good to bad. Shouldn't
Utilities do what we have to and lead the way in
Conservation of every kind?
In warm weather Louisvillians in their runabouts, house
boats, etc. ply the river as do the Delta Queen Boats.
These people leave the city to see the beauty of the
River and the unexplolted landacapes.
Think, gentlemen, if there isn't a law, there should
be one, to leave that which is beautiful and to improve
that which is not. At this rate, soon there will be
no more America the Beautiful.
Is not anyone strong enough to say wNoi" to LG & E and
thus no to backward progress?
Towards the end of the hearing I believe Zeller asked
a speaker what alternatives were possible, referring to
the air pollution. The speaker said low sulfur coal
for one and that was about it.
I forward these alternatives and ask your Atlanta
Office of the Environmental Protection Agency to answer
each one In writing.
4 1* Build plants in cities. Sell the fly ash, lime, substances
as fill and raise flood plane areas for future flood safe
river front development. Of course that is if it is
fairly inert which a O.H. Kaplan implied it was.
If it is subject to leaching of toxic substances, then
It should not be stored anywhere and thus should not
be produced.
COMMENT DOCUMENT • U, CONTINUED
5-187
-------
John E. Hagan III 4
Environmental Protection Agency
April 6, 1978
5 2. All Utilities are missing a marvelous opportunity to
cool their superheated generating water. They could
sell it. Think how many homes, businesses, and factories
could be heated and even cooled with this unused, in the-
j. In the US heat source, of course less electric
would tre used to heat water, power , conventional air
conditioners, etc. This would be^for more efficient
and logic use, two terms one never hears being applied
to a Utility.
Q 3» Has anyone ever thought about the vunerabllity of
putting power plants on the banks of the Ohio?
It is not beyond the realm of possibility that we might
be attacked. My God, any idiot in a war plane could
follow something the size of the Ohio, have a turkey
shoot, and knock out the entire Midwest. This should
be given serious thought. There is no reason why
power plants should be so _y_ery_ conspicuous.
There are plenty of valleys that run eight, ten, fifteen
milea back from the River that a Utility could nestle a
plant in and run a pipeline and rail track to the River
for the water and coal it needs. In this fashion the
Ohio could be used but not abused. I know fewer people
would object to such a development that is literally out
of the main stream.
7 4. Utilities this winter have learned some ways of
conserving and ao have consumers. Power plants need
not be lit up like a movie set. Surveillance could be
conducted with day /night cameras or infrared. After
all, no one pays them to light up the country. It IB
waste.
The use of more efficient equipment and motors should
be considered. Consumers will conserve. The best
selling appliance will sell because of it's efficiency.
More homes and businesses will use solar heat and build
deeper into the ground for more insulation thus using
less energy of all kinds. As a result, cleaner air.
HWhy so?M you ask. Because less coal will need to be
consumed.
8 5. There is a power source that should be investigated.
I am. If I can get it built I will disconnect from
our local Utility posthaste paying the minimum monthly
bill. If my unit goes out, I will then use the Utility
as a back up. Lord knows the local electric company
isn't reliable.
COMMENT DOCUMENT - U, CONTINUED
5-188
-------
John E. Hagan III
Environmental Protection Agency
April 6, 1978
For instance last winter when the Big Blizzard hit,
the electric went out and did not come on for a day
and a half. This was repeated during a minor ice
storm and so on throughout the year.
The power source is the Minto Wheel. You may be aware
of it. I will briefly explain.
It is a wheel, big or small* having tubular tanks around
its perimeter the one at the top being connected by
tubing to the bottom one and so on around its perimeter.
It will have 8, 10, 12 pairs, one of each pair is filled
with freon 12 or 22. A portion of the wheel say 1/5
of its diameter is submersed in water, if hot water
is introducedcreating a temperature variance between
top and bottom, the freon having a low boiling point,
starts boiling to the top of the immersed container
forcing the still liquid portion up through the tub to
the container on top.
The top is now heavier and starts falling and so on as
long as a temperature variante is involved it goes Its
slow but powerful way and can be geared to produce
electricity cleanly and quietly.
Utilities have a lot of hot water. Can't they at least
try it? They|^Ve already paid to heat the water, why
not make money on cooling it?
Very truly yours,
L. Paul Venard
President
LFV/pr
COMMENT DOCUMENT • U, CONTINUED
5-189
-------
RESPONSE TO COMMENT DOCUMENT U
Comment Number Response
The statement made by Charles A. Perry at the public
hearing on March 28 was correct. The decision on
issuance of an NPDES permit was not made until shortly
before the publication of this FEIS.
The water effluent and air emission "numbers" which
LG&E must meet are not just backed up by promises but
also by enforcement by EPA and the Commonwealth of
Kentucky (refer to response to comment 4, Comment
Document 0, page 5-143). The limitations imposed
by EPA on the proposed project are in some cases
more stringent than the New Source Performance
Standards.
The analysis of the combined impact of the proposed
LG&E project and the Clifty Creek plant at Madison
assumed uncontrolled S02 emissions from the Clifty
Creek plant. It was also assumed that at some future
time the Clifty Creek plant would be brought into
compliance with existing air quality standards. There-
fore, a separate analysis was made of the combined
impact of the two plants with Clifty Creek emissions
controlled, (it should be noted that the additional
interaction modeling conducted following the publication
of the DEIS did not assume compliance by Clifty Creek,
as a date for such compliance has not yet been set.)
Further, Mr. Zeller's comment quoted here was actually
in reference to the statement of Ms. Louise Grosse of
EPA Region V regarding future compliance by Clifty Creek
(see page 49 of the Public Hearing transcript).
The comments contained in this and the following
paragraphs (up to comment 4) have been noted and
were considered during the final determination
process.
The siting of power plants involves the considera-
tion of many factors, such as: the availability of
a sufficient water source; access to bulk transport
of coal; avoidance of concentrations of air pollu-
tants; the availability of a large tract of developable
land; balance of the regional electric transmission
grid; avoidance of known sensitive areas such as
historic sites; and avoidance of large concentrations
of households, which would be displaced or otherwise
5-190
-------
RESPONSE TO COMMENT DOCUMENT U, Continued
Comment Number
4 (continued)
Response
adversely impacted. The location of power plants in
urban areas is less than optimum by all of these
criteria. The availability of water and coal makes
sites on or near navigable waterways highly advantageous.
Existing air quality is often degraded in urban areas
due to industrial activities and concentrations of
automobile emission, which frequency place these areas
in non-attainment classifications. Adequately large
tracts of land for power plants are seldom available
within cities and, if available, would add a tremendous
cost to the generation of electric power.
Fly ash and other by-products from power plants can be,
and in a few instances have been, sold for fill and for
higher order uses in certain instances. However, the
supply of these by-products from power plants far exceeds
the present market demand for them.
Quantities of heated water are expelled as one by-product
of the generation of electric power. This heated water
can be, and in some instances has been, sold for other use.
However, as with other by-products, the supply of this
water far exceeds the demand for it by other sectors of
the economy.
Please refer to the response to comment 2, Comment
Document N, page 5-116 of this FEIS.
The siting of power plants involves the consideration
of many factors, as indicated in the response to comment
4, above. A site selection study was conducted to select
a site for the proposed plant. This study considered
possible sites, river and off-river, throughout a 1,700-
square-mile area. Two major factors generally disqualified
off-river sites. First, the terrain in this region imposes
a severe limitation on large tracts of land suitable for
development as a power plant site. Second, an off-river
site would require additional water and coal transport
facilities from the river to the site. This arrangement
would not eliminate any known impacts, but simply shift
them to another area. Further, the arrangements would
incur the additional environmental and cost impact of
developing a pipeline and railroad corridor through a
tributary valley which would not otherwise be necessary.
5-191
-------
RESPONSE TO COMMENT DOCUMENT U, Continued
Comment Number Response
7 The Applicant's policy for lighting of its power plants
is to install and operate only the lighting necessary
for safe nighttime operation of the facility.
The Applicant fully concurs with the comment regarding
efficient equipment and motors. LG&E supports efficiency
and conservation on the part of all consumers of electric
energy, including itself. LG&E maintains an active
program for providing information on the conservation
of energy through the news media and in brochures sent
to all of its customers.
8 Please refer to the Department of Energy letter dated
August 2, 1978 attached to the response to Comment
Document H (page 5-56 of this FEIS).
5-192
-------
JAMES R. PATTON. JR.
GEORGE BLOW
CHARLES OWEN VERRILL, JR.
JOSEPH L. BRAND
THOMAS HALE BOGGS. JR.
TIMOTHY J. MAY
HARRY A. I NMAN
EDWARD T. MITCHELL
ELLIOT H. COLE
J. GORDON ARBUCKLE
WILLIAM C FOSTER
DAVI D C. TODD
LAWRENCE G. MEYER
RICHARD A. EARLE
ERNEST S. CHRISTIAN, JR.
ROBERT H. KOEHLER
E. BRUCE BUTLER
DAVID B. ROBINSON
JOHN H. VOGEL
ALLAN ABBOT TUTTLE
BART S. FISHER
PATTON, BOGGS & BLOW
I8OO SEVENTEENTH STREET, N. W.
WASHINGTON, D. C. HOO36
(202) aa
OF COUNSEL
WILLIAM J. COLLEY
JAMES G. O'HARA
FRANK BOAS
LONDON BRUSSELS
April 7, 1978
JOHN OBERDORFER
MICHAEL A, FLOYD
LAN NY J. DAVIS
LINDA ELIZABETH BUCK
DONALD A. LOFTY
DOMENICO DE SOLE
SHAOUL ASLAN
JOHN V. E. HARDY, JR.
TIMOTHY A. VANDERVER, JR.
CHARLES B.TEMKIN
NANCY W. NEWKIRK
JOH N F. WOODS
MIDDLETON A. MARTIN
RICHARD S. CHARIN
TIMOTHY NORTH SEWARD
GARRET G. RASMUSSEN
JAMES B. CHRISTIAN, JR.
JANET M. MEIBURGER*
TIMOTHY A. CHORBA*
JEANNE C. TRAHAN
CLIFTON PETER ROSE
CABLE'BARPAT
ITT T£i_EX:44O324
WU TELEX: 89-452
TELECOPIER:223-O233
"NOT ADMITTED IN D. C.
Environment Division
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
ATTN.: Ms. Mona Ellison
Re: NPDES No. (KY0041971)
Dear Ms. Ellison:
Under separate cover, various members of Save
the Valley, Inc. ("STV"), notably Harold G. Cassidy and Paul
Scully, have submitted to you STV's comments regarding the
referenced impact statement. In addition to those comments,
we would like to emphasize the, following points.
I ' i. The EIS proceeding is defective because
the draft was filed after the fact.
As we have stated many times in the past, EPA
was obligated, once it determined that its actions and those of
other agencies in connection with the authorization of this
facility, were subject to NEPA, to file the Draft EIS and
obtain public participation prior to reaching any decisions
5-193
COMMENT DOCUMENT -V
-------
PATTON, BOGGS X BLOW
U.S. Environmental Protection Agency
ATTN.: Ms. Mona Ellison
April 7, 1978 Page Two
which would facilitate, further or commit to the project in
question. EPA has repeatedly refused to accept this principle
and, indeed, has acknowledged to us in writing that it has
consciously deferred the publication of the Draft EIS pending
the reaching of a final determination on the PSD issue. This
procedure clearly contravenes NEPA and has deprived STV of the
opportunity to meaningfully comment or impact upon the air
quality determinations which are so critical to the statement.
Indeed much of the analysis in this EIS turns upon conclusions
already reached in the PSD proceeding. This defect alone is
sufficient to invalidate the earlier PSD proceedings and to
require that the Draft EIS be revised to consider the decisions
arrived at in the earlier proceeding and republished after such
revision.
2. The statement does not identify or
describe the "action" which it considers
Although the statement purports to be a "lead agency"
impact statement it fails to identify in any but the most
cursory fashion the authorizations required from other agencies,
the statutes and regulations applicable to such authorizations
and the requirements to be met in connection therewith.
3. The description of the applicant and
its customers is misleading
The statement that neither the applicant nor its
COMMENT DOCUMENT • V, CONTINUED
5-194
-------
PATTON, BOGGS X BLOW
U.S. Environmental Protection Agency
ATTN.: Ms. Mona Ellison
April 7, 1978 Page Three
subsidiaries "sells electricity directly to any ultimate
consumers in Indiana" appears consciously calculated to
obscure the question of whether any of the power generated by
the facility will be supplied to a federal facility in Ohio
which is itself in violation of pollution control requirements
and which, itself, is obligated by court approved settlement
decree to consider the regional impacts of its continued
power procurement.
This question and its legal implications must be
fully explored as must the extent and legal implications of
the applicant's participation in the Indiana Kentucky Electric
Company, which itself operates a violating facility in Madison,
Indiana.
If STV's information regarding these two matters
is correct, then the non-disclosure of such matters in the EIS
casts serious doubt on the extent to which EPA has made any
independent inquiry into the facts as represented by the applicant,
4. The discussion of alternative energy
sources is incomplete
Although the impact statement states that energy is
not available from neighboring utilities on a long-term basis,
there is no discussion whatsoever of planned additional
generating capacity in the region which may become available in
COMMENT DOCUMENT - V, CONTINUED
5-195
-------
PATTON, BOGGS & BLOW
U.S. Environmental Protection Agency
ATTN.: Ms. Mona Ellison
April 7, 1978 Page Four
the future. A detailed analysis of future generating capacity
on a regional basis and a determination as to the most environ-
mentally acceptable power generation pattern is clearly required
before giving any weight whatsoever to the bald statement that
power will be unavailable from other sources.
Further, the DEIS does not state the extent to which
the alleged non-availability is a result of continuing power
demands from federal facilities in Ohio. It does not explain
the reasons for or impact or legal implications of the
continued failure of EPA and other government agencies to
adhere to the Presidential policy against continued procurement
from facilities in violation of air pollution control laws
(e.g. the facility in Madison, Indiana) nor does it address
the possibility of reducing power plant concentration and
environmental effects by procuring federal power from a number
of more widely dispersed facilities, rather than the one
facility in Madison, Indiana. Finally, it does not address
the regional environmental benefits of converting the federal
facility to a clearly feasible less energy consumptive uranium
enrichment process. Since this is a "lead agency" statement and
since the foregoing issues clearly do impact the need for and
alternatives available to the project in question they are factors
which must be carefully and extensively considered.
COMMENT DOCUMENT - V, CONTINUED
5-196
-------
PATTON, BOGGS & BLOW
U.S. Environmental Protection Agency
ATTN.: Ms. Mona Ellison
April 7, 1978 Page Five
The conclusion that existing older units cannot
be upgraded is based on the premise that flue gas desul-
furization, with its attendant extensive land area require-
ments, is the only feasible treatment technology. As more
fully discussed below, solvent refining of coal, on a
regional cooperative basis, is an environmentally preferable
alternative. The availability of solvent refined coal could
substantially impact the decision relative to upgrading of
existing facilities and must be carefully considered. Finally,
the assertion that upgrading of existing facilities is
economically unfeasible is stated as a bare conclusion with no
attempt at quantification whatsoever. Neither the decision-
maker nor the public have any basis for analysis of this
conclusion.
Similarly the discussion viz, the feasibility of
"Joint Projects" is wholly conclusory and completely inadequate.
The statement that applicant "prefers" to rely on internal
generating capability does not constitute environmental analysis.
The need for careful analysis of this alternative is particularly
acute when there is a proposal to build another major facility
barely one mile away from the proposed site and when that
facility could clearly be built with adequate capacity to serve
the alleged needs of the applicant.
COMMENT DOCUMENT - V, CONTINUED
5-197
-------
PATTON, BOG OS & BLOW
U.S. Environmental Protection Agency
ATTN.: Ms. Mona Ellison
April 7, 1978 Page Six
> 5. The discussion of alternative means
of generating required power is in-
complete
The discussion of alternatives in this section is
artifically and improperly constrained by the assumption, which
is contrary to statements appearing elsewhere in the EIS, that
the power from the facility would be needed by 1981. This
artificial constraint has prevented meaningful consideration
of alternative means of generating required power which may
well be available at the time the plant actually needs to be
commenced, including:
coal gasification;
solvent refined coal;
low head hydroelectric; and
solar.
The possibility of widespread implementation of industrial co-
generation programs between now and 1990 also needs careful
consideration and analysis.
The solvent refined coal approach requires particularly
careful attention since such an approach would so significantly
affect the possibility of continued utilization of existing
facilities, the range of available sites to be considered, the
compliance status of existing power generation facilities in the
region and so forth. In this connection, it would appear to be
COMMENT DOCUMENT - V, CONTINUED
5-198
-------
PATTON, BOGGS X BLOW
U.S. Environmental Protection Agency
ATTN.: Ms. Mona Ellison
April 7, 1978 Page Seven
necessary to obtain the views of an organization with expertise
in the solvent refined coal process such as Battelle Memorial
Institute in Columbus, Ohio.
6. The DEIS fails to consider or analyze
important regulatory alternatives
The DEIS gives no consideration whatsoever to the
clearly available alternative of deferring approval of the
subject facility until a later date. In view of the tremendous
technological uncertainties associated with the question of
whether the ambitious "design" performance levels for the
subject facility can be continuously achieved in practice, the
rapid development of alternative generating technologies, the
present absence of effective regional power generation planning
and so forth, a deferral decision is exceedingly attractive from
an environmental viewpoint. Such a deferral would not in our
opinion seriously prejudice the utility. Indeed, a recent EPA
publication reports that the applicant has postponed start-up
of major units at the Mill Creek facility "because power demand
has not come up as rapidly as expected".
Another regulatory alternative which requires careful
analysis and consideration is the exercise of authority pursuant
to SEC. lll(j) of the Clean Air Act to waive certain pollution
control requirements. Consideration of such alternatives is
COMMENT DOCUMENT - V, CONTINUED
5-199
-------
PATTON, BOGGS & BLOW
U.S. Environmental Protection Agency
ATTN.: Ms. Mona Ellison
April 7, 1978 Page Eight
particularly important in the instant situation since the DEIS
makes obvious that rigid insistence on scrubber technology
actually has an adverse environmental impact in that it eliminates
from consideration a number of viable upland sites where land
use and aesthetic impacts would be far less serious and where
ground level concentrations of pollutants might be less serious
even if less stringent treatment is required.
7. The DEIS does not consider important
environmental impacts
Consideration of air pollutant impacts is limited
to those pollutants which have been designated as criteria
pollutants under the Clean Air Act. It is well established,
however, that emissions from coal fired power plants contain
suspected carcinogens and other chemicals known to have adverse
health effects. Particularly in light of the facility's
proximity to other coal fired power plants and the potential
for interraction with vapor emissions from the Marble Hill
facility, these factors must be carefully considered.
There is no information in the DEIS regarding the
hydrology of the area proposed for sludge impoundment nor is
there any discussion of potential groundwater contamination
and drinking water source effects. Consideration of this
factor based on actual test borings and aquifer flow studies
must be conducted.
COMMENT DOCUMENT - V, CONTINUED
5-200
-------
PATTON, BOGGS & BLOW
U.S. Environmental Protection Agency
ATTN,. Ms. Mona Ellison
April 7, 1978 Page Nine
Q 8. No consideration is given to the
question of compliance with applicable
laws other than the Clean Air Act and
the FWPCA. For example:
The requirements of Executive Order 11988, May 24,
1977, regarding location of facilities in Flood Plains are no-
where addressed or dealt with. The requirements of EPA policy
regarding location of solid waste disposal facilities (see 43 F.R.
4942, 4946) are nowhere considered even though they would appear
to prohibit solid waste disposal at the present site. The Fish
and Wildlife Coordination Act is nowhere even mentioned. The
Uniform Relocation Act has not been complied with. The potential
applicability of Section 4(f) of the Department of Transportation
Act is nowhere even mentioned.
Q 9. The implications of EPA's non-attainment
area policy are not recognized
Although the statement recognizes that the facility
in question will contribute to a violation of secondary criteria
in the area around Madison, Indiana, it seeks to avoid the
implications of this conclusion by alleging that the contribution
is de minimis. We are not aware of any "de minimis" provision
in the non-attainment policy. Furthermore, even if there were
such a provision, its application would be wholly inappropriate
where, as in the present case, the applicant is a substantial
owner of the violating facility which is a major cause of the
COMMENT DOCUMENT • V, CONTINUED
5-201
-------
PATTON, BOGGS & BLOW
U.S. Environmental Protection Agency
ATTN.: Ms. Mona Ellison
April 7, 1978 Page
non-attainment. In such circumstance, the non-attainment
policy makes it clear that the existing violating facility
constitutes an absolute bar to construction of any other
facility in the area by any owner of the violating facility.
10- The DEIS does not provide an adequate
basis for public analysis and
confirmation of modeling results
We question the accuracy of the modeling and
computations which form the basis for the conclusion that
the subject facility would have a minimal impact on air quality
in the Madison, Indiana area. As other commenters have indicated,
STV representatives have been denied the opportunity to review
the model used or the presumptions upon which the modeling was
based. The modeling results, however, indicate that the "corridor
effect" documented in the ORBES study has not been taken into
account and that the "tall stacks" policy may have been improperly
applied. The Draft EIS requires revision and republication to
remedy these difficulties and to provide a satisfactory basis for
public analysis and comment upon the decision to be reached in
this matter.
11. The DEIS is narrowly focused and fails
to consider regional impacts
Although the ORBES report documents the need for
consideration of power plant problems on a regional, interstate
COMMENT DOCUMENT • V, CONTINUED
5-202
-------
PATTON, BOGGS & BLOW
U.S. Environmental Protection Agency
ATTN.: Ms. Mona Ellison
April 7, 1978 Page Eleven
basis, and although the facility in question is affected by
federal actions of broad regional impact, the DEIS fails to
consider the cumulative impact of facilities now planned or
under construction even though certain of such facilities are
even now undergoing permit review by the agency.
CONCLUSION
12 In summary, it seems obvious that the Draft EIS fall
considerably short of NEPA's requirements and that the major
focus of these proceedings is the confirmation of decisions
already reached. A complete rethinking of this approach is
clearly required.
Very truly yours,,
" v>'t*
J. Gordon Arbuckle
Counsel to STV
JGA:Iv
COMMENT DOCUMENT - V, CONTINUED
5-203
-------
RESPONSE TO COMMENT DOCUMENT V
Comment Number Response
1 EPA strives to prepare good EIS's and to arrange for the
mitigation of unacceptable impacts before issuing a draft
EIS. Therefore, a great deal of time (at the Applicant's
expense) was spent working with other agencies and the
Applicant to modify the project and to develop mitigative
measures which in EPA's opinion would improve the project.
EPA is required to make a PSD determination within one year
of application to the Agency whether an EIS on the project
is or is not finished. No action under the Clean Air Act,
including PSD approval, is subject to NEPA. EPA's NEPA review
of a new source is triggered by application for an NPDES water
discharge permit, according to section 511(c) of the Clean Water
Act.
Regarding public participation prior to decision making,
this NEPA requirement was satisfied by a public scoping
meeting for the EIS held in Bedford in February 1976 and
the public hearing on the EIS. Also, the EPA met
several times with members of Save the Valley (STV) to
discuss their concerns. The EPA also received corre-
spondence relative to this proposed plant and considered
this in the EIS preparation.
EPA has always been open with its data gathering and
air modeling on this project and any information re-
quested by STV would have been made available to them
(please refer to the letter attached to the response
to comment 22, Comment Document N, page 5-136 of this EIS).
The EIS was delayed upon knowldege of forthcoming
amendments to the Clean Air Act because this was determined
to be preferable to the risk of issuing a document which
would be out of date immediately upon issuance. An amended
EIS would then have been required.
Some analyses in the EIS are necessarily the same
as those in the January 18, 1978 PSD Re-determination
and Approval. The EIS considered the consumption of
the available increments as a secondary development
impact to the plant area, and both the EIS and PSD
contained assessments of impact on ambient air quality,
What was determined to require further analysis was
source interaction of the proposed Trimble County
plant and the existing Clifty Creek plant at Madison.
That work is found in Section 4 of this FEIS.
5-204
-------
RESPONSE TO COMMENT DOCUMENT V, Continued
Comment Number Response
2 The action which the EIS considers is described on the
cover page and on pages 1 and 2 of the DEIS.
The authorization, statutes, regulations, and re-
quirements to which the proposed project is or may
be subject is the responsibility of the Applicant,
not the EPA. It is the Applicant that must identify,
seek, and meet the requirements of all other permits,
etc. issued by all agencies that have jurisdiction
over part or all of the components of the proposed
facility. EPA does not coordinate the Applicant's
permit activities, nor is it responsible for them.
However, consistent with its requirements under NEPA,
EPA does notify all state and federal agencies, as
well as local agencies, intervenor groups, other
interested groups, and the general public, when it
has received a permit application for a particular
project and when it intends to prepare an EIS.
Under the old CEQ guidelines, EPA would then be
obligated to coordinate the EIS preparation with
any other federal agency which also had permit
authority over the project. In the case of the
Trimble County Generating Station, this type of
coordination has been maintained with the Corps
of Engineers, Louisville District.
In addition, EPA has worked with the Kentucky
Department for Natural Resources, the U.S.
Department of Energy, the Kentucky state archae-
ologist, and the U.S. Fish and Wildlife Service,
as well as the Corps of Engineers, to ensure that
their concerns were addressed in the EIS and to
resolve issues of data collection and impact
mitigation both prior to and following the
preparation of the DEIS.
And finally, in accordance with the requirements
of the EIS process, copies of the DEIS and FEIS
have been circulated to all agencies having permit
authority over the proposed project. The DEIS and
FEIS have also been made available to all those
whose specialized knowledge was felt to be of
value in the assessment process or whose juris-
diction, constituents, or lives could be affected
by the project.
5-205
-------
RESPONSE TO COMMENT DOCUMENT V, Continued
Comment Number
2 (continued)
Response
The Applicant, in addition, submitted copies of the DEIS
to the Public Utility Commission and the Commonwealth of
Kentucky as part of its state permit applications.
There was no intent in the "Identification of Applicant"
(Section 1.1 of the Draft EIS) to conceal the fact that
LG&E indirectly provides electric capacity for the Depart-
ment of Energy's nuclear enrichment plant in Portsmouth,
Ohio. Section 1.1 was intended to describe LG&E' s ultimate
consumers which are all located within the state of Kentucky,
LG&E's relationship to OVEC and to OVEC's customer, the
Department of Energy, is described sufficiently in "Reserve
Capacity" (Section 1.3, page 1-16 of the EIS Supporting
Report).
LG&E's obligation to supply capacity to OVEC for the
Department of Energy's electric load requirements is
provided for in its capacity requirements, as opposed
to its load requirements (see Table 1.3-1 on page 1-17
of the DEIS Supporting Report). That is, LG&E does
not provide any component of reserve capacity for its
OVEC obligation. It does provide energy for the peak
load requirements of its ultimate consumers. Thus,
LG&E does not have a direct obligation to the Depart-
ment of Energy, and the Department is not an ultimate
consumer by LG&E's definition of the term.
It is assumed that the commenter's point about the non-
compliance of the Ohio facility (Portsmouth Gaseous
Diffusion Plant) refers to water quality. It is true
that this facility is not in compliance, but it is
presently on an EPA-approved compliance schedule
(please refer to the Department of Energy letter
dated August 2, 1978, page 5-56 of this FEIS).
EPA Region IV has stated in the EIS that there are
monitored violations of S02 standards in the Clifty
Creek-Madison area and that these violations have
also been shown via modeling. The cause of these
violations still seems to be at issue.
The commenter's suggestion that there may be "legal
implications" to the continued procurement by the
U.S. Department of Energy of power from OVEC has
been noted. The matter cannot be adequately covered
5-206
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RESPONSE TO COMMENT DOCUMENT V, Continued
Comment Number
3 (continued)
Response
by EPA in this EIS; however, the comment was referred
to the Department of Energy (refer to the previously
referenced letter, page 5-56 of this FEIS).
The "Purchase of Required Energy" discussion in Section
3.1.3 on page 3-2 and 3-3 of the Supporting Report for
the DEIS is a brief but adequate explanation of why
LG&E feels it cannot rely on neighboring utilities
to furnish its electric requirements. Most utilities,
including LG&E, are reluctant to make firm commitments
for bulk sales much beyond a period of a few months—
much less a period of over a decade as encompassed
by the Trimble County plant. Even if a long-term commit-
ment could be secured, it is very unlikely that the
power could be furnished at a cost and at a level of
reliability and adequacy comparable to what LG&E believes
it could provide with the Trimble County plant.
A comprehensive analysis on the availability of capacity
assistance from regional utilities is found in "The 7th
Annual Review of Overall Reliability and Adequacy of
the North American Bulk Power Systems" prepared by the
National Electric Reliability Council (NERC). One of
the many conclusions in this 28 page report, released
September 1977, is that a generation deficit could
begin in 1981 in the ECAR region which would take years
to build the additional facilities required to recover.
Please refer also to the Department of Energy letter
dated August 31, 1978, page 5-59 of this FEIS.
The current load requirements of the Department of
Energy's Portsmouth, Ohio uranium enrichment plant
is 1,967 MW, and, at the time the EIS was written, this
load was scheduled to increase to 2,260 MW by 1980. It
now appears, due to the utility industry's deferment of
constructing nuclear units, that the Department's load
requirement of 1,967 MW will continue through the early
1980's.
To put the 293 MW additional load requirement of the
Portsmouth plant in proper perspective, it is approxi-
mately 9 percent of the 3,325 MW peak native load growth
expected for the entire ECAR region for 1 year (1977 to
1978). From another perspective, the current DOE load
of 1,967 MW is only about 3 percent of the 62,582 MW
native peak load expected for the 1978 summer.
5-207
-------
RESPONSE TO COMMENT DOCUMENT V, Continued
Comment Number
4 (continued)
Response
On page 11-139 of the Portsmouth Gaseous Diffusion Plant
Final EIS (ERDA 1555), it is indicated that the Depart-
ment of Energy assessed the impact of continued power
procurement for the enrichment plant. The conclusion
was that no significant effect on the ECAR region or
its separate utilities would be likely to be experienced,
(Please also refer to the Department of Energy's letter
dated August 2, 1978, page 5-56 of this FEIS.)
EPA Region IV has no knowledge of any power procurement
from OVEC by EPA for its own consumption.
Unless the physical restraints (the lack of space is
the most formidable one) associated with upgrading
existing generating units can be resolved, an economic
feasibility study would serve no purpose. Moreover,
the Applicant feels it cannot base generating capacity
planning on the use of equipment which is commercially
unavailable such as coal gasification or solvent re-
fined coal which, in the event they are successfully
developed in the future, may make existing power plant
sites adequate for upgrading generating units. The
long lead times required for construction or upgrading
generating capacity dictate that purchase commitments
be made 5 years or more in advance of in-service dates
for equipment which is commercially available at the
time the commitment is made.
Aside from the environmental and reliability aspects,
a feasibility study should reflect the costs of serving
customers with jointly owned facilities as compared to
the costs of serving them with solely owned facilities.
LG&E's generation, fuel, and plant construction costs
have generally been lower than those of neighboring
utilities. Assuming that this is presently correct,
it is unlikely that jointly owned facilities would be
advantageous to LG&E's customers. Therefore, a thorough
feasibility study in this EIS does not appear to be
warranted.
EPA is confident that Kentucky's Public Utility Commis-
sion, acting under its mandate, would challenge LG&E
on the proposed new plant if the Commission felt that
LG&E's customers would be severely hurt by the construc-
tion of the project.
5-208
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RESPONSE TO COMMENT DOCUMENT V, Continued
Comment Number Response
5 The last sentence on page 11 of the DEIS states, "At the
time (1974) that the Applicant began planning for the
proposed project, it was anticipating the need for a new
unit by 1981, which eliminated a nuclear plant from
cons iderat ion
This statement was neither an attempt to prejudice the
discussion on nuclear alternatives nor to show that
capacity from the Trimble County facility would be
needed in 1981—2 years before the presently scheduled
startup of the first unit. The statement was intended
to show that the 7-year period (1974 to 1981) was in-
sufficient time for the planning, design, and construction
of a nuclear power plant.
A decision to defer the startup of Mill Creek Units 3 and
4 and the Trimble County Units 1 through 4 was made in
1976. Although the Trimble County schedule was slipped
2 years, there still was not enough lead time to make
nuclear a viable option.
The Department of Energy did not wish to comment on
alternative means of power generation except to say
the alternative sources listed by the commenter would
probably not be available to the Applicant. (Please
refer to the letter dated August 2, 1978, page 5-56 of
this FEIS.)
6 LG&E does not enjoy the luxury of being able to post-
pone important capacity planning decisions indefinitely
while either looking for load growth trends to emerge
or waiting for technology to develop which will offer
some plant design alternatives.
Due to the lead times associated with placing the first
generating unit in service in 1983, the Applicant
maintains there is no room in the present schedule
for deferring the actual start of construction beyond
the third quarter of 1978.
The Applicant must supply the power that is needed.
The load forecast in the EIS seems to be substantiated
by recent actual data.
5-209
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RESPONSE TO COMMENT DOCUMENT V, Continued
Comment Number
6 (continued)
Response
If the predicted load growth is not actually realized, the
scheduling of subsequent units at Trimble County will be
evaluated before commitments for major equipment are
required. However, the Applicant states that it does
not have that flexibility on the first units.
Section lll(j) is a means by which any person proposing
to own or operate a new source may request a waiver from
air pollution requirements based on use of an innovative
technological system or systems of continuous emission
reduction. The Applicant did not request a waiver
(application was made before the Clean Air Act Amend-
ments of 1977 and applicability of this procedure). In
any event, scrubbers used for control of sulfur dioxide
emissions are considered a proven control technique, and
not innovative. Under the above circumstances, Section
lll(j) has no application to this situation.
There is increasing awareness of the presence of uranium
and thorium "daughters" in fly ash and in airborne par-
ticulates in the stack plume of coal-fired power plants.
It is true that these are presently unregulated pollutants
under Section 122 of the Clean Air Act as amended in
1977. When coal-fired power plants are in close proximity
to nuclear power plants, in certain localities under
particular meteorological conditions, excess activity
from the coal-fired plant may significantly increase
monitored radioactivity around nuclear plants.
EPA is currently researching this and has many fossil
fuel plants under study as specified in Section 122 of
the Clean Air Act as amended in 1977. The EPA admini-
strator will review all relevant information and determine
whether or not emissions of radioactive pollutants into
the air will cause, or contribute to, air pollution which
may reasonably be anticipated to endanger public health.
The frequency of interaction of the Trimble County stack
and Marble Hill cooling tower plumes can be estimated
based on the meteorological data for the area. Since
the effects of this interaction would be proportional
to the concentration of water vapor in the cooling
tower plume, impacts will typically be associated with
the interaction of a visible Marble Hill plume with the
Trimble County plant stack plume. Based on Table 5.1-38
of the MH-ER, visible plumes will extend to 3 kilometers
5-210
-------
RESPONSE TO COMMENT DOCUMENT V, Continued
Comment Number
7 (continued)
Response
approximately 740-1,450 hours per year. Meteorological
data from Louisville indicate that the wind direction
required to align the plumes occurs during 10.35 percent
of the year. Thus, the Marble Hill cooling tower and
Trimble County plant stack plumes will be in alignment
some 75-150 hours per year.
However, in order for the plumes to interact, they must
be located at approximately the same level in the atmo-
sphere. In order to estimate the interaction potential,
we have used the conservative estimate that plume inter-
section may occur during 50 percent of the alignment
cases. This reduces the number of potential interactions
to less than 75 hours per year or an annual probability
of less than 0.85 percent.
We have not included the additional effect of plume
rise in providing these estimates. In general, the
rate of rise of any plume is proportional to the distance
from the source, plant design characteristics, and
meteorological parameters. Typically the Marble Hill
cooling tower plume will have reached its maximum
height before reaching the Trimble County plant, while
the Trimble County plant stack plume will continue its
ascent for approximately 1-2 kilometers downwind. The
point of intersection will be limited in duration and
will vary in distance between 1 and 2 kilometers of
the plant. Therefore the probability of interaction
at any point will be reduced even further.
Since the potential for interaction of the two plumes
is quite small, the effects of such an interaction
must be regarded as negligible.
Regarding the potential for ground water contamination
resulting from solid waste disposal, please refer to
the response to comment 13, Comment Document N, page
5-118 of this FEIS.
Applicable laws and guidelines other than the Clean
Air Act and the FWPCA were considered in the process
of preparing the DEIS and FEIS.
5-211
-------
RESPONSE TO COMMENT DOCUMENT V, Continued
Comment Number
8 (continued)
Response
With regard to Executive Order 11988, those steps taken
to comply with that order were the identification and
evaluation of potential sites not located within a flood
plain. Also, measures were taken to minimize the impact
of the project, should it be constructed, on the wetland
portions of the Wises Landing site.
With regard to 43 FE 4942, 4946, it should first be
noted that these are proposed regulations. Second, the
solid waste disposal program, including those measures
designed to prevent adverse impact that are proposed to
be used by the Applicant if the facility is constructed,
is in compliance with the proposed guidelines. (See
particularly 43 FR 4947, Recharge zones of sole source
aquifers, and 43 FR 4948, paragraphs 4 and 5, first
column.)
With regard to the Fish and Wildlife Coordination Act,
although not mentioned in the DEIS, close coordination
with both federal and state agencies was part of the
Trimble County EIS preparation process. A series of
meetings was held and measures to mitigate adverse
impact to wildlife resources were developed to be
implemented should the project be constructed (see
the response to comment 1, Comment Document F, page
5-26 of this FEIS).
With regard to the Uniform Relocation Act, the Applicant
had already obtained the land for the flood plain
portion of the site from its previous owners prior
to the initiation of the EIS process. Further, the
Act only applies to projects conducted or funded
(partially or wholly) by the EPA, which is not the
case with the proposed project.
The DOT Section 4(f) is concerned with the "considera-
tion, consultations, and alternative studies for a
determination that there are not feasible and prudent
alternatives to the use of land from a publicly owned
park, recreation area, or wildlife and waterfowl refuge
of national, state, or local significance...of any land
from a historic site of national, state, or local signifi-
cance." While the Section 4(f) requirement specifically
applies to DOT programs, the proposed project has in
fact been conducted in accordance with the principles
identified in the preceding quotation.
5-212
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RESPONSE TO COMMENT DOCUMENT V, Continued
Comment Number Response
9 The Madison, Indiana area was not a recognized non-
attainment area at the time of the PSD review. There
are specified "significant contribution" values for
predicted concentrations (see EPA's Guidelines on Air
Quality Modeling) which are thresholds for determining
when a plant's plume affects an area.
10 Region IV"s Air Programs Branch has, in meetings and
by phone, indicated a willingness to discuss the models,
modeling techniques, and any other aspect of this effort
with STV (please refer to the letter to Mr. Arbuckle
attached to the response to comment 22, Comment Document
N). There is still an open invitation to discuss The
modeling techniques used and presently available do not
account for a "corridor effect." The ORBES techniques
are not at this time acceptable methods for predicting
ground level concentrations.
The "tall stacks" policy in affect at the time of
the review and re-review were applied as required.
The EIS process provides for the issuance of a draft
which is by definition subject to revision. This
FEIS contains a remodeling of the Trimble County-
Clifty Creek plants' potential interaction. The
entire supporting data for the conclusions of this
study are available upon request.
11 The DEIS for the proposed Trimble County Generating
Station considers the effect of the proposed plant
upon the existing regional environment. This assess-
ment includes the combined effects of the proposed
Trimble County plant with all regional plants now
in operation and all proposed regional plants
scheduled to begin operation before the Trimble
County plant.
The policy of EPA is that new sources are to be consid-
ered on a "first-come" basis. Future plants will be
considered with respect to their effect on regional
conditions that exist at the time they are proposed.
12 Please refer to the response to comment 1, Comment
Document U, page 5-190 of this FEIS.
5-213
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OR. HILLY II. STOUT, SOFT
CECIL KISHER, o. P. P.
CLYOKCROPPER, FEDERAL CORD
Trimble County Schools
P. O. Flox 67 Phone: 502/255-3554
BEDFORD, KENTUCKY 40006
BOARD OF EDUCATION
CAROLE MARTIN, CHAIRPERSON
STEVE THARP, v. CHAIRPERSON
JACK CARDER, MEMBER
JAMES MCMAHAN, MEMBER
GLENN FISHER, MEMBER
7, 197&
Wi. John E. Hagan 111, Chie.& EIS BAanch
Envifiome.ntal PAote.ction Agency Region 1 1/
345 CouAtland StAe.zt, N.E.
Atlanta, Ga. 3050S
VejOA. MA. Hag an
The. puApoAe. o& tiuA letteA is> to Ae.quzAt the. EnviH.ome.ntal Px.ote.ct
ion Age.nc.if to px.ovi.de. a cloAeA analytic ofi the. impact ofa the. Louit>vi£le.
GOA & E£e.ct/uc. piopoAe.d plant on the. Achootb o& TsumbZe. County. The.
e.ntiA.e. *c.hool t>yi>tm -ci &iouide.d now be.c.auAe. theAe. -CA no e£eme.ntaA.y
in Be.d£osid.
P(Via.QMipk 7 on Page. 73 OjJ the. Vnafit Env-viome.ntal Impact Stateme.nt
that the. -impact cou£d be. AeveAe. "unleA* the. px.eAe.ntly pianne.d
300-pupil eZme.ntaM.y school iA con&tAucte.d." HoweveA, it should be.
stated that the. impact could be. AeveAe. eve.n ii the. biiitding JJ> conAfiuct-
e.d. That px.opo&nd building would n.eJLie.ve. px.ue.nt crowding. It would not
ptiovidt 4pace jjoi "56 conAtfaiction peAAonne£ c.hildx.w and appioxAmat&ly
500 opeAating peAAonn&l childA.e.n." The. crowding o& T/Uwble. County schools,
could go &Aom AeveAe. to ctitical, ye.au be.6ox.e. the. incAeaAe.d Aeve.nu&>
the. impact.
1 To analyze, the. •mpa.ct on Achoolt, oft the. L. G. 6 E. plant, the. EPA
neecii to anbweA the. fioltowing question*'-
1 . How much incAejue. in x.e.ve.nueA will L. G. g E. conttibute. to the.
school budget compaAe.d to the. total e.x.pe.cte.d gAowth o& the. budget?
2. What peAce.ntage. incAeaAe. will the.x.e. be. in school population?
3. I/Jill the. incAejued school population OCCUA be.£oAe. significant
Ae.vn.nue.
4. Can the. Ae.ve.nue. ofifaet the. impact"?
5. CoMAideAing the, low local pAopeAty Aate. in TAimble. County,
additional "mejOAuAeA to mitigate, the. px.oje.cte.d impact" aAe. not
unAeaA enable..
5-214
COMMENT DOCUMENT •
-------
Environmental Protection Age.nc.ij Re.gi.on Page. 2
Ga. 3030$
On Page. 73 o& the Vra&t EIS, section II/, paragraph 6 states that
the school* could accommodate. Increased demand during construction phase
l& teachers aides were employed.
7 . Where Mould the aides be pat?
2. How many aides Mould be necessary &or how many Students?
3. In the guides where classes now average 35 pupils, would aide*
mitigate the e^ect o& an average oft 40 perhaps?
The tame paragraph states that "revenue* derived irom construction
personnel relocation* will help o^set impact."
1. Will construction personnel relocations mean the trailers
referred to elsewhere In the EIS?
2. How much property tax. can be attributed to these relocations?
The school space problem li> further complicated by these factors''
1. The school system cannot pass bond l&sues on "expected" revew.es.
The state will not allow a district to designate money ior bond
and Interest payments until that amount can be held In the budget
over 2 or 3 years period.
2. Many people In Trimble County mJUL not vote a tax. Increase because
they think {tuture tax.es {,rom L. G. g E. will pay &or a building.
This presents a dilemma when the facilities are needed even
before L. G. s E. population Increases occur.
3. EPA In Atlanta, contradicts EPA School population predictions.
Who u> accurate?
Paragraph ], section III, on page 74 states that the "school system
may undergo long-teAm improvement as a result o& revenues..." However,
li revenues lag too &ar behind problems, then improvement may not occur.
Also, even l& long-term improvement does develop, say In 1990, more
immediate "measures to mitigate impacts11 may be justified. Please sub-
stantiate this paragraph further In the falnal EIS.
On page 74, section IV, paragraph 2 states that "careful planning
by county and School o^lclals will help reduce the potential impact."
That statement puts the monkey on the back o£ local people to solve problems
over which they have no control. School o^lcijals would welcome EPA and
L. G. B E. to come to our schools when they analyze the problems. Please
do not write. o&& solutions to "Increased revenues" and "careful planning"
In an o^lclal document such as the Vra&t EIS. The preparers o& the Dra^t
do not appear to be aware oi the actual situation. A closer analysis by
EPA may contribute to solutions.
COMMENT DOCUMENT • W, CONTINUED
5-215
-------
Env-Uiomarital Piote.cti.on Agency Pa9e
Atlanta, Go.. 3030B
include, thte Ittt^i P
-------
RESPONSE TO COMMENT DOCUMENT W
Comment Number Response
As noted in Comment Document FF, page 5-319 of this FEIS,
LG&E is currently working with the Trimble County School
Board to specificially address its concerns. A series of
meetings between LG&E and the school board have been
held and a report addressing their specific concerns
has been submitted to them.
5-217
-------
Eugene F. Mooney
JULIAN M.CARROLL
SECRETARY tel «lj |g| GOVERNOR
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
OFFICE OF THE SECRETARY
FRANKFORT, KENTUCKY 40601
TELEPHONE (502) 564-33BO
April 13, 1978
Mr. John E. Hagan, III, Chief
EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
RE: Comments on the Draft Environmental Impact Statement on The Trimble
County Generating Station.
Dear Mr. Hagan:
The above mentioned Environmental Impact Statement has been circulated
to the Kentucky Environmental Review Agencies for their comments. Enclosed
are the comments that have been returned by them. Any further comments
received will be forwarded to your attention.
Sincerely,
Boyce R. Wells
Environmental Review Coordinator
Office of Planning and Research
BRW:km
enclosure
COMMENT DOCUMENT •
5-218
-------
CALVIN G. GRAYSON
SECRETARY
COMMONWEALTH OF KENTUCKY
DEPARTMENT OF TRANSPORTATION
FRANKFORT, KENTUCKY 40601
JULIAN M, CARROLL
GOVERNOR
March 30, 1978
Mr. Boyce Wells
Environmental Review
Office of Planning and Research
Department for Natural Resources and
Environmental Protection
6th Floor Capitol Plaza Tower
Frankfort, Kentucky 40601
SUBJECT: EIS Review 78-5
Trimble County Generating Station
Dear Mr. Wells:
"| The Kentucky Department of Transportation has reviewed the subject
project and wishes to make the following advisory comment. The imple-
mentation of this project may require relocation of a section of KY 1488.
However, the applicant is aware of these possibilities and has been con-
sulting with the Bureau of Highways in Louisville, Kentucky.
Thank you for the opportunity to review this project
Resp
Edward Sue Perkins P.E.
A-95 Coordinator
Division of Urban & Regional Planning
Kentucky Department of Transportation
ESP: dw
cc: Bill Monhollon
Assistant District Engineer
COMMENT DOCUMENT • X, CONTINUED
5-219
-------
Eugene F. Mooney
JUL.AN M C
ARROLL
Govc f N o n
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF ENVIRONMENTAL PROTECTION
JOHN A. ROTH
COMMISSIONER
FRANKFORT, KENTUCKY
March 30, 1978
MEMORANDUM
TO: Boyce Wells, Environmental Review
Office of Planning & Research
THROUGH: Norman E. Schell , Director^
Hazardous Material & Waste ^Management
FROM: Caroline Patrick Haight, Chief
Non-Hazardous Waste Management Section
SUBJECT: Environmental Impact Statement
Trimble County Generating Station
The most questionable passages in the EIS from the point of
view of the division occur in Volume II pages 6-74 and 6-75 where there
is a discussion of waste handling and disposal.
2 There is no indication that the heavy metal concentrations in
both fly ash and scrubber sludge have been considered at all, let alone
their possible impact on the environment.
3 On Page 7-4 of Volume II, paragraph 7.3.3. it is stated that
"solid waste (fly ash and scrubber sludge) will be rendered stable,
impermeable and non-leachable, if possible, by means of a chemical
stabilization process." Without test data indicating how permeable "im-
permeable" and how Teachable "non-leachable" are, such statements are
not useful for assessing environmental impact, particularly when it is
not even known if it is possible»to apply this process.
It is admitted, (page 6-74), that the glacial outwash aquifer
underlying the site is "a major natural resource," and that it will be
contaminated if the "solid waste cannot be made totally stable and non-
leachable."
Again, I am skeptical of such extreme language and would prefer
to see test data. I feel that we may need to require engineering contain-
ment of the waste disposal site to prevent significant groundwater contamination
CPH:HA:mg
COMMENT DOCUMENT - X, CONTINUfin
5-220
-------
ROBERT D. BELL Iff KH \A JULIAN M. CARROLL
Secretary Ipl wN JUl Governor
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF NATURAL RESOURCES
*$gg&8K£c Bernard T. Carter
COMMISSIONER
FRANKFORT, KENTUCKY 40001
March 7, 1978
Environmental Review
Office of Planning and Research
Department for Natural Resources
and Environmental Protection
6th Floor, Capital Plaza Tower
Frankfort, Kentucky 40601
Gentlemen:
4 In the opinion of the Division of Conservation, the
chosen site location for the Louisville Gas and Electric
power generating station would have adverse affects on future
farm production output, aesthetic values and wildlife habitat.
5 By constructing the plant on the Trimble County site 600
to 700 acres of cropland would be taken out of production with
400 acres being some of the best cropland in the county. Based
on a 36 year period, the economic loss of crop production
would be approximately $3,900,000. This may seem to be an
insignificant amount but soil and good cropland is a resource
that is limited in supply. This type of land is being sought
after by all types of construction activities with little
concern over preserving this land for future crop production and
agricultural needs.
6 There were six alternate sites that were mentioned as
possible construction sites that would have little adverse affect
on current or future land use. This is because the alternate
areas mentioned are marginal cropland acres with low wildlife
potential. The use of these areas would increase the construction
costs but the long term affect would benefit the public by pre-
serving cropland for future generations.
COMMENT DOCUMENT • X, CONTINUED
5-221
-------
Environmental Review
Page Two
' If the Trimble County site is used for the power plant site
other considerations need to be made. In the impact statement,
the Louisville Gas and Electric Company plans to use two ravines
as a solid waste dumping area. Since the ravines currently have
a water carrying capacity the water should be diverted by the
use of diversions to keep the water from filtering through the
dumping site. If not diverted the water may filter leachable
solutions from the dump and affect water quality. We urge
that other possibilities and alternate sites be strongly looked
at before construction is allowed on the Trimble County site.
I appreciate the opportunity to make these comments and
review the Trimble County generating station environmental
impact statement.
Very/truly yours,
Stanley Head
Director
Division of Conservation
SH:jls
COMMENT DOCUMENT - X, CONTINUED
5-222
-------
POBRRT D BELL
SEC RL i* f Y
J u L t A N M C A t
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF ENVIRONMENTAL PROTECTION
JOHN A. ROTH
COMMISSIONER
FRAN KFORT, KENTUCKY 4oeoi
M EMORANDUM
March 27, 1978
TO:
THROUGH:
FROM:
SUBJECT:
Boyce Wells, Environmental Review
Office of Planning § Research
John A. Roth, Commissioner
Bureau of Environmental Protection
John T. Smither, Director
Division of Air Pollution Control
Draft Environmental Impact Statement - LG § E
Trimble County Generating Station
The Kentucky Division of Air Pollution Control has reviewed the subject
Draft EIS and offers the following comments.
8 The draft EIS adequately addresses the control of particulate, sulfur
dioxide, and nitrogen oxide emissions for which new source performance standards
exist. Also, measures for control of fugitive particulate emissions generated
from coal handling operations are adequately described.
9 The draft EIS contains a detailed ambient air quality analysis wherein
ground level concentrations have been predicted using dispersion modelling
techniques. The modelling results indicate that ambient air quality standards
as well as significant air quality deterioration increments will not be exceeded.
However, modelling was performed using the actual estimated emission rates
instead of the allowable emission rates. As a result of this, the draft EIS
does not show that the allowable PSD increments for sulfur dioxide will be
exceeded at an allowable emission rate of 1.2 pounds per million BTU heat input.
"|0 The air quality analysis also includes modelling results of the interaction
that could be expected from the proposed plant and the existing Clifty Creek
power plant located approximately 17 km to the north. These modelling results
are also based on actual estimated emissions and indicate that the proposed LG $
plant will not significantly combine with Clifty Creek to cause an ambient air
quality problem. However, modelling performed by the Division docs indicate that
a problem could exist when conditions are favorable for plume combination.
COMMENT DOCUMENT • X, CONTINUED
5-223
-------
Ml-MO to Boyce Wells
March 27, 1978
Page 2
The attached copy of the Division's statement made at the March 29, 1978,
Public Hearing on the proposed plant reflects the Division's most current analysis
on the environmental compatibility of proposed project. As that statement indi-
cates, the Division of Air Pollution will be performing additional air quality
analyses when necessary meteorological data is acquired. Therefore, the Divisionfs
final comments on the environmental compatibility of the proposed plant will be
forthcoming at a later date.
JWD:kl
COMMENT DOCUMENT • X, CONTINUED
-------
ROBERT D. BELL
Secretary
JULIAN M. CARROLL
Govnrnor
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF NATURAL RESOURCES
XKWMXXXXyHCXXX BERNARD T. CARTER
COMMISSIONER
FRANKFORT, KENTUCKY *oeoi
MEMORANDUM1/
•'/ ti
<-{.' • f/\
TO: Boyce Wells
Environmental Review
FROM: A. Leon Smothers
Division of Water Resources
DATE: February 22, 1978
SUBJECT: LG & E's Draft Environmental Impact Statement for
their proposed power plant in Trimble County.
11 In addition to the comments contained in my memo to you dated
February 17, I would point out that neither section 2.3.2 nor
2.8.7 points out the effects on future floods that will arise
from constricting the floodway with embankments proposed in
conjunction with the power plant.
ALS:tic
COMMENT DOCUMENT
5-225
X, CONTINUED
-------
ROBERT D. BELL K" ft $ .,"fl JULIAN M. CARROLL.
SECRETARY 'SLj. <.' " 'jfff GOVERNOR
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF NATURAL RESOURCES
JflCSHHOQQBaXX BERNARD T. CARTER
COMMISSIONER
FRANKFORT, KENTUCKY 40601
TO: Boyce Wells
Environmental Review
FROM: A. Leon Smothers ,
Division of Water Resources (-1'•
DATE: February 17, 1978
SUBJECT: LG & E's Draft Environmental Impact Statement for their
proposed power plant in Trimble County.
"|2 We have the following comments on the referenced statement:
1. In section 5.3 neither the introductory section on the
hydrologic characteristics of the Ohio River nor the
section on the stages of the river discuss the effect
that placing several large embankments in the floodways
of the Ohio will have on future flood levels.
2. Section 6.1.3. in discussing surface water indicates
that the proposal will not affect low flow on the Ohio.
They do not discuss the effect on flood flows.
We are keeping our copy of the draft Environmental Impact Statement
for our files.
ALS:tlc
COMMENT DOCUMENT - X, CONTINUED
5-226
-------
RESPONSE TO COMMENT DOCUMENT X
Comment Number Response
1 Comment noted. No response required.
2-3 Please refer to the Summary of Major Concerns and
Agency Responses, pages 5-1 to 5-5 of this FEIS, to
the response to comment 13, Comment Document N, page
5-118 of this FEIS, and to pages 3-25 to 3-36 of
Section 3 of this FEIS.
4 We concur with this statement.
5 In the Supporting Report to the DEIS, page 6-134, it
is noted that the proposed site was estimated to have
contributed $34,000 to the farm income of Trimble County
in 1969. This amount, over 36 years, would indicate
a loss of farm income of $1,224,000 (1969 dollars).
Escalated on the basis of the U.S. Department of Agricul-
ture parity index to 1978 dollars (the proposed year of
construction startup), this amounts to a loss of $2,437,000
in farm income over the 36-year operating life of the
proposed facility.
We are in agreement that bottomland soils are a valu-
able and finite resource that, particularly along the
Portsmouth-to-Evansville stretch of the Ohio River, is
being increasingly converted to nonfann uses.
6 Of the six alternate sites to the Trimble County site,
three are also bottomland sites with agricultural use
comparable to that of the Trimble County site. One of
the remaining three sites, West Point, is also a bottom-
land site, although its land was judged to be "marginal
for farming." Air quality considerations made this
site particularly unattractive compared to the Trimble
County site.
7 Please refer to the response to comment 13, Comment
Document N, page 5-118 of this FEIS.
8 Comment noted. No response required.
9 The allowable PSD increments for sulfur dioxide would
be exceeded if the allowable emission rate were 1.2
pounds per million Btu of heat input. This is the
reason the allowable sulfur dioxide emission has been
conditioned to a maximum of 0.84 pounds per million
Btu of heat input in order to protect the 3-hour PSD
increment.
5-227
-------
RESPONSE TO COMMENT DOCUMENT X, Continued
Comment Number ^___ Response
10 On the basis of this comment, EPA had Dames & Moore
remodel the Trimble County-Clifty Creek potential
interaction. This work is described in Section 4 of
this FEIS.
11 Please refer to the response to comment 3, Comment
Document E, page 5-24 of this FEIS.
12 Please refer to the response to comment 3, Comment
Document E, page 5-24 of this FEIS.
5-228
-------
L. Irene rigman Long
Attorney at l^aw
BedforJ, Kentucky 40006
502-255-4444
April 8, 1978
Mr. Clyde Baldwin
Kentucky Department for Natural Resources
and Environmental Protection
Division of Water Quality
Century Plaza, U.S. 127 South
Frankfort, Kentucky 40601
In Re: Proposed Louisville Gas &
Electric Project, Uise's
Landing, Trimble County,
Kentucky
Dear Mr. Baldwin:
This is to advise you that this office represents
the Trimble County Uater District #1. Said uater district
is the sole supplier of uater for residential and other
consumption in the city of Bedford and the outlying areas
of Trimble County, presently supplying uater to some 530
customers, more or less. The uater district has made
application with the Trimble County Court for an expansion
of the district which is presently under consideration and
uhich, when approved,uill greatly expand the territorial
limits of the said district.
The Trimble County Uater District #1 uses as its
source of uater supply deep uells located at Uise's Landing
in Trimble County. If you recall, I inquired of you at the
meeting of the U.S. Environmental Protection Agency on March
28, 1978, in Trimble County as to uhether or not the
Kentucky Division of Uater Quality had knowledge of this
fact and if it uas reflected in the report to the EPA. My
understanding is that you did not have this knowledge and
that it is not a part of your studies or your report.
It appears to me that the impact of the proposed
plant at Uise's Landing on the supply of water to the
residents of Trimble County should be investigated by your
department and a report of the results of your investigation
forwarded both to the subject water district and to the EPA.
It is of some concern that protection be afforded to the
source of water for the residents of Trimble County served
by the Trimble County Uater District #1.
5-229 COMMENT DOCUMENT - Y
-------
11. Irene I igman Long
Attorney at Law
BeJforJ, Kentucky 40006
502-255-4444
Mr. Clyde Baldwin
Page 2
April 8, 1978
I would appreciate action by your department in
this matter.
Yours very truly,
a
Irene P. Long ^
IPL/mla
Copy to: Mr. John E. Hagan, III, Chief EIS Branch
Environmental Protection Agency Region IV
345 Courtland Street N.E.
Atlanta, Georgia 30308
eret o
COMMENT DOCUMENT - Y, CONTINUED
5-230
-------
RESPONSE TO COMMENT DOCUMENT Y
Comment Number Response
Please refer to Comment Document Z and to the response
to comment 13, Comment Document N, page 5-118 of
this FEIS.
5-231
-------
April 20. 1978
Ms. E, Irene Plgman Long
Attorney at Law
Bedford, Kentucky 40006
Re: Proposed Louisville Gas & Electric
Project, Wise's Landing, Trimble County
Dear Ms. Long:
I appreciate you taking the time to write me concerning the proposed
power plant and your concern for the Trimble County Water District #1 well supply
which 1s located at Wise's Landing. Since receiving your letter, we have gone
back Into the Environmental Impact Statement and staff members had In fact noted
the well supply. At the first review, they felt that since the wells were some
mile and half down stream from the sludge lagoons and considering the type of
solidification process proposed by L G & E 1t would not be an adverse Impact.
I However, after talking with Mr. Geroge Shureck, Assistant Director,
Division of Sanitary Engineering (Drinking Water) 1t does appear to warrant
some additional study and comment 1n the preparation of the final EIS.
Therefore, by copy of this letter I am advising the U.S. Environmental Protection
Agency that consideration be given for additional review of this aspect by both
them and Dames 4 Moore, the Independent consultant. Possibly, EPA may wish to
require frequent water quality analysis of the Water District well so as to
assure no contamination or 1f contamination were to occur 1t would be Immediate!v
known. •*
Once again, let me thank you for your letter, and I wish to say that r
enjoyed our brief but pleasant conversation at the public hearing.
Since
ClydeKP. Baldwin, P.E.
Chief Sanitary Engineer
CPB:lcc Division of Water Quality
cc: *hn E. Hagan, EPA
George Shureck, San. Eng.
Northern Ky. Field Office
3
5-232 COMMENT DOCUMENT - i
-------
RESPONSE TO COMMENT DOCUMENT Z
Comment Number Response
As a result of this and other comments received from
Kentucky agencies (specifically comments 2 and 3 of
Comment Document X and comments 1-45 of Comment
Document EE), EPA met with these agencies to discuss
their concerns. It was determined during the meeting
that Kentucky, as the solid waste disposal permitting
agency, would be responsible for requiring whatever
additional geotechnical studies and engineering safe-
guards are considered necessary to ensure the environ-
mental safety of the proposed solid waste disposal
plan. Please refer to the letters beginning on
page 5-122a of this FEIS.
5-233
-------
DEPARTMENT OF THE ARMY
LOUISVILLE DISTRICT CORPS OF ENGINEERS
P C BOX 59
LOUISVILLE KENTUCKY 4O2O1
ORLPD-R 1 ° MAY 1973
Mr. John E. Hagan III
Chief, Environmental Impact
Statement Branch
U.S. Environmental Protection
Agency, Region IV
345 Courtland Street
Atlanta, Georgia 30308
Dear Mr. Hagan:
The Louisville District, U.S. Army Corps of Engineers, has reviewed
the Draft Environmental Impact Statement (DEIS) regarding the Trimble
County Generating Station. The following comments are offered for
your consideration.
1 The proposed intake structure described in the DEIS is not consistent
with that described in a permit application submitted by Louisville
Gas & Electric (LG&E) Company. The structure as proposed in the permit
application has a bottom elevation of 395.5 feet mean sea level which
would require considerable construction and maintenance dredging. The
Final EIS for this project should include this revised design and a
discussion of the probable impacts that would occur from such dredging.
As the proposed conventional intake structure would require dredging
that previously was not thought necessary, the alternate perforated
pipe intake system should again be reviewed as potentially less envi-
ronmentally damaging.
2 The proposed discharge structure indicates secondary outlets will be
utilized during "extreme high flood stages". The location of these
secondary outlets should be provided in the Final EIS along with an
indication of the frequency they would be utilized (number of days per
year and flood elevations) and probable discharge volumes. The poten-
tial impacts anticipated from these discharges should also be addressed.
COMMENT DOCUMENT - AA
5-234
-------
ORLPD-R 1 0 MAY 1973
Mr. John E. Hagan III
It should be noted that no secondary discharge outlets were included
in the permit application submitted by LG&E to this office.
3 The proposed coal barge unloading dock and fleeting area included in
the LG&E permit application and the proposed project plan, Figure 4.1-1,
of the DEIS indicates a fleeting area for 15 full and 15 empty barges.
The clearance to the center of the channel would be approximately 1000
feet, rather than 900 feet indicated on Page 4-44 of the DEIS.
4 The proposed dry reactant, fuel oil, and chemicals unloading dock in-
cluded in Figure 4.1-1 of the DEIS indicates a fleeting area for nine
full and nine empty barges. The LG&E permit application supporting
documentation indicates that no more than a total of nine barges will
be moored in these areas at any time.
Questions regarding these comments should be directed to Mr. Terry
Siemsen of my staff (FTS 352-6475).
^THOMAS P. NACK
Colonel, Corps of Engineers
District Engineer
erct
COMMENT DOCUMENT - AA, CONTINUED
5-235
-------
RESPONSE TO COMMENT DOCUMENT AA
Comment Number Resp
onse
In the DEIS, the elevation of the intake structure's
pump pit floor was shown as 409 feet above mean sea
level (msl). This bottpm elevation has now been re-
vised to 395.5 feet msl. This revision was made to
insure that, should a catastrophic event cause a loss
of pool, water would still be available for the genera-
ting station. With the pump pit at 395.5 feet msl,
assuming the pipes are submerged 10 feet below the
water surface, it would be possible to supply water
to the station until the river surface falls to 407
feet msl. Any surface elevation lower than 407 feet
msl would require the station to be completely shut
down.
At the present time, the river bottom elevation at
the proposed location of the face of the screenhouse
is approximately 407 feet msl. To maintain an adequate
water flow into the intake in the event the river did
fall to 407 feet msl, the floor of the pump pit must
be placed at elevation 395.5 feet msl. Approximately
8,500 cubic yards of material must be dredged from
the river in order to place the floor of the pump pit
at this elevation. The area to be dredged includes
an area approximately 150 feet by 150 feet in front of
the intake structure, creating a depression in the
river bottom approximately 11.5 feet deep. This area will
require maintenance dredging during plant operation
approximately every 5 years.
The dredged material will be placed on the site above
the ordinary high water elevation of 428.5 feet msl.
Material dredged during the plant construction phase will
be used for fill and landscaping. This material consists
of silty fine clay.
Dredging operations will add to the turbidity and
sediment load in the Ohio River and will destroy bottom-
dwelling organisms that may be located in the area
that would be dredged. In addition, nutrients and
other materials such as heavy metals and hydrocarbons
that may be contained in the sediments in the dredging
area could be released into the water from sediments
suspended in the water by the dredging operation. The
amount of material to be dredged constitutes approximate-
ly 3.4 percent of the total amount of dredging that
would occur during the construction of the proposed
facility. Thus, the additional impact to the Ohio River
5-236
-------
RESPONSE TO COMMENT DOCUMENT AA, Continued
Comment Number
1 (continued)
Response
resulting from dredging associated with the intake
structure is small. Dredging during plant operation
will periodically (every 5 years) disturb and destroy
any new populations of bottom-dwelling organisms that
may have developed in the dredged area. The turbidity
and sediment load of the Ohio River will be increased
in the area of the intake structure and for a short
distance downstream. Because barges will be operating
in this area, consequently creating a continued if
minor disturbance and suspension of the river bottom
sediments and riverbanks soils, and because the dredging
will be a short-term activity confined to a small area,
the additional turbidity and sedimentation is expected
to have a minor impact on adjacent aquatic organisms.
Fishes are expected to leave or avoid the area temporar-
ily; bottom-dwelling organisms within a short distance of
the dredging operations may be silted over and smothered.
Sediments suspended during dredging operations may also
scour periphyton from the submerged portions of the
docking and unloading structures temporarily reducing the
periphyton numbers in this area.
The area of most concern associated with the proposed
lowering of the intake structure's pump pit floor is
the potential of the dredged-out area in front of the
discharge structure to attract fishes, thus increasing
the potential for fish impingement on the intake
structure screens.
The perforated pipe alternative, while acknowledged as
environmentally preferable to the proposed conventional
intake structure as far as fish impingement and entrain-
ment are concerned, remains unsatisfactory for the
following reasons:
a. The river bottom at this point of the river slopes
gradually from the shore. In order to supply water
to the station during periods of low water, it
would be necessary to extend the intake pipes a
considerable distance into the river beyond the
coal barge unloader. The pipes would have to be
protected from barge traffic by large diameter
cells, which would pose a hazard to river
traffic.
5-237
-------
RESPONSE TO COMMENT DOCUMENT AA, Continued
Comment Number Response
1 (continued) b. The perforated pipe system would be very difficult
to maintain if access to the pipes were required,
given the nature of the proposed layout. Ordinary
dredging methods could not be employed should silt
accumulation threaten to interfere with opera-
tion of the system.
2 The by-pass outlets described in the DEIS have been
eliminated from the proposed discharge structure design.
During periods of high water, the circulating water
system will be operated at higher recycling rates, thus
eliminating the requirement for such outlets.
3 1,000 feet is the correct distance.
4 Nine is the correct number.
5-238
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
June 1, 1978
SUBJECT Trimble County EIS Review
M&i
FROM Mich
Technical Anal
V i
TO: Sue Walker, C
EIS Review SecVbn
The Technical Analysis Section (TAS), Air Programs Branch (APB), has
reviewed the draft EIS for the proposed Trimble County Generating Station.
For the most part, the EIS was complete. However, some issues need
clarification. Therefore, the following comments are provided.
1. Mention was made of a sludge fixation agent in the summary volume.
Later in the report, the fixation process was a proposal that would
be evaluated after start-up. Since this process may or may not work,
what contingency is planned if the proposed method of sludge
stabilization does not work?
2. The emission rate of TSP from the proposed facility is 0.051 pounds per
MBTU heat input, which is less that the "current" New Source Perform-
ance Standards (NSPS). However, thejarSfiflsed-USPS for electric
utility steam generators is 0.03 pounds per million BTU heat input
Thus, the emission rates as proposed would violate the_proposed NSPS.
3. Population data used for the study appears to have been,gathered
from two sources, i.e. Louisville Chamber of Commerce, and OBER5.
Both of these sources of data »™> not recommended pi anningJaols^
The USEPA Region V approved population projections are those
generated by the 201/208 Water Quality Management studies or those
prepared by the Bureau of Economic Analysis. Therefore, the basic
question as to the future need ror the Lb&h expansion could oe
questioned since the approved planning tools were not used.
4 The report noted in Chapter 2 "frequent violations of the sulfur
' dioxide . . . ambient air quality standards." However, ho data was
present to establish this claim.
5. Chapter 5 contained a comment on the relative frequency of fog at
the Louisville and Cincinnati airports. The report inferred that
the Cincinnati airport lies in the Valley. In fact, the Cincinnati
airport has been on top of the ridges in Kentucky for several years.
The question of where the Cincinnati meteorological data was
observed must be addressed. Did the data come from the old or new
Cincinnati airports? Or was it a combination of both sites?
COMMENT DOCUMENT - BB
5-239
fOPM niO-6 (REV- 3-76'
-------
6. Table 5.1.2-4 referenced seven monitor stations operated by
IKEC-Clifty Creek. However, the table only listed six of the
monitor's data. What became of the data from the seventh monitor?
7. The Draft EIS contained a very limited data base detailing the
baseline air quality. Even with such a limited data base, the
particulate ambient concentrations are very close to the secondary
standard.
8. The maximum ozone concentration at Wise's Landing was listed in
Table 5.1.2-10 at 371 ug/m3. This value appears suspicious, since
the winter meteorological conditions do not normally produce the
highest ozone levels. There is no mention of quality control
procedures in the EIS or any mention of any quality assurance
visits. What assurances are there that the data is indeed valid?
9. For the air quality analysis, it appeared that only the LG&E facility
and the existing IKEC-Clifty Creek facility were used in the
modelling. There appears to be two other power plants being
proposed within 15 miles of the LG&E site. The assessment of the
cooling tower impact appears to be under-estimated since the
PSI nuclear facility at Marble Hill will be located just across
the river.
10. The physical layout of the Plant's stacks ( 760 feet high) with
respect to the cooling towers (400 feet high by 470 feet wide and
500 feet high by 455 feet wide) and the terrain suggests that
stack downwash may be induced. However, this phenomena was not
addressed in the EIS analysis.
11. Appendix H could not be located. Since this appendix supported
the air quality analysis, it could not be determined where the
maximum air quality impacts were expected. In addition, a
comparison between the CRSTER and Valley models could not be
found. Perhaps these questions were addressed in the missing
appendix.
12. Significant portions of the PSD Class II increment appears to
have been consumed. The modelling incorporated only stack
emissions. Past experience has indicated that fugitive emissions
can play a very significant role in the degredation of air quality.
The EIS discusses fugitive emissions and controls in general terms.
However, the quantitative impact of these fugitive emissions was
not discussed. Recently developed emission factors should make
this analysis possible.
COMMENT DOCUMENT - BB, CONTINUED
5-240
-------
13. The EIS discusses alternatives to maintain emission standards for sul-
fur dioxide during flue gas desulfurization malfunctions. The
use of low sulfur coal is suggested. The EIS fails to mention that
the electrostatic precipitators lose efficiency with low sulfur
coal. Particulate emission rates which are already greater than
the proposed NSPS would more than likely be even greater.
What alternatives are proposed to maintain the TSP emission standards
if low sulfur coal is to be used during FGD outages?
COMMENT DOCUMENT • BB, CONTINUED
5-241
-------
RESPONSE TO COMMENT DOCUMENT BB
Comment Number Response
1 Sludge fixation processes that have been successfully
demonstrated are available from several commercial
vendors, including I.U. Conversion Systems, whose
treatment process the Applicant is now tentatively
proposing to use (see page 3-30 of this FEIS). The
Applicant must convince the Commonwealth of Kentucky,
which has solid waste disposal permit authority for
this project, that the proposed treatment of the solid
waste will render it environmentally safe. Otherwise,
as specified in the Stipulation between the Applicant
and the Regional Administrator of EPA Region IV, an
alternative disposal site must be found for the solid
waste.
2 Mr. Lazaro's comment is true. It is, however, pre-
mature. The effective date of the forthcoming NSPS
for power plants is as undecided as the numerical limits.
At this time, existing NSPS are applicable.
3 The OBERS projections of population are prepared by the
U.S. Department of Commerce, Bureau of Economic Analysis.
The 201/208 Plans for Louisville used projections pro-
vided by the Louisville and Jefferson County Planning
Commission and by Kentuckiana Regional Planning and
Development Agency. They were within 5 percent of OBERS.
EPA Region IV approved these figures. These, along with
OBERS, are the recommended EPA planning tools.
4 Please see pages 5-10 and 5-13 of the DEIS Supporting
Report.
5 The report did not intend to imply that the Cincinnati
airport is in the valley. It is located above the river
valley. The meteorological data cited were taken at
the present Cincinnati airport.
6 Indiana Kentucky Electric Company did not release the
data from the seventh air monitor.
5-242
-------
RESPONSE TO COMMENT DOCUMENT BB, Continued
Comment Number Response
7 Mr. Lazaro's statement is true. However, it is not
relevant to the approvability of the proposed plant.
Rather, what is of concern is whether the post-construc-
tion air quality meets the PSD increment and the NAAQS.
8 Although high winter ozone readings are somewhat unusual,
the occurrence of this value is not sufficient to ques-
tion the validity of the data. The EIS does not normally
contain QA procedures (the Kentucky QA manuals are
longer than the EIS).
9 The proposed plants should not be included in this
EIS. Rather, since evaluations are performed and permits
issued on a first-come, first-served basis, the Clifty
Creek and Trimble County plants would be included as
existing (or permitted) plants if and when EPA Region
IV prepares EIS's for any subsequent proposed plants
in this area. EPA Region IV1s Ghent Station EIS assessed
the combined effects of the Clifty Creek and the proposed
Trimble County plants.
10 It is our feeling that cooling towers do not cause
down-wash and, in fact, may enhance plume rise when
operating. However, there is no proven method for quali-
tatively or quantitatively evaluating this effect, if
any.
11 Appendix H is found in Volume II of the DEIS Supporting
Report. Also, on p. 6-40 of the DEIS Supporting Report,
the maximum 3-hour and 24-hour concentrations are stated
as being predicted to occur 1.4 kilometers southwest
and northeast, respectively, of the plant.
12 Consumption of the increment by stack emissions has
been properly evaluated. No reliable method exists for
evaluating the ambient impact of fugitive emissions.
Further, the impact area would not coincide (were the
methodology available).
13 The comment is correct, in that the precipitator
efficiency will drop, and emissions increase, if low
sulfur content coal is used. It is difficult to
quantify this effect in order to tell whether NSPS
for TSP will be violated.
5-243
-------
Eugene F. Mooney
JULIAN M.CARROLL
SECRETARY 151 fU\ Ipl GOVERNOR
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
OFFICE OF THE SECRETARY
FRANKFORT, KENTUCKY 40601
TELEPHONE (502) 864-3350
June 1, 1978
Mr. John Hagan, Chief
Environmental Impact Statement Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
RE: Late Comments - Trimble County
Generating Station - Environ-
mental Impact Statement
Dear Mr. Hagan:
Enclosed is a copy of the comments made by the Department
of Fish and Wildlife Resources on the above-mentioned Environmental
Impact Statement. Hopefully they can be responded to in the final
statement.
Sincerely,
Boyce R. Wells
Environmental Review Coordinator
Policy and Program Analysis
BRW:bsc
Enclosure
JUH
COMMENT DOCUMENT -
5-244
-------
M ,ur E
•M MISSION
r MtSTRICTS
T. PAUUCAH
^ C S A i * i o . (~ o 1. 1 ' M n i A
IA A F. ^ I? PICK. TAYLOR MILL
Cru- ; i *<>\ TiC. PA LMEP.Jn. LEXINGTON
7 1 H - U • \V W. CAMrnrLL. JACKSON
f-onp/RT C WRBB. GFJAYSON
=HINO HAYES. TYNER
COMMONWEALTH OF KENTUCKY
DEPARTMENT OF FISH & WILDLIFE RESOURCES
ARNOLD L MITCHELL,COMMISSIONER
CAF'IIAI. Pi A/A Towrn
FRANKFORT. I1 .?<1OO
April 18, 1978
Mr. Eugene F. Moone.y, Secretary
Department for Natural Resources
and Environmental Protection
Office of Planning and Research
6th Floor, Capital Plaza Tower
Frankfort, KY 40601
RE: Draft El.S-Trlmble County
Ceneratlng Station, l.otn1'
ville Gas & Fleetric (l/'.
Dear Mr. Mooney:
| Members of my staff have reviewed the above-mentioned document and find t In-
plan of study and data generated from it to be adequate. There are, however,
several points relevant to the project that require further consideration and
study.
The permanent loss of approximately 1,850 acres of wildlife, habitat (Sec-
tion 6.6, Paragraph 1) constitutes a very significant loss. The loss of this
particular type of habitat in this region due to the proposed project will have
a substantial impact on local, regional, and migratory wildlife species. Those
points are brought out in the document but the relative importance of the looses
are somewhat understated. Since wildlife species cannot be stockpiled on, or
substantially assimilated into adjacent habitats, there will be a permanent loss.
As Indicated by the data supplied, the biological communities to be affected
by the project appear to be well developed and stable. At the site, there ir, n
wide variety of habitat types interspersed to form a unique biotic situation.
The unique features of this area are attributed not only to the iritcrsperslon of
habitats, e.g., wetland, riparian, upland, pasture, and agricultural land, hut
also to the distinct absence of similar situations within some distance from 1 he
site. Our surveillance of the area indicates the nearest area of this type lh.ii
lies adjacent to the Ohio River on the Kentucky side is 62 miles downstream on the
Hardin-Meade county line with the nearest upstream area being 74 miles away in t lie
area known as Aurora Ferry Slough in Boone County.
MAY 3 \
COMMENT DOCUMENT - CC, CONTINUED
5-245
DEPT foi rvit^M. « .-
i LNVIHOIJMF.NTAL PROTECTION
OFFICE OF PLANNING i
RCSr.AKCH -. '
-------
Mr. Ktigcne F. Mooney
Page Two
Apr 1.1. 18, 1978
Due Lo the uniqueness of the site, the tremendous diversity ot floral and
faiin.il assemblages, and the proposed degree of impact upon fish and wildlife'
resources and their habitats due to site development, it becomes apparent that
in the interests of fish and wildlife resources and the public in general, cer-
tain problems must he addressed by LG&E.
Rlimination of 1,850 acres of wildlife habitats and the disruption of local
and regional wildlife patterns brought about by the changing from rural to indus-
trial ideals, priorities, and attitudes towards the land constitutes a major action
with substantial impacts upon fish and wildlife resources. Several alternatives
exist through which these Impacts may be eliminated or offset. Discussions follow:
Fish and wildlife habitats are becoming drastically reduced across the slate
in genera.! and along the mainstem of the Ohio River in particular. Unless ade-
quate mitigation can be sought and agreed upon by the applicant and those agmicics
responsible for insuring the continued exlstance of fish and wildlife resources
and their habitats, the only recourse is to call for complete site relocation to
a less sensitive area where impacts would be less critical.
It is stated in the document (page 5, last column, Trimble County sice) (hat
"the relocation of the Corn Creek channel will involve destruction of the associ,-) r ec|
aquatic habitat and woodJand along the stream banks." While the proposed plant
arrangement insures the relocation of Corn Creek, it is the opinion of this Oepai-t —
ment that this action could be properly mitigated by initiating the following r»<>tions:
1) Design of the new relocated channel should be such that it would dupli-
cate the old channel in length, width, and depth. If any riffle areas
occur in the old section, they should be reconstructed in the new.
2) Banks of the new channel should be stabilized via revegetation imniof|j-
ately following channel work. Vegetation composition should be similar
in type and density to that of the old channel.
It is also stated (page 15, last column, Trimble County site) that "a v,i.ln,-ible
wetland area would also be affected." This, we assume, is the slough area formed
when Corn Creek was cut off. This area is, in all likelihood, the most productive
and valuable of all. wildlife habitats on the site. The pending isolation of this
slough from the other habitat types exhibited on the site, however, will detract
from its relative importance.
The slough area and adjoining floodplain are now (without development) the
center of activity for wildlife species within the project area. This area will
become less important with construction of the project, and future encroachment
will eliminate it's importance all together. Therefore, its protection and the
protection of all habitats riverward of it must be assured for the life of the
project.
COMMENT DOCUMENT • CC, CONTINUED
5-246
-------
Mr. Eugene F. Mooney
Page Three
April 18, 1978
The possibility exists for the enhancement of the areas remaining on l lie-
site through the cropping, for agricultural purposes, of the area riverward of
the slough. The past and present agricultural activity on the floodplain pro-
duces wildlife foods that are utilized primarily by migrating waterfowl and up-
land wildlife species. Again this year, as in past years, high water from the
Ohio inundated the fields during the fall migration and the flooded fields were
used as resting and feeding areas for several hundred waterfowl. Elimination of
this area would eliminate a valuable link in habitats required by waterfowl migra-
ting through the Ohio River valley.
The value of the slough and the area riverward of it to waterfowl is exempli-
fied by the high hunting pressure exerted by 'local sportsmen. This is well docu-
mented through the Trimble County Conservation Officer, Ronald Sherman. A fact-
that further substantiates the need for enhancement in the undeveloped area mound
the slough is the attraction of waterfowl to fly ash ponds. Warm water effluents
are very attractive to waterfowl and are heavily utilized. While this provides
resting areas, a food source is scarce within the ponds. Consequently, cropping
the area riverward of the slough would benefit them greatly.
As stated earlier, fly ash ponds attract waterfowl but they are seldom avail-
able as hunting areas for sportsmen. The elimination of this hunting base won.Id
have an impact on local and regional hunters. While we do not advocate the opening
of the fly ash pond to hunting, we do suggest that the area riverward of the slough
be open with access being from the river only.
In summary, onsite mitigation should be as follows: the relocated seel ion of
Corn Creek should be similar In length, width, and depth to the old channel. Rif-
fles should be reconstructed and riparian vegetation reestablished at a density
and composition similar to that removed. The slough area should remain as if is
and in no May be altered. The area riverward of the slough should remain undeveloped
and preferably cropped to produce wildlife foods. Hunting should be allowed in the
slough area with access being from the river only.
With the elimination of some 1,850 acres of wildlife habitat, there is no way
that the site can be mitigated to replace losses of habitat, movement corridors,
food sources, breeding sites, etc. Also, since upland sites on the LG&E property
are slated to be used as disposal sites for sludge and fly ash, their importance as
wildlife refugia is only temporary. Off site mitigation should be initiated. We
submit, then, that biologists from either the lead agency and LO&E or both should
moot with representatives fo this Department to discuss and plan solutions to this
problem prior to the issuance of the Final EIS.
While the location of the transmission line corridor has not been placed as of
yet, we will address it generally. It is our recommendation that following the Ini-
tial clearing of the corridor, disturbed areas should be disked, fertilized, and
seeded with a legume/grass mixture using Kentucky bluegrass, smooth brome, canary
grass, or timothy as grasses and alfalfa, birdsfoot trefoil, alsike, white or red
clover, korean or sericea lespedeze or partridge pea for legumes. This community
COMMENT DOCUMENT - CC, CONTINUED
5-247
-------
Mr. Eugene F. Mooney
Paj;p Four
April 18, 1978
should then he allowed to proceed through successional stages to allow native
shrub species to invade and establish themselves. The community should then be
maintained with registered safe herbicides, by mechanical means or fire at a level
of 2/3 grass/legume and 1/3 mixed shrub.
The Department of Fish and Wildlife Resources strongly requests that the
mitigatory steps outlined in this letter be addressed in the Finnl EIS. We offer
the services of our professional staff in formulating concrete plans regarding
the proposed mitigation outlined here (hopefully prior to submission of the Final
ETS). It is under the auspices of KRS 150.015 and the Fish and Wildlife Coordina-
tion Act that we request these mitigatory steps be initiated.
Thank you for the opportunity to comment and we look forward to your con-
tinuing cooperation.
Yours very truly,
Arnold L. Mitchell
Commissioner
ALM:LES:smw
copies: Joe Bruna, Director of Game
Bill Graves, P-R Coordinator
Peter W. Pfelffer, Asst. Dir. , Fisheries
Ronald Sherman, Trimble County CO
Bob Johnson, U.S. Fish and Wildlife Service
Mary Veale, U.S. Environmental Protection Agency
Environmental Section Files
COMMENT DOCUMENT • CC, CONTINUED
5-248
-------
RESPONSE TO COMMENT DOCUMENT CC
Comment Number Response
1 Please refer to the response to Comment Document F,
page 5-26 of this FEIS.
5-249
-------
t. Irene lignian Long
Attorney at Law
Bedford, Kentucky 40006
502-255-4444,
July 26, 1978
fir. John E. Hagan, Chief
EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, Georgia 30308
In Re: Proposed Louisville Gas &
Electric Project, Uise's
Landing, Trimble County,
Kentucky
Dear Mr. Hagan:
Our office had foruarded at an earlier date the
concerns of the Trimble County Water District #1 to the
building of the proposed Louisville Gas And Electric
facility in Uise's Landing, Trimble County, Kentucky.
I am enclosing herewith tuo items uhich ue
should like to have placed in the record in this regard:
1. A copy of a Resolution from the Trimble
County Uater District #1 going on record to object to the
location of the Louisville Gas And Electric project at
Uise's Landing in Trimble County, Kentucky, on the basis
of the threat uhich the facility proposes to the uater
supply of the counties using the deep uells at Uise's
Landing;
2. A copy of the report of Charles Eduard Oldham,
geologist, outlining in detail the real and certain danger
of contamination of the subject uater supply by reason of
the proposed project.
Kindly place these items in the record. Ue trust
that you uill give much consideration to the impact uhich
this project uill have on the water resources of this area
of the Commonwealth of Kentucky.
Yours very truly,
IPL/ms Irene P. Long
Enc- COMMENT DOCUMENT
5-250
-------
A SUMMARY of the GEOLOGICAL FACTORS THAT
POSE a HAZARDOUS THREAT TO THE WATER
QUALITY of the WISES LANDING AQUIFER
by the STORING OF SLUMS ON THE PROPOSED
WISES LANDING (LOUISVILLE QAS AND
ELECTRIC) GENERATING STATION, TRIMBLE
COUNTY, KENTUCKY
prepared by
River Qlty Geological Survey and Supply
Charles Edward Oldham
Geologist
July 14, 1978
COMMENT DOCUMENT - DD, CONTINUED
5-251
-------
CREDENTIALS OF THE AUTHOR
Oldham County High School (1968)
Park Aerial Survey (summer, 1968)
U.S. Navy , photo- intelligence (1968-1970)
University of Louisville (1970-1974)
B.A. Geology - Minor Anthropology, University of Louisville
(1970-1974)
Cannelton Dam Survey, Assistant to Dr. Conkin
summer, 1972
Assistant for Departments of Archaeology, Geology, Geological
Engineering (Speed) 1972
Excavated and restored Lucas Mammoth, Muckport, Indiana
(1973-1978)
Excavated Ruby Mammoth Sixth and Lee Street, Louisville, KY
summer of 1974
Graduate Study at Eastern Kentucky University
summer 1974
Started own business River City Geological Survey and Supply
1975 **"*
Graduate Research at Indiana University, 1976
Returned to University of Louisville 1977-1978 for 2nd
teacher certificate in Earth Science
Signed contract with Trinity High School summer 1978 for
1978-1979 school year - Earth Science, five classes
12 hours to complete for a M.A.T. in Natural Science
Published numerous small papers to various journals and
groups, the latest two were:
Kentucky Speleofest _!26, pages 18 through 44,
Geologic Setting of Hardin County, Road
Indiana Highways. April 1977, A Hew Technique for
Preserving Mammoth Skeletal Remains,
COMMENT DOCUMENT - DD, CONTINUED
5-252
-------
The entire Environmental Impact Statement issued
by the Environmental Protection Agency ia filled with
innacuracies, gross misconceptions and generalizations.
Important data is covered up with extraneous facts and
figures and buried in unlikely areas within the text.
•J I have never read such a hodgepodge of misused and
misunderstood conclusions based on fradulent "facts"
Buried on page 39, section two is the following statement
which, in my estimation Should have been presented much
earlier in the flow of the text.
"Power generation is an integral component of an
area's economy and the way land is used. The need for
electrical energy is dictated by the types of land use
and the growth of energy-consuming industries and
residential development. Yet the very elements of the
economy that require power often compete for available
land, water, and air resources. Power plant siting must
acknowledge other "higher and better" economic land uses
such as existing industrial, commercial, and residential
use and also the value of irreplaceable land resources such
as prime farmland, unique lands preserved for their scientific
value or lands dedicated to public use, and lands supporting
valuable historic and archaeological resources.
The goal in siting power plants is to locate them where
they will be compatible with existing land uses and where
they will not preempt a future, better use of the land
resource, nor destroy or make impossible the maintenance
and/or recovery of important cultural and environmental
qualities important to human welfare. Thus, the ideal is
to site on lands that are marginal in their present use and
where a power plant would therefore represent a "higher and
better"use. Since the definition of such use is subject to
change, the only approach that can usually be taken in siting
power plants is to take into account the long range plans
and planning objectives of local and Mgional governments
and abide by existing land use zoning regulations."
page 2-39
COMMENT DOCUMENT • DD, CONTINUED
5-253
-------
According to thia statement Wises Bottom possesses
a "higher and better" economic land use of being a source
of excellent uncontaminated water for the counties of
Trimble, Henry, West Carroll and Oldham. With the continuing
contamination of the Ohio River and aquifers up and down-
stream, this is and will be a precious natural resource
for the future.
As to the value of irreplaceable land resources,
Wises Bottom contains some of the best farmland in Trimble
County and in no way can be called "marginal". This statement
also speaks of "unique Ifcnds to be preserved for their
scientific value". What then of the archaeological sites
that abound in the cultivated fields and in the substrata
below as exposed by the action of the Ohio River and Corn
Creek on their banks.
"Will not preempt a future, better use of the land resource
nor destroy or make impossible the maintenance and/or
recovery of important cultural and environmental qualities
important to human welfare."
Wises Bottom future lies with service to people in the
form of a retreat for city dwellers, a park if you will, as
well as a haven for the many indigenous and endangered
species who call it home. A resort or park would not
pollute the aquifer and would not preclude other parallel
developments, i.e., marinas, related resorts, country homes
and cottage industries.
"Thus, the ideal is to site on lands that are marginal in
their present use and where a power plant would therefore
represent a "higher and better" use."
COMMENT DOCUMENT - DD, CONTINUED
5-254
-------
In my opinion Wises Bottom is far from marginal
and may indeed be the key to Trimble County's future
in so far that is is one of the few remaining unpolluted
sites along the Ohio River and is a source of pure water
for Trimble, Henry, Carroll and Oldham counties.
COMMENT DOCUMENT - DD, CONTINUED
5-255
-------
PHYSIOGRAPHY AND TOPOGRAPHY OF WISES BOTTOM AND
VICINITY
2 The authors of the EPA report admit a direct correlation
between the physiography of the area, the production of
air pollutants and air pollution in the valley and the
dangerous effects it will have to the entire Ohio River
Valley. However they fail to state the heights of the
hills in Trimble County, the mean elevations for the hills
is 800' plus , or about a 400' rise in elevation from the
River level.
Air Quality. 2.1.1, page four, paragraph 5
"Generally, the service area' is characterized by rolling
hills; in parts of Jefferson, Bullitt, Hardin, and Meade
Counties, these rise over 600' from the valleys. This could
present a potential air quality problem due to plume impactlon
on the hills or to downwash effects. Within the Ohio River
Valley, the flood plain is of varying width but is flanked
on either side by bluffs that typically rise ifOO* from the
valley floor. Air quality problems associated with plume
impaction and downwash effects are likely to occur along
the entire reach of the Ohio River."
The EPA further state that the climate will be conducive
to the build up of air pollutants.
Having Climate. 2.1.1, page three, paragraph 2
"The prevailing (most frequently occurring) wind direction
in the area is generally from the south through southwest,
although there are seasonal variations. Due to the relatively
light annual average wind speed and low mixing depth,
meteorological conditions are occasionally conducive to the
buildup of air pollutants, particularly during the late summer
and autumn."
3 Also in Volume II, Table I/*, page 58 and 59, the EPA
conclude that sulfate formation will induce an increased acid
rain near the plant for its entire operating life (36 years).
Perhaps one could justify one of these irritants but the •
COMMENT DOCUMENT - DD, CONTINUED
5-256
-------
combined effect of all three is indeed a hazard to health
of everyone within the area.
"TABLE lit, page 58 and 59
Source of Impacts
Sulfate Formation
Projected Impacts or Effects
Increased Acidity of rainfall near the plant
Duration and Degree of Impact
Throughout 35-year total operating life of plant11
When atmosphere tests were made in the site area
"Photochemical oxidant concentrations, however, frequently
exceeded the 1-hour ambient air quality standard during the
monitoring program." page ifO, paragraph 1, Vol. 2
4 Without the generating plant in operation, these tests
showed a violation of air-quality standards.
Taking the EPA's own statements:
THE LAND. 2.2, page 5, paragraph 1
"Relief, drainage, soil and rock type, and geologic structure
affect site development costs, determine the natural hazards
to which the power plant will be subject over its economic
life, and' determine the magnitude of ground and surface
water contamination problems and engineering costs incurred
in environmental measures."
pag'e 5-46» paragraph 2
"The Silurian limestones are susceptible to solution activity
that often results in cavities and shallow sinkholes in many
areas."
"The uplands are in an early to mid-mature stage of development
and show numerous signs or karstic topography, including
sinkholes, numerous springs, and disappearing streams."
Volume 1, section 5-35, paragraph 3
2nd sentence: "The presence of a karst topography on the
uplands in the site area that includes sink holes, numerous
springs, and disappearing streams would dictate that underlying
sediments are being recharged by the Silurian formations.
•
5 As to the disappearing streams, the water has to go
somewhere and usually reappears as springs in the sides and
the base of bluffs.
COMMENT DOCUMENT - DD, CONTINUED
-------
•TABLE 14, page 58 and 59
5ource o f Impac t s
Solid Waste disposal in ravines RA and RB.
Projected Impactsor Effects
Under maximum worst-case coal conditions, ravines will be
completely filled so that the top of the fill will be the
same height (around 800' above mean sea level) as the
present ridge tops
Duration and Degree of Impact
Major" impact," asi a~~dramatlc change in topography will occur"
6 Therefore the Silurian formation is within all their
crack joints and solution channels will be exposed to the
sludge. There will be both lateral and vertical mixing of
sludge, water, and groundwater. This contaminated water
will then migrate through the rock to springs and seeps that
recharge the Wises Landing Aquifer.
"Ground water (and any water-borne contamination) is carried
along these open Joints, although the rock itself is tight
and has very little primary permeability" page 2.9,
paragraph 1
7 As to the statement that the Silurian rock forms have
very little permeability, refer to Chart No. 1, taking into
account the defination of permeability as "a rock is said to
be permeable if water or other liquid in contact with its
upper surface tends to pass through the rock more or lees
freely to the lower surface. Permeability may be achieved
by the rock being either porous or pervious. The essential
feature of a bed of T>ermeablo rock is that the liquid it
contains may be extracted by pumping." (Whitten,D.G.A. and
Brooks, J.R.U., 1972).
COMMENT DOCUMENT - DD, CONTINUED
-------
STRATIGRAPHY OF WISES BOTTOM SITE AND IMMEDIATE VICINITY
The stratigraphy of the geologic formations in
the Wises Bottom site extends from the recent (Holocene)
Alluvial deposits (40" plus) found in the bottom of stream
and river channels in the area and the Colluvium (0 to 5')
that covers the sides of the valley walls (consisting of
fall down block of various formations and weathered shale)
covered with a thin forest soil of the Fairmount Soil Group.
(Swadley, W.C., 1977) (EIS vol. section 5, page 51,
paragraph 6).
"Surficial Soils
Plant Site and Ravines page 5-51, paragraph 6
"Fairmount soils, which are shallow, clayey, and rocky,
occur primarily on steeper slopes."
8 These soils are not impervious, will not stop the sludge
from migrating into the various aquifers.
The Plestiocene Deposits consist of Loess (wind born
Silt, 0-10*) Lacustrine Deposits (Lake Bed Silty clays,
0-30' plus), glacial outwash (gravel, silt, sand and clay,
100' plus), and glacial drift (100'plus, clay, gravel, silt and
sand}
9 The Loess best exposed .05' from the mouth of Corn Creek
and occurs under most of the generating plant area, and is
part of the aquifer. The Loesn in a very unstable bed and
subject to extensive erosion, not at all souad for supporting
man-made structures.
10 The Lacustrine deposits are not exposed within the site
area but may be covered by the glacial outwash which covers
over half the site. This clay may be of good quality but
COMMENT DOCUMENT - DD, CONTINUED
5-259
-------
there is not enough exposed at the site to be of any value.
11 The Glacial Outwash occurs under 50% of the generating
plant area and is part of the aquifer. This is not a
homogenous bed but rather is composed of lenses, beds,
cross beded layers, etc. that are entertongued. However
there is a fairly persistant bed of gravel at the basal
section.
12 The Glacial Drift is found on the uplands at or directly
below the 800' level. The Drift consists of clay, sand and
gravel and should not come in contact with the sludge at all.
The interface of the dri«£t and the bedrock and/or soil below
is a natural waterway for wet weather seeps.
Silurian
13 The presence of the Louisville Limestone and the Waldron
Shale is very questionable. "Formations (Louisville Limestone)
not exposed in map area, presence inferred from formation
thickness-reported by Peterson and others (1971) for the
La Grange quadrangle adjacent to the south area mapped as
Louisville (?) Limestone and Waldron(?) Shale marked by thick
reddish-brown soil containing scattered silicified fossils and.
blocks of brown-weathering chert that contains abundant fossil^
especially corals." (Swadley, E.G., 1977).
14 The Laurel Dolostone 55' plus or minus, fine to medium
grained, with beds up to 2' thick. A persistent bed (1-2*)
of greenish shale occurs four or five feet from the basal
COMMENT DOCUMENT - DD, CONTINUED
5-260
-------
5-*
Laurel. The Laurel occurs along sides of steep hollows
and large breakdown blocks, as much as 10 x 30' are found
Just below the out crop and are scattered all the way to the
valley floor. Basal contact is sharp and springs and seeps
are commonly found at this contact.
15 The Osgood Shale is 16-20' thick and is interbedded
with limestone lenses. When in contact with the Laurel and
Saluda, these units become very good aquifers. Water seeps
occur at upper and lower contacts. Water seeps can also be
encountered at interfaces between limestone and shale
lenses.
16 Th« Brassfield is very limited in thickness (about
1 to 5') under the outcrop, if present at all.
Ordovician
17 The Saluda is a silty Dolostone Member of the Drakes
Formation thinly bedded with a shale break at about midway
through the member.
18 The Saluda is commonly well exposed at heads and sides
of steep hollows. The upper contact is commonly marked by
a bench dotted with numerous small sinks (Swindley, W.C., 1977-).
Contact is not generally exposed due to the jumble of weathered
blocks from the upper half of the foundation.
"|9 Tn® Bardstown Member of the Drakes Formation (25-60*).
Interbedded limestone and shale, irregular beds less than V*
thick are the rule. Lust content 50%. Exposed along stream
banks and some hillsides. Basal contact-generally sharp,
thickens to the north and merges with the Bull Fork Formation.
COMMENT DOCUMENT • DD, CONTINUED
5-261
-------
20 Marble Hill Beds of the Drakes Formation pinch in and
out merging with the Rowland Member, above and below (0-301)
limestone and mudstone.
21 Rowland Member of the Drakes Formation (0-55') are lust
interbedded with shale raicrocrystalline to knoboy. Pinches
in and out with the Marble Hill Member o.f the Drakes Formation
and the Bull Fork Formation.
22 The Bull Fork Formation (60-200'). Interbedded with
limestone and shale (50% and 5$). Limestone beds from 6"
to as much as 2V1. Weathers to a rubble, some beds are
micro to medium crystalline limestone. Brakes into and
intertongues with the Grant Lake Formation.
23 The Grant Lake limestone (70-1001), interbedded limestone
and shale, limestones grade from rubbly to crystalline.
Upper contact graduation with that of the Bull Fork
Formation, basal contact generally sharp.
24 Galloway Creek Limestone (201 plus or minus), limestone
and shale beds appearing and disappearing within 100'
(laterally) of each other, discontinuous bedding. Only a
20' plus or minus exposed in New Bethlehem Quadrangle Area.
COMMENT DOCUMENT - DD, CONTINUED
-------
GROSS ERRORS IN STRATIQRAPHIC STATEMENTS
Geologic Setting page 5-36, 5.2.2
Stratigraphy
"Bedrock units immediately underlying the plant site
consist of sedimentary strata ranging in age from Middle
Silurian to Upper Ordovician."
25 This statement iaferrs by the term "plant site" that
•
Middle Silurian rocks underly the generating complex when
they actually only occur toward the tops of the uplands.
Section 5-43, Figure 5.2.2:3, SITE GEOLOGIC COLUMN
26 The Louisville Limestone is questionable and due to
illegibility of the print on the page, (print too small to
see without aid) the question mark appears to be a number.
On the Bethlehem Quadrangle the Waldron Shale is questionable
within that quadrangle.
Geologic Setting 5.2.2
Stratigraphypage 5-45> paragraph 1
"Silurian strata occur over most of the upland areas and
are the youngest bedrock formations on the plant site.
These strata are principally composed of limestone and dolomite
formations, interbedded with shale members that are generally
less than 15 feet thick. The areal extent of Silurian strata
on the site is limited to a very small fringe on the eastern
property boundary. As interpreted from the lower limit of
karstic development shown on a detailed topographic map of
the plant site, the base of Silurian age formations occurs
at approximately elevation 730 to 750. The base of Silurian
strata has been found at about elevation 700 at the Marble
Hill Nuclear Generating Station site, almost directly across
the Ohio River from the Trimble County Generating Plant site."
27 The phrasing of this paragraph in regard to the Silurian
Strata leaves much to be desired. It seems that the authors
are unwilling to state formation names and the reader can only
guess at whether the Silurian Strata referred to is that of the
Louisville Limestone, the Waldron Shale, or the Laurel
Dolostone. The shale referred to in the paragraph could be a
COMMENT DOCUMENT - DD> CONTINUED
5-263
-------
8
shale break that occurs when*the Laurel Louisville lime-
stone, the Waldron Shale, or a shale break that occurs in
the upper lower Laurel Dolostone, or even the Osgoode
Formation which is composed of a upper and a lower shale
with intervening but not continuous layers of limestone.
STRUCTURAL GEOLOGY
28 The Wises Bottom area is fairly stable tectonically,
however there is severe faulting in the lower Laurel
limestone, Osgood Formation, and Saluda exhibited in a river
bluff cut on Kentucky Highway 1793, Oldham County, Kentucky
and directly across the river outside Charlestown, Indiana,
Indiana Highway No. 62. (Peterson, W.L. and Wigley, P.B.,1971)
29 Also the Kentucky River Fault runs through much of
Henry County, Kentucky and then there is Jepth Knob, which
may or may not be a cryptovolcanic structure. There is also
a bifurication of the Hollowing Fork Fault running underneath
Louisville and appearing at the position of "Liberty Rock"
at the Falls of the Ohio.
30 But the largest quakes in the history of Kentucky are
connected with the New Madrid fault system. Tremors from
this formation have been felt at late as April 3» 1974 in
Trimble County and surrounding areas.
Seismic History of the Plant Site. Ravines and Transmission
Line Corridors5-47, paragraph 2
"The New Madrid earthquakes had their epicenters along the
Mississippi River fault near the Mississippi Bmbayment.
The Mississippi Valley fault zone begins at the Mississippi
Embayment and extends northeast to Vfntjennes, Indiana. The
fault is tectonically very active."
COMMENT DOCUMENT • DD, CONTINUED
5-264
-------
Islands in the river appeared and disappeared. Reelfoot
Lake at the Tennessee-Kentucky line was created and the
backward flow of the Mississippi and Ohio Rivers were noted
at many locations (McFarlan, A.C., 1950).
"The New Orleans safely rounded to below the falls.)" (Falls
of the Ohio). "But there was little time for rejoicing, or
even relaxing. Hardly had she anchored tnan the world seemed
to rend itself at the seams. The ground heaved and shook.
The waters rushed madly from bank to bank. At one point they
•
even flowed upstream. The greatest earthquake ever to strike
North America, the New Madrid tragedy of 1811, as it has been
labeled, seemed to grasp the little boat as if resenting
the intrusion of steam to challenge Father Mississippi's
long reign." (Samuel, R., Huber, L.V., Ogden, W. TALES OF
THE MISSIPPI 1955).
Mineral Resources
31 In reference to Section Two, page 21, paragraph 2, the
JBPA report failed to mention water as a natural mineral
resource. Water is a Mineral.
" Ice Occurs solid as ice, snow and frost, or liquid
IT Q
Water ae water! hardness, 2; specific gravity, .92;
colorless to white, luster adamantine; transparent
on thin edges.
Though we seldom think of ice and its liquid form, water,
as a mineral, still it is one, and perhaps the most important
of all minerals, as well as the most common. Ice melts at
32°F. and vaporizes at 212°F., being then termed steam.
Because it is so common and liquid At .ordinary temperatures,
it acts as a solvent for a host of other minerals, and is
therefore the agent by which they are transported from place
to place and redeposited in veins and beds." (Loomis, F.B.,
1948).
COMMENT DOCUMENT • DD, CONTINUED
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10
32 Water from the Wises Landing Aquifer is the most
important natural resource that Trimble County posesees.
WATER
» ENVIRONMENTAL IMPACTS OF THE PROPOSED PROJECT
INTRODUCTION page 49, paragraph 1
"Impacts to the land and water will be confined to the site
and its immediate environs."
"Many of the impacts of the plant on the people of Trimble
County and other areas (including other counties in Kentucky
and Indiana) will be beneficial; some will not"
33 The source and quality of water for the residents of
Trimble, Henry, Gldham., and West Carroll contained within
the Wises Landing Aquifer -will not be benefited by the
introduction of contaminates by the Louisville Gas and Electric
generating plant and the storage of sludge. Nor will the
"Impacts to the land and water be confined to the site and
its immediate environs."
34 The entire section (2.3 THE WATER) from pages 2-23
through 2-34 reads with reference to the entire service area
including the site Wises Bottom and tends to generalize and
obliterate the hydrological nature of the proposed site
rather than stating the specifics of the site area.
It is my intention to state the specific hydrological
conditions of the site and the site area that will illustrate
the extreme hazards of storing sludge on a delicately balanced
aquifer
Identification. Ground Water P.3.1
"Ground water resources in Kentucky are" primarily limited
to bedrock aquifers, except for the sand and gravel outwash
that fills the Ohio River buried valley. Most of the service
area is underlain by limestone and shale that yield from
COMMENT DOCUMENT - DD, CONTINUED
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11
0.1 to 10 gallons per minute (gpra) from drilled wells."
35 The word primarily tends to infer that the following
phrase will be of secondary importance. Using the word
"except" in this first sentence tends to leave the reader
with the impression that alluvial aquifers are insignifant
sources of water.
36 The EPA seems to be confused on the amount of water
that can be pumped from the Wises Landing Aquifer. Two
statements below taken from the Environmental Impact Statement
illustrate this:
"Ground water supplies sufficient water for regional domestic
use (7,500 gallons per day (gpd) from wells situated on
alluvium and along drainage lines (Hall and Pcamquist, I960;
Palmquist and Hall, I960; Brown and Lambert, 1963; Gallaher
and Price, 1966). Upland wells and wells situated away from
drainage lines usually fail to yield a usable quantity of
water."
Water Quality. Seciton 2, page 2-27
"Most of the service area is underlain by limestone and
shale that yield from 0.1 to 10 gallons per minute (gpm)
from drilled wells. Wells penetrating the sand and gravel
aquifer along the Ohio River flood plain yield from 200
to 1,500 gpm."
Bedford Water District pumps an average of 316,800
gallons per day from the Wises Landing Aquifer, Henry
County Water District pumps 864*000 per day which together
equal 1,180,800 gallons per day for these two water districts.
37 The authors of the EPA Study combined the Bedford and
Milton water service and came up with the sum total of 450
people. In reality the Bedford Water District as of July 14,
1978, had 540 customers using an average of three people per
^^™"""™""^™™*"™"^™^~ »
household this comes to 1,620 people plus 50 customers in
West Carroll, based on the monthly consumption of 200,000-
COMMENT DOCUMENT - DD, CONTINUED
5-267
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12
310,000 gallons per month (using an average of three
persons per household) equals 1,770 people. This does
not include the Henry County Water District or the people
pumping directly from the aquifer (private wells).
Henry County serves 1,800 to 2,000 customers and
has 2,100 additional inactive meters. Henry County Water
•
District serves Henry, Trimble, Oldham and West Carroll
Counties and within these areas serves the cities of
Campbellaburg, New Castle, and 5096 of Eminence.
38 Bedford and Henry County Water Districts flouridate
and chloridate their water but do not soften it a* the
authors of EPA have stated. Other than bi-weekly samples
of water sent to Frankfort for bacteria counts, there will
be no other way to determine contamination of the water in
their systems. No testing equipment is installed on their
lines.
39 As f°r privately owned water systems, the authors
inventoried 22 drilled wells, if dug wells, 35 cisterns,
and 2 springs. Of the 26 wells the EPA only tested eight (8).
The EPA authors have noted a predominance of drilled
wells on flood plain from Barebone Creek to Corn Creek as
opposed to cisterns, etc. They also noted that only the
Minicipal Wells and one privately owned well have screens
below the casing. There are lenses, according to EPA,
of coarse sand and gravel in the lower part, give an average
of 100 to 500 gallons per day.
Authors note that the water is relatively hard and that
one privately owned well and the municipal wells have water
softeners "A few residents stated a dependence on
well water for livestock which (Pleasant View, Opekasit
Farm) is a dairy farm".
COMMENT DOCUMENT - DD, CONTINUED
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13
Trimble County has seven (7) Louisville Gas and
Electric customers and 540 water customers. Henry County
has 46 LG&E customers 1,800 to 2,000 water customers and
this number is growing all the time as people move into the
county from Jefferson and Oldham to get away from growing
urbanization.
West Carroll County has 0 Louisville t3as and Electric
Customers and 50 plus water customers.
WATER'USE. Ground Water 2.3.4
"Though the most predominant water source in the service
area is from surface water, significant quantities of ground
water are being withdrawn from counties bordering on the
Ohio River. Greatest use Is in Jefferson County, particularly
for the city of Louisville. Individual industries in the
county withdrew 2k.2 million gallons per day (mgd) from
sand and gravel aquifers in 1968" ... In two other counties,
Meade and Oldham, nearly all water supplies are derived from
ground water aquifers; in Hardin County, about 75 percent
of the water used Is ground water."
The reason why individual industries are beginning to
buy water from the Louisville Water Company is because the
aquifer in the louisville area is contaminated by both
sewage and industrial wastes. Plans are now in the making
to draw water from the Louisville Aquifer to use in cooling
buildings thus reducing their consumption of electrical
power. It is sad that the Louisville Aquifer's potential
has been reduced to this state.
It might be further noted that the urbanization that
covers the surface of the Louisville Aquifer has created a
situation in which water within the Aquifer is becoming
trapped and reduced pumping rates for industrial use has
allowed the water table underneath Louisville to rise in
hydrostatic pressure around foundations and is becoming
an increasing danger.
COMMENT DOCUMENT - DD, CONTINUED
5-269
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40 If the Wises Landing Aquifer becomes contaminated and
the local water districts discontinue pumping operations,
LG&E could experience an abrupt rise in the water table
that could have disasterous effects upon their foundations
and over the entire Bottom.
41 During the 1937 Flood, Merle Wayne Jackson observed at the site
a phenomenon known as a surge or blowout well above the
flooded area. A blowout occurs when the water in a river
channel rises faster than the water table in adjacent
aquifers.
The probability of this occurring beneath the raw sludge
storage ponds is greater than the surrounding area because of
the induced hydrostatic pressure caused by the ponds themselves.
During the winter of 1977-78, Paul Venard who has a farm
Just upriver from the site, observed a similar phenomenon in
his fields. As the water in the Ohio River was rising, the
water in the Aquifer rose and air was pushed out giving the
ground a frothy appearance.
Water Use, Ohio River 5.3.3, page 5-150
"There are no known Ohio River water users within the
immediate vicinity of the site, other than the proposed
Marble Hill Nuclear Plant (River Mile 570). The nearest
water user below the site is 10 miles downstream."
42 The EPA Authors neglected to mention that the Ohio
Uiver rechar^ec the Aquifer.
page 5-153
"The Laurel Dolomite is the predominant aquifer unit and
may produce greater than 100 gallons per day, although most
residents contacted reported adequate ^to less than adequate
production from their wells."
"Both domestic and livestock needs are served by this veil.
Springs were found emanating from the hillsides at various
noints along the upland at the contact between the limestone
e iiTrii-ff Two domestic supplies were dependent on
which were flowing from ^Co 1 gallons ?er minute."
COMMENT DOCUMENT - DD, CONTINUED
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15
43 This is one of the formations against which the sludge
will be resting and since Calcium Sulfate CaSO^ is
water soluable, (Hurlbut, C. Jr., 1971, Whitten, D.G.A.
and Brooks, J.R.V., 1972, Loomis, F.B., 1948, and Smith,
Orsino C., A.B.A.M.,1953) which is the main constituent
along with many heavy metal ions such as lead, mercury,
•
•
uranium, cobalt, arsenic, iron. Not only is the Wises
Landing Aquifer in danger, but all the bedrock in the
ravines.
Water Quality. Ground Water 2.3.3, page 2-28
"Because the bedrock aquifers are relatively impermeable,
the saline connate water (water trapped in rock since its
deposition) has not been hydrodynamically flushed by
meteoric water (precipitation) -to a significant depth."
44 How can a bedrock aquifer be "relatively impermeable"
when by definition impermeable is a direct opposite of
permeable which is defined as "a rock is said to be
permeable- if water or other liquid in contact with its upper
surface tends to pass through the rock more or less freely
to the lower surface. Permeability may be achieved by the
rock being either porous or pervious. The essential feature
of a bed of permeable rock is that the liquid it contains
may be extracted by pumping." (Whitten, D.G.A., 1972)
45 Perhaps the authors of this statement meant to say that
shale breaks within the bedrock impair the transmission
of water vertically (not horizontally) within an aquifer and
thus trap connate water. The statement also implies that
lateral water transmission does not occur when it does and
thus sludge stored in a valley would contaminate even these
beds that have n been flushed by surface water.
COMMENT DOCUMENT • DD, CONTINUED
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16
Water Quality. Ground Water 2.3.3, page 2-28, paragraph 3
"Water produced by deeper wells is usually brachish and
becomes saltier with Increasing depth. Sulfur water is
sometimes encountered In wells and springs. Bullitt's
Salt Lick near the Salt River has been a notable salt
supply since pioneer days."
46 Why have the authors continuously referred to
Bullitt's Salt Lick in this statement when* wells within
the site area produce brine, sulfur water (water containing
dissolved hydrogen sulfide) and water with large quantities
of iron ions in suspension. (Hall, F.R., and Palmquist,
W.N.Jr., I960)
Are the authors trying to draw the reader away from
conditions in the site area by- giving rather distant
examples of adverse hydrological features of the site area?
Surface Water, section 2, page 31» paragraph 1
"The fresh-salt water interface lies approximately at
elevation 400 feet (mean sea level) along the Ohio River, and
at 700 or 800 feet in the upland reaches. Numerous
springs in Meade and Hardin Counties have low to medium
chlorine concentrations of 3 to 100 parts per million..."
47 Again, the authors give distant examples of hydrological
conditions rather than consulting published data from the
site area.
"It has been estimated that ground water contributes 15 to
30 per cent of annual stream flow in the Bluegrass Region..."
48 It then follows that if groundwater contributes
15-30 percent of annual stream flow, that water contained
within the bedrock of the area flows at a considerable rate
and that any contaminate ir. contact with this rock would be
rapidly spread.
COMMENT DOCUMENT - DD, CONTINUED
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17
Water Quality, Surface Water 2.3.2, page 2-27, paragraph k
"Surface runoff is rapid due mainly to impermeable strata
(limestones, shales, and siltstones.)"
49 This statement implies that all limestones are
impermeable which is a false statement. While shales are
generally impermeable, some are not thick enough to prevent
the recharge of underlying strata, example - the thin layer
of Waldron Shale inferred to be in the site area. It also
implies that silt stones are impermeable. While some are,
most are not, but rather are quite good aquifers.
Surface Water 2.3.2, page 2-27, paragraph k
"In. summer, many of the smaller streams become intermittent,
while the larger streams tend to pool or to maintain a low
flor."
50 While it is true that most small streams in the area do
not show water flowing year round, this does not take into
account the water flow which occurs and the alluvial that fills
the streams channels. It is a common practice in times of
drought to dig holes in stream bottoms to obtain the water
flowing beneath.
Surface Water 2.3.2, page 2-27, paragraph 5
"This indicates that flash-flood conditions can be expected
on the smaller tributaries".
The Water 2.3» page 23, paragraph 2
"The major plant structures must be protected to ensure normal
plant operation during severe floods".
See Chart III.
COMMENT DOCUMENT - DD, CONTINUED
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18
Stages 5-112
"The maximum high water level for the reach of the Ohio
River adjacent to the Trimble County site occurred during
the 1937 flood. At River mile 572, this level was 470.0'"
"The river stage corresponding to the 100-year flood peak
is 461 feet, and the stage corresponding to the Standard
Project Flood is 482«."
51 Refer to Chart IV, flood-prone area.6 in the New
Bethlehem Quadrangle. When such floods occur, they will
include the area of the proposed emergency storage ponds
and will cause extreme hydrostatic pressure to be exerted
over the remaining flood plain area.
Hydrplogic Characteristics Corn and Barebone Creeks
page 5-116
"Prior to 1950, the lower portion of Corn Creek was
channalized, leaving a half-mile-long cutoff oxbow whose
water level rises and falls with that of the Ohio River at
the northern end of the plant site."
52 The rising and falling of the water in the oxbow cutoff
is another illustration of the interaction between the water
table and. the aquifer and the rising and falling of the
Ohio River.
53 In the following quoted EPA statements are other illustra-
tions of taking data from distant areas and applying it to
geological events that occur in Wises Bottom instead of
collecting data in situ. Why in four years was the EPA
unable to construct a V-gauge in the following creeks and
obtain on site data? Instead they have estimated average
and peak flows for Barebone and Corn Creeks from published
data of Harrod's Creek, Pond Creek and Baregrass Creek, all
of which completely differ geologically from each other and
Corn and Barebone Creeks.
COMMENT DOCUMENT - DD, CONTINUED
5-274
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19
5-116
"No historical data are available for average and peak flows
in Corn and Barebone Creeks. Staff gauges have been placed
at seven creek sampling stations, and discharge rates have
been recorded twice monthly during 1975. These data are
reported in Table 5.3.1-2."
"Estimated values for average and peak flows in Corn and Barebone
Creeks may be determined from the characteristics of other
streams in northern Kentucky for which data are available.
Corn Creek is similar to Harrods Creek in topography, geographic
location, and soil cover, but is larger and has a drainage
pattern similar to Pond Creek. On this basis, an average
yield of 1.5 cfs per square mile has been estimated, resulting
in a mean annual flow of 51 cfs. Barebone Creek exhibits
characteristica similar to Harrods Creek, and the flow rat* is
estimated at 1.65 cfs per square mile, resulting in an average
flow of 23 cfs."
"Estimates of peak discharge were made by using the annual
peak discharge of Bear Grass and Pond Creeks for their
periods of record and developing frequency curves by total
drainage area using the Regional Analysis Method (U.S. Dept.
of Agriculture,n.d.). This results in a 2-year peak of
1,400 cfs and a 10-year peak of 2,400 cfs for Corn Creek.
For Barebone Creek, the estimated 2-year peak discharge is
1,100 cfs and the 10-year is 2,200 cfs."
54 The EPA states that sloping hillsides have a moderate
slow permeability and a high run-off of surface water. The
water on.a hillside is effected by gravity and naturally
would not have time to soak in thus changing the permeability
values.
page 5-124» paragraph 3
"Moat of the site consists of silty and loamy alluvial
soils, much of thia in cultivation, with moderate to slow
permeability. The remainder of the site is wooded,
steeply sloping hillside with moderately slow permeability
and a high runoff potential."
Hydrologies Characteristics. Surface Waters; Ravines RA and RB
page 5-124
"Two tributary streams drain Ravines RA' and RB into Corn Creek.
These streams tend toward a low-flow or an intermittent
condition. North Creek (RA), which is about 3,3 feet wide
and 0.6 to 1.3 feet deep, appears to form relatively small,
shallow pools in dry weather. South Creek (RB) is 3.3 to
6.61 wide and averages 1.7' in depth. It appears to have a
more constant flow, but it also probably tends to form long,
shallow pool areas in dry periods. The South Creek flow seems
to be augmented by seepage from exposed water-bearing strata
along the faces of the ravine. Both of the ravines present a
fairly steep gradient (1671 and 170' per mile), as evidenced
COMMENT DOCUMENT - DD, CONTINUED
5-275
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20
by the cuts incised into the bluff rising above the upper river
terrace (about Jf50 to 490' above MSL). Due to this gradient
and the rock strata, the stream bed is composed of gravel and
rubble from the ravine faces."
55 The EPA failed to consider the below ground flow of
water in ravines RA and RB which occurs during normal flow
and during droughts. They do indicate that the channel
of the ravines is composed of gravel and rubble from their
valley walls and not an indigenous clay. They also admit
the presence of seepage from the valley walls of the ravines.
Water Quality. Ohio River 5.3.2, page 5-133
"Apparently no studies have been made of the water quality
of the Ohio River in the immediate vicinity of the Trimble
County Generating Plant site. Studies of the water quality
of the Ohio River have been performed upstream and downstream
of the plant site and provide general information of the physical
and chemical parameters of the .region."
56 The use of the word "apparently" indicates that EPA
is not sure whether studies have been made of the water
quality. Why couldn"t EPA refer to the records available
from both Henry and Bedford Water County Districts?
Surface Water, page 2-31, paragraph 4
"High coliform counts tend to occur during periods of low
flow in the river. Late spring and summer tend to foster
these high counts. Other enteric bacteria also have been
encountered - Salmonella. Shigella. and Klebsiella. Thus,
raw Ohio River water must be disinfected before any
industrial or domestic use."
57 Thus if the aquifer is contaminated by heavy metal ions,
local farmers, The Bedford Water District, The Henry County
Water District, will have to find an alternate source of water.
These water districts serve from 3»570 to 3,770 plus people.
COMMENT DOCUMENT - DD, CONTINUED
5-276
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21
58 These water districts are funded by FHA and do not
have the resources to build a treatment facility capable
of taking raw Ohio River water and processing it for domestic
use. Even if they could, and funds were available, there are
no filtering systems within economic reason to produce water
of the quality that is taken from the Wises. Landing Aquifer
now. It might be noted here that the Wises Landing Aquifer
is a natural resource of tremendous economic potential and
EPA has a moral obligation to our future generations to
preserve this source of high quality water for future
generations. ' ">*'-
Water suitable for domestic^ purposes is rapidly becoming
a diminished resource.
Surface Water, page 2-32, paragraph 1
^'Second, depending on the quantity and dissolved-solids
concentration of discharged waters, it appears that meeting
the dissolved-solids-concentration criteria in the Ohio,
Kentucky* and Green Rivers will be no problem. However,
because of the extreme low-flow conditions in smaller
tributaries, total plant discharges probably cannot be accepted
in the smaller tributaries."
59 Taking this statement to fact why is LG&E going to
construct an emergency storage pond for sludge in the recut •
channel of Corn Creek??
page 5-134, paragraph 2
*More than 1,600 industries and 130 sewage treatment plants
are discharging organic compounds, heavy metals, high BOO
wastes, and fecal organisms into the main stream and
tributaries of the Ohio River".
60 In the next 50 years (Iff-years construction, 36-year
•
operating life) of the proposed LG&E plant more and more
COMMENT DOCUMENT • DD, CONTINUED
5-277
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22
allowances will be made to Utilities and industry until
the Ohio River water will become unfit as a source of
water. Then the importance of pure waters produced in
aquifers will geometrically increase until they are the
most important natural resource that Kentucky will possess.
"Water is vital to our lives. We must make every effort
to conserve it, protect it from pollution,' and use it
wisely, if our civilization and way of life are to
continue". Wallace W. Hagan
Director and State Geologist
Kentucky Geological Survey
page 5-139, paragraph 8
"Chemical analyses of ttTe'-s-tream sediments... show increases
in potassium levels that probably reflect agricultural
activity in the area. Potentially toxic metals such as
chromium, copper, lead, and manganese are not present in
quantities that might be harmful or dangerous".
(51 While these toxic metals are not present in quantities
that are hazardous at this time, the addition of more
heavy metal ions will surely contaminate the water of the
aquifer.
Ground Water of the Plant Site and Ravines, page 5-
"Ground water produced from the sand and gravel aquifer
underlying the Ohio River flood plain is generally of the
calcium-magnesium bicarbonate type. The water is classified
as very hard and may contain iron in objectionable concentratione,
The concentration of eulfate is usually significant, ranging
from about 20 to 70 mg/1."
62 Water in the aquifer already has a heavy concentration
of sulfates and the additional sulfates that will be
•produced by the leaching of the sludge will bring this
sulfate concentration to a hazardous level.
COMMENT DOCUMENT - DD, CONTINUED
5-278
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23
Ground Water of the Plant Site and Ravines, page 5-Uf2,
paragraph c.
"Ground water produced from the bedrock aquifer is usually
of relatively poor quality, particularly from wells
drilled deeper than 100 feet. Shallow wells that are
fed primarily from weathered cracks in the upper bedrock
surface produce water that is hard but of good chemical
quality. Deeper wells that draw from permeable zones within
the bedrock formations often produce water
that contains sodium chloride or hydrogen sulfide in
noticeable concentrations. Deep bedrock aquifers become
more saline with increasing depth and eventually contain
unpalatable brine."
EPA notes that the upper bedrock has weathered cracks
or solution channels and these were also noted at the Marble
Hill excavation. Some of these are quite large and could be
considered small caves,- -generally these are found in the
Laurel Dolostone. EPA also notes that deeper wells in the
area produce water unfit for domestic use and could not be
used for alternate sources of water (Bedford and Henry
County Water Districts) should their present supply from
the Wises Landing Aquifer be contaminated.
Ground Water of the Plant Site and Ravines page 5-1^2,
paragraph 5
"These analyses included determinations for heavy metals
and toxic substances that are known to be present in some
power plant ashes. All seven of the ground water samples
analyzed showed that toxic elements (including arsenic,
barium, boron, cadmium, chromium, lead, mercury, selenium,
silver, and flouride) are not present in detectable
concentrations." PH 7.6 to 7.7. Dames and Moore,
March 2Zf-26, 1976."
64 Taking EPA at word; how did Dames and Moore detect
these ions in the Paul Venard water sample analysis?
This water sample did indeed show a detectable concentration
of these raetalic ions and additional ions from power plant
ashes(processed or unprocessed) will render the aquifer
water undrinkable for man and livestock.
COMMENT DOCUMENT - DD> CONTINUED
5-279
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24
Solid Waste Disposal System page 27, paragraph 1
"Operation of the proposed Trimble County Generating Plant
will result in the production of two kinds of solid waste;
a sludge-type waste from the wet limestone sulfur dioxide
removal system and ash from coal combustion."
paragraph 3
"Two kinds of ash result when the coal is burned: "bottom"
ash and "fly" ash."
page 32, paragraph 2
"A total of approximately 7,200 acre-feet of bottom ash will
be produced during the 36-year life of the plant (approximately
2^0 acre-feet per year). A total of approximately 15^,200
acre-feet of unprocessed fly ash and scrubber sludge will
be produced during the same period".
65 All of these wastes contain contaminates harmful if
not hazardous to the aquifer and all the life the aquifer
in turn supports. The great"~quantities produced will make
the management of the waste disposal areas in connection with
local hydrology and proposed containment facilities an
insurmountable task and a hazard to all the people who use
the Wises Landing Aquifer.
page 32, paragraph k
"Scrubber sludge and ash contain chemical compounds that are
potentially harmful to the environment. The traditional
method of disposal for ash is a pond lined with clay or
other impervious material to prevent leakage or seepage."
"The Applicant evaluated basically two kinds of disposal
scheme alternatives for the solid wastes to be produced by
the Trimble County Generating Plant: an onsite disposal
pond for the bottom ash and an onsite landifll type of
disposal for the scrubber sludge and fly ash."
66 The EPA admits that scrubber sludge is potentially
harmful to the environment. They further state that these
disposal areas should be lined with clay.or an impervious
material NOT local silty clays which allow the passage of
•
water from the surface to the aquifer, nor the colluvialium
COMMENT DOCUMENT - DD, CONTINUED
5-280
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25
that contains numerous fall down blocks, -gopher holes,
and other animal dens not to mention old pits and trenches
from previous human habitation.
page 33, paragraph 1
"In other words, both kinds of pollution control methods--
pollutant removal and zero discharge—resulted in much
larger storage area requirements than were previously
required for power plant operation".
paragraph 2
"In addition, the Applicant would have to increase the size
of the ash disposal pond to hold plant process wastewater
(approximately 340 gallons per minute, maximum peak flow)
and a yearly average rainfall of approximately 550 gallons
per minute. In order to provide the plant process systems
with adequate water, approximately l,2Jfl gallons per minute
of Ohio River water (maximum peak operating conditions)
would have to be added to^tlre pond".
67 It would seem that common sense would predict that
zero discharge of contaminates would be impossible under
the present estimations and as EPA and LG&E have stated
..time and time again that this type of waste disposal is in
the experimental stage with no guarantees except that they
will try something else. But by the time they discover their
error it will be too late. The old axiom that technology
can solve any problem and will conquer nature is false.
The enclosed article (Toward Safe Scrubber-Sludge Disposal,
Powerr July 1978) emphasizes the need of awareness of
geological and hydrological factors that govern the suitability
of sites for the ultimate disposal of sludge.
COMMENT DOCUMENT - DD, CONTINUED
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26
FAUNA OF THE AREA
page ZfO, paragraph 2
"no rare or endangered plant or wildlife species were
found on the site. However, the Corn Creek/oxbos area of
the site, in combination with the agricultural fields,
provides a highly productive habitat for an abundant wild-
life population. The site is also apparently heavily used
by migratory waterfowl in the spring when the low-lying
agricultural fields are flooded."
68 I have forthcoming affidavits on sightings of these
following rare or endangered species:
Blue Heron
Osprey
Golden Eagles
and the other 127 species TJlHDirds sighted by EPA and all
the other woodland creatures that call Wises Bottom home.
SENSITIVE AREAS
The authors stated in relation to the oxbow area of
Corn Creek that the quality of this area "habitat" is worthy
of special attention. They support this by the variety of
micro environments of the area i.e., "The combination of
agricultural, bottomland woods, streams, and upland wood
vegetation." thus large numbers of species of wildlife are
attracted to the area.
page if 7, paragraph 3
"These species would not be able to find as varied or
productive an area elsewhere within the project area (i.e.,
within a 25-mile radius of the site)."
69 While the Applicant LG&E has agreed not to destroy a small
area that migratory birds use as a stopover, the authors have
not considered the effect of the destruction of the surrounding
area and its effect upon this small island of "tranquil!ty"
in a sea of disaster.
COMMENT DOCUMENT - DD, CONTINUED
S-7R?
-------
27
Significant Aquatic Habitats 2.3.7, page 2-33
"There are few aquatic habitats within the Applicants
service area that could be construed as "significant".
There are no high quality fishing streams in the regional
service area".
70 According to the chart on section 1, page 1, Louisville
Qas and Electric services the counties of Jefferson, Oldham,
•
Bullitt, Maade, Hardin, Henry, Trimble, Shelby, Spencer.
I cannot believe that the EPA can make such a broad judgment
without any supporting evidence.
page 40, paragraph 5
"An archaeological and historical/architectural survey of
the proposed Trimble County, site was conducted in several
phases between April l9?5~an
-------
28
SENSITIVE AREAS page k7', paragraph
"The Mahoney property to the north of the plant site is
believed to contain a unique archaeological site. While
this site has not been formally investigated, Wilson and
Janzen (who conducted the Phase I archaeological/historical
investigation of the proposed site), inspected the site
and called it "spectacular". Personnel from the University
of Louisville Archaeological Survey also discovered n
in situ in the highwall along the Mahoney property;
they have classified this site as Early Archaic. This site
will not be impacted by the project".
72 If Janzen can find a spectacular site in the area,
others are probably present as the area provides not only
a unique environment for woodland creatures, but would also
provide a healthy habitat to aboriginal tribes.
73 Paul Venard has a magnificent collection from Wises
Bottom including several rare and spectacular pieces. The
Louisville Archaeological Team did not even contact nor
investigate this local collector.
74 „ The EPA on pages 58 and 6if, Section Two, gave a list
of "places within the Applicant's service area that have been
entered in tne National Register of Historical Places, as well
as archaeological sites on file with the State Archaeologist".
My own records of sites in the area were recorded by the
Jefferson County Archaeological Survey during the COG Studies.
I know that these sites coupled with sites surveyed by the
Jefferson County Archaeological Survey (most have been
published and are available at University Libraries throughout
the state) make the EPA list seems to be a mere token.
COMMENT DOCUMENT • DD, CONTINUED
5-284
-------
CONCLUSION
75 The EPA failed to make a thorough study of the hydrology
of the site area. Therefore the EPA drew the wrong
conclusions about the potential hazard of contaminating the
Wises Landing Aquifer. They failed to note that even though
some of the formations in the area do not produce great
quantities of water to wells, they do provide the numerous
streams and seeps along the bluffs and ravines with water and
these do recharge the Wises Landing Aquifer.
76 Any sludge containing mixtures of heavy metal ions and
a matrix of water soluable calcium sulfate brought into contact
with any of the aquifefs^irlll eventually leach and flow
laterally, then vertically, into the Wises Landing Aquifer,
77 Once the contaminates are in the bedrock or the sand
and gravel deposits, it is already too late. So any monitoring
wells would inform LQ&E that they had ALREADY contaminated the
aquifer and should not be considered by EPA to be any protection
to the thousands of people in (four) counties that depend
upon this aquifer.
78 The attached article published in "Power1,1 July 1978, is
distributed to all people involved in the Utility Industry*
The article exemplifies the major problems encountered when
sludge is stored upon aquifers.
79 The storing of sludge in the ravines RA and RB is totally
unsound as there are NO impervious clay deposits lining these
valley walls, only some weathered shale,^thin forest soil, and
lots of fall down block from the formations above* There
COMMENT DOCUMENT • DD, CONTINUED
5-285
-------
Conclusion, continued
are numerous seeps and springs and lots of animal dens
that go all the way back to the bedrock.
In my area of specialization, I have found many errors
and saw many other mistakes in other fields throughout the
text. I have noted a few of these where 7 have the
professional background to back up my corrections. However
in the future the EPA should hire comuetant and unbiased
surveyors to do this type of work.
Charles Edward Oldham
July 17, 1978
COMMENT DOCUMENT - DD, CONTINUED
5-286
-------
BIBLIOGRAPHY
U.S. Environmental Protection Agency, ENVIRONMENTAL
IMPACT STATEMENT, TRIMBLE COUNTY GENERATING STATION,
January 23, 1978
U.S. Environmental Protection Agency, ENVIRONMENTAL
IMPACT STATEMENT, TRIMBLE COUNTY GENERATING STATION,
Supporting Report. V.I.
The Department of the Army Corps of Engineers, Louisville
District, FLOOD PLAIN INFORMATION, OHIO RIVER TRIMBLE
COUNTY, KENTUCKY; June, 1976.
McFarlan, Arthur C., GEOLOGY OF KENTUCKY, University of
Kentucky, 1950.
Samuel, Rayj Huber, Leonard; Ogden, Warren G., TALES OF
THE MISSISSIPPI, New ...York, Hastings House, 1955.
"""-"•«'..,
Hurlbut, Cornelius S., DANA'S MANUAL OF MINERALOGY,
Eighteenth Edition, New York, John Wiles and Sons, 1971.
Loomis, Frederic Brewster, FIELD BOOK OF COMMON ROCKS AND
MINERALS, New York, Putnam's Sons, 1948.
Whitten, D.G.A., Brooks, J.R.V., THE PENGUIN DICTIONARY OF
GEOLOGY, Great Britain, 1972.
Smith, OG., IDENTIFICATION AND QUALITATIVE CHEMICAL
ANALYSIS OF MINERALS, New York, Van Nostrand, 1953.
Peterson. W.L. GEOLOGIC QUADRANGLE MAPS OF THE US, LA
GRANGE QUADRANGLE, OLDHAM COUNTY, KENTUCKY, Washington, D.C.,
19.71.
Swadley, W.C., GEOLOGIC QUADRANGLE MAPS OF THE U.S.,
BETHLEHEM QUADRANGLE, TRIMBLE AND OLDHAM COUNTIES, KY,
Reston, Virginia, 1977.
Wayne, William J., ICE AND LAND, A REVIEW OF THE TERIIARY AND
PLEISTOCENE HISTORY OF INDIANA, Indiana Academy of Science,
Indianapolis, 1966.
Hagan, Wallace W., ORIGIN OF THE JEPTHA KNOB STRUCTURE, KY.
ed. by C. Ronald Seeger, University of Kentucky, 1968.
McFarlan, Arthur C., BEHIND THE SCENERY- IN KENTUCKY,
University of Kentucky, Leslngton, 1958.
Thornbury, William D., GLACIAL SLUICEWAYS AND LACUSTRINE
PLAINS OF SOUTHERN INDIANA, Bloomington, Indiana, 1950.
COMMENT DOCUMENT - DD, CONTINUED
5-287
-------
Bibliography, Continued
Wayne, William J., PLEISTOCENE FORMATIONS IN INDIANA,
Bloomington, Indiana, 1963.
Jilleon, Willard Rouse, GEOLOGY OF A FAULTED AREA SOUTH
OF JEPTHA KNOB; Frankfort, Kentucky, 1962.
McCabe, John A., FLOODS IN KENTUCKY-MAGNITUDE AND FREQUENCY,
University of Kentucky, Lexington, 1962.
Geological Society of Kentucky Spring Field Conference,
LATE CENOZOIC GEOLOGIC FEATURES OF THE MIDDLE OHIO RIVER
VALLEY, Kentucky Geological Survey, Lexingon, 1974.
U.S. Dept. of Agriculture, KENTUCKY LAND USE SUITABILITY MAP,
Lexington.
Bolger, Robert C., GROUND WATER, Commonwealth of Pennsylvania,
1965.
U.S. Geological Survey, HYDROLOGIC UNIT MAP-1974, STATE OF
KENTUCKY, Reston, VA,_ 1974.
Peterson. W.L., Wigley, GEOLOGIC QUADRANGLE MAPS OF THE U.S.,
OWEN QUADRANGLE, OLDHAM COUNTY, KENTUCKY,
Price, William E., Jr., GEOLOGY AND HYDROLOGY OF ALLUVIAL
DEPOSITS ALONG THE OHIO RIVER BETWEEN ETHRIDGE AND THE
TWELVEMILE ISLAND, KENTUCKY, U.S. Geological Survey, 1964.
Whitesides, D.V. and Ryder, Paul D., EFFECTS OF PUMPING FROM
THE OHIO RIVER VALLEY ALLUVIUM BETWEEN CARROLLTON AND GHENT,
KENTUCKY, University of Kentucky, Lexington, 1969.
Krieger, R.A., Bushman, R.V., Thomas, N.O., WATER IN
KENTUCKY, University of Kentucky, Lexington, 1969.
Mull, D.S., CttShman, R.V., Lambert, T., PUBLIC AND INDUSTRIAL
WATER SUPPLIES OF KENTUCKY, 1968-1969., University of
Kentucky, Lexington, 1971.
Freeman, Louise B.. REGIONAL SUBSURFACE STRATIGRAPHY OF THE
CAMBRIAN AND ORDOVICIAN IN KENTUCKY AND VICINITY, Frankfort,
I960.
Gray, Henry H., GLACIAL LAKE DEPOSITS IN SOUTHERN INDIANA^
ENGINEERING PROBLEMS AND LAND U3E, Bloomington, 1971.
Willman. H.B., GEOLOGY ALONG THE ILLINOIS WATERWAY-A BASIS
FOR ENVIRONMENTAL PLANNING, Illinois State Geological Survey,
Urbana, 1973.
McGregor, Duncan J. GYPSUM AND ANHYDR-ITE DEPOSITS IN
SOUTHWESTERN INDIANA, Indiana Department of Conservation, 1954,
COMMENT DOCUMENT - DD, CONTINUED
5-288
-------
Bibliography, continued
Bell, Edwin A., SUMMARY OF HYDROLOGIC CONDITIONS OF THE
LOUISVILLE AREA KENTUCKY, Us. Government Printing Office,
1966.
Flint, R.F., GLACIAL AND QUATERNARY GEOLOGY, Wiley, 1971.
Gallaher, John T., HYDROLOGY OF THE ALLUVIAL DEPOSITS IN
THE OHIO RIVER VALLEY IN KENTUCKY, Washington, 1966.
Palmquist, W.N.. Hall. F.R., AVAILABILITY OF GROUND WATER
IN CARROLL, GALLATIN, HENRY, OWEN, AND TRIMBLE COUNTIES,
KENTUCKY, U.S. Geological Survey, Washington, I960.
Qauri, K. L., STRUCTURALLY DEFBRMED LATE ORDOVICIAN TO
EARLY SILBRIAN STRATA IN NORTH-CENTRAL KENTUCKY AND SOUTHEAST-
ERN INDIANA, Geological Society of America Bulletin. V.80,
1969. •
Livesay, A., GEOLOGY OF THE MAMMOTH CAVE NATIONAL PARK AREA,
University of Kentucky, 1962.
Krumbein, W.C. and Sloa'a^XL., STRATIGRAPHY AND SEDIMENTATION, •
Freeman, San Francisco , 1963*
Billings, Marland P. STRUCTURAL GEOLOGY, third edition,
Prentice Hall, 1972.
U.S. Geological Survey, MAP OF FLOOD PRONE AREAS
U.S. Geological Survey, MAP OB BETHLEHEM QUADRANGLE
COMMENT DOCUMENT - DD. CONTINUED
5-289
-------
t
65O5 LonQview Lane-Louisville. Kentucky -4O2O7
Phone 5O2 893 762O
Art • Deeign • Photography
COMMENT DOCUMENT - DD, CONTINUED
5-290
-------
During the late winter flood of 1978 the
Ohio River was rising rapidly, the ground was
saturated with days of rain. On Inspecting
. •
flooding conditions, I first heard bubbling
noises close, far away, all around.
Then I realized It was the ground. Air
was being forced quickly to the surface even
through the rock and^grc&vel road. This told me
three things;
1. The aquifer was really moving
2. The ground was very porous
3. A large percent of surface water has
to go directly Into the aquifer.
t. Paul VeSarcT
July 17, 1978
PV/pr
STATE OF KENTUCKY COMMENT DOCUMENT - DD, CONTINUED
COUNTY OF TRIMBLE
Subscribed and suorn to before me by L. Paul Uenard,
this July 17, 1978.
My Commission expires August 27^1981.
o
.yr
5-291
-------
O
September 22,* 1976
Dear Mr. & Mrs. Venard:
The following are the results of the water quality analysis which
was run on a sample taken from the well at your house on March 26, 1976.
The sample taken from the hand-pumped well at the house up-river was not
tested. A list of the upper llial-t-^f^each chemical parameter as set by the
U.S. Public Health Service Standards is also included for comparative
purposes.
(PARTS PER MILLION) UPPER LIMIT, PPM.
CHEMICAL PARAMETER
Arsenic
Barium
Boron
^Cadmium
Calcium
Chromium, Total
Iron, Soluble.
Lead
Magnesium
Manganese
Mercury
Selenium
Silver
Sodium
Alkalinity (CaCOj)
Chloride
Fluoride
Total Hardner. ;
YOUR WELL
< 0.001
/ 0
< 0
99
<0
• 0
<0
25
0
< 0
< 0
'0
6
272
9
< 0
.20
01
2
02
02
05
7
02
0005
005
05
9
0
0
4
NUr.-iH-
pH
Sulfote
Total Dissolved Solids
354.0
7 . h
34.0
358
POTABLE WATER STANDARDS
0.05
1.0
1.0
0.01
200
0.05
0.03
0.05
125
0.05
0.001
0.05
0.05
200
1000
250
1.5
1000
(7 is optimum)
250
1000 (500 is desirable)
* U.S. Public Health Service Standards, 19C2
COMMENT DOCUMENT • DD, CONTINUED
5-292
-------
17
'•> (. .
7i /-. t - 6 l^i- * v
' rf-1 < < . ,--» A' t
,. /.
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/
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-V.
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CV
COMMENT
DOCUMENT - DD, CONTINUED
5-293
-------
RESPONSE TO COMMENT DOCUMENT DD
Comment Number Response
1 The comments in these three pages from the Trimble County
Water District #1 have been noted and considered in
the final permit issuance determination. We would
like to note that we do not agree with the District's
accusation that the EIS is filled with "gross mis-
conceptions." We do admit that the document contained
some inaccuracies. Where these have been noted in
comments on the document, we have indicated our
errors. In no case do we acknowledge the use,
deliberate or otherwise, of "misused and misunderstood
conclusions based on fradulent 'facts.'"
2 The height of the hills is addressed in the DEIS; for
example: "The bluffs reach a maximum elevation of
over 800 feet, with relief of 350 to 400 feet,"
Section 5.2.1, Physiography and Topography, p. 5-35.
3 With the exception of sulfate concentrations, which
cannot be predicted with any existing modeling tech-
niques, the concentrations of other pollutants that
would be emitted by the proposed project have been
extensively studied, including the combined impact
of the Trimble County emissions with those of the
Clifty Creek power plant. EPA has concluded, on
the basis of the studies conducted, that air quality
standards would not be exceeded as a result of the
operation of the Trimble County plant.
4 This statement is true. However, EPA does not believe
that the proposed project would contribute to photo-
chemical oxidant concentrations in the area.
5 Ground water recharge that occurs in the upland area
as a result of internal drainage on the karst landscape
does flow toward the lowest free seepage face. In the
case of the Trimble County plant site, this would be
toward the river bluff and associated ravines. However,
the karst development is interrupted by shale beds which
occur within and below the limestone (or dolomite) strata.
The result of this phenomenon leads to the development
of "contact springs," which usually occur at the base
of karst limestone formations and at a fairly constant
elevation. Seepage will therefore occur as "contact
springs" along the side of bluffs or ravines, but not
necessarily at the base of bluffs. This seepage
feature is recognized (see Swadley, 1977), and no
material impact on the plant site is expected to be
associated with it.
5-294
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number Response
6 The sludge is proposed to be stablized and rendered
impermeable and nonleachable. Provided that this is
accomplished as planned, the stated scenario is
impossible.
7 This statement is taken out of context, and seems to
reflect a lack of understanding of the concept of
permeability in an engineering sense. No material
is totally impermeable, so the question becomes one
of degree. In a practical sense, a material is
virtually impermeable when its hydraulic conductivity
is less than 1 x 10"? cm/sec.
8 This statement is also out of context. Description of
"Fairmount Soils" refers to an agricultural association
and is not correlated with any specific geologic or engi-
neering category. The author also erroneously presumes
that the sludge will not be stabilized and will be free
to migrate. This is not true. The statement "these
soils are not impervious" belongs to the author, not to
Dames & Moore.
9-24 These descriptions were all taken from Swadley, 1977,
as a primary information source. They generally pertain
to the Kentucky portion of the Bethlehem 7-1/2 minute
quadrangle and not specifically in the plant site itself.
Following the descriptions taken from Swadley1s map are
comments made by the author which are generally careless
or totally erroneous.
Geologic descriptions contained in the DEIS were corre-
lated from adjacent mapped quadrangles because the
Bethlehem Quadrangle was not published or released as
an open file document at the time the material in the
DEIS was written.
9 Not true. The areal extent of loess is very restricted,
and it is not part of any aquifer in the area. No
structures will be built on loess, and it is not
highly erodible when proper construction practices
are used.
10 Possibly true, but the author's conclusion that there
is not enough is contradicted by drill exploration of
the site by the Applicant's geotechnical consultant,
ATEC.
5-295
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number Response
11 Comment noted. No response required.
12 Swadley (1977) shows glacial drift well above the 800-
foot level, in which case it cannnot come into contact
with sludge. If sludge is adequately stabilized, there
would be no deleterious impact in any case.
13-14 Comment noted. No response required.
15 The comment regarding aquifer properties is incorrect.
16-17 Comment noted. No response required.
18 The meaning of the last sentence of the paragraph is
unclear.
19 Description poorly summarized. "Lust content 50%": we
assume the author meant "limestone."
20-24 "Lust" repeated (comment 21). In general, these para-
graphs are crude summaries of the material in Swadley
(1977) concerning strata that are undergoing some facies
variation in the area. None of the material has any
significant bearing on potential power plant impacts.
25 The property purchased by LG&E, referred to in whole
as "the site," does in fact include a portion of the
bluff as discussed in Section 5.2.2 of the Supporting
Report, specifically the first paragraph of page 5-45.
This bluff portion of "the site" does include strata
of Middle Silurian age (refer to the figure on page 5-41)
The inference that "the site" includes only the "genera-
ting complex" was never stated or implied anywhere in
the DEIS.
26 This figure was taken directly from a USGS GQ map of a
quadrangle adjacent to Bethlehem. The Louisville lime-
stone, if it does exist, exists only as erosional
remnants. The thickness is properly designated as a
question mark. In this case, it does not imply maximum
stratigraphic thickness, but the observed thickness in
accordance with USGS practice.
5-296
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number Response
27 Formational names were not identified because field
mapping was incomplete at the time of the study.
Stratigraphic names are not of material consequence
to the impact analysis, although physical evidence
concerning the lower limit of karst development is.
Insufficient site-specific information was available
to apply formational names with a comfortable degree
of confidence.
28-29 None of the structural features named have any impact
on the Trimble County site since they are tectonically
inactive. The mere fact that they exist is of no
consequence to the project.
30 Comments and subsequent narrative are completely out
of context. The author is describing a MM Intensity XII
seismic event that occurred at a distant place, implying
that similar epicentral ground motions could also occur
at the Trimble County site. The author fails to state
that attenuation estimates by competent seismologists
produced estimates of MM Intensity V damage at the
plant site due to the 1911-1916 New Madrid event. For
a modern, well-designed structure, these values are of
minimal concern, since wind loads and other live load
considerations generally govern structural design.
31 Ice certainly is a mineral and is often regarded as
such where it exists in this form on a seasonally
permanent basis. Water is also regarded as a
(renewable) resource. However, water in its liquid
state is not regarded as a mineral resource. Like-
wise, water in its vapor state is not a mineral (where
do clouds fall on Mohs hardness scale?). Since both
surface and ground waters are discussed in the document
under separate categories, the subject has received
proper attention and the author's comment serves no
constructive purpose. It should also be noted that
ice does not boil at 212°F. Since the "triple point"
of water is 32°F, solid ice cannot exist above that
temperature.
32 Comment noted. No response required.
5-297
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number Response
33 It has not been demonstrated that "contaminates" [sic]
will be introduced into the Wises Landing aquifer. The
second quotation from the DEIS is being deliberately
misconstrued as applying the word "benefit" to "water
pollution." We do not at this time believe that the
public water supply drawn from wells in Wises Landing
would be contaminated by the proposed project, if the
solid waste is made stable, impermeable, and nonleachable
as proposed. Therefore, quantifiable impacts to land
and water would be confined to the site and its immediate
environs.
34 The author is again deliberately misreading the DEIS. As
defined on the first page of Section 2.0 of the Supporting
Report, within which Section 2.3 falls, the purpose of this
portion of the DEIS is to provide "a general environmental
description of the area chosen by the Applicant for siting
their proposed 2,340-MWe power plant. This area consists
of those counties to which the Applicant provides electric
service, either partially or wholly...." Site specific
information on ground and surface water is presented in
Section 5.0 of the DEIS Supporting Report.
35 Bedrock wells are considered as the primary water source
because bedrock aquifers underlie the vast majority of
the service area. The geographic areas where alluvial
aquifers are available are relatively small. No value
judgment relating to aquifer importance was either stated
or implied when read in the context of the report.
36 This comment is based on a simple confusion of units
(gpm and gpd), plus a lack of understanding of the text.
a. Regional domestic use of 7,500 gpd per well is
equivalent to 5.2 gpm per well. This reflects
ground water yields from individual wells located
on tributary alluvial drainage paths. No connec-
tion with any pumping activity at Wises Landing is
stated or implied.
b. Daily water pumpage at the Trimble County District #1
(incorrectly referenced as the Bedford Water District)
of 316,800 gpd is equivalent to 220 gpm. Henry
County pumps 864,000 gpd or 600 gpm. Both systems
yield water within the stated range of "200 to 1,500
gpm" for the sand and gravel aquifer along the Ohio
River.
5-298
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number
36 (continued)
37
38
Response
We would again like to note that material contained
in Section 2.0 is a general summary of regional condi-
tions and was not intended to be specific to the Wises
Landing site.
In an apparent attempt to exaggerate his point, the
author claims that the report indicated a "sum total
of 450 people" served by Bedford and Milton water service
combined. However, the report states that Bedford
and Milton serve "about 450 people each" (page 5-151,
third paragraph). This information was taken from
published records, D.S. Mull, et al., Public and Indus-
trial Water Supplies in Kentucky, 1968-1969, Kentucky
Geological Survey Circular 20, 1971. The DEIS was
written 3 years ago; the authors obviously did not
have access to records of service dated July 14, 1978.
Figures listed under "distribution" were taken as people
rather than customers since that is the implication
given in the text of the Mull, et al. report. It is
clear that both the authors and the Kentucky Geological
Survey stand to be corrected.
The author then states that Bedford Water District
pumps 200,000 to 310,000 gallons per month. In the
preceding paragraph, the author quotes an average pumping
rate of 316,800 gallons per day. We should like to
advise the author at this point, that a month is approxi-
mately 30 days in length, and that both of these units
are different by that factor. We concluded from this
analysis that the author has again confused his time
units. If, however, this is a typing error and both
units are the same, then we are surprised to note that his
average pumping rate is substantially higher than the
stated upper figure of the typical range.
An update of the data used in the DEIS is presented in
the following attachment.
During the water well inventory of the immediate site
area, Dames & Moore was told that Trimble County Water
District wells were equipped with a water softening
unit. If they were misinformed, then they stand to be
corrected. However, the DEIS Supporting Report does
not state that Henry County water was softened.
Regarding the last two sentences of this comment:
water can be tested at any point where it reaches
a tap, and at any time desired. No special effect
is needed (see following attachment).
5-299
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number
39
40
41
Response
42
43
44
45
46-47
Comment noted. No response required.
The pumping at Wises Landing has virtually no effect
on drawdown at the proposed plant site.
"Raw sludge storage ponds" - an inaccurate characteriza-
tion of the emergency sludge storage pond. This pond
will be lined with clay and will contain a permanent
head of water at least as great as the maximum flood
of record (1937 flood). Under these conditions, a
"blowout" is not possible.
The hydraulic connection between the Ohio River and
the aquifer is discussed on page 5-133 of the DEIS
Supporting Report.
Once again, the author fails to recognize that the
sludge is proposed to be stabilized. He also assumes
that trace elements will be totally soluble in their
landfill environment, which would be untrue if the
material is rendered impermeable and nonleachable
as proposed. Furthermore, the hydraulic gradients
will not be reversed since the recharge area behind
the bluff will always remain at a greater elevation
than the waste disposal fill. The conclusion drawn
is not supported by any factual conditions, assump-
tions, or data.
This is the second time this comment has been made
(see response to comment 7). The author is evidently
unfamiliar with the principles of fluid mechanics and
the theory of flow through porous media.
The statement quoted is from the regional setting
(Section 2) portion of the DEIS Supporting Report.
It means exactly what it says. Efforts by the author
to reach conclusions related to specific environmental
impacts from regional baseline information are not
appropriate. In this regard, conclusions reached by
the author are incorrect.
The quotations are from the regional setting (Section 2)
portion of the DEIS Supporting Report. See response to
comment 34.
5-300
-------
GROUND WATER USAGE - UPDATED PUBLIC SUPPLY DATA - TRIMBLE
COUNTY WATER DISTRICT NO. 1 AND HENRY COUNTY WATER DISTRICT NO. 2
The water source is listed as two wells having rated pumping capacities of
170 gal/min (244,800 gal/day) each. The only treatment in use is chlorination;
the use of fluoridation equipment has been ordered. (Ref: Kentucky Division
of Sanitary Engineering, water plant inspection report dated 4/4/78).
According to the Division of Sanitary Engineering, (Public Water System
Inventory Subsystem, page 1279, last update date 6/1/78), the system is
reported to serve a population of 800 persons from two water wells. Average
water production is 120,000 gal/day and maximum production is 140,000 gal/day.
Chemical analyses of Trimble County Water District No. 1 were provided by
the Division of Sanitary Engineering as follows:
Parameter Lab Result
Sample collected on 5/5/77 Arsenic <0.01 mg/1
from a residence Barium 0.04 "
in Bedford Cadmium 0.004 "
Chromium <0.002 "
Lead 0.02 "
Mercury <0.0002 "
Selenium <0.005 "
Silver <0.002 "
Nitrate (N) 0.8 "
Distribution information is derived from the annual report to the Public
Service Commission of Kentucky for the year ending 12/31/77.
Type of Customer Reported Annual Usage Computed Average Consumption
525 residential customers 28,164,250 gal 77,162 gal/day
1 commercial customer (West
Carroll) 3,309,500 gal 9,067 gal/day
Tank/truck sales 2,947,550 gal 8,075 gal/day
Public fire protection service 140,000 gal 384 gal/day
TOTAL (Reported) 34,613,300 gal 94,831 gal/day
TOTAL (Computed) 34,561,300 gal 94,688 gal/day
Presuming an average per capita use of about 50 gal/day, the estimated total
number of persons served by Trimble County Water District No. 1 at 1886 (resi-
dential, redistribution, and rural cistern sales) as of 12/31/77. The averge
consumption rate is 39 percent of the capacity of one well or about 19
percent of the rate capacity of the total water system.
5-300a
-------
Henry County Water District No. 2
The water source is listed as four wells haveing a combined capacity of
1,728,000 gal/day (about 300 gal/min at each well). The water is chlorinated
and fluoridated as prescribed by law. The system operates on three of the
four wells and serves a total population of 3,500 persons. Average water
production is 605,000 gal/day and the maximum production is 1,104,000 gal/day.
(Public Water System Inventory Subsystem, page 573, last update date
6/1/78).
Distribution information is taken from the annual report to the Public Service
Commission of Kentucky for the year ending 12/31/78, as follows:
Type of Customer Reported Annual Usage Computed Average Consumption
1445 residential customers 98,633,442 gal 270,228 gal/day
(4)* sales for resale 105,397,670 gal 288,761 gal/day
TOTAL 204,031,112 gal 558,989 gal/day
*Includes municipal water systems serving Campbellsburg, New Castle, Eminene, and
West Carroll.
Presuming an average per capita use of about 50 gal/day, the estimated total
number of persons served by Henry County Water District No. 2 at 11,180. However,
this estimate could be very high since no allowance was made for municipal fire
protection services, or industrial usage; there are no records for either category,
The average consumption rate (as of 12/31/77) is 32 percent of the maximum
rated capacity of the water system.
Reported Expansion to Trimble County Water District No. 1
Verbal notice has been received from Irene P. Long that Trimble County Water
District No. 1 has been ordered by the Public Service Commission to immediately
expand its service area to include all foreseeable future extensions. On
the basis of this order, approximately 100 additional residential customers
will be added within about 1 year.
5-300b
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number Response
48 The author is again confused between regional data and
site-specific data. While 15 to 30 percent of annual
stream flow in the entire Bluegrass Region may be due
to ground water "base flow," it should be noted that
Ravines RA and RB contain intermittent streams that
are not sustained by ground water seepage to a measur-
able degree. In other words, they "dry up." Then the
author confuses flow quantity with flow velocity and
tries to relate this to contamination risk. The entire
analysis is invalid because the three parameters are
unrelated to each other.
49 The general statement applied to the geologic conditions
of the region, not the site, that have been described
previously in the text. The author's "implication" can
only be made when the statement is taken out of context,
which in fact it is.
50 Comment noted. No response required.
51 This was answered previously (see response to comment 41)
As an additional comment, it should be noted that the
author has significantly exaggerated the "flood effect"
and has also implied that the emergency storage pond
will (in itself) cause "extreme hydrostatic pressures
to be exerted over the remaining flood plain area."
52 Comment noted. No response required.
53 The author has again deliberately misread the DEIS
Supporting Report. As stated in the first quotation,
gauges were established in Corn and Bearbone Creeks
in 1975 and read every 2 months. The "historical"
data mentioned refer to data prior to 1975. The
calculations of flow rate are based on comparisons
made on the basis of data collected in 1975.
54 Permeability is a mathematical coefficient, measured
as an inherent property of a material. It has nothing
to do with surface slope whatsoever. The author has
again succeeded in confusing himself by attempting to
combine two unrelated parameters.
55 The author seems to be confusing the intermittent
streams in Ravines RA and RB with the entire floor
of each ravine.
5-301
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number Response
56 "Apparently" indicated that the data search had not
turned up such studies. The records of the Henry and
Trimble County Water Districts were overlooked as far
as Ohio River water quality is concerned.
57-58 Comment noted. No response required.
59 Again, the quotation is from Section 2 and does not
apply to the proposed site specifically. It is unclear
what connection the author intends between the quotation
and his comment.
60 Comment noted. No response required.
61 The author is presuming two things to support his con-
clusion:
a. LG&E would contribute (significantly) an addition
of heavy metals to streams sediments
b. Any increase in the concentration of heavy metals
would be harmful
Because neither of these presumptions are true, the
author's conclusion is invalid.
62 This description of ground water quality was taken from
the USGS and is applicable to ground waters of the Ohio
River alluvium. Accordingly, the DEIS Supporting Report
states, "the concentration of sulfate is usually signifi-
cant, ranging from about 20 to 70 mg/1." The author then
(incorrectly) interpreted "significant" to mean "a heavy
concentration," which is not true. While sulfate is not
hazardous in itself, the U.S. Public Health Services has
suggested a maximum limit of 250 mg/1 for potable water.
Maximum recorded values of sulfate in ground water are
less than 30 percent of the U.S. Public Health Service
suggested limit, within proximity of the plant site.
From this, it is concluded that sulfate levels in the
ground water are not extraordinarily high. Furthermore,
it is apparent that both the likelihood of sulfate
leaching and its purported effects on ground water
quality are not likely to occur. The author's scenario
and subsequent conclusions are both therefore incorrect.
5-302
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number Response
63 Comment noted. Regarding karst topography features on
the site, please refer to the response to comment 13,
Comment Document N, page 5-118 of this FEIS.
64 All of the analyses for heavy metals showed that these
concentrations were below the detection limits of the
analytical equipment. Since various pieces of laboratory
equipment have different minimum detection limits (which
also differ from element to element), the proper method
of reporting is to state that they are below these detec-
tion limits, rather than to report them as 0 or absent.
Noting the analysis of water from the Venards' well,
all undetected trace element values are reported as
less than «) the detection limit of an approved labora-
tory method. No heavy metals were in fact detected.
The author's contention that the power plant will "render
the aquifer water undrinkable" is not supported.
65 The author's opinions regarding the management of waste
disposal areas are noted. However, it should be pointed
out that several states have issued permits for similar
waste disposal management plans for facilities of the
size of those proposed, and that a number of commercial
waste product mangement companies, such as Dravo Corpora-
tion and I.U. Conversion Systems, have viable methods for
handling the amount of solid waste material that would
be produced by the proposed power plant. If the solid
waste is stabilized as proposed, this along with the
proposed engineering safeguards and mandatory monitoring
programs will provide a highly sophisticated waste
management program, one that is specifically designed
to protect the aquifer from potential contamination
by any potentially harmful materials contained in the
waste.
66 This statement is out of context since the author
again fails to recognize the raitigative measures
proposed (i.e., chemical fixation). The author's
argument is exaggerated.
67 It is certainly true that scrubber sludge disposal
is in an experimental stage, and there are no
guarantees connected with this or anything else
in the real world. However, the problem is one
that must be addressed if we are to burn coal for
the benefit of obtaining electrical energy in an
5-303
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number
67 (continued)
Response
68
69
70
71
72
73
environmentally acceptable fashion. We believe that LG&E
is taking a rational approach in their plans to dispose
of scrubber sludge. Furthermore, LG&E has agreed to take
whatever measures are dictated by the EPA in accordance
with the stipulation agreement and NPDES permit conditions.
None of the three species mentioned are on the Kentucky
or Federal Threatened or Endangered Species list. The
osprey and golden eagle are considered rare or endangered
by the Kentucky Department of Natural Resources, as cited
by Jan V. Babock, Endangered Plants and Animals of Kentucky,
Lexington, Kentucky, University of Kentucky, 1977.
The blue heron (both the great blue and little blue) are
common in Kentucky.
This is discussed on pages 6-6 and 6-7 of the DEIS
Supporting Report.
This conclusion was reached by personnel from the
University of Louisville's Water Resources Laboratory,
who prepared the material in Sections 2.2, 2.3, and
2.8, on the basis of their extensive experience in the
area in question and of available data concerning the
area.
The author's comment is confusing. He seems to be
implying that all archaeologists do poor work, which
is an obviously poor generalization. The survey of
the Trimble County site was not conducted by the
Jefferson County Archaeological Survey.
The potential of the area for other significant sites
was investigated by excavations in areas identified
as likely to contain such sites. The selection of
excavation testing areas was made by Dr. Janzen in
conjunction with the Kentucky State Archaeologist,
Dr. Clay.
As previously noted, the Louisville Archaeological
Survey did not conduct the survey of the Trimble
County site. Their discovery was made independently
of that survey.
5-304
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number Response
74 All sites that had been published in the National
Register of Historic Places, or filed with the state
archaeologist as of February 1, 1977 were, to the best
of our knowledge, included in this list.
75 Incorrect conclusion - the DEIS Supporting Report
does list seepage along valley walls as a recharge
mechanism (top, page 5-133). The author, in fact,
acknowledges this in comment 55. It should be emphasized
at this point that its relative contribution is very
small.
76 Incorrect conclusion - The stated plan to stabilize
sludge by means of chemical fixation is ignored by the
author. The statement is not supported by any data or
scientific rationale.
77 Incorrect conclusion - Mitigative measures can be taken
at any time and under almost any circumstances. These
may include one or more of the following:
a. Direct cleanup
b. Interceptor wells (deep wells or well
points)
c. French drain interceptor
d. Hydraulic barriers (via injection wells)
e. Isolation or sealing (by grout curtain
or slurry trench)
f. In-situ neutralization
g. Natural dispersion
78 The article also notes that sludge fixation is one way
to solve the potential ground water contamination
problem presented by untreated scrubber sludge.
5-305
-------
RESPONSE TO COMMENT DOCUMENT DD, Continued
Comment Number Response
79 Incorrect conclusion - Provided that the scrubber sludge
is stabilized as planned and the experimental landfill
provides a clear demonstration to the EPA that surface
and ground waters are not being degraded, a clay lining
may not be required (see Stipulation agreement). In
the event that a clay liner is required, natural clays
do exist in both ravines. It is likely that natural
clays can be utilized as "impermeable" lining materials
when properly reworked and compacted by suitable con-
struction methods.
5-306
-------
Eugene F. Mooney Julian M. Carroll
Secretary COMMONWEALTH OF KENTUCKY Governor
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF ENVIRONMENTAL PROTECTION
JOHN A. ROTH
COMMISSIONER
FRANKFORT, KENTUCKY 40601
August 21, 1978
Mr. Theodore F. B\isterfeld
Surveillance and Analysis Division
Environmental Impact Statement Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
RE: Proposed L G & E Project
Wise Landing, Trimble County,
Kentucky
Dear Mr. B\isterfeld:
Transmitted herewith are additional comments concerning the above-
referenced project (Attachment 1). These comments were generated
in response to a request by Irene P. Long of Bedford, Kentucky,
on July 26, 1978 (Attachment 2).
I realize that EPA has closed the comment period on the Draft EIS
but feel that these comments would be a helpful and necessary part
of any review process. Mr. McCann extended his comments beyond
the initial Long request because the Division of Water Quality did
not have a staff geologist at the time the draft was reviewed.
Please accept these comments as an integral part of the Division's
position. I sincerely feel that all available information should
be analyzed and presented to the agency and the public. For what-
ever short-term delays this may cause, I apologize, but I believe
it will help prevent future long-term problems.
'AUG 2 3 1978
COMMENT DOCUMENT - EE
5-307
-------
Theodore F. B\isterfeld
August 21, 1978
Page Two
If you have any questions, please do not hesitate to contact the
undersigned or Mr. McCann.
Sijhcerely,
itobert E. "Blanz, wirector
Division of Water Quality
cc: Mike McCann
Secretary Eugene Mooney
Irene P. Long
Milton Rush
Attachments
COMMENT DOCUMENT • EE, CONTINUED
5-308
-------
Eugene F. Mooney Julian M. Carroll
Secretary COMMONWEALTH OF KENTUCKY Governor
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF ENVIRONMENTAL PROTECTION
JOHN A. ROTH
COMMISSIONER
FRANKFORT, KENTUCKY 40601
MEMORANDUM
TO: Clyde P. Baldwin
Chief Environmental Engineer
FROM: M. R. McCann /M, K /fy ^ •
Geologist
DATE: August 17, 1978
SUBJECT: Wises Landing Power Station (LG & E),
Trimble County
1 As per your request to review C. L. Oldham's objections to the LG & E
coal burning power plant at Wises Landing, I have decided to review the
Environmental Impact Statement as well as Oldham's report with respect to
possible groundwater harm and geological ramifications of scrubber waste
disposal. Accordingly, I have attached a page-by-page commentary on both
reports.
My overall impression of the Environmental Impact Statement as a
technical scientific report is disappointing. There appears to have been
virtually no on-site geologic or hydrologic investigation. The information
on the geology, groundwater, and hydrology is condensed out of the respective
USGS reports. Although USGS does competent work, their reports do not
provide specific enough information to properly evaluate this site. Further-
more, the USGS information itself on occasion is not correctly interpreted.
For example, on Page 5-36, it is stated "Bedrock units immediately underlying
the plant site consists of sedimentary strata ranging in age from Middle
Silurian to Upper Ordovician." However, the plant site is underlain by Upper
Ordovician rocks only while Middle Silurian rocks outcrop on the ridgetops
and valley walls.
2 There appears to have been no attempt to determine the dynamic water
table in the alluvium. There should have been a continuous well level
recorder installed in an observation well on the site at the beginning of the
environmental assessment study. Also, there should have been a program of
drilling observation wells to determine the shape and direction of slope of
the water table, and water level measurements made throughout the year to
detect seasonal variations. Only water levels for the months of August -
September 1975 are in the Environmental Impact Statement (Page 5-126).
COMMENT DOCUMENT - EE, CONTINUED
5-309
-------
Clyde P. Baldwin
Page 2
August 17, 1978
3 The discussion of the geology and hydrology of the ravines RA and RB
where sludge is to be disposed is inadequate for the magnitude and the
geologic setting of the disposal project. I question whether either ravine
has ever been walked from top to bottom by the investigators.
The discussion of the sludge disposal process needs to include:
1. Previous uses of this method and cases where
ravines have been filled.
2. The possible consequences of disposal of 58,600
acre-feet of sludge in a steep karst valley need
to be addressed more thoroughly.
4 Although I am not in total agreement with some of Mr. Oldham's more
hyperbolic statements, I share his conclusion that a thorough study has not
been made.
5 Speaking as the Division of Water Quality Groundwater Geologist, I must
express my grave concern for the preservation of the quality of water in the
Wises Landing aquifer. I believe that the hazards to this source of public
drinking water have not been adequately addressed in the Environmental Impact
Statement.
MRM:pas
cc: Shelby C. Jett
COMMENT DOCUMENT - EE, CONTINUED
5-310
-------
WISES LANDING POWER STATION
ENVIRONMENTAL IMPACT STATEMENT
Page Comments
5 2-23 Neglects to mention Trimble County Water District.
7 2-27 This is the average for Ohio River alluvium no site-
specific data?
8 2-28 Impermeability is in the vertical direction, fair to
excellent in horizontal direction.
9 2-31 What have Meade and Hardin County to do with this area?
10 2-32 Why no mention of Trimble County Water District?
11 3-13 This site rates low on geologic conditions with respect
to soil and rock in ravains RA & RB.
12 3-35 (3-47) No mention is made of possible damage to ground and
surface waters from sludge disposal.
13 3-59 No mention is made of possible leachate discharge from
sludge disposal in ravines.
14 3-90 This is an inadequate discussion of the disposal of this
sludge.
15 3-118 Assumption? Relatively non-1 eachable? The data and
discussion are inadequate for the magnitude and geologic
setting of this disposal project. Where are the
permeability, leachate, and composition figures? Where
is the discussion of the consequences of damming near-
perennial springs? Of handling the runoff?
16 3-121 These processes are for sanitary landfilling not valley fill.
17 4-42 to 4-44 This is still an inadequate discussion of sludge disposal in
the ravines. The ravine disposal proposed is nothing at all
like sanitary landfill procedures.
18 5-36 All but the ravines are underlain by Upper-Ordovician not
Mid-Silurian.
19 5-45 A more detailed discussion of the stratigraphy of the
ravines is needed including field reconnaissance for karst
features.
20 5-116 These creeks should have been gauged.
COMMENT DOCUMENT - BE, CONTINUED
5-311
-------
Wises Landing Power Station
Page 2
August 17, 1978
Page Comments
21 5-124 Inadequate discussion of ravines RA & RB hydrology. There
is no justification for the words "seem to rise", "appear
to" and "tends towards a low flow". Those streams should
have been carefully monitored over the entire yearly regime.
22 5-126 There should have been a continuous well recorder installed
at the beginning of the Environmental Impact Statement and a
well survey with observation well drilling to determine the
dynamic behavior of the water table through at least one
year on the floodplain-terrace portion of the site.
23 5-133 A detailed description of what the USGS is doing is needed
here.
24 5-142 Only a 3 day well inventory program? Just one set of
analysis? No description of previous rainfall or other
hydrologic conditions.
25 5-150 This is a misleading statement. Wells 2-9, 21-23, 27 are
in close (possible affected) proximity.
26 6-8 Here, recharge from Ohio River is asserted. Where is the
study?
27 6-73 Inadequate discussion of groundwater impacts.
28 7-4 There has not been adequate thought given to this disposal
process nor to the alternatives if it proves unfeasible.
The situation might occur where solid waste is being pro-
duced at a rate of 5 acre-feet per day with no where to put
it.
29 7-5 Inadequate description of groundwater monitoring program.
COMMENT DOCUMENT - EE, CONTINUED
5-312
-------
WISES LANDING POWER STATION
OLDHAM 'S REPORT
Page Comments
30 3 What causes Oldham to think groundwater from RA and RB
reaches Wises Landing? The Environmental Impact State-
ment stated that rock has little "primary" permeability.
This is probably true. Secondary permeability is by far
the most important factor in this area in the bedrock.
31 4 He's probably right.
32 5-A, 6 Lust content?
33 7 Oldham is correct, this a gross error in map interpretation.
34 9 Tectonics not a risk factor.
35 14 Tnis is a very real possibility (Blowout). The Ohio
probably recharges the aquifer.
3£ 15 What about hydrostatic head buildup due to covering ground-
water exit points? Leachate?
37 16 Wny doesn't the Environmental Impact Statement have chemical
data on local springs?
38 17 Wrong, siltstones are not good aquifers.
39 18 A very good question.
40 19 Again, what happens to this flow when dammed?
41 23 Only a three (3) day (March 24-26, 1976) well inventory?
42 24-25 Insufficient data supplied in Environmental Impact Statement
as to disposal of solid waste, scrubber ponds, etc. and their
effect on the environment.
43 29 I agree, EPA has failed to provide a thorough study of the
hydrology of the site area. The Environmental Impact State-
ment is essentially a literature review.
* am n°t convinced that contaminated groundwater from ravines
RA & RB would have a direct route to Wises Landing via the
Bedrock. That possibility does exist, however, and has not
been properly investigated.
45 Furthermore, contamination due to parallel migration in the
alluvium or from recharge of the Ohio is also a likely source
of pollution to Wises Landing and does not seem to be addressed
in the Environmental Impact Statement.
COMMENT DOCUMENT - EE, CONTINUED
-------
RESPONSE TO COMMENT DOCUMENT EE
Comment Number Response
1 Preliminary onsite geological investigations, including
drilling, were conducted by ATEC for LG&E. Data result-
ing from these investigations were studied and included
wherever possible in the DEIS. Some hydrological inves-
tigations on the site are being conducted by the USGS.
This work was initiated on a recommendation by Dames &
Moore. Additional geologic and hydrologic investiga-
tions of the site will be performed for the ravines.
Regarding the presence of Middle Silurian rocks, refer
to the response to comment 25, Comment Document DD, page
5-296 of this FEIS.
2 Please refer to the response to comments 23 and 26 of
this comment document.
3-5 Please refer to the response to comment 13, Comment
Document N, page 5-118 of this FEIS.
6 As noted several times in responses to Comment Document
DD, Section 2.0 of the DEIS Supporting Report is a
summary of general conditions in the so-called "Area of
Interest" for the siting of the proposed project. This
section does not, and was not intended to, contain site-
specific data.
7 Please refer to the response to the previous comment.
8 Comment noted. No response required.
9 Please refer to the response to comment 6.
10 Please refer to the response to comment 6.
11 It is not clear why Mr. McCann says that the Trimble
Count site rates low on geologic conditions with
respect to rock and soil in ravines RA and RB. All of
the necessary geologic conditions, stated as necessary
in the EIS, have been met.
12 This is discussed in Section 6.0 of the DEIS Support-
ing Report. The referenced pages of the DEIS deal
with general site conditions related to identified
siting criteria. It is not intended to detail specif-
ic conditions in terms of the proposed project. These
are discussed in Sections 5.0 and 6.0.
5-314
-------
RESPONSE TO COMMENT DOCUMENT EE, Continued
Comment Number Response
13 Please refer to the response to the previous
comment.
14 Please refer to the response to comment 13, Comment
Document N, page 5-118 of this FEIS.
15 Please refer to the response to the previous comment.
16 Please refer to the response to comment 14, above.
17 Please refer to the response to comment 14, above.
18 Please refer to the response to comment 25, Comment
Document DD.
19 Please refer to the response to Comment 13, Comment
Document N.
20 As stated on the page referenced, these creeks were
gaged and discharge rates were recorded twice monthly
during 1975.
21 Please refer to the response to comment 13, Comment
Document N.
22 Please refer to the response comments 23 and 26, below.
23 Three wells in line between the river and the valley
wall are being monitored by the USGS to evaluate
flood wave response in the alluvial aquifer. To date,
no analyses have been made to determine hydraulic
diffusivity, but the results of monitoring are reported
in USGS. report KY-77-1, "Water Resources Data for
Kentucky, Water Year 1977."
24 The well inventory program was designed to collect
background data on the number and location of wells
in the area and to selectively sample water quality.
25 Mr. McCann is correct. The statement is incorrect.
5-315
-------
RESPONSE TO COMMENT DOCUMENT EE, Continued
Comment Number Response
26 As mentioned throughout the DEIS, no site-specific data
were available to evaluate hydraulic communication be-
tween the Ohio River and the alluvial aquifer. One pur-
pose of the USGS monitor well program was to shed
light on this very question. However, in broad terms,
nearly all ground water references that pertain to the
Ohio River cite some degree of hydraulic communication
with the aquifer as the principal source of recharge.
(Selected references include Ky. G.S., I.C.-18 for a
qualitative discussion, and USGS W-R I 2-74 for
more quantitative study. Additional references will
be furnished upon request.)
27 We concur. Please refer to the response to comment 13,
Comment Document N.
28 Please refer to the response to comment 13, Comment
Document N
29 Please refer to the response to comment 13, Comment
Document N.
30 Comment noted. No response required.
31 There are three separate comments on page 4 of Mr.
Oldham's comments. It is not clear to which of
these Mr. McCann is referring. Refer to responses
to comments 8-10, Comment Document DD, page 5-286
of this FEIS.
32 Comment noted. No response required.
33 Please refer to the responses to comments 25-27,
Comment Document DD, page 5-296 of this FEIS.
34 Comment noted. No response required.
35 Please refer to the responses to comment 41, Comment
Document DD, page 5-300 of this FEIS.
5-316
-------
RESPONSE TO COMMENT DOCUMENT EE, Continued
Comment Number Response
36 Some hydrostatic head increase will occur when springs
and other ground water seepage points become blocked
due to valley fill operations in ravines RA and RB.
As a result, minor reversals in the direction of ground
water flow will occur in the upper karst bedrock aquifer.
However, no flow of ground water will take place where
a seepage is blocked. Instead of flowing toward a
spring in the ravines, ground water will flow to some
other exit point along the bluff, probably at a similar
horizon. Since the source of this water is direct
recharge from local precipitation, no contamination
could enter the karst aquifer from the solid waste
disposal operations, provided that the fill material is
relatively impermeable and non-leachable. Please also
refer to the response to comment 43, Comment Document DD,
page 300 of this FEIS.
37 There was no particular reason in either our choosing
or avoiding springs for chemical ground water analyses.
Principal criterion was to gather enough data to examine
baseline conditions, by including representative numbers
of domestic sources over a wide geographic area and
a range of hydrogeologic conditions. Of the seven
wells sampled (see page 5-146 of the DEIS Supporting
Report), four covered the alluvial aquifer since it is
the most significant in terms of yield. One included a
well in the tributary alluvium of Browning Branch, and
two covered the karst upland area. The two sampling
points tapping the karst limestone aquifer should be
chemically similar to the springs in that area. These
two sampling points were originally chosen because
they are properly constructed sanitary wells. In this
regard, we generally pre-screen potential sampling
points to avoid improperly constructed wells that
are usually contaminated directly from surface water
infiltration.
38 Comment noted. No response required..
39 Please refer to the responses to comment 20 of this
comment document.
5-317
-------
RESPONSE TO COMMENT DOCUMENT EE, Continued
Comment Number Response
40 It is not clear which flow is being referred to. Surface
water flow will not be dammed. Ground water flow might
be "dammed" when the solid waste fill reaches a spring
horizon. Our response to comment 36, above, applies
for this case.
41 Please refer to the response to comments 24 and 37
of this comment document.
42 Please refer to the response to comment 13, Comment
Document N, page 5-118 of this FEIS.
43 Please refer to the response to comment 13, Comment
Document N.
44 Comment noted. Please refer to the response to comment
13, Comment Document N.
45 It does not appear that either parallel migration in
the alluvium, or recharge from the Ohio River can be
regarded as a likely source of pollution to Wises
Landing, provided that the solid waste disposal opera-
tions proceed as proposed. The magnitude of both disper-
sion and dilution that would occur between waste disposal
activities and Wises Landing is so large that any impact
on the Wises Landing aquifer should be negligible.
5-318
-------
DR. BII.I.Y II. STOUT, SUPT
CECIL FISHER, D. P. P.
CLYDE CROPPER, FEDERAL CORD.
Trimble County Schools
P. 0. flox 67 Phone: 502/255-3554
BEDFORD, KENTUCKY 40006
BOARD OF EDUCATION
CAROLE MAHTIN, CHAIRPERSON
STEVE THARP, v. CHAIRPERSON
JACK CARDER, MEMBER
JAMESMCMAHAN, MEMBER
GLENN FISHER, MEMBER
August 24, 1978
Mr. John E. Hagan III, Chief EIS Branch
Environmental Protection Agency Region IV
345 Courtland Street, N.E.
Atlanta, GA 30308
Dear Mr. Hagan:
1 Mr. Bob Sommers of Louisville Gas & Electric is working with
the Trimble County Board of Education in obtaining estimates on the
influx of people into our county due to the generating station. His
estimates will serve as a base for future planning as to our needs.
2 Since Mr. Sommers is working with us in obtaining these figures,
I resend my previous questions. However, the fact remains that we
are overcrowded.
Sincerely,
Bill Stout, Superintendent
Trimble County Schools
BS:jb
5-319
COMMENT DOCUMENT • FF
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RESPONSE TO COMMENT DOCUMENT FF
Comment Number Response
1 Comment noted. No response required.
2 Comment noted. Since the date of this letter, additional
meetings between LG&E and the School Board have been held
in order to continue to aid the School Board to resolve
their situation.
5-320
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^•0 AND AS SO( I A !l s
consulting engineers
3398 WEST GALBRAITH ROAD -X- CINCINNATI. OHIO 45233
AREA CODE 513/521-1967
August 26, 1978
Mr. Theodore F. Blisterfeld
Surveillance and Analysis Division
Environmental Impact Statement Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
SUBJECT: Proposed L G & E Project
Wises Landing
Trimble County, Kentucky
Dear Mr. Blisterfeld:
This is to advise that I have been retained by the Trimble County
Water Company to investigate the impact of the subject project
on the groundwater aquifers supplying the Trimble County District,
Henry County District No. 2, and West Carroll District.
My preliminary work indicates that the basic data used in prepa-
ration of the Draft EIS is outdated, incorrectly interpreted,
and misleadingly presented. Consequently, said Draft EIS fails
to address the magnitude of impact.
Respectfully submitted,
JAMES E. HOUGH & ASSOCIATES
•^/ ~\
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^•James E. "Doughy PE, PG ^
JEH/hm
cc: Irene P. Long
M. R. McCann
SOIL
SUBSURFACE
5-321
COMMENT DOCUMENT
FOUNDATION
GG
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RESPONSE TO COMMENT DOCUMENT GG
Comment Number Response
Mr. Hough's comment is too general to enable an adequate
response. Please refer to the response to comment 1,
Comment Document DD, page 5-294 of this FEIS.
Mr. Hough attended the meeting between the EPA and the
Commonwealth of Kentucky on September 6 regarding the
issue to solid waste disposal. His specific concerns
and recommendations were discussed at that time, and
made part of the record of that meeting for considera-
tion by the state. Please also refer to the response
to comment 13, Comment Document N, page 5-118 of this
FEIS.
5-322
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APPENDICES
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Permit No. KY004197l
Application No. KY0041971
r :- ;-,-; — *.;« APPENDIX A
i'-f"V':'A [. '
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Federal Water Pollution Control
Act, as amended, (33 U.S.C. 1251 et. seq; the "Act"),
Louisville Gas and Electric Company
P. 0. Box 32010
Louisville, Kentucky 40232
is authorized to discharge from a facility located at
Trimble County
Units 1, 2, 3 and 4
Trimble County, Kentucky
to receiving waters named Ohio River
from discharge points enumerated herein, as serial numbers Q01 002 003
004, 005, 006 and 007
during the effective period of this permit
in accordance with effluent limitations, monitoring requirements and other
conditions set forth in Parts I, II, and III hereof.
This permit shall become effective on
This permit and the authorization to discharge shall expire at midnight,
September 30. 1980. Permittee shall not discharge after the above date
of expiration without prior authorization. In order to receive authorization
to discharge beyond the above date of expiration, the permittee shall submit
such information, forms, and fees as are required by the Agency authorized
to issue NPDES permits no later than 180 days prior to the above date of
expiration.
Signed this day of
Paul J. Traina, Director
Enforcement Division
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through exr>ir?tion
the permittee is authorized to discharge from outfall(s) serial number (s) Q01 ~ Point source(s) runoff
from construction
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Measurement Sample
Instantaneous Maximum Frequency Type
Flow-mS/Day (MGD) N/A I/week Grab
Total Suspended Solids (mg/1) _!/ I/week Grab ?."
Total Settleable Solids (ml/1) N/A 2/week Grab
Turbidity (JTU) N/A 2/week Grab *
I/ Pending repromulgation of effluent guidelines for this waste category, limitations on total
suspended solids shall not be applicable. Within 90 days of repromulgation, permittee shall
submit a proposed implementation schedule and shall expeditiously complete necessary facilities,
if any, to assure compliance with such repromulgated regulations. In.the interim, construction
practices and control of site runoff shall be consistent with sound engineering practices such
as those contained in "Guidelines for Erosion and Sediment Control Planning and Implementation,"
EPA-R2-72-015 (August, 1972) or "Processes, Procedures and Methods to Control Pollution Resulting
from all Construction Activity," EPA-430/9-73-007 (October, 1973). Where an impoundment is
utilized by permittee, it shall be capable of containing a 10-year, 24-hour rainfall event.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be ^ ^ ^ i=
monitored each time the pond is sampled.. j* JjJ ^ -o
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There shall be no discharge of floating solids or visible foam in other than trace amounts. n w M •-<
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Samples taken in compliance with the monitoring requirements specified above shall be taken at * o "
the following locatlon(s): Discharge from the runoff treatment pond prior to entry into the 5 *"" °
Ohio River. o =s
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A. EFFLt:z:;«Tr LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration
the permittee is authorized to discharge from outfall(s) serial number(s) 002 - Cooling tower blowdown
Such discharge shall be limited and monitored by the permittee as specified below:
Effluent Characteristic Discharge Limitations Monitoring Requirements
Daily Average Daily Maximum Measurement Sample
Frequency Type
Flow-m3/day (MGD) N/A N/A Continuous Recorder
Temperature *C(°F) N/A 31.7 (89.0) I/ Continuous Recorder
Total Residual Chlorine See Below I/week 2/ Multiple Grab*
Additional Monitoring (See Part III.L) N/A N/A I/month Grab
Total residual chlorine may be discharged continuously but shall not exceed a maximum instantaneous
concentration of 0.20 mg/1 at any time. Chlorination control practices shall be instituted to minimize
discharge of total residual chlorine. A report describing procedures and chlorine usage shall be submitted
annually along with the first quarterly monitoring report submitted after January 1st of ench year. In the
event that the units cannot be operated at or below this level of chlorination, the applicant may submit a
demonstration, based on biological toxicity data, that discharge of higher levels of chlorine are consistant
with toxicity requirements of the Kentucky Water Quality Standards. Effluent limitations will be modified
00 consistant with an acceptable demonstration.
Discharge of blowdown from the cooling system shall be limited to the minimum discharge of recirculating
water necessary for the purpose of discharging materials contained in the process, the further build-up
of which would cause concentrations or amounts exceeding limits established by best engineering practice.
A report showing how conformance with this requirement will be met, including operational procedures, shall
be submitted during the system design stage. Additionally, annual reports on cooling tower operation
shall be submitted showing compliance with this requirement. Such reports shall be submitted along with
the first quarterly monitoring report submitted after January 1st of each year. Discharge temperature
shall not exceed the lowest temperature of the recirculating cooling water prior to the addition of make-up.
Blowdown shall contain no detectable amount of materials added for corrosion inhibition including, but
not limited to, zinc, chromium, and phosphorus. 3>
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be 3 S S^
monitored I/week. £ ^ o
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There shall be no discharge of floating solids or visible foam in other than trace amounts. ? - >
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Samples taken in compliance with the monitoring requirements specified above shall be taken at the 3 o §
following location(s): discharge from the combined cooling tower discharge prior to entry into the § 2.
Ohio River, except that flow measurements shall be provided for each tower separately. ~~
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CONTTNUKD
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A.. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration _
the permittee is authorized to discharge from outfall(s) serial number(s) 002 (continued) - Cooling tower blo«j*own
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I/ The receiving water shall not exceed (1) a maximum water temperature change of 2.8°C(5.0°F) relative
~ to an upstream control point and (2) the maximum temperatures by month noted below, outside of a
mixing zone which shall not exceed (1) a maximum width of 100 feet nor (2)a 150-foot Ixnear
downstream length.
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Jan.
Feb.
Mar.
10.0(50)
10.0(50)
15.6(60)
April
May
June
21.1(70)
26.7(80)
30.5(87)
July
Aug.
Sept.
31.7(89)
31.7(89)
30.5(87)
Oct.
Nov.
Dec.
25.6(78)
21.1(70)
13.9(57)
21 During the first two-month period of substantially full power operation, analyses shall follow each
~ application of chlorine until sufficient operating experience has been obtained to assure conformance
with limitations and then analysis frequency may be reduced to one day per week.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration
(UnitsTthrough Jp0^ C° disch^e ^om outfaUCs) serial nu.berCs) 003 - Intake screen backwash
Such discharges shall be limited and monitored by the permittee as specified below:
materialremovedfKe "*? **?** V±^OUt limltatlon or <»°nitoring requirements. However,
material removed from the bar racks by mechanical equipment shall not be returned to the Ohio River
and shall be disposed of in an environmentally acceptable manner.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration
the pernittee is authorized to discharge from outfall(s) serial nuraber(s) 004 - Point source(s) runoff from
stabilized scrubber sludge to Corn Creek
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic Discharge Limitations Monitoring Requirements
Instantaneous Maximum Measurement Sample
Frequency Type
Flow-m3/Day (MOD) N/A I/week Grab
Total Suspended Solids (mg/1) 50 J./ I/week Grab
Additional Monitoring (See Part III.K.) N/A I/month Grab -
I/ Applicable to any flow up to the flow resulting from a 24-hour rainfall event with a probable
" recurrance interval of once in ten years. If an impoundment is utilized by permittee, it shall
be capable of containing a 10-year, 24-hour rainfall event.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be
monitored I/week on a grab sample. "*
There shall be no discharge of floating solids or visible foam in other than trace amounts. i_
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Samples taken in compliance with the monitoring requirements specified above shall be taken at the
following location(s): point(s) of discharge from the runoff holding pond prior to mixing with
uncontaminated stormwater runoff. 3
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning On start of discharge and lasting through expiration
the permittee is authorized to discharge from outfaJl(s) serial number(s) 005 J7 - Point source (s) runoff from material
storage to construction runoff pond (001)
Such discharges shall be limited and monitored by lh-v permittee as specified below:
Effluent Characteristic Discharge Limitations Monitoring Requirement* ^*
• • - «.-?
Instantaneous Maximum Measurement Sample t»
Frequency Typ«
Flow-tn3/Day (MOD) N/A I/week Grab
Total Suspended Solids (mg/1) 50 U I/week Grab
Additional Monitoring (See Part III. L.) N/A I/month Grab
Material storage runoff shall include rainfall runoff to navigable waters through any discernible,
confined and/or discrete conveyance from or through any coal, ash or other material storage pile.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taker, in compliance with the monitoring requirements specified above shall be taken at thf following location(s):
Point(s) of discharge from the material storage runoff treatment pond .prior to entry into construction
runoff treatment pond.
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I/ Serial number assigned for identification and monitoring purposes. to §
~2/ Applicable to any flow up to the flow resulting from a 24-hour rainfall event with a probable £J 2.
recurrence interval of once in ten years. If an impoundment is utilized by permittee, it shall c
be capable of containing a 10-year, 24-hour rainfall event. a.
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00
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through espiration, the permittee is authorized
to discharge from outfall(s) serial number(s) 006 _!_/ - Construction sewage treatment effluent (two units in
parallel will ultimately be provided). Such discharges shall be limited and monitored by the permittee as
specified below:
Effluent Characteristic
Flow-m3/Day (MGD)
BOD5
Total Suspended Solids
Settleable Solids (ml/1)
Dissolved Oxygen
Chlorine Residual
Fecal Coliform _3/ (organisms/100 ml)
Discharge Limitations
Other Units
(mg/1 except as noted)
Daily Average Daily Maximum
Monitoring Requirements
Measurement Sample
Frequency Type
N/A
30
30
1.0
S
N/A
N/A
e e
Bel
N/A
60
60
1.0
o w
N/A
N/A
5/week 2/
2/month 2j
2/month 2/
5/week
I/week 2/
5/week
I/quarter
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Effluent shall contain a minimum of 2.0 mg/1 of dissolved oxygen at all times.
applicable subsequent to rerouting of effluent to bottom ash pond.
This limit shall not be
Prior to commercial operation of Unit 1, this waste stream may be directed to the runoff treatment pond
(Discharge serial No. 001) after treatment in the sewage treatment plant. Subsequently, effluent shall
be routed to the bottom ash pond.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
locations: Combined sewage treatment plant effluent prior to mixing with any other waste stream.
_!_/ Serial number assigned for identification and monitoring purposes.
2J Subsequent to rerouting of this waste stream to the bottom ash pond, the measurement frequency
may be reduced as follows: flow - I/week, BOD5 - I/month, Total Suspended Solids - I/month
and Dissolved Oxygen - eliminated.
3/ Geometric mean.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration
the permittee is authorized to discharge from outfall(s) serial number(s) 007 JL/ - Operational sewage treatment plant effluent
discharged to bottom ash pond.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Flow-m3/Day (MGD)
BOD 5
To^al Suspended Solids
Settleable Solids (ml/1)
Chlorine Residual
Fecal Coliform 2/
(organisms/lOTT ml)
Discharge Limitations
Other Units (rig/1 except-as noted)
Daily Average Daily Maximum
39.7(0.0105)
30
30
1.0
N/A
N/A
60
60
1.0
N/A
N/A
Monitoring Requirements
Measurement
Frequency
I/week
I/month
1 /month
5 /week
5 /week
I/quarter
Sample
Type
Grab
Grab
Grab
Grab
Grab
Grab
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
Sewage treatment plant effluent prior to mixing with any other waste stream.
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2/ Geometric mean.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on commercial operation date of Unit 1 and lasting through expiration
the permittee shall monitor as specified below serial number (s) Q08 I/ ~ Plant Intake
Effluent Characteristic
Flow-m3/Day (HGD)
Temperature C(°F)
Additional Monitoring (See Part III.L.)
Discharge Llm it ,-itj.rns
Int.'. i!ui_anc.ous
H£> y j.mum
N/A
N/A
N/A
Monttoring Requiremcnts
Measurement Sa-.ple
Frcquency
Continuous
Continuous
I/month
Pump logs
Recorder
Grab
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Saaples taken in compliance with the monitoring requirements specified above shall be taken at th-
following location(s): Plant intake.
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Page 11 of 20
Permit No. KY0041971
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent limitations
specified for discharges in accordance with the following schedule:
a. Errosion and sediment control reports (III.G.)
(1) First report - 4 months after start of construction
(2) Second through fourth reports - quarterly after first report
(3) Subsequent reports - annually after fourth report
b. Groundwater monitoring reports (III.H.) - quarterly with annual
c. PClTreport (III.B.) - 180 days prior to receipt of PCS containing
equipment
d. 316(b) study (III.D.)
(1) Study plan - one year prior to commercial operation date ol
(2) Start Unit 1 study - 3 months after commercial on-line date
of Unit 1
(3) Report Unit 1-18 months after commercial on-line date or
Unit 1 . , -,
(4) Start Units 1 & 2 study - 3 months after commercial on-line
date of Unit 2
(5) Report Units 1 & 2 - 18 months after commercial on-line date
of Unit 2 . .
(6) Start Units 1 - 3 study - 3 months after commercial on-line
date of Unit 3 ,,..»..
(7) Report Units 1-3-18 months after commercial on-line date
of Unit 3
(8) Start Units 1-4 study - 3 months after commercial on-line
date of Unit 4
(9) Report Units 1-4-18 months after commercial on-line date
of Unit 4
e. Ravine discharge monitoring (III.K.)
(1) Proposal - ISO days prior to commercial operation date
(2) Implement - commercial operation date
f. Slowdown report (002) - annually with first quarterly monitoring
report
g. Chlorine procedures and usage report (002)-annually with first
quarterly monitoring report
h. Condenser tube report (III.J.) - annually after commercial operation
date
2 No later than 14 calendar days following a date identified in the above
schedule of compliance, the permittee shall submit either a report of
progress or, in the case of specific actions being required by identified
dates, a written notice of compliance or noncompliance. In the latter
case the notice shall include the cause of noncompliance, any remedial
actions taken, and the probability of meeting the next scheduled requirement
Note: Any construction of new waste treatment facilities or alterations to
existing waste treatment facilities will require a permit or authorization
for construction in accordance with applicable state law and regulations.
11 APPENDIX A, Continued
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APPENDIX A, Continued
12
.-i 20
KY0041971
C. MONITORING AND REPORTING
1. Representative Sampling
Samples and measurements taken as required herein shall bo representative of the volume
and nature of the monitored discharge.
2. Reporting
Monitoring results obtained durinp the previous 3 months shall be summarized for
each month and reported on a Discharge Monitoring Report Form (EPA No. 3320-1).
postmarked no later than the 28th day of the month following the completed reporting
period. The first report is due on . Duplicate signed copies of
these, and all other reports required herein, shall be submitted to the Regional
Administrator and the State at the following addresses:
_, . r .. „ f _ „ ,
Chief, Water Enforcement Branch
Envlr^ntai Protection Agenc,
345 Courtland Street, N.E.
ACUnca, Georgia 30308
Dept. for Natural Resources and
40.01
3. Definition
a. The "daily average" concentration neaas the arithmetic average
(weighted by flow) of all the daily determinations of concentra-
tion made during a calendar month. Daily determinations of
concentration made using a composite sample shall be the concen-
tration of the composite sample. When grab samples .are used, the
daily determination of concentration shall be the arithmetic
average (weighted by flow) of all the samples collected during
that calendar day.
b. The "daily maximum" concentration means the daily determination
of concentration for any calendar day.
c. "Weighted by flow" means the summation of each sample concentration
times its respective flow in convenient units divided by the
summation of the flow values.
d. "Nekton" means free swimming aquatic animals whether of freshwater
or marine origin.
e. For the purpose of this permit, a calendar day is defined as any
24-hour period.
12
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APPENDIX A, Continued
PART I
13 ,,i 20
Ni. KY0041971
f.
j.__.j^ ,» . . ° •* &*i i- u j. viUcu Dy CuG nuiTlDSr
during the calendar month when the measurements were made.
8* lh!/'dally ma?imum" discharge means the total
4. Tett Proocdure$
Test procedures for the analysis of pollutants shall conform to regulations published
pursuant to Section 304(g) of the Act, under which such procedures may be required.
5. Recording of Results
For each measurement or sample taken pursuant to the requirements of this permit, the
permittee shall record the following information:
a. The exact place, date, and time of sampling;
b. The dates the analyses were performed;
c. The pereon(s) who performed the analyse*;
d. The analytical techniques or methods used; and
e. The results of all required analyses.
G. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more
frequently than required by this permit, using approved analytical methods as specified
above, the results of such monitoring shall be included in the calculation and reporting of
the values required in the Discharge Monitoring Report Form (EPA No. 3320-1). Such
increased frequency shall also be indicated.
7. Records Retention
All records and information resulting from the monitoring activities required by this
permit including all records of analyses performed and calibration and maintenance of
instrumentation and recordings from continuous monitoring instrumentation shall be
retained for a minimum of three (3) yean, or longer if requested by the Regional
Administrator or the SUte water |x>llution control agency.
13
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APPENDIX A, Continued
PART II
'- 1 '" :*J **8 * Pilt!C ^ "' 20
^ '<""" N"KY0041971
A. MANAGEMENT REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall he consistent with thr t.-rms and conditions of this
permit. The discharge of any pollutant identified in this permit more frequently than or
at a level in excess of that authorized shall constitute a violation of the permit. Any
anticipated facility expansions, production increases, or process modifications which will
result in new, different, or increased discharges of pollutants must be reported by
submission of a new NPDES application or, if such changes will not violate the effluent
limitations specified in this permit, by notice to the permit issuing authority of such
changes. Following such notice, the permit may be modified to specify and limit any
pollutants not previously limited.
2. Noncompliance Notification
If, for any reason, the permittee does not comply with or will be unable to comply with
any daily maximum effluent limitation specified in this permit, the permittee shall
provide the Regional Administrator and the State with the following information, in
writing, within five (5) days of becoming aware of such condition:
a, A description of the discharge and cause of noncompliance; and
b. The period of noncompliance, including exact dates and times; or, if not corrected.
the anticipated time the noncompliance is expected to continue, and steps being
taken to reduce, eliminate and prevent recurrence of the noncomplying discharge.
3. Facilities Operation
The permittee shall at all times maintain in good working order and operate as efficiently
as possible all treatment or control facilities or systems installed or used by the permittee
to achieve compliance with the terms and conditions of this permit.
4. Adverse Impact
The permittee shall take all reasonable steps to minimize any adverse impact to navigable
waters resulting from noncompliance with any effluent limitations specified in this
permit, including such accelerated or additional monitoring as necessary to determine the
nature and impact of the noncomplying discharge.
5. Bypassing
Any diversion from or bypass of facilities necessary to maintain compliance with the
terms and conditions of this permit is prohibited, except (i) where unavoidable to prevent
loss of life or severe property damage, or (ii) where excessive storm drainage or runoff
would damage any facilities necessary for compliance with the effluent limitations and
prohibitions of this permit. The permittee shall promptly notify the Regional
Administrator and the State in writing of each such diversion or bypass.
14
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.
APPENDIX A, Continued
PART 11
P,fc 15 of 20
Permit No. KY0041971
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or
control of wastewaters shall be disposed of in a manner such as to prevent any pollutant
from such materials from entering navigable waters.
7. Power Failures
In order to maintain compliance with the effluent limitations and prohibitions of this
permit, the permittee shall either:
a. In accordance with the Schedule of Compliance contained in Part I, provide an
alternative power source sufficient to operate the wastewatcr control facilities;
or, if such alternative power source is not in existence, and no date for its implementation
appears in Part I,
b. Halt, reduce or otherwise control production and/or all discharges upon tho
reduction, loss, or failure of the primary source of power to the wastewater control
facilities.
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the head of the State water pollution control agency, the
Regional Administrator, and/or their authorized representatives, upon the presentation of
credentials:
a. To enter upon the permittee's premises where an effluent source is located or in
which any records are required to be kept under the terms and conditions of this
permit; and
b. At reasonable times to have access to and copy any records required to be kept under
the terms and conditions of this permit; to inspect any monitoring equipment or
monitoring method required in this permit; and to sample any discharge of pollutants.
2. Transfer of Ownership or Control
In the event of any change in control or ownership of facilities from which the authorized
discharges emanate, the permittee shall notify the succeeding owner or controller of the
existence of this permit by letter, a copy of which shall be forwarded to the Regional
Administrator and the State water pollution control agency.
3. Availability of Reports
Except for data determined to be confidential under Section 308 of the Act, all reports
prepared in accordance with the terms of this permit shall be available for public
15
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APPENDIX A, Continued
PART II
P 16 , 20
ra(;c ol
Permit No. KY0041971
inspection at the offices of the- State, water pollution ronlro! j^rnry and the Regional
Administrator. As required by the Act, effluent data ahall not be considered confidential.
Knowingly making any faJse statement on any such report may result m the. imposition of
criminal penalties as provided for in Section 309 of the Act.
4. Permit Modification
After notice and opportunity for a hearing, this permit may be modified, suspended, or
revoked in whole or in part during its term for cause including, but not limited to, the
following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant
facts; or
c. A change in any condition that requires either a temporary or permanent reduction or
elimination of the authorized discharge.
5. Toxic Pollutants
Notwithstanding Part II, B-4 above, if a toxic effluent standard or prohibition (including
any schedule of compliance specified in such effluent standard or prohibition) is
established under Section 307(a) of the Act for a toxic pollutant which is present in the
discharge and such standard or prohibition is more stringent than any limitation for such
pollutant in this permit, this permit shall be revised or modified in accordance with tho
toxic effluent standard or prohibition and the permittee so notified.
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, A-5) and "Power
Failures" (Part II, A-7), nothing in this permit shall be construed to relieve the permittee
from civil or criminal penalties for noncornpliance.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or
relieve the permittee from any responsibilities, liabilities, or penalties to which the
permittee is or may be subject under Section 311 of the Act.
8. State Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or
relieve the permittee from any responsibilities, liabilities, or penalties established pursuant
to any applicable State law or regulation under authority preserved by Section 510 of the
Act.
16
-------
PART 11
Page I? of 20
Permit No. KY0041971
9. Property Righto
The issuance of this permit does not conv«?y .my property rights in eithi-r
real or personal property, or any exclusive privl legeh, nor dot-s fi
authorize any injury to private property or any invasion of personal
rights, nor any infringement of Federal, State or local laws or regulations,
10. Severability
The provisions of this permit are severable, and if any provision of this
permit, or the application of any provision of this permit to any circum-
stance, is held invalid, the application of such provision to other
circumstances, and the remainder of this permit, shall not be affected
hereby.
PART III
OTHER REQUIREMENTS
A. If the permittee, after monitoring for at least 12 months, deter-
mines that he is consistently meeting the effluent limits contained
herein, the permittee may request of the Director, Enforcement Division, that
the monitoring requirements be reduced to a lesser frequency or be
eliminated.
B. There shall be no discharge of polychlorinated biphenyl compounds
such as those commonly used for transformer fluid. In the event
that PCB containing equipment is used on site, administrative
procedures shall be instituted to (1) maintain a detailed inventory
of PCB use, (2) assure engineering design and construction to
preclude release of PCB's to the environment, and (3) effectively detect
the loss of PCB's from equipment. Detail of such procedures shall br»
submitted no later than 180 days prior to receipt of PCB containing equipment,
c- The company shall notify the Director, Enforcement Division in writing not
later than sixty (60) days prior to instituting use ot any additional
biocide or chemical used in cooling systems, other than chlorine, which
may be toxic to aquatic life other than those previously reported to the
Environmental Protection Agency. Such notification shall include.
1. name and general composition of biocide or chemical,
2 96-hour median tolerance limit data for organisms
' representative of the biota of the waterway into
which the discharge shall occur,
3. quantities to be used,
4. frequencies of use,
5. proposed discharge concentrations, and
6. -EPA registration number, if applicable.
17 APPENDIX A, Continued
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PART III
Page 18 of 20
Permit No. KY0041971
D. In accordance with Section 316(b) of the Act, by three months after the
commercial operation date of Unit 1, the permittee shall, implement an
approved program to monitor nekton and shellfish impinged on plant intake
structures and fish eggs and larvae and other organisms entrained by the cooling
water system. Additionally, studies shall be conducted for two, three and four
unit operation for one year following the commercial operation date of each
successive unit. Study plans shall be submitted to the Director, Enforcement Division
for approval not later than one year prior to the commercial operational date of
Unit 1. Note: Study requirements for Units 2, 3 and 4 may be modified, reduced
or eliminated consistant with results obtained from previous units.
By 18 months after commercial operation dates of each unit, the permittee shall
submit a summary report to the Director, Enforcement Division and State Director as to
the effects of the cooling water intake with regard to Section 316(b) of the
Act. If significant impingement and/or entrainment is occurring, this report
shall include:
1. An evaluation of facility or procedure modifications,
If necessary, to minimize the environmental impact
of the cooling water intake,
2. An evaluation of methods to return viable nekton and
shellfish collected on the intake screens to ambient
temperature water at a point outside the influence of
the plant intake and discharge, and
3. Proposed facilities or modifications with attendant
implementation schedule(s) for implementing 1 and/or
2 above.
At the conclusion of this study period, subject to opportunity for hearing
and review, the permittee shall implement procedures and or facility
construction associated with the intake structure(s) if significant impingement
or entrainment occur.
E. Effluent discharge structure(s) for outfall serial number 002 shall be designed
to assure a minimum dilution factor of 20 for all plant discharge and river flow
conditions. Subsequent to commercial operation of each unit, field measurements
(supplemented as necessary with modeling results) shall be conducted to assure
conformance with this requirement and to determine three-dimensional configura-
tion(s) of the thermal and chlorine plumeS. A report showing compliance with
the assigned mixing zone shall be submitted by one year after the commercial
operation date for each unit.
F. All plant waste discharges not specifically allowed under this Authorization to
Discharge including, but not necessarily limited to, ash transport
water, boiler blowdown, metal cleaning wastes and low volume wastes
(as defined in 40 CFR Part 423) shall not be released to any waste
stream which discharges to Waters of the United States.
18 APPENDIX A, Continued
-------
PART III
Page 19 of 20
Permit No. KY0041971
G. The permittee shall implement the Erosion and Sedimentation Control
Plan as submitted to the Environmental Protection Agency on September 1, 1977.
A monitoring report shall be submitted quarterly during the first year
of construction and annually thereafter. The report shall be submitted
within one month after completion of the monitoring period, with the
first report due four months after start of site construction. Modification
of the Erosion and Sedimentation Control Plan requires the prior written
approval of the Director, Enforcement Division.
H. The permittee shall implement the Groundwater Monitoring Plan as submitted to
EPA on September 1, 1977. The permittee shall monitor monthly using EPA
approved methods to determine the following constituents in the groundwater
.downgradient of the bottom ash pond, emergency fly ash and sludge storage
pond, coal storage areas and sludge disposal areas (Ravines RA and RB):
chloride, copper, iron, lead, mercury, nickel, pH, specific conductance,
selenium, sulfate, sulfide and total dissolved solids. If the quarterly reports
demonstrate significant increases (as determined by the Director, Enforcement
Division) in contamination of groundwater, the permittee shall implement
measures acceptable to the Director, Enforcement Division to control this con-
tamination. Such measures may include but are not limited to: sealing,
relocating, or alternate location of the ash pond, coal storage, and other
waste disposal areas. If the quarterly reports demonstrate no significant
increasing contamination, the permittee, after consultation and with the
approval of the Director, Enforcement Division may reduce or eliminate the
monitoring program.
In the event the permittee proposes to use new areas for coal storage or
ash sludge disposal, the Director, Enforcement Division may require additional
monitoring comparable to the above-described plan.
I. No herbicides shall be used prior to initial mechanical clearing of the Clark
County, Indiana transmission line and on the Middletown line tie-in. Main-
tenance use of herbicides shall be limited to EPA registered products used
solely on potential "conflict" arboristic species and in strict accordance
with the labeled instructions governing their usage.
J. The permittee shall provide a technical study that determines the corrosion/
erosion rate of condenser tubes during facility operation to assure protection
of aquatic organisms. A study plan shall be submitted not later than one year
prior to the commercial operation of Unit 1. Annual reports of study results
shall be submitted starting one year after commercial operation date of Unit 1.
K. Not less than 180 days prior to commercial operation of Unit 1, the permittee
shall submit a proposal for monitoring the characteristics and effects of runoff
from stabilized scrubber sludge from Ravines A and B to Corn Creek and shall
implement an approved study by the commercial operation date of Unit 1. Moni-
toring shall include ravine discharge characteristics as well as upstream and
downstream monitoring of chemical parameters and biological impact. Details
of the program shall be developed based on characteristics of ongoing research
on scrubber sludge stabilization being conducted by the permittee and others.
19 APPENDIX A, Continued
-------
DRAFT
PART III
Page 20 of 20
Permit No. KY0041971
L. Additional monitoring of the cooling tower blowdown (002), material storage
runoff (005), and plant intake (008) shall be conducted at a frequency of
once per month to assure conformance with applicable water quality standards.
Parameters shall include ammonia; chloride; nitrate; sulfate; total alkalinity;
total hardness; total phosphorus; total, dissolved, settleable and suspended
solids; and total aluminum, chromium, copper, iron, lead, magnesium, manganese,
mercury, nickel, selenium, and zinc. After monitoring for a period of 12 months,
the permittee may request of the Director, Enforcement Division that the monitoring
requirements be reduced to a lesser frequency or be eliminated.
M. In accordance with Section 306(d) of the Clean Water Act (33 USC Section 1251,
et seq.) the standards of performance for conventional pollutants as contained in
this permit shall not be made any more stringent during a ten year period begin-
ning on the date of completion of such construction or during the period of
depreciation or amortization of such facility for the purposes of Section 167 or
169 (or both) of the Internal Revenue Code of 1954, whichever period ends first.
The provisions of Section 306(d) do not limit the authority of the Environmental
Protection Agency to modify the permit to require compliance with a toxic effluent
limitation promulgated under BAT or toxic pollutant standard established under
Section 307(a) of the Clean Water Act, or to modify, as necessary, to assure com-
pliance with any applicable State Water Quality Standard. This permit shall be
modified, or alternatively, revoked and reissued, to comply with any applicable
effluent standard or limitation issued or approved under sections 301(b)(2) (C) ,
and (D), 304(b)(2), and 307(a)(2) of the Clean Water Act, if the effluent standard
or limitation so issued or approved:
(1) Contains different conditions or is otherwise more stringent than
any effluent limitation in the permit; or
(2) Controls any pollutant not limited in the permit.
The permit as modified or reissued under this paragraph shall also contain any
other requirements of the Act then applicable.
N. The State of Kentucky Department for Natural Resources and Environmental Protection
has certified the discharge(s) covered by this permit with conditions (Attachment )
Section 401 of the Act requires that conditions of certification shall become
a condition of the permit. The monitoring and sampling shall be as indicated
for those parameters included in the certification.
Any effluent limits, and any additional requirements specified in the attached
state certification which are more stringent supersede any less stringent
effluent limits provided herein. During any time period in which the more
stringent state certification effluent limits are stayed or inoperable, the
effluent limits provided herein shall be in effect and fully enforceable.
20 APPENDIX A, Continued
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-------
APPENDIX B
GROUND WATER MONITORING PROGRAM
TRIMBLE COUNTY GENERATING PLANT
INTRODUCTION
The applicant will implement a ground water monitoring program, as
required by EPA, to detect escape of pollutants from waste ponds, waste
storage areas, and coal storage areas at the Trimble County site. Monitor-
ing of water wells during construction of the plant will develop a 5 to
8-year data base. This baseline data will help indicate any change in
the range of constituents in the ground water after the plant is opera-
tional. Monitoring of the ground water will be performed quarterly
during construction and monthly during operation of the plant. Quarterly
reports will be submitted to the EPA and the Commonwealth of Kentucky.
Applicable EPA-approved methods, as outlined in Methods for Chemical
Analysis of Water and Wastes (EPA, 1976), will be used to determine,
within limits of detection, various constituents of ground water.
SITE GEOLOGY
The Trimble County site is characterized by unconsolidated glacial-
fluvial deposits which are underlain by bedrock consisting of Middle
Silurian to Upper Ordovician bedrock.
Unconsolidated sediments of the Ohio River valley include granular
glacial outwash deposits that overlie the bedrock channel and a thin
mantle of fine-grained alluvium that blankets the surface of the flood
plain (Figure 5.2.1-1).
The Holocene (Recent) age layer of surficial alluvium ranges in
composition from brown, sandy silt to silty clay. The alluvium is gen-
erally from 6 to 15 feet thick throughout the upper terrace of the flood
plain, although it is up to 40 feet thick at the bank of the Ohio River.
The Holocene alluvium has been deposited on the flood plain as a result
of floods since the Wisconsin Glacial Stage.
Underlying the Holocene alluvium is a thick wedge of coarse-grained
glacial outwash deposits; the thickness of the deposits ranges from zero
at the eastern valley wall to over 120 feet in central portions of the
flood plain. The top of the outwash generally lies between elevations
450 and 465 throughout the upper terrace area. Adjacent to the Ohio River,
the outwash begins at elevation 440 in the center of the property but
falls off to about elevation 405 to the north and south of the subsurface
high spot.
The glacial outwash deposits are typically composed of fine- to
coarse-grained sand often containing some gravel or cobbles in varying
proportions. The base of the outwash deposit is usually marked by a
bed of large boulders and cobbles just above the top of bedrock. Pre-
liminary borings indicate that the top of bedrock varies from elevation
-------
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ALLUVIAL
PLAIN
OUTWASH
TERRACE'I;
LEGEND
ALLUVIAL PLAIN-SILTY & CLAYEY SANDS, CLAYEY SILTS
OUTWASH TERRACE-SILTY & CLAYEY SANDS, CLAYEY
SILTS WITH VERY COARSE-GRAINED STRINGERS
mjm RIVER VALLEY SLOPE-RESIDUAL RED SILTY CLAYS
Source: Fluor Pioneer Inc.,
1975
LOUISVILLE GAS & ELECTRIC CO.
TRIMBLE COUNTY GENERATING PLANT
SURFICIAL DEPOSITS
FIGURE 5.2.1-1
APPENDIX B, Continued
-------
APPENDIX B, Continued
327 to 342 under most of the site occupied by the flood plain, beyond the
slope of the valley wall. A generalized subsurface cross section through
the central portion of the site area is shown on Figure 5.2.2-1.
Two ravines, RA and RB, extend eastward from the river bluff at the
northern portion of the site. Preliminary borings indicate that the
bottom of each ravine contains a blanket of soil from 30 to 37 feet thick
and that the top of bedrock is near elevation 405 at the mouth of each
ravine. Soils within 5 to 15 feet of the ground surface are described as
silts and clays with variable amounts of sand and gravel. Below the
surficial material, a gray clayey silt soil of medium stiff consistency
was encountered by the preliminary borings. The presence of organic
material within the clayey silt stratum suggests a glacial lacustrine
origin of the deposit.
Bedrock units immediately underlying the plant site consist of
sedimentary strata ranging in age from Middle Silurian to Upper Ordovician.
The areal extent of these upper bedrock units is shown on the Geologic Map
of Trimble County, Kentucky, Figure 5.2.2-2. The stratigraphic descrip-
tion of bedrock units is given on the Geologic Column, Figure 5.2.2-3.
Silurian strata occur over most of the upland areas and are the
youngest bedrock formations on the plant site. These strata are princi-
pally composed of limestone and dolomite formations, interbedded with
shale members that are generally less than 15 feet thick. The areal
extent of Silurian strata on the site is limited to a very small fringe
on the eastern property boundary. As interpreted from the lower limit
of karstic development shown on a detailed topographic map of the plant
site, the base of Silurian age formations occurs at approximately
elevation 730 to 750. The base of Silurian strata has been found at
about elevation 700 at the Marble Hill Nuclear Generating Station site,
almost directly across the Ohio River from the Trimble County Generating
Plant site.
Strata of Upper Ordovician age form bedrock units throughout most
of the plant site. Directly below the Silurian contact is the Saluda
Formation, a thinly bedded dolomite unit about 63 feet thick. The Saluda
Formation is underlain by the Dillsboro Formation, a thick sequence of
limestone and dolomite interbedded with shale. Most of the carbonate
beds are thin, rather coarsely crystalline, and contain numerous fossils.
Upper Ordovician strata, collectively known as the Richmond Group (below
the Saluda Formation), and the underlying Maysville Group are both
included in the Dillsboro sequence.
The Dillsboro Formation extends from approximately elevation 680
to far below the flood plain and bedrock channel of the Ohio River
buried valley.
The Kope Formation (or Eden shale) underlies the Dillsboro Formation
at depth and is the lowest unit of the Upper Ordovician Series. The
Kope Formation does not outcrop on the site, although it is present at.
depth. Middle Ordovician, Lower Ordovician, and Cambrian strata also
occupy the subsurface domain above the Precambrian basement surface.
-------
946.7 (REV. 6-61)
DATE
CHECKED BY
FILE
REVISIONS
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N-VttLUES FROM STANDARD
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ENTRE DEPTH OF PENETRATION
NOT SHOWN
-------
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Source: Fluor Pioneer Inc.,
1975
LOUISVILLE GAS & ELECTRIC CO.
TRIMBLE COUNTY GENERATING PLANT
GEOLOGIC MAP OF
TRIMBLE COUNTY
FIGURE 5.2.2-2
APPENDIX B, Continued
-------
NOMENCLATIVE
.1 I Ahi if I'
WORKIBS
.
Dolom.le
AND LIIHOLOG'
Eolian Dcpovl*
'.' L!_'7?
'
SILT, CLAY, SAND, AND GRAVEL,
SILT, CLAY, SAND, AND GRAVEL.
J SILT AND '.AND.
LIHESTOUE, DOLOMITE, AND MINOR SHALE.
-.
'
• '. SHALE.
DOLOMITE AND LIMESTONE.
SHALE AUD DOLOMITE.
LIMESTONC AND DOLOMITE.
SHALE AND LIMESTOHE.
DOLOMITE AND MINOR SHALE AND LIMESTONE.
LIMESTONE AND SHALE.
LIMESTONE AND SHALE.
LIMESTONE AND SHALE.
LOUISVILLE GAS & ELECTRIC CO.
TRIMBLE COUNTY GENERATING PLANT
SITE GEOLOGIC COLUMN
FIGURE 5.2.2-3
APPENDIX P, Conllnuud
-------
APPENDIX B, Continued
COAL STORAGE AREAS AND SOLID WASTE DISPOSAL AREAS
The onsite solid waste disposal areas and the coal storage areas will
have a compacted native clay liner. At this time, the Applicant has not
determined what method will be used to line ravines RA and RB.
MONITORING PROGRAM
Construction Period
Monitoring of three wells during the construction period on a regular
basis will establish data to help determine and identify possible existing
pollutants. Prior to major construction activities on the site, a contractor
will put in two wells for use during construction. These wells will be
utilized for establishing baseline ground water conditions and may be
subject to Kentucky Safe Drinking Water Act requirements if the wells
regularly serve potable water to 25 persons. After installation of the
two wells, standing water levels will be measured in each well and a set
of water samples will be collected. This sampling will be accomplished
by pumping the wells for 1 hour at 10 gpm or at least until 500 gallons are
removed so that the water entering the well is from the aquifer and not
contaminated from the installation of the well itself. The water samples
will then be analyzed using approved EPA procedures. The initial samples
of the ground water from each well will undergo a complete background
analysis. The initial parameters in the background analysis to be measured
will include: silica, iron, manganese, calcium, magnesium, sodium, potassium,
bicarbonate, sulfate, chloride, fluoride, nitrate, total dissolved solids,
hardness as CaCO and non-carbonate, specific conductance, pH, copper, lead,
mercury, nickel, and selenium. Other constituents, if deemed necessary by
EPA, will be analyzed in accordance to the same standards.
The third well (No. 9 on Figure 5.3.2-2) is presently used for domestic
purposes and will also be monitored for the same constituents as above. This
domestic well, drilled 100 feet into alluvium and adjacent to the site, will
be sampled to establish any potential offsite contamination.
After the initial background analysis is performed and interpreted,
quarterly monitoring of the three wells will be initiated. Grab water
samples from each well will be analyzed by a laboratory for at least the
following constituents: copper, iron, lead, mercury, nickel, selenium,
sulfate, total dissolved solids, specific conductance, and pH. The analytical
procedures approved by EPA will be followed. If unexpected variations or
fluctuations in the quarterly analyses are found, monthly monitoring of
the three wells may be implemented.
Operational Period
Operational monitoring will be conducted on the one offsite well
(No. 9 on Figure 5.3.2-2) and six onsite wells having the general locations
presented on Figure 7.6-1. If the two wells, which are to be used to
-------
•—26 •—18
LEGEND:
32 Water well inventory number
• Inventory only
O Inventory and chemical analysis
O 1/2
±
SCALE OF MILES
LOUISVILLE GAS & ELECTRIC CO.
TRIMBLE COUNTY GENERATING PLANT
WATER WELL INVENTORY
LOCATION MAP
FIGURE 5.3.2-2
APPENDIX B, Continued
-------
PAGE NOT
AVAILABLE
DIGITALLY
-------
APPENDIX B, Continued
supply water for construction activities, generally correspond to the
above locations, they would serve as two of the six wells designated
for operational monitoring. Otherwise, six additional> wells would be
drilled down gradient of the onsite bottom ash, emergency fly ash,
and scrubber sludge disposal pond, as well as coal storage areas.
The drilling of these wells will be supervised by a geological engineer
who will detail the proper elevation for placement of the well-screen.
The expected elevation for the bottom of each well is 410 feet above
sea level. An assessment will be made as to whether a permeable zone
exists at each well at this bottom elevation. Adjustments on the place-
ment of screens in each well will be msde to detect any potential
leachate generated. All monitoring wells will be screened from the
bottom of the well to the top of permeable materials. Wells will be
properly sealed within 5 feet of the ground surface to prevent surface
water contamination.
WATER QUALITY SAMP1ING PROCEDURE
After proper completion of each well (1) water levels will be
measured; (2) each well will be pumped tc remove stagnate water contained
in the well as well as drilling contaminants (approximately 500 gallons);
and (3) water samples will be collected tc be analyzed according to EPA
standard methods. The initial set of samples for all of the wells will
be analyzed for the following constituents: silica, iron, manganese,
calcium, magnesium, sodium, potassium, bicarbonate, sulfate, chloride,
fluoride, nitrate, tctal dissolved solids, hardness as CaCO and non-
carbonate, specific conductance, pH, copper, lead, mercury, nickel, and
selenium.
On a monthly basis, thereafter, water levels will be measured in
each well; each well will be pumped for a period of time and water samples
collected for analysis. The analysis will include copper, iron, lead,
mercury, nickel, selenium, sulfate, total dissolved solids, specific
conductance, and pH. In addition, well Number 6, down gradient of the
fuel storage area, will be monitored for hydrocarbons, grease, and oil
to detect any possible spill of the fuel.
The EPA will be informed of any proposed changes to the monitoring
program. The EPA may require additional monitoring, if warranted, follow-
ing the placement of additional units on the site or following the
initiation of use of new areas for coal storage, ash, or sludge disposal
ponds. If leachate is suspected, ground water monitoring in the ravines
may be required.
Should the monthly reports demonstrate significant contamination of
ground water, the Applicant will implement measures to mitigate such con-
tamination to assure that no future contamination will occur. Those
measures acceptable to EPA may include but not be limited to: sealing,
relocating, or altering operations of the ash or sludge disposal ponds
and/or coal storage areas.
After monitoring for a period of 12 months after commerical operation
of Unit #1, if no significant contamination of ground water is found, the
permittee may request of the Regional Administrator that the monitoring
requirements be reduced to a lesser frequency or be eliminated.
11
-------
y FLUOR PIONEER INC.
APPENDIX C
EROSION AND SEDIMENT CONTROL PLAN
The proposed erosion and sediment control plan is indicated
on drawing TC-500120. The first facility to be construc-
ted will be the sediment retention basin (See Section 4.3.3) .
The sediment retention basin will contain a discharge struc-
ture as shown on drawing 317296-SKS115. Fill for the dike
surrounding the sediment retention basin will be taken from
the bottom ash storage pond area. The outer slopes of the
sediment retention basin will be riprapped immediately after
construction.
Top soil stripped from the site will be used for constructing
the aesthetic berm at the south end of the property and will
be used for establishing ground cover at other areas. Strip-
ping of top soil will be undertaken only as required for con-
struction. Top soil will be stockpiled temporarily as shown
on the Erosion and Sediment Control Plan drawing 317296-SKS115,
Another stockpile for clay, which will be used for lining the
ash and sludge storage ponds, will be located near the stock-
piled top soil. Perimeter ditches will surround these stock-
piled areas and the runoff will be directed to the sediment
retention basin via one of the three major open channels which
will traverse the site in the east-west direction.
-------
APPENDIX C, Continued
FLUOR PIONEER INC
The major earthwork activity will be the construction of the
emergency flyash and sludge storage pond and the bottom ash
pond. As the dikes surrounding these areas are being con-
structed, seeding and mulching of the exterior slopes will be
carried on concurrently. The interior slopes would not be
protected since it will be necessary to regrade and line the
slopes with clay after the dikes are constructed. During the
fill operation the top surface of the dikes will be sloped
toward the inner slope. This procedure will allow most of
the runoff to accumulate inside the diked area. Any excess
accumulation of water inside the diked area, which would ham-
per construction, would be pumped from the ponds and diverted
to the sediment retention basin.
The construction of relocated highway 1488 will require cut
and fill operations along the eastern portion of the site.
Runoff in this area will be diverted to relocated Corn Creek
at the northern edge of the site and to Barebone Creek at the
south. The graded areas within the right-of-way will be seeded
and mulched immediately after construction.
Approximately fifteen feet of soil must be removed at the loca-
tion of main plant structures. The excavation would then be
filled with compacted granular soil to the bottom of the foun-
dations. Stockpiled soil in this area would be surrounded with
perimeter ditches or hay bale diversion dikes which will direct
-------
APPENDIX C, Continued
T FLUOR PIONEER INC.
the runoff to one of the main open channels leading to the
sediment retention basin. Any water accumulating in the
excavated areas will be pumped to open channels and directed
to the sediment retention basin. Similarly, any water in the
clay borrow pit located in the vicinity of relocated highway
1488, will be pumped to open channels that lead to the sedi-
ment retention basin.
The majority of the earthwork on the site will extend over a
period of approximately five years. During this period, the
ground cover will be disturbed only as required for construc-
tion purposes. Where required, sheet runoff from disturbed
areas will be directed to the sediment retention basin.
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APPENDIX D
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
343 COURTLAND STREET
ATLANTA. GEORGIA 30308
IN THE MATTER OF
NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM
APPLICATION NO. KY0041971
LOUISVILLE GAS
AND ELECTRIC COMPANY
TRIMBLE COUNTY POWER PLANT
UNITS 1, 2, 3, and 4
STIPULATION FOR THE
APPROVAL C? THE
REGIONAL ADMINISTRATOR
Applicant
PRELIMINARY STATEMENT
The Louisville Gas and Electric Company, (the "Applicant")
has applied for a National Pollutant Discharge Elimination System
(NPDES) permit from the Environmental Protection Agency (EPA)
to discharge pollutants from the proposed Triable County Power
Plant. The application has been identified as IfPDZS No.
KY0041971. On March 19, 1975, the EPA Regional Administrator
made the determination that construction of the Triable County
Plant was construction of a new source within the purview of
Section 511 of the Federal Water Pollution Control Act (the
Act) and thereby would require an environmental review pursuant
to the National Environmental Policy Act of 1969 (STZPA) , prior
to issuance of the permit. On November 3, 1975, EPA decided
that an Environmental Impact Statement (EIS) would be necessary
for this project.
The EIS identified potentially unacceptable environmental
impacts in the form of future contingencies. The stipulations
set forth below were developed pursuant to EPA's authority and
responsibility under the Act and under NEPA. It is understood
by both parties that this stipulation has been entered into
for the purposes of preventing or minimizing potentially adverse
environmental impacts identified in the EIS and for the purposes
of obtaining EPA's recommendation to issue the perait.
-------
APPENDIX D, Continued
STIPULATION
The Applicant and the Regional Administrator, Environmental
Protection Agency, Region IV, stipulate and agree as follows:
1. Prior to start-up, the Applicant shall line the bottom
ash pond and the emergency fly ash/scrubber sludge
disposal pond to impede leaching.
2. Within 12 to 18 months after initiation of the scrubber
waste stabilization process, the Applicant shall
demonstrate to the Regional Administrator the efficacy
of its operation. If long term retention of pollutants
without significant leaching can not be demonstrated,
the Applicant shall select and submit to the Regional
Administrator for approval either a long term off-site
disposal area and waste disposal plan or a plan to modify
the on-site disposal areas to accommodate unstabilized
scrubber sludge. If appropriate, the applicant shall
also provide an acceptable interim plan to lessen or
avoid adverse impacts to the environment. If off-site
disposal is selected by the Applicant, then the.Applicant
agrees to provide a complete environmental impact
analysis (EIA) of the proposed long term plan. EPA
shall determine the proper scope of the EIA, which at
a minimum will include detailed descriptions of the
entire process including transport, control of surface
runoff, control of leachate, alternatives and a complete
projection of impacts to the natural and manmade
environments.
The applicant agrees not to initiate construction on
any portion of the plan prior to receipt of approval
from the Regional Administrator.
3. The Applicant will maintain, on site, a 30-day supply
of alternate coal of a quality which will permit
operation of one unit (s) within the emissions limits
specified in the EPA Prevention of Significant
Deterioration Approval for this plant. The Applicant
will burn the alternate supply of coal and/or follow
other operating procedures designed to operate the
station within the above stated limitation when a flue
gas desulfurization system is out of service.
-------
APPENDIX D, Continued
After 12 nonths of FGD system operating experience,
the Applicant shall submit to the Regional Administrator
for review and approval a long-tern operating procedure
and malfunction contingency plan for the operation of
the station.
4. Prior to the selection and initation of construction
of the proposed final alignment of the Clark County,
Indiana transmission corridor, the Applicant shall submit
to the Regional Administrator for review and approval
the following:
a. A plan of study (POS) for determining archaeological
resources along the transmission corridor, and
b. A POS for a ground level vegetative/wildlife habitat
survey along the transmission corridor.
The Regional Administrator shall approve or sodify
each POS following consultation with the Indiana
State Archaeologist and Director, Indiana Department
of Natural Resources, respectively. The Applicant
shall perform the studies as approved and supply
a report on the results of the studies to the
Regional Administrator for completion of EPA's
environmental review on this portion of the project.
The applicant agrees not to initiate construction
on this transmission line prior to receipt of
approval frons the Regional Administrator.
5. Except for future determinations by the Regional
Administrator on matters herein, the Applicant waives
its right to request an adjudicatory hearing on any
iteai agreed to herein.
6. Nothing in this Stipulation shall be ceened to relieve
the Applicant from liability for non-compliance with
other provisions of the Federal Water Pollution Control
act as amended, or any other federal laws, including
any requirements of the Resource Conservation and
Recovery act of 1976 which might be 3ade applicable
to this facility.
-------
APPENDIX D, Continued
7. The terms contained herein shall not bind any person
not a party to the Stipulation and shall not bind the
Applicant or the U.S. Environmental Protection Agency
until signed by the Applicant and the Regional
Administrator, Region IV.
9-22-78 LOUISVILLE GAS AND ELECTRIC COMPANY
Date
ttotn
Date
Applicant
BY:
ice President - Operations
Director, Enfo
U.S. Environme
Region IV
:ment Division
1 Protection Agency
ional Administrator
.S. Environmnetal Protection Agency
Region IV
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APPENDIX E
RE: U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
IN CONJUNCTION WITH
KENTUCKY DEPARTMENT
FOR NATURAL RESOURCES
AND ENVIRONMENTAL PROTECTION
*** *** ***
TRANSCRIPT
0 F
PUBLIC HEARING
March 28, 1978
Bedford, Kentucky
BRUCE D. HANDY
REPORTER
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
Public Hearing, U.S. Environmental Pro-
tection Agency, Region IV, in Conjunction with Ken-
tucky Department for Natural Resources and Environ-
mental Protection, held at the Trimble County Middle
School, Highway 421, Bedford, Trimble County, Ken-
tucky, on March 28th, 1978, commencing on or about
7:00 P.M., E.S.T.
*** *** ***
Mr. Charles A. Perry, Chairman
Dr. John Roth
Mr. zeller
Mr. John E. Hagan, III.
*** *** ***
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BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
OPENING STATEMENT
BY MR. CHARLES A. PERRY:
The meeting will come to order, please.
Good evening ladies and gentlemen. My name is
Charles Perry and I am the acting regional counsel
of the U.S. Environmental Protection Agency, Region
IV, Atlanta, Georgia. The regional administrator
of Region IV, Mr. John C. White, has designated me
to conduct this hearing tonight.
Tonight's hearing is concerned with
possible actions by this agency with respect to the
Trimble County Generating Station, a new facility
proposed by the Louisville Gas & Electric Company.
L.G.& E. has applied for a National Pollution
Discharge Elimination System permit for this fac-
ility.
issuance of such a permit for these new
source generating units is a Federal Act requiring
compliance with the provisions of the National
Environmental Policy Act of 1969. This Act requires
an agency of the Federal Government to prepare an
environmental impact statement whenever the agency
proposes to take Federal action significantly
affecting the quality of the human environment.
Accordingly, the EPA has commissioned
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APPENDIX E, Continued
facility, and further, the permit requires compli-
ance with these limits on initiation of the discharge.
Let me emphasize at this point that the
NPDES permit is the basic enforcement tool for water
pollution abatement, and the NPDES permit imposes
strict legally enforceable limitations on the dischar-
ger .
Once the permit is issued, the discharger
is legally bound to meet its requirements and any
violation may subject the permittee to criminal and
civil penalties.
Mr. Charles H. Kaplan, coordinator of the
Thermal Analysis Unit, Region IV, EPA will discuss
the NPDES permit for this facility later this even-
ing.
The pollutant limitations and other con-
ditions of the draft permit are tentative and open
to comments from the public at this hearing.
We have made available for distribution
here this evening a summary draft environmental
impact statement for the Trimble County facility,
copies of the Public Notice and NpDES Fact Sheet,
and agenda for this hearing.
Each of these documents, as well as
other relevant documentation and all comments
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
received tonight or submitted in writing within
the next two weeks, will become a part of the
administrative record concerning the Trimble County
facility.
The information in the record will be
used to determine the environmental compatibility
of permit issuance and to prepare a final NPDES
permit.
This permit would be included in the final
environmental impact statement.
In addition, you should be aware that all
substantive comments from the public on the Trimble
County facility and the draft environmental impact
statement, whether received here tonight and trans-
cribed for the record or submitted in writing direct-
ly to EPA, will be summarized and addressed in the
final environmental impact statement.
Before we proceed further, let me say
that I am aware of citizen concern about present air
quality in and near Madison, Indiana. This matter
bears upon our deliberations tonight because of the
proximity of the proposed giant to Madison.
Shortly, I will ask a representative
of EPA Region V office in Chicago to inform this
hearing of present compliance activities of the
Clifty Creek Station and what you can anticipate
-7-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
in the future regarding this matter.
With that, I would like to recognize
Doctor John Roth, Commissioner of the Bureau of
Environmental Quality, Kentucky Department of
Natural Resources and Environmental Protection.
DR. JOHN ROTH: Good evening, ladies
and gentlemen. My name is John A. Roth, I am the
Commissioner of the Bureau of Environmental Protec-
tion, Kentucky Department for Natural Resources and
Environmental Protection.
I am representing the Department as
cochairman of today's hearing and we welcome the
opportunity to participate in the hearing to con-
sider construction of Louisville Gas & Electric's
units one, two, three and four, with the Region IV
of the United States Environmental Protection
Agency.
The Department's purpose for being
here today is two-fold:
One. To provide input to the hearing
record by staff and.
Two. To carefully evaluate the testi-
mony offered at this hearing in regard to the statu-
tory and regulatory requirements of the Department.
The representatives of the Department
-8-
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REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
MR. TED BISTERFELD: Thank you,
Mr. Perry.
Good evening ladies and gentlemen. I
am Ted Bisterfeld, EPA Project Officer for the Environ-
mental Impact Statement on the proposed twenty-three
hundred forty megawatt coal fired Trimble County
Generating System.
The National Environmental Policy Act
requires that the responsible Federal official
prepare a statement of environmental impact, known
as an EIS, for all major Federal actions signifi-
cantly affecting the quality of the human environ-
ment.
The purpose of the EIS is to provide
government agencies and the public with information
to insure appropriate environmental iipacts are
considered in the decision making process on
Federal actions.
EPA's Authority to prepare an EIS is
stated in Section 511 Part C of the Federal Water
Pollution Control Act as amended, 1972.
Two actions by EPA under this Act are
defined as major Federal actions, one of these is
the issuance of a new source wata: discharge permit.
For these actions, the responsible
-10-
BETTY M WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
official, in this case the Regional Administrator,
must determine if the potential for significant impacts
exists.
If so, then an EIS must be prepared.
In the case of the Trimble County Project,
the issuance of the new source NPDES permit has been
determined to significantly affect the quality of the
human environment.
Louiville Gas & Electric have also
applied for a construction permit from the Corps of
Engineers to allow work below normal pool level
within the Ohio River.
This is also a major Federal Action
subje± to the National Environmental Policy Act.
EPA has accepted the role of lead agency
for preparation of the EIS and the Corps' Louisville
Office has assisted in the EIS preparation.
The EIS preparation process utilized
what we call the third prty concept.
Louisville Gas & Electric nominated
Dames and Moore to be the environmental consultant.
EPA reviewed and subsequently approved
this firm on their objectivity and qualification.
Dames and Moore was retained by Louisville Gas &
Electric, however, EPA directed the consultant in
-11-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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the preparation of the EIS.
EPA retains responsibility for the con-
tent of the EIS.
Briefly, I would like to explain the for-
mat of the EIS. The magnitude of the proposed pro-
ject required a detailed assessment of many potential
areas of impact.
The preliminary draft was too bulky and
complex for general distribution. Therefore, an
eighty-one page draft EIS was developed by summariz-
ing the two volume supporting report.
This procedure is consistent with recent
Council on Environmental Quality Directives to reduce
paper work and make EIS's more readable.
The EIS process began by defining the
purpose for the station. The need for power section
was developed to provide the laymen with sufficient
information, in understandable terms, to evaluate
Louisville Gas & Electric Company's premise for
needing to construct new generating capacity.
An independent consultant and the
Federal Power Commission reviewed this information
prior to the issuance of the draft EIS.
The second most important element in the
process was to investigate non-structural and struc-
-12-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
tural alternatives.
The alternate siting analysis initially
considered seventeen sites. Trimble County was
determined to be an environmentally and economically
suitable site upon which to do site specific investi-
gations.
Data on the background environment and
•ite specific projections of jqpact were performed.
The supporting report covers all identi-
fied impacts in detail.
The summary draft EIS emphasizes the
primary operational impact, that is the impact on
s v
air quality. Many citizens and several conserva-
tion groups have provided EPA Region IV, with con-
structive comment on this key issue.
As a result, a concerted effort was made
to assess this complicated issue with the best pre-
dictive models presently available to Region IV.
The draft EIS was made available to the
public on February 23rd, 1978. Delays were realized
in completing this EIS because the August, 1977
amendments to the Clean Air Act required another
review of the project.
Although the Clean Air Act requirements
are exempt from the National Environmental Policy
-13-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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Act, the EIS was delayed so the additional analyses
could be included.
The draft EIS contains a section on
mitigative measures. Our efforts in this regard
are not completed until we have your comment.
Your suggestions in this matter will
be given careful consideration.
It should be understood that this
draft impact statement represents EPA's assessment
of the project and proposed action.
The decision has not been made regard-
ing permit issuance. That decision will be printed
in the final EIS.
Your comments on this decision will
likewise be given careful consideration.
Please be specific in your comments
to the extent possible. Any comments you may have
on improvements to the format or content of the
EIS would also be appreciated.
EPA desires to make the EIS process
responsive to the public.
The commenting period on the draft EIS
will officially close April 10, 1978. Comments
received by that date will be considered as if they
had been presented here tonight.
-14-
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APPENDIX E, Continued
ladies and gentlemen, my name is Charles H. Kaplan.
I am employed by the U.S. Environmental Protection
Agency as coordinator in the Thermal Analyst Unit
of the Water Enforcement Branch for the Region IV
office.
I am headquartered in Atlanta, Georgia.
It is my responsibility to draft National Pollutant
Discharge Elimination System permits for power plants
in the Region IV area.
As you know, one of the purposes of this
hearing is to acquaint you, the public, with the con-
ditions of the proposed permit for the Trimble County
Power Plant.
At the registration desk there are copies
of the public notice and Fact Sheet for the facility.
Under the provisions of the Federal
Water Pollution Control Act, as amended, a discharge
must meet two different sets of criteria.
The first is that the effluent must
meet the requirements of the effluent guidelines
and standards for the steam electric power generating
point source category which were promulgated on Octo-
ber 8, 1974.
The second is that the discharge when
viewed in conjunction with other discharges into the
-16-
BETTY M. WILSON
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APPENDIX E, Continued
Ohio River and Corn Creek must not violate the
Kentucky Water Quality Standards.
Applying these requirements to the Trimble
County Discharge gives rise to the effluent limita-
tions included in the draft permit.
The proposed permit contains limitations
on the amount of pollutants such as total suspended
solids, 5-day biochemical oxygen demand, chlorine
residual, fecal coliform organisms, and heat which
may be discharged into the Ohio River and Corn Creek.
The fact sheet contains copies of the
proposed effluent limitations, and special conditions
to assure that the plant is constructed and operated
in an environmentally acceptable manner.
A map of the plant site is included a*
attachment A to the fact sheet.
There will be four units at the Trimble
County Plant when construction is completed. These
units are in the design stage and are classified as
new source units.
As new source units, they will have to
meet EPA's most stringent requirements. The waste
treatment facilities that are proposed by Louisville
Gas & Electric will meet these limitations.
in order to meet the limitations proposed
-17-
BETTY M. WILSON
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14
16
17
18
19
20
21
22
23
24
APPENDIX E, Continued
in the permit, Louisville Gas & Electric will provide
the following waste treatment facilities:
First. Cooling towers are proposed for
removing waste heat from the condenser cooling water
and dissipating it directly to the atmosphere rather
than to the Ohio River. Cooled water will be recycled
to the condensers for reuse and only a small portion
will be discharged to the Ohio River.
Second. A settling pond has been proposed
for neutralization and sedimentation of construction
runoff, and material storage runoff prior to discharge
to the Ohio River. Effluent from a construction
stage sewage treatment plant will also be discharged
to this pond on a temporary basis.
Third. Treatment ponds have been provided
for neutralization and sedimentation of runoff from
the sulfur dioxide scrubber sludge storage ravines
prior to discharge to Corn Creek.
Fourth. An ash pond is proposed for
equalization and sedimentation of all other waste
streams from the facility. Individual waste streams
will receive necessary pretreatment prior to discharge
to the ash pond. However, it should be noted that
there will be no discharge from this ash pond to the
Ohio River.
-18-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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23
APPENDIX E, Continued
On January 4th, 1978, the Kentucky
Division of Air Pollution Control received an appli-
cation from Louisville Gas & Electric to construct
a four unit, two thousand three hundred and forty
megawatt coal burning power plant to be located in
Trimble County near the Community of Wise's Landing.
Therefore, pursuant to Kentucky Air Pollu-
tion Control Regulation 401, KAR3:010, Section 7 (1)
(A). The Division of Air Pollution Control initiated
a review of the application to determine if a permit
to costruct could be issued.
Generally, the review included a determina-
tion as to whether the new units would comply with
Federal New Source Performance Standards of Emission
Limitations and allowable increases in pollutant
ground level concentrations for the prevention of
air quality deterioration.
similarly, the review included a deter-
mination as to whether the new units would cause
National Ambient Air Quality Standards to be exceeded.
More specifically, Federal New Source
Performance Standards for pollutant mass emission
limitations and National Ambient Air Quality Standards
apply to the pollutants particulate, sulfur dioxide,
and nitrogen oxides.
-20-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
1
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25
APPENDIX E, Continued
record opacity for reporting periodically to the
Division of Air Pollution Control.
Sulfur dioxide.
The allowable emission rate for sulfur
dioxide is one point two pounds per million BTU heat
input. This is equivalent to five thousand eight
hundred twenty-one pounds per hour of sulfur dioxide
from each of units one and two, and seven thousand
nine hundred thirty-three pounds per hour from each
of units three and four when operating at rated capa-
city.
Assuming a coal of four point three percent
sulfur and ten thousand four hundred fifty-five BTU'a
per pound heat content, a control efficiency of
eighty-four point six percent would be required.
The company proposes to install flue gas
desulfuriattion systems whose performance is guaranteed
by the manufacturer to be ninety percent.
At the present time, Louisville Gas &
Electric favors limestone based FGD systems.
Also, Stack Instrumentation will be re-
quired for continuously monitoring and recording thei
sulfur dioxide emission rate from each unit.
Nitrogen oxides.
The allowable emission rate for nitrogen
-22-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
oxides is point seven pounds per million BTU heat
input. The boilers will be purchased with a design
guaranty that nitrogen oxides emissions will not
exceed point seven pounds per million BTU heat input
at all loads.
If source testing indicates that emissions
will exceed those allowed, the units would have to be
derated to meet the standard. Instack monitors for
continuously recording nitrogen oxide emissions will
be required for each unit.
I will now like to go to the air quality
analysis form in conjunction with this review.
Dispersion modelling to estimate particu-
late and sulfur dioxide ground level concentrations
has been performed. The analysis used allowable
pollutant mass emission limitations as defined by
Federal Standards of performance for new stationary
sources.
The results of this analysis are summar-
ized as follows:
This is a table form so we are going to
handle it this way. Let's look at the pollutant parti-
culate. The annual standard for particulate is seventy
five micrograms per cubic meter.
The contribution from L.G.& E. would be
-23-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
point five micrograms. When you add the background to
that, you get fifty-seven point five micrograms well
within the standard of seventy-five on an annual average
The twenty-four hour standard for particu-
late is two hundred and sixty micrograms per cubic
meter. The secondary standard is one hundred and
fifty.
The value predicted by modelling the pro-
posed L.G.& E. Plant unit one thru four will be nine
point six micrograms.
When you add that to the existing back-
ground in the area you will get one hundred and thirty-
three micrograms within both the primary and secondary
standards.
Now, let's look at sulfur dioxide. The
annual standard sulfur dioxide is eighty micrograms
per cubic meter. When you add the contribution from
all units, you will get six point one micrograms. Add
that to the existing background, you have forty-six
within the standards of eighty.
Looking at the twenty-four hour standard
for sulfur dioxide. The standard is three hundred
sixty-five micrograms. You look at the contribution
from the proposed facility, one hundred and fifteen
point seven micrograms.
-24-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
Add to the existing background, two hundred
and twenty-eight, within the standard of three hundred
and sixty-five.
Now, look at the three hour standard for
sulfur dioxide. The secondary standard standard
is thirteen hundred cubic meters. The L.G.& E.
contribution to the three hour standard is seven
hundred and seventeen micrograms.
Added to the background you would have
a thousand and forty-eight micrograms per cubic
meter, still within the acceptable three hour standard.
The air quality analysis did not stop.
It also included modelling to predict the interaction
that could be expected between the proposed L.G.& E.
Plant and the existing Clifty Creek Power Plant.
The Clifty Creek Plant is located in
Indiana near Madison and is approximately seventeen
kilometers north of the proposed L.G.& E. site.
The only expected areas of plume inter-
action between the two plants are north of Clifty
Creek and south of L.G.& E. That is a hundred and
sixty-three radial or a hundred and eighty-three
radial. The results of this analysis are summarized
as follows:
If you will look at the twenty-four hour
-25-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
standard, remember I said that twenty-four hour stan-
dard was two hundred and sixty micrograms. The con-
tribution from Clifty Creek, north of Clifty Creek
would be one hundred and eighty-two.
L.G.& E. added to that would be eight poin
five for a total of one hundred and ninety-point five
micrograms.
Now let's look at the three hour standard.
You remember I told you that was thirteen hundred. if
you look at contribution from Clifty Creek, it's three
hundred and sixty degree radial, one point five kilo-
meters from the Clifty Creek Plant, it's fourteen hun-
dred and fifty-six, an existing violation of an
standard.
L.G.& E. contribution at that point will
be an additional forty-five micrograms for a total
of fifteen hundred and one microgram at a point one
point five kilometers from the Clifty Creek Plant
north of the Clifty Creek Plant.
We will go through the impact south plant.
The twenty-four hour standard shows Clifty Creek
to be adding seventy micrograms at a point eighteen
kilometers due south of Clifty Creek.
L.G.& E. will be adding forty micrograms
for a total of one hundred ten on a twenty-four hour
-26-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
standard within the limitations.
The three hour standard, Cliffy Creek will b<
adding - - I'm sorry, three hundred and seventeen from
Clifty Creek and three hundred and fifty from L.G.& E.,
for a total of six hundred and thirty-three. That is
within the standards.
Remember, I am talking about at this point
when I am talking about L.G. & E., I'm talking about th
impact from all point four proposed units.
These results indicate that Clifty Creek
Sulfur Dioxide emissions are causing the three hour
secondary ambient air quality standard of thirteen
hundred to be exceeded more than once a year and that
the proposed L.G.& E. Plant could significantly exacer-
bate this violation when all four units are operated
simultaneously.
A significant impact for a three hour aver-
age is defined as twenty-five or more micrograms per
cubic meter.
Although at the time of this review, the
Federal Environmental Protection Agency had delegated
authority to the Kentucky Division of Air Pollution
Control to assure that no significant air quality
deterioration would occur, Region IV EPA has retained
PSD Review Authority since they performed the initial
-27-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
review prior to the Clean Air Act Amendments of
August, 1977.
However, the analysis performed by the
Division indicates that the twenty-four hour and three
hour sulfur dioxide PSD increments will be exceeded
if the one point two pound per million BTO standard
is not reduced to an acceptable standard of point
eight four pound per million BTU.
With respect to performance testing.
A stack test to prove compliance with
applicable emission standards will be required for
each unit within sixty days after full load is reached
but not later than one hundred eighty days after start
up.
The test procedures and results are subject
to the review and approval of the division.
Likewise, the policy of the division
requires on-site observers from the division during
the testing to confirm actual operating parameters
and satisfactory testing procedures.
Conclusion.
Based on the information submitted in
the L.G.& E. Construction permit application, the
Division of Air Pollution Control has concluded that
no emission limitation or ambient air quality standard
-28-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
We are of the opinion that if the Clifty
Creek Plant met the current state implementation plan
requirements or was on an acceptable schedule to
achieve compliance prior to the time the proposed units
would come on line, then construction approval could b
given.
Although approval for units three and four
could not be given at this time, the division will
reserve the available PSD increments until such time
as these units are approved or disapproved.
Finally, it should be understood that each
proposed unit will be required to meet any applicable
requirements of the Clean Air Act Amendments of 1977,
Public Law 95-95, and regulations adopted pursuant
thereto.
Therefore, we will consider construction
permits for each individual unit just prior to the
time that construction of the unit commences.
Thank you very much.
MR. PERRY: Thank you, Mr. Smither.
fety+tmgf
At this time, I would like to recognize Mr. WiIlium
S. Gregory of Air Program Branch of Region IV.
A**f JM4T101
MR. •WTTTT^M S. GREGORY: Good evening
ladies and gentlemen. I am William Gregory, an
Engineer with the Air Program Branch of EPA Region iv
-30-
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APPENDIX E, Continued
the increments for sulfur dioxide emissions were
limited to point eight four pounds of sulfur dio-
xide per million BTU at peak input.
The particulate increments were protected
at the emission limit of point one pound particulate
per million BTU at peak input.
The analysis of the Trimble County Gen-
erating Station and the Clifty Creek Generating
Plant for interaction at that time did not reveal
an exacerbation of a violation of the National Ambient
Air Quality Standards based on two exceedances at an
exact location and using one year meteorological data.
The modelling result did, however, indi-
cate a violation of National Ambient Air Quality
Standards by the Clifty Creek Generating Plant.
We are aware that even with the full
year meteorological data there are still an infinite
number of interaction possibilities between these
plants.
Therefore, we are requesting the state
of Kentucky to forward their analysis for our review.
Our office will review the technical analysis complet-
ed by Kentucky for the construction permit in order to
determine whether or not our PSD approval is still
appropriate for all four units.
-32-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
Thank you.
MR. PERRY: Thank you, Mr. Gregory.
MR. ZELLER: At what time do you think
that review would be completed and we would be in a
position to know whether EPA concurs with the state
Analysis?
MR. GREGORY: I anticipate^ it shouldn't
take over three weeks.
MR. ZELLER: Thank you very much.
MR. PERRY: Thank you. At this time
I would like to recognize Mr. Clyde Baldwin of the
Kentucky Division of Water Quality.
MR. CLYDE P. BALDWIN: Good evening
ladies and gentlemen. Mr. Zeller, Commission Roth,
my name is Clyde P. Baldwin, I am Chief Sanitary Engin-
eer for the Division of Water Quality, Bureau of
Environmental Protection, Department for Natural
Resources and Environmental Protection.
As you are aware, the proposed Trimble
County Power Station which is to be sited in the
Trimble County near mile point five seventy-two on
the Ohio River is being considered here this evening.
Currently L.G.& E. operates three other
coal fired electric power generating plants in Jeffer-
son County, and it's proposing to construct a coal fire|d
-33-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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25
APPENDIX E, Continued
plant with^X four units for Trimble County.
The largest unit will be six hundred and
seventy-five megawatts, and a total of all four would
be twenty-three hundred and forty megawatts.
Unit one is proposed to start construction
in October of 1978, and to be operational in March - -
excuse me, but I left off the year. The Division
of Water Quality offers the following comments:
The Division received and reviewed the
draft environment impact statement for the generating
units in question. We also aided the U.S. Environment*
Protection Agency in drafting proposed NPDES permit.
In its present form, we feel the Federal
permit is in accordance with Kentucky Law and Water
Quality Regulations, we feel this is an exceptionally
good permit, in it provides in using the bottom ash
basin as a back-up for any equipment or personnel
malfunction within the plant.
In our review of this permit, we were
particularly interested that the five following
requirements be included:
Cooling towers to insure that no thermo-
pollution problems occur. Stabilize SL2 sludge runoff
that it be of good quality. Proper sanitary waste
treatment both during construction and during operation
-34-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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6
8
9
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12
13
14
15
16
17
19
20
21
22
23
24
25
APPENDIX E, Continued
in Chicago, Illinois. Miss Gross is with the Air
Enforcement Branch of that Region, and is an attorney
for the Branch and I would at this time like to ask
her to make a statement.
MISS LOUISE GROSS: Good evening ladies
and gentlemen. As Mr. Perry has indicated, I am here
today to briefly discuss the Clifty Creek Enforcement
situation as far as the Region V in Enforcement Divi-
sion is concerned.
First, with regard tofarticulate matter
compliance. Clifty Creek is on the schedule as a
result of the State of Indiana compliance. This sched-
ule calls for installation of electrostatic precipi-
tators on all six units.
Controls on unit six have been completed.
The original final compliance date for the remaining
five units in the Indiana Order was September 1st,
1979.
This final date is now being changed to
July 1st, 1979 as required by the Clean Air Act
Amendment of 1977.
A Public Hearing regarding this change
will be held at the Indiana Air Pollution Control
Board Meeting on April 26th, 1978 at 1:00 P.M.
With regard to sulfur dioxide, the situa-
-36-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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24
25
APPENDIX E, Continued
tion is more complicated. On May 31st, 1972 EPA
approved Indiana Regulation APC13 for the control of
sulfur dioxide in Indiana insofar as those emission
limitations would be adequate to assure obtaining and
maintenance of the National Ambient Air Quality
Standards for Sulfur Dioxide.
Late in 1974 the State of Indiana revised
its regulation and promulgated a new classification
regulation called APC22, which classifies Indiana
counties according to the need for emission control.
These regulations were partially approv-
ed by the EPA Administrator with the exception of
five counties in Indiana including Jefferson County
where the Clifty Creek facility is located.
The results of this partial disapproval
of the original APC13 was to remain in session as far
as Jefferson County was concerned.
This action by the Federal EPA Adminis-
trator took place on August 24th, 1976.
In the meantime, several utilities have
*PC
challenged both the new and the old «*fr 13 as well as
the new APC22 in the Circuit Court for Marion County.
On November 10, 1975 this state Court in-
validated all challenged regulations, "For failure to
comply with the proper procedural requirements in
-37-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
violation of the limitation of Indiana Statutes
governing the adoption of these rules and regulations".
The decision was appropriately appealed to
the Indiana State Appellant Court and all pertinent
briefs have been filed since October of 1976.
Pending this determination on appeal,
EPA elected not to enforce the State Sulfur Dioxide
Regulation, recognizing that issues of economic and
technological feasibility have been raised in the
State Court and that at least some cloud was cast on
the consideration given these issues by the adopting
agency.
The state of Indiana at that time represent
ed that new sulfur dioxide emission limitations would
be passed expeditiously while the State Attorney Gen-
eral indicated to us that the Appellant Court determine
tion which we were waiting for would soon be forth-
coming .
However, neither of these options have
materialized as of today. As a result of this, the
U.S. EPA is now reassessing its position with respect
to the enforcement of the sulfur dioxide regulations.
Alternatives which we are presently con-
sidering include litigation and Federal promulgation.
Please be assured that EPA Region V offic«
-38-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
is indeed sensitive to the situation and we intend to
vigorously pursue all available options.
Thank you.
MR. PERRY: Are there any other Federal
or State officials here tonight that would like to
make comments? I don't see anyone.
Are there local elected officials who
would like to comment at this time? No one, all right.
Let me make just a brief statement con-
cerning the conduct of the hearing and set some
ground rules.
We have now completed these presentations
by the socalled governmental agencies involved and we
will now proceed to the real purpose of this evening's
hearing, the receipt of public comments.
It is an expressed goal of both the Federal
Water Pollution Control Act and the National Environ-
mental Policy Act to encourage and provide for public
participation and input into the determinations re-
quired by those statutes.
The draft environmental impact statement
and NPDES permit, are, therefore, being discussed in
this open public forum to encourage full participation
of the public in the decision making process, to deve-
lop greater responsiveness of governmental action to
-39-
BETTY M, WILSON
REGISTERED PROFESSIONAL REPORTER
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22
23
24
25
APPENDIX E, Continued
public's concerns and priorities, and to develop
improved public understanding of the Trimble County
facility and the actions this agency has proposed with
respect to this proposed facility.
The hearing is being conducted pursuant
to forty code Federal Regulation Section One Twenty-
Five point Thirty-Four of our regulations and should
represent to you an opportunity to make your views
with respect to the project known to the governmental
agencies charged with the responsibility of making
decisions concerning this plant.
Notice of this public hearing was publish-
ed in the Trimble-Banner-Democrat and in the Louisvili*
Courier Journal on February 16, 1978.
In addition, copies of the public notice
were mailed to each of those individuals or organiza-
tions on the EPA mailing list as well as to all
appropriate governmental agencies.
Before I proceed further, I would like to
ask everyone here who has not already done so to
register, to please do so before you leave. We ask
that you register so that we can keep a record of those
in attendance, and also that we can send you a notice
of our determinations regarding this facility.
EPA personnel are at the registration
-40-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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21
22
23
24
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APPENDIX E, Continued
at the door and will tak« your registration card.
Those of you who would like to be added to our mailing
list should check the appropriate box on the card.
If you have not already registered, and
wish to make an oral statement today, would you please
register your intent at this time.
A complete agenda of this meeting is also
available at the registration desk for all parsons who
would like to have one as well as a copy of the Public
Notice and Fact Sheet, and the summary draft environ-
mental impact statement.
This hearing will be conducted informally;
formal rules of evidence will not apply and both oral
and written comments will be accepted.
Any and all persons present and desiring
to make oral comments or to submit written comments
will be afforded an opportunity to do so.
If you have a written statement which
will accompany your oral presentation, I would ask
that we be given a copy of that written statement
prior to your beginning.
If you have a lengthy written state-
ment, I ask that your oral presentation be in summary
form if at all possible. Oral presentations should
be limited to seven minutes or less and I may inter-
-41-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
rupt and cut such presentations short, if necessary,
for those presentations that exceed this limit.
Members of this panel may ask questions
of any person presenting oral comments where it is
felt necessary to clarify the nature or substance of
the comments of any part thereof.
However, I would like to emphasize that the
audience will notbe permitted to ask questions of those
persons commenting for the record.
As we proceed with the agenda, I would like
to ask each person making a statement to step to the
microphone, state his or her name and the interest or
organization that you represent.
This hearing is being recorded by a Court:
Reporter for future transcription for the record.
In addition to all oral, written comments
submitted tonight, the comment period on the draft
environmental impact statement remains open for an
additional two weeks, and allows the submission of
further comments.
We will hold the written record of this
hearing and any other comments received as a matter of
public record at the Regional Office of EPA in Atlanta.
At this time, I would like to recognize
the Louisville Gas and Electric Company representative
-42-
BETTY M, WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
The load forecast, published in the EIS
reflects an era of moderate load growth, as compared
to the rapid growth actually experienced during the
sixties and early 1970's.
While one year's load experience is hardly
conclusive proof of the accuracy of a forecast which
spans more than a decade, the 1977 summer loads, which
have been experienced since the data was compiled for
the EIS, indicates that the load forecast as set forth
in the EIS is reasonable and that there is no evidence,
based on such exprience, that the forecast should be
modified.
The eighty-six degree design base peak was
seventeen hundred and forty-eight megawatts, as compare 1
to seventeen hundred and seventy-eight megawatts fore-
casted for the 1977 summer season.
Thus, the design base peak load for 1977
is within approximately two percent of the forecast
and well within acceptable deviation tolerances which
may be expected to occur from year to year.
Moreover, it is important to note that the
economic and weather conditions during the 1977 summer
were representative of the conditions on which the
forecast is based.
The winter demand loads have not been
-44-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
The inability of coal handling equipment
and boiler auxiliary equipment to handle wet and frozei
coal at normal firing rates reduced the output of
generating units up to thirty percent at times when
temperature related loads were placing maximum demands
on system capacities.
Aside from the shortages of fuel occasion-
ed by the UMW Coal strike, the overall capacity sit-
uation in the midwestern region became so critical
during the week of January 9, 1978, that a number of
electric utilities within the area were calling for
load reductions and rationing of electric supplies
because of the deficiency of capacity.
The interconnected electric system became
overburdened to the extent that electric clocks were
running twenty-eight seconds slow at one point,
indicating a capacity deficiency of thousands of
megawatts.
Similar situations occurred for sustained
periods during the weeks of January 10 and January
17, 1977, when due to heavy weather related electric
demands coupled with coincident equipment deratings
and forced outages of substantial magnitude across
the area, emergency load relief measures were necess-
ary and time errors of up to twenty-nine point four
-46-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
seconds were accumulated.
This past summer, during the week of
Jiy 18, area loads again exceeded the available
capacity within the ECAR Region, requiring the emergenc
import of substantial amounts of power from outside
the area.
These instances have dramatically demon-
strated that there is not enough excess generating
capacity in the area, and without the timely installa-
tion of proposed generating units, there will be a
deterioration in the reliability of electric supplies
which could create serious economic and social
problems for the area.
At this point I would like stop my pre-
pared statement and make the following statement in
lieu of the statement that was made by Mr. Smither
of the Kentucky Department of Natural Resources and
Environmental Protection stating that there is a
significant interaction between the Trimble County
and Clifty Creek Plants, appears to be in conflict
with information developed by the EPA and presented in
the EIS.
We are asking that EPA examine the
validity of the analysis and data developed by the
Kentucky Department of Natural Resources and Environ-
-47-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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25
APPENDIX E, Continued
mental Protection.
And we would like to submit the handwrit-
ten statement as part of our written statement.
In conclusion/ the company is of the
opinion that the environmental impact assessment has
adequately and properly considered all significant
environmental aspects of the proposed installation
and that the Trimble County project can be construc-
ted and operated within acceptable limits of environ-
mental impact by the use of the-state-of-the-art-
technology it has agreed to incorporate in the station
design.
Further the company believes that the need
for additional generating capacity in its electric
system in the amount proposed to be installed at this
site is reasonable and compelling.
The company/ therefore/ respectfully
requests the acceptance of the environmental impact
statement as drafted and the timely issuance of the
necessary permits required for preceding with such
construction.
MR. PERRY: Thank you, Mr. Somers,
question from the panel.
MR. ZELLER: I would like to have it
as a comment than a question.
You did indicate earlier that the EPA
-48-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
will evaluate the project and as Mr. Smither outlined
as a very excellent statement we expect to have that
done within a reasonable time, as have other speakers
also indicated that indeed much of the problem relative
to the Trimble County Plant and the four unit» involved
are from another facility, Clifty Creek and I think I
detected some good news in that regard in terms of
appropriate action that will be taken, but I just want-
ed the record to show that yes, EPA certainly will
evaluate the information submitted by the state.
We have a great deal of respect for the State of
Kentucky in their model *t work, they do an excellent
job.
MR. PERRY: Thank you.
DR. ROTH: Mr. Somer, I would also like
to indicate that I believe Mr. Smither indicated that
he intended and our Air Quality Division intends to
do additional modelling to verify result and to further
emphasize the situation, and we welcome the review
by Region IV of our work.
Furthermore, our problem which we have
is the fact that even though Region V is reviewing the
specific situations including a portion of our prob-
lem we have no indication of timeliness with which
appropriate solution will be forthcoming.
-49-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
MR. PERRY: Thank you for your comments,
We will now proceed with the public comment period.
I would first like to recognize Mr. W.
F. Grote, and as we go through these, let me note a
couple of things.
First of all, these cards are noted in
the order in which you registered, so that the order
in which you registered and got here will be the
order in which you will be called to speak.
And secondly, if I mispronounce someone's
name, please forgive me, it's not intentional.
MR. WALTER GROTE: My name is Walter
Grote, I have been in the manufacturing business
approximately all my life, over fifty years. I am
a resident of Madison, Indiana. I have been a member
of Save The Valley from its inception.
I have been aware of the pollution prob-
lem including sulfur dioxide if that exists in our
area. It was hard to believe that Louisville Gas and
Electric is planning on building a still bigger pollu-
ter a few miles down the riwr of the existing plant.
Not only another coal fired polluter,
but one twice the size of that which we now have.
There are four major reasons why Louis-
ville Gas and Electric has disqualified itself from
-50-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
Wise's Landing.
This impact statement, this has been going
on for several years. Mr. Royer made the statement
that it will be made public by August. We have to
wonder what changes are being made to meet objections
as they come up.
The first major reason for disqualifying
L.G.& E. is they stacked the deck by giving a contract
to the environmental impact study to floor Pioneer
Incorporated.
Major objection reason number two.
Top officials of L.G.& E. tell us, the local people
here, how successful their scrubbers operate at the
same time hedging on the various prospectuses for
the sale of common preferred stock by saying that the
scrubbers were designed to remove by saying they
believe the scrubbers would remove. In no case
did they state positively that the scrubbers would
do the job, and yet in talking to us, they didn't
qualify, they said they were successful, but when
it got to legal language they hedge.
Major reason number three. Royer,
vice president of Louisville Gas and Electric telling
the Beford Rotary Club three major reasons for
choosing Wise's Landing. He did not tell the
-51-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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23
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APPENDIX E, Continued
truth and misrepresented.
Major reason number four. The data
given to Teko and Keene River number four which is
the critical unit for them and securing approval
in the Jefferson County area is not truthful and
constitutes misrepresentation.
I will now cover the four major reasons.
Major reason number one. During the
past four years many moves have been made by Louis-
ville Gas and Electric and EPA that raise certain
questions in our minds. It looks to us that this
is not an environmental study as such, but by their
actions an attempt is being made to maneuver L.G.& E.
into a qualifying position.
The first official notice that this
environmental impact study was a step in granting
the permission of L.6.&E. was a letter from the
Atlanta office from EPA stating that L.G.& E. had
given a tentative, a tentative contract to make the
study to floor Pioneer Corporation.
This letter from EPA added various ques-
tions in our mind as to what was going on between
EPA and L.G.& E.
The stdement in this letter that the
contract was tentative is not the truth. We knew for
-52-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
some time that actual work had been performed on
both the air and water study.
We had already learned that the Floor
Pioneer Corporation had contracted to make this very
sensitive study which would affect the Health, Safety
and Welfare for the people in our area.
Our lawyer is presenting our protest to
EPA, cited a Court decision for this situation wherein
the Court spoke of the danger of stacking the deck.
The statement that Doctor Cassidy will
make, he points out an historical connection between
L.G.& E. and Floor Pioneer as a factor that they
had over - - had several hundred of millions of
dollars of contracts with L.G.& E. that would likely
be part of the work on the plant if it was built.
This in our opinion is a despicable conflicjt
of interest, not only a conflict of interest, but
despicable when the issue is our health.
We, because of some actions and maneuvers
on the part of EPA now have the serious question as
whether or not EPA knew that actual work had been
performed on that impact study by Floor Pioneer
Corporation, that it was not a tentative contract,
but actually work was performed.
we wish to ask the EPA if they had - -
-53-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
is a copy of the Trimble Banner, and he outlined a
number of counties served with electricity by L.G.&
including Trimble and Henry Counties.
Wise's Landing is in Trimble County.
We knew that it was misrepresenting the electric
of L.G.& E.. We contacted the L.G.& E. office in
Louisville. We finally talked with a man who knew the
subject. When we read up the counties mentioned by
Royer, this man said that those counties were for gas
distribution, that their electric service distribution
area did not extend the same as their gas service.
He mailed us a map which if you want to
see it I will show it to you, how much smaller their
electric area is than their gas. Right here in this
area they serve the gas, this building here I understand
is not from the electricity from L.G.& E. it is either
from Public utility from the Kentucky utility or the
Shelby Rural Electric Company.
They also - - we have Public Service
Commission protected maps that show that L.G.& E. has
a hand full of customers along the Oldham-Jefferaon
County line, just along that line they have a couple
of dozen of them. They don't extend back into
Trimble County at all, and also a few customers in
Henry County, right along the Trimble-Henry County
-56-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
line. They do not service - - I would say they
service less than five percent or four percent of
all Henry County.
That county is also served there by Ken-
tucky Utility and Shelby Coop, and all this talk
about having to expand if they build at Wise's Land-
ing, but that is the fastest part of their area, there
is no such thing.
They don't even service all of Oldham
County. The largest city in Oldham County is La-
Grange. They do not service LaGrange. They are re-
stricted there to along the river.
If the business there in the eastern part
of Oldham County increases a thousand percent, I doubt
that they will have a hundred thousand dollars more
of electricity bills.
It is not their area entirely, there
is a number of customers where the customers are
located.
The only reason that Wise's Landing is
a real good site for L.G.& E., it's a good way to
get rid of their pollution problems that they have
down in Jefferson County.
The second reason for Royer choosing
wise's Landing was the existing transmission lines.
-57-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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99
APPENDIX E, Continued
You do not get transmission lines for areas you do not
serve. For a hand full of customers along the county
line, there are approximately ninety-nine percent of
Trimble and Henry Counties served by Kentucky Utility
and Shelby Rural Electric Corporation.
Wise's Landing is isolated, it's like
being on an island surrounded by Kentucky Utility
and Shelby Rural Electric. These companies have a
monopoly. They can't expand, they've got a certain
territory, and that is where they stay.
The third reason given by Royer is the
Ohio River. It also flows the length of Oldham and
Jefferson Counties. Oldham and Jefferson Counties
are close to the coal fields, but if their plant were
built in Louisville county or Jefferson County, it
will be so located that they could account for over
ninety-percent of their dollar sales.
Reference made for reason number four.
This is something here that but all these assumptions,
if assumptions are made on data based from L.G.& E.,
&sdQ>
we question it, but the data given for €»eko on Cane
Run number four units or scrubbers is not truthful
and constitutes misrepresentation. The Teko report
is issued every few months, it is compiled under
contract by EPA. The report views a statement, the
-58-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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24
25
APPENDIX E, Continued
Teko report views the statement that because of the
Green River is frozen during the early months of
1977, they could not barge the calcium with rocks
for use in scrubbers for Cane Run number four.
About two weeks ago Doctor Cassidy and
myself went to the EPA office in Atlanta. I asked
from what point on the Green River that L.G.& E.
barges calcium hydroxide.
They cite their - - they had no answer
and finally after pressing several times, one of the
men that said I know where it is. When asked where he
said, right next door to their plant.
It's a huge plant, I don't think they
lost it.
This claim that the frozen Green River
prevented operation of the scrubbers is totally
discredited by the letter of L.G. & E. which we secur-
ed by the Public Information Act by the letter of
L.G. & E. of February 11, 1977 to the enforcement
director of EPA in Atlanta.
On page, this letter from - -
MR. PERRY: (Interrupting) Mr. Grote,
I don't want to foreclose anything you have to say,
but if you could please, we would appreciate your
summarizing so the other people here will have an
-59-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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19
20
21
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23
24
25
APPENDIX E, Continued
opportunity also.
MR. GROTE: (Continuing) Let me summar-
ize just a minute here. This is important, then some-
one else can have the floor.
This letter of L.G.& E. to E.P.A. totally
discredits the Green River business. There is no
sense thinking, it's covering up, and there is just
too many assumptions, the people in this area do not
have to trust L.G.& E. They disqualified themselves.
MR. PERRY: All right. Comments from
the panel, and I believe there will be - -
MR. JOHN HAGAN: I would like to make
one comment on Mr. Crete's statement as a point of
clarification. Mr. Grote did indicate that in the
letter to Save-The-Valley from EPA indicating Floor
Pioneer was the tentative contraction the environmental
impact statement. That is a true statement. At the
time Floor Pioneer was under contact to L.G.& E. to act
as their prime architect engineer for the design and
construction of the Trimble County Plant, L.G.& E.
proposed that Floor Pioneer because of work that they
had previously done on siting, should be the environ-
mental impact statement consultant.
Consistent with the regulations dealing
with objectivity under which we operate, letters
-60-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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20
21
22
23
24
25
APPENDIX E, Continued
sent to noninterested individuals and groups solicit-
ing their comments on the objectivity of Floor Pioneer
as an environmental consultant for EIS.
Because of the longstanding relationship
between Floor Pioneer and L.G.& E. it was deemed by
the Environmental Protection Agency that Floor Pioneer
did not con&Ltute an unbiased third party and conse-
quently the environmental impact statement contract
was not given to Floor Pioneer.
The environmental impact statement was
prepared by the firm of Dames and Moore, firm which
is widely known to the power field which is also
very widely known to the environmental field, a firm
of unquestionable competence.
There has been indication that there may
have been collusion or in some way some conspiracy
with Floor Pioneer, and Dames and Moore/ and L.6.& E.,
and EPA.
I can tell you only that when the two
engineer firms such as Floor Pioneer and Dames and
Moore are working on the same project, it is absolute-
ly imperative for the smooth operation of the project*
The data and i*formation bo freely exchanged
between the two. There have been no secrets that I
know of in our office certainly between L.G.& E. and
-61-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
— UJ -J 0
19
20
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99
APPENDIX E, Continued
EPA, or between Dames and Moore and Floor Pioneer.
We feel that this is the atmosphere of
which the environmental impact statement must be done,
it's the only environment in which such an open and
free exchange of information can be placed, and regard-
less of what anybody may think, I would not want it
any other way.
I am not aware specifically what work was
done by Floor Pioneer prior to the time that Dames
and Moore was selected as the environmental impact
consultant.
The project was already underway when the
decision was made to prepare an impact statement.
Whatever work had been done prior to that decision, I
assume had been done either by L.G.& E. or by Floor
Pioneer.
Whatever information was available at that
time was made freely available to Dames and Moore so
that they could evaluate and those portions that were
•
acceptable and pertinent were, I assume, excluded in
your EI5.
Again, the£* is a normal process of opera-
tion and 1 would not have it any other way.
MR. GROTE: Our comments that there
was prior work done on it prior to your letter, it was
-62-
BETTY M. WILSON
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APPENDIX E, Continued
not a tentative contract, what you did with Dames and
Moore has no bearing. I am saying that there is a
conflict of interest and if you knew the work was
performed, then I think you people have jeopardized
your position.
MR. PERRY: Any further comments by
the panel. I would like to re-emphasize one thing
that Mr. Hagan stated and that is to my knowledge therl
has been no conflict of interest or collusion or
conspiracy by EPA with L.G.& E. or any of the parties
involved here. If there is such collusion and
conspiracy, then I am sure the regional adminis-
trator I know would so recommend that the regional
administiation take very strong action in that regard.
The next speaker I have here is Mr. Fred
Hauck. I believe he asked to be recognized towards
the end of the hearing, but if you would like to make
a stdement now, we will welcome it.
MR. FRED HAUCK: That represents many
hours of work for many people. I can cut this down
to the time limit you suggested, by leaving out almost
two thirds of it.
MR. PERRY: I'm sorry, I was distracted.
MR. HAUCK: Didn't you say I have
seven minutes?
MR. PERRY:
If you could hold it to
-63-
BETTY M. WILSON
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APPENDIX E, Continued
about seven minutes if Mr. Bisterfeld could keep
time of that and signal I would appreciate it.
MR. HAUCK: There is a tremendous
number of man hours in this paper and I will have to
leave out about two thirds of it to hold it to seven
minutes, shall I do that?
MR. PERRY: We will appreciate it,
I think, so that everyone will have an opportunity to
speak.
MR. HAUCK: Seven minutes it will be.
We, as representatives of the Sierra Club, - - my
name, by the way is Fred Hauck, and I am an engineer,
and L.G.& E. and I are speaking, but barely some-
times, and I hope when we get through in spite of the
harsh words that I have here that we will continue to
speak both with EPA and with L.G.& E.
We as representatives of the Sierra Club
believe that our arguments have carried more than
normal weight because we are not vested interest,
nor are we trying to protect or enhance our jobs.
We don't believe EPA heard us six months
ago at the hearing in Carrollton, we will therefore
try to speak more forcefully.
We insist on our share of the common good
It would seem that some of you have forsaken that
-64-
BETTY M. WILSON
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APPENDIX E, Continued
This means that the growth pattern of the
past years tended to desert the compound pattern
established during the 1950's and '60's. When real
dollar kilowatt hour rates were falling.
We have found, for example, that L.G.&E.
actual peak demand has drawn only sixty megawatts for
each year since 1966. At this rate it will take
almost forty years to use the capacity of the propos-
ed twenty-three hundred and forty megawatts Wise's
Landing installation.
In case you don't believe your ears, I
repeat, that L.G.& E.'s average growth rate for '66
thru '77, the proposed twenty-three hundred and forty
megawatts would last exactly thirty-nine years.
We talk in terms of percentage growth
rates because it's easier to make comparisons. The
twenty-three hundred and forty megawatts works out to
about eight percent annual compound growth. That
compares with the utility oriented recommendations of
4.12 percent by Westinghouse Electric Corporation,
Alvin Weinberg's institute suggests three and a half
to four and three quarters percent.
This eight percent annual gain works out
in an average annual growth of two hundred and seventy
three megawatts per year. This in the face of the pas
-66-
BETTY M. WILSON
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APPENDIX E, Continued
eleven years growth of only sixty megawatts per
year.
In other words, the growth rate is increas-
ed about four times.
The best worded statement that indicates
how electricity use has grown over the past years
was made by an economist who was Chairman of the
Federal Power Commission task force and I am going to
read this if you don't mind.
The past growth of electricity consumption
can be attributed to three factors. An increase in
population, an increase in real income per capita,
and a decrease in the price of electricity relative to
other mass commodities.
It is the implications of this latter rela-
tionship that are generally ignored by industries, and
I think that is what L.G.& E. is ignoring.
In addition to those factors, there are a
number of new constraints on the growth of electricity
consumption. One is natural gas production was expect-
ed to drop fifty percent in its peak in 1973 until
about 1980, instead of that, it's dropped only about
ten percent.
The projection for the future as long as
1985 or something like eighteen to twenty trillion
-67-
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APPENDIX E, Continued
cubic feet.
Natural gas, by the way is still
furnishing in something like three times the number
of BTU's to the point of use that electricity is.
Several statements have been made about
air pollution, The Sierra Club went to the trouble
and expense of duplicating Technocrons excellent and
very complete studies of the movement of air masses
through the Ohio River Valley.
We sent those both to the state, Doctor
Roth I think got a copy, and John, I believe you got
a copy. We sent several copies to the EPA. By
the way, we have been trying actually for six months
since the occasion of your hearing to get an express-
ion of EPA'a thoughts on the Technocron study.
They seem to be afraid of it.
I will read this little section on con-
servation. Has L.6.& E. considered the possible long
range effect of conservation. Two ardent supporters
of the new conservation practices spoke in Louisville
just last Wednesday at the National Rural Electric
Coop Association meeting.
EPA, David Freeman and lawyer Thomas
Robert Merit made excellent statements. So I
will read these three statements.
-68-
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APPENDIX E, Continued
at the podium, I would like to ask you a few ques-
tions if you don't mind.
MR. HOCK: Go ahead.
MR. ZELLER: First of all, let me
assure you EPA always hears the Sierra Club and if
you think we haven't heard you before, I am sorry
and I will be glad to hear from you here.
MR. HAUCK: We know you didn't hear
it the last time.
MR. ZELLER: All right. Your concerns
with changing growth patterns of the utilities are
experiencing now, we have gotten a lot of opportunity
to work with I guess probably about fifty different
electric utilities at my office and it is very compli-
cated and very complex at this time right now in
terms of what are we accomplishing with conservation
and what should we look for down the road as you
probably know, most of the electric generating utili-
ties have cut back significantly from their projected
lows let's say than they may have ten or fifteen
years ago.
MR. HAUCK: Right.
MR. ZELLER: And I think in many cases
that we are waiting to see just what will happen.
I was wondering a little bit when you mentioned this
-70-
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APPENDIX E, Continued
one figure of sixty megawatts growth per year. Did
you include in that the fact that the older units
were being retired or other units were going off
line, that seems like an extraordinary small growth
pattern, I don't want to debate that.
MR. HAUCK: It is and it amazed me,
those figures came from L.G.& E. annual report and to
be sure I've got the annual report on time. I even
shot my life savings and bought three ySVi'l of their
stock so that will make me watch you extra close,
but we have to have a little levity here tonight, there
is no sense in spreading the blood all over the floor,
we can do better than that.
The sixty megawatts came from dividing
the peak load in 1966 subtracted from the peak
load in 1977 by the intervening number of years which
is eleven, I think.
I believe that L.G.& E. is thinking
thoughts that all of us thought up until I would say
four years ago.
We all thought that electricity consump-
tion had to grow ten percent every year and definitely,
because that was the only answer, but I think there is
a lot of other things now and the thing that changes
the fastest right this minute are the conditions of
-71-
BETTY M. WILSON
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APPENDIX E, Continued
I want to say, first of all, that we have
been a little doubtful that EPA really would hear us,
and I will tell you why.
When they first came out with preconstruc-
tion review and preliminary determinations for
Trimble County Generating Station, it contained in
the title the expression to be constructed near Wise's
Landing.
To be constructed, no qualifications.
This sort of surprised us. We would have thought
the proposed plan, we would have thought they might
have said it might be constructed depending, but no,
to be constructed.
This was back in October, 1976, that kind
of thing worries you, doesn't it.
Then we heard in the preconstruction - -
then we heard about this new statement, construction
scheduled to begin in July, 1978, page two of the
summary sheet of this environmental impact state-
ment that you see out here, this little green booklet.
Construction schedule to begin in July,
1978. Doesn't that show you that they made up their
minds, makes me think they didn't want to hear
us, and I raised this question yesterday seriously
because of the repeated appearance we have had.
-73-
BETTY M. WILSON
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APPENDIX E, Continued
The problem, of course, is tremendously
complicated. I would have put it very simply, L.G.
& E. wants to take their pollution problem out of
Jefferson County, Kentucky, and give it to Trimble
County.
They will let us on both sides of the
river suffer poor health and decease quality of
life so that the customers of L.G.& E. can have
power.
That is the simple statement of the
nub of the whole business.
Now, we have been deluged with all sorts
of numbers, I want to come back to some of those
numbers in a moment. This is avery dumb statement
but it is a true one.
L.G.& E. claims the plant will be nice
and clean. EPA agrees that the plant will be nice
and clean.
Now, the obvious thing that strikes us
is, is this, is the proposed plan were really so
clean, there would be no reason for bringing it out
of Louisville.
Actually the claims are that if some of
the old L.G.& E. polluting plants were replaced by
the supposedly clean units. The air in Louisville
-74-
BETTY M. WILSON
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APPENDIX E, Continued
will be improved. It just would be improved.
And then their Air Pollution Board will be glad
to welcome more industry, but L.G.& E. resists this
suggestion and the suggestion that they are placing
within their own electric service area that could
take the battle.
The fact is that the proposed Wise's
Landing Plant would not be and indeed cannot be, it
cannot be as clean as EPA requirements. There is
no, no scrubbers operating in the United States, or
as far as we could find out, anywhere else in the
world which will do what EPA requirements with a
plant this size burning high sulfur coal.
None, and the prospects are minimal
that there ever will be especially since the process
required produces an enormous amount of slough.
Now, there may be other processes that
will come along in due course which will do the
work, but there is no - - no known masses that will
do it now, and will do what EPA requires on the
basis of what they lay out in this draft environment
impact statement.
So very plainly speaking, EPA requires
construction of a plant which is supposed to meet
pure air requirements, designed to meet pure air
-75-
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25
APPENDIX E, Continued
requirements, but there is a whale of - - a
chasm between design and performance, as you know
that, you know what your marriage - - law of marriage
vowels say, that is design, performance may not be
quite as good.
And in the case of EPA cleaning up the
atmosphere, it's definitely not the case, so very
plainly speaking EPA requires construction that is
supposed to meet clean air requirements, it's known
that the plant cannot meet the EPA requirements,
that must be met if it is to comply with the law.
And so, ladies and gentlemen, the facts
are legislative. That is the old King Knute syndrome,
So that permission can be legally given to L.G.& E.
for a step in the direction of building this plant.
I tell you, the whole thing makes us
extremely uneasy. I don't want to go any further
than that, but I would like to say - - except to say
one or two things, you might ask why somebody - -
how would Cassidy live in Hanover, Indiana and
apart from larger issues, you might ask why I living
in Hanover, Indiana side of the river close to
Milton in Madison should be concerned about a power
plant ten miles away and the answer is very simple
it would pollute my air.
-76-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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20
21
22
23
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2ft
APPENDIX E, Continued
Pollution does not recognize the state
boundaries. We already have a great polluter in
Madison, the Clifty Creek Plant.
We already have more sulfur dioxide than
the whole City of Louisville and Jefferson County
in the Madison-Milton area.
It has been shown that pollution will
travel long distances, three hundred miles the fluid
from the City of Louisville is still recognized and
with good form, three hundred miles away down wind
from that city.
EPA tells us the computer modelling says
it will not be very polluted or by this proposed plan.
However, they have neglected as far as we can see to
consider these three very important studies that
Technocron has. They use the model which is called
twister and when we asked to see this model they said
they couldn't supply it to us.
Now, if you are using the model and you
won't let me see what is in it, this is as far as we'v
got, but we have got the points we wanted. They
have not considered the best modelling procedures
as far as we can determine and what w» said before.
Well this is enough. We returned to
the Kentucky Department for Natural Resources, Environ
-77-
BETTY M. WILSON
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APPENDIX E, Continued
mental Protection and we asked to not permit this
envasion to Trimble County take place, it is wrong
from moral belligerent scientific point of view to
further pollute our valley to endanger our health
and to destroy our quality of life in any way.
Please weigh the evidence and you will
see shaky grounds over which EPA and L.G.& E. are
trying to proceed against us, thank you.
MR. PERRY: Comments from the panel.
MR. ZELLER: I like your comparison
to clean air, I haven't had that before, Doctor
Cassidy, I think that is excellent.
DR. CASSIDYi That just occurred to me
that the air in here is so polluted about my previous
remark.
MR. ZELLER: 1 think we have obviously
we have an honest disagreement in terms of what tech-
efcit/fu
nology can be accomplished with flue gas «n*i*eriza-
tion «M scrubbers. We have great respect for you,
Doctor Cassidy, your academic background and your
experience in research and we appreciate your comments
EPA has spent considerable efforts in
this area and as you know based on many reports that
were published that we feel competent in terms of the
types of treatment efficiency that we come up with,
-78-
BETTY M. WILSON
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APPENDIX E, Continued
and we believe we can substantiate those.
Finally as another point very clearly
I don't believe I understood your remark there on the
modelling. Our model that we have in Atlanta in terms
of dealing with problems like this certainly operates
in the sunshine and we have no problem with this, you
or anyone else that would like to review our modelling
effort, perhaps I misunderstood you.
DR. CASSIDY: No you didn't, because sir,
because when we were there we asked about this model
and we were told it was proprietary and that was the
end of that statement.
It was something that was being done - -
MR. ZELLER: (Interrupting) Mr. Gregory,
I think this is kind of important and maybe you could
do some commenting.
MR. GREGORY: When was this happening?
DR. CASSIDY: Was it that last meeting
we had down there when I was present?
MR. GREGORY: Well, if somebody did say
that and it was a misunderstanding because you have
access to any of our models.
DR. CASSIDY: It could easy be a misunder-
standing.
MR. GREGORY: On another comment that you
-79-
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APPENDIX E, Continued
plant is talked about it is not stated the plant
will thus and such, but the plant would thus and
such, because if - -
MR. ZELLER: (Interrupting) That is a
point well taken.
DR. CASSIDY: You see, it upsets us
because we already are suspicious on account of the
other things that Mr. Grote mentioned the number of
things that you can't afford to let the public
lose faith in you by anything, especially by what
you do.
MR. ZELLER: I appreciate that, thank
you.
MR. PERRY: Any other comments from the
panel. Thank you, Professor.
Our next speaker is Mr. Harold Alsup.
MR. HAROLD ALSUP: I don't have any
written statement, but I would like to read this state-
ment and give it to you all so you can investigate it
if you don't mind.
This was in the Courier Journal on the
7th day of July, coal plant may be causing early
death in east. These are some of the conclusions
of science in the National Laboratory in New York
and at the University of Pittsburgh.
-81-
BETTY M. WILSON
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APPENDIX E, Continued
The scientists have been at work for
two years on forces of energy study in the National
Academy of Science financed by three million dollar
grant.
One or more of the striking families of
this study is that the stack gas exhausted power
plants in the midwest are roughly ten times more
harmless on the east coast than in the midwest within
fifty miles of it.
Doctor Cassidy you ought to give that a
little thought, I think it would be better off with
the power plant built within the county than it would
be fifty miles away from the county.
MR. ZELLER: Thank you, sir.
MR. ALSUP: Well now, I have also been
familiar with Save-The-Valley and I have followed
their statements and I have read them.
I have saved them, studied them, and I am
not going to go into this line, I am not a scientist and
in fact my education is very limited, but I believe I
do have enough sense to draw a few conclusions from
especially Mr. Cassidy's statements that were made
on this.
You find that each time over there, a
good deal of the time that his statements were not
-82-
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APPENDIX E, Continued
facts. Truth, or whatever you want to call it,
because they were not accepted all of them, isn't tiat
right, on one count I think you had seventeen pages
of statements and then I think seven of them were
stricken from the record.
I mean, it could be information that was
available to the case you are talking about here.
Well, I mean nevertheless, what the EPA wanted to
know, and but anyway it's the point, I am for this
power plant and I think Trimble County needs a plant,
and it doesn't matter to me whether L.G.& E. serves
this community or not.
I am just darn glad they are coming into
it, and I think it would be a benefit to the county,
this county don't have nothing. You see the schads
are quite different over here than they are over
in Madison, and I want to read a statement here from
the Madison Courier, if I might, Madison Courier.
REPORTER'S NOTE: At this
time Mr. Alsup read aloud
the article.
MR. ALSUP: Now, if that was good for
Madison, why wouldn't it be good for Trimble County
too. And I am thankful of IKE for its fairness for
our air quality to have to be cut back on account
-83-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
of what territory you are in.
I think in the State of Kentucky, Trimble
County if they don't want a power plant/ I think it's
fair, we have to take it under consideration that the
quality of air that they are putting out over there
and a lady here just got up and said about IKE
emissions and I really believe you people instead of
coming over here and telling us to Save The Valley
and I think you ought to go back home and clean up
IKE.
I think that you could use that energy
to do that and do that much better service than coming
over here and telling us about ours.
I thank you, gentlemen. I would say more
if I could.
MR. ZELLER: You said quite a bit.
MR. PERRY: Thank you, Mr. Alsup.
Our next speaker is Mr. staley B. wheater.
MR. STANLEY B. WHEATER: I live in
Hanover also, I speak only for myself as a citizen
from across the river and I am not having the deci-
sion to talk to the people of Trimble County and t«ll
them what they should do, but much concern for the
health of my community, I noticed in the environmental
impact statement some mention of Madison and quite a
-84-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
little bit mentioned of Trimble County here, and as
far as if I am reading it correctly, the studies and
models relate to, and if I heard correctly tonight,
to what happened with the north of Madison. We in
Hanover, three thousand people live there, the nine
hundred students that attend Hanover College view
IKE plant stacks and in view of the fact that if this
plant is built at Wise's Landing and the fifteen
hundred boys and girls that attend the consolidated
schooling that serves four counties and four townships
in Jefferson County, Indiana, we are concerned about
what is going to happen to us between these plants,
ten miles from this one, just a couple or three miles
from the IKE plant and I assure you over here we are
doing everything we can to get the IKE plant to cut
- - quit putting that sulfur up in the air.
They claim there is no system on earth
that can get rid of the commodity of sulfur that they
have in that sulfur coal economically and without
producing too much sludge, and that plant is only half
the size of the one that they are proposing to put
dyn here just across the river from the proposed and
already started construction on the site of the nuclear
power plant.
I too would have to say I think there is
-85-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
« a
.„
16
APPENDIX E, Continued
a general feeling that the governmental agency such
as Environmental Protection Agency and the hearings
that they have may be window dressing.
We hope that this is not true, if every-
thing - - if every plant proposed, however it's approv-
ed, if statements such as that which a meritorious
professor at large of Hanover College, Cassidy said,
that no plant of this size has ever been produced that
is getting this amount of SO2 out of the air, that is
not true, you should tell us that. If these things
are operating to fifty percent now, if this is to be
the first one in the world to be built within the
plant of within twelve miles of a plant, that we so
far haven't been able to get any way to have S02
control on, you should tell us why it has to be put
here so close to another one.
We know that the advertising fir this
meeting as was mentioned as you started, Mr. Perry,
was carried in the Courier Journal and then in the
Trimble County paper, the students at Hanover College
have not been made aware of it through local papers
and people that live in my town, although there is not
very many represented here tonight, learned about it
especially through an advertisement in the Madison
Courier signed by practically every Doctor in Jeffer-
-86-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
son County area pleading with us and pleading with you
not to allow this plant to be built. Thank you.
MR. ZELLER: I want to make a brief common
with regard to getting sulfur out of air. I think our
problems have been far more complex legally than they
have been technically.
The technology clearly exists in terms
of removal of sulfur dioxide. We have had, because of
laws and regulations, provide for due process, many,
many issues, and because there is a lot of dollars
involved, many, many issues, lies within the Court
and we have had problems there, but approaching it from
a purely technical standpoint, I think it clearly, I
can assure you that the technology to remove sulfur - -
MR. WHEATER: That is reassuring and I
thank you. What is the largest one in operation now?
MR. ZELLER: I can't respond to that,
I will have to ask some of the technologists, Ray
Gregory or John Smither, could you - - L.G.& E. has
a fairly large operating unit.
MR. SMITHER: I can't remember the sizes,
Howard, but there must be forty, fifty various install-
ation across the country today.
MR. ZELLER: I think it's higher. It
seems to me that there is something like eighty units
-87-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
across the country.
MR. SMITHER: I think ninety that have bee
approved, but I am talking about ones that actually - -
the sum phase of operation.
MR. WHEATER: Do you have any idea - -
MR. SMITHER: (Interrupting) Large units.
MR. WHEATER: Over from one point two
such as they have in - - down already at Clifty Creek.
MR. SMITHER: There is no reason the
scrubbers won't operate, if you remember my statement
if I do not feel the scrubbers were reliable to remove
scrubbers, I would not stand up there and tell you
that I thought they would.
MR. WHEATER: Thank you.
MR. ZELLER: Guess again, again the
problem with Clifty Creek is not the fact that you
cannot deal with a scrubber there, it is that a scrubbe •
has not been built there, and as I pointed out there hai
been issues that have been somewhat bounced around
since 1972 and hopefully it's reaching a point here.
We believe it's reached a point where we
will see something very positive happen.
MR. PERRY: I think there Mr. Zeller
might be trying to practice law.
MR. ZELLER: I do that every chance I
-88-
BETTY M WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
get.
MR. PERRY: I know. The next speaker
that we have if there are no further comments is Mr.
Milton Rush.
MR. MILTON RUSH: My name is Milton
Rush. I am a farmer in Trimble County and I am
concerned about the future in this area if the several
proposed electric generating plants are ever establish-
ed.
In my opinion, health, agriculture and the
quality of life will deteriorate.
Currently, there are two large electric
generating plants in our area, the IKE Plant in Madison,
Indiana, and Ghent Plant in Ghent, Kentucky.
The IKE Plant has been covering our area
for about twenty-five years with ash and sulfur dioxide
pollution.
Only recently have IKE been forced to
install tall stacks and modern equipment but we will
continue to get sulfur dioxide even if we cannot see
it.
Several large utilities have plans to
establish five more electrical generating units in
this area which would make seven in the few miles from
wise's Landing to Ghent.
-89-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
So many plants in such a small area could
produce enough acid rain to be devastating.
Although we are here tonight to discuss
only one of the new proposed plants, all of them should
be taken into consideration, rather than one at a
time.
A couple of years ago a group of citizens
from the area went to Washington, D.C. and asked our
senators for help. This has resulted in the impartial
ORBES report which we hope will be given serious
consideration.
Most of you are familiar with the farm
crops which have been damaged in western Kentucky
as a result of emissions of sulfur dioxide from a
TVA Fossil Fuel Plant.
Farmers have had to spend a couple of
years in Court in order to collect the damages.
In July of 1977, TVA officials admitted
that sulfur dioxide pollution emitted from TVA's
Johnsonville Plant destroyed about ninety acres of
soybeans in West Tennessee.
This is what I fear will happen in Trimble
County, Carroll and Henry if the Trimble County
Generating Station is built.
On July 22, 1977, the U.S. Environmental
-90-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
Protection Agency released a study by a plant scien-
tist in Corvallis, Oregon, and that study showed
that acid mist can reduce bean plant weight and
chlorophyll content up to a staggering thirty-three
percent.
Trimble County is well known for its
vegetables, apples, peaches, strawberries and tobacco,
and I wonder if a twenty to thirty percent loss in
farm income will be off set with taxes from utilities.
I am informed by officials of L.G. & E.
that this will not happen with the Wise's Landing
Plant and the environmental impact statement covers
their plans to install the latest of modern equipment.
Although these methods and equipment are
designed to remove ash and sulfur dioxide, I question
whether or not they have been proven effective.
In my opinion, Louisville Gas and Elec-
tric Company is one of the better utilities in this
country. They are to be commended on the efforts
to develop a satisfactory scrubber to remove ninety
percent of the sulfur dioxide.
I question whether their scrubber has been
successful.
The EPA'S own bimonthly report on scrubbers
in the United States indicates that there is not one
-91-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
single successful scrubber installation which has opera
ted on a large facility and removed ninety percent
of the sulfur dioxide for at least one year.
A permit should not be granted to build
the Trimble County Generating Station until positive
proof is available that the L.G.& E. scrubber is effec-
tive.
According to the impact statement, L.G. &
E. proposes to use natural draft cooling towers for the
Trimble County Generating Plant.
The best estimates that I have been able
to obtain indicate approximately thirty-two million
gallons of water will be released from these towers
each day.
Directly across the river from Wise's
Landing is the proposed Marble Hill Nuclear Barer
Plant, and it is estimated that two units there would
release thirty-four million gallons of water per day.
This makes a total of sixty-six million
gallons of water per day from a small two square mile
area.
It has been reliably reported that although
apples do not seem to be hurt by the high moisture,
peaches have suffered damages in certain years.
Tobacco is a principal crop in this area
-92-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
— UJ UJ
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APPENDIX E, Continued
and accounts for over forty percent of the crop income.
Tobacco requires an ideal climate for
curing.
I fear that sixty-six million gallons of
additional daily moisture will destroy tobacco for the
farmer in this area.
The environment impact statement does not
seem to fully cover the effects of heavy moisture on
the environment.
In the final analysis the decision on the
Trimble County Generating Station will come down to the
trade off. The question will be whether it is better to
sacrifice a few hundred farm families so that thousands
of other people can enjoy cheaper electricity.
In considering this trade off/ I hope that
the Environmental Protection Agency and the Kentucky
Department of Natural Resources will realize that
building a new power plant is not always progress and
that food, water and air will become more iportant
to our survival in the future. You cannot eat a
lightbulb.
God has blessed us with a beautiful coun-
try. Let us not destroy it.
Thank you very much for giving me this
opportunity to express my opinions.
-93-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
MR. ZELLER: Thank you for a very good
statement. I cannot respond with any accuracy in
terms of the questions you have raised about the cool-
ing /tower, but I think that is a valid question.
MR. RUSH: Farm income, this is a rural
community - -
MR. ZELLER: (Interrupting) And it makes
- - it's a reasonable assumption, and of course, that
is the purpose of this hearing is to obtain informat-
ion and to have tte input into the environmental impact
statement and I assure you that these are the kinds of
questions you will be responding to in the final
environmental impact statement.
MR. RUSH: Thank you, sir.
MR. PERRY: We have a few more speakers
and we have been at this for something more than two
hours now and I would propose that we take about a
five minute break so that everybody could stretch,
thank you.
REPORTER'S NOTE: After a
five minute recess in the
hearing, the following
was heard.
MR. PERRY: Ladies and gentlemen,
we would like for you to take your seats so we can
reconvene the hearing.
-94-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
The next speaker is Doctor Thomas D.
Breitweiser.
DR. THOMAS D. BREITWEISER: I don't
have a prepared statement, but I am actually not going
to say anything or bring up any new things that haven't
been said already by you people.
I have been to a number of these meetings
before and the EPA does their best, I think they have
printed some of the things I have said, but I would
like for you to say also that I can't see that they
have any effect on any decision that has been made,
and I expect to go to a number of these again and
I just heard out of the corner of my ear about Indiana
Power Light wanting to put one up the river here, so
all you folks will meet each other again, I suppose.
My name is Thomas Breitweiser and I am a
practicing physician in Madison, Indiana.
Now, I have written to EPA in Atlanta and
I have asked that they include the Jefferson County
Medical Society in their list of interested organiza-
tions, if one of you gentlemen will take care of that
for me. Thank you Mr. Hagan.
Now, I would like to quote from a previous
final environmental impact statement and this was for
the Portsmith Treatment Plant in Ohio, and it's on page
-95-
BETTY M. WILSON
flEGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
County Generating Plant interact with the chimney
fumes from the Clifty Creek Plant, the maximum com-
bined three hours average concentration of sulfur
dioxide in the Madison area would be two thousand
eight hundred ninety-eight micrograms per cubic meter
which constitutes a violation of the air quality
secondary standards which are one thousand three
hundred micrograms per cubic meter, and it goes on
to say that this study shows however that this viola-
tion would have occurred even if the Trimble County
Plant were not in operation as a contribution con-
tributed by this plant was only one tenths micro-
grams per cubic meter.
Then too, maximum twenty-four hour
concentration resulting from the combined emissions of
the two plants that were proposed to be four hundred
ninety-five micrograms per cubic meter in the Madison
area.
This concentration exceeds the twenty-four
hour primary ambient air quality standards of SO2;
however, the amount of SO2 contributed in violation
of the Trimble County Plant was only nine ten
thousands micrograms per cubic meter, and we are talk-
ing about a level here that is twice what I previous^
quoted, over twice that the Environmental Protection
-97-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
Agency stated was a deadly level, and it seems to me
that what this - - these last two things I'm reading
are saying is that we already have such a high level
that just a little bit more is going to be okay.
Now, I reread this several times, and I
would like for someone to explain that to me, why
don't we get rid of the bad situation we have first.
It doesn't make just a little bit more any
better, I don't understand the philosophy that goes
along with this.
We are talking about human health, and
you gentlemen here seemed to make the decisions.
What I have said in these meetings before
doesn't make any decision, you gentlemen make them,
and I don't understand the philosophies.
We have a deadly pollution for a violation
of standards yet we are having a meeting talking about
more. Why don't we straighten up what we have got firs
That is all I have, do you have any
questions?
MR. ZELLER: No, sir, I don't have aay
questions, I can agree with many of your comments, i
certainly and hopefully we have - - well, we obviously
do need to talk about cleaning up before we talk about
building any more power plants. I don't disagree with
-98-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
MR. BISTERFELD:
him with that copy.
DR. BREITWEISER:
see it?
The EPA will supply
Would you like to
DR. ROTH: Yea. Can EPA get me a copy?
MR. BISTERFELD: We have a copy - -
MR. SMITHER: (Interrupting) We have it,
Jack.
MR. PERRY: Thank you, sir, I'm sorry
for the interruption.
MR. C. L. GOSSOM: My name is C. L.
Gossora. First of all, I am from Trimble County for
some fifty-one years. First I would like to say
that I am not here to make any accusations again
EPA, any collusion or any other factors of that
nature.
I would like to speak as a native from
Trimble County. I might be in the minority, but I
believe that Trimble County needs this power plant,
and I have some reason for it.
Since back in 1840 this county started
out with some forty-six hundred people and right now
I think it's about fifty-six hundred, that is an
average probably, an increase of about eight a
year.
-100-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
I have raised six boys in Trimble County.
Five of them are of the age to work and they have all
had to leave Trimble County to seek employment because
there is nothing here for them.
we need the tax base. We n«d a new school
in Trimble County, and there has been much said about
increasing the taxes.
As most of you know we have talked almost
to the limit now. With some fruitful activity I believe
on our part this power plant that L.G.& E. proposes
to build I believe not only would build our schools
but would better our way of life.
We have the same needs, the same wants
as people in Madison have, as people in Louisville
have and as people in Cincinnati have. We may be small
in number, but we expect the same quality of life as
other people have.
If you get out here on Highway 421 and
Highway 42 at 6:00 o'clock in the morning you will see
the great transition from Trimble County, there is
very few people who work here in Trimble County who
have to go other places to work.
I would rather see a power plant in Trimble
County than I would a petro chemical plant, an aluminum
plmt or some other high employment plant for this
-101-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
reason. We would not have to spend all of our tax
base for services. We would not have to provide
shopping centers and churches and schools and that
sort of thing which would eat up the tax base.
There has been much said about the IKE
Plant. We have many of our people that work at that
plant and when it was said we have been eating the
dust for some twenty-five years, and we have received
no tax from i,t whatsoever.
Madison built about eight million dollars
worth of schools as well as I remember, the J. G. Jenn-
ings Company built the high school over there for
approximately eight million dollars and the power com-
pany paid the biggest part of that.
I have known that they have advanced money
to keep the system operating from one year to the
next.
When you talk about the Madison Plant,
you're talking about twenty-five year old technology.
Sure, there is a lot of dust, I will agree to that,
there is also sulfur dioxide, but I have every confi-
dence in the technology of our people in the United
States that they will come up with a way to solve this
problem and I have confidence in EPA that they will
force it to be done.
-102-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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25
APPENDIX E, Continued
whole lot to do with the guesstimate on the amount
of coal because of their buying power from other
sources.
The pollution in the Louisville area I
think has been proven to be mostly by automobiles,
and not nearly so much by industry as by the automobile
traffic that is in there.
Let me close with this, if the people in
Trimble County are against this power plant as a majority
then I would be against it, but let the Trimble County
decide for ourselves.
Sometimes we may be a little bit dumb act-
ing, but we are certainly not stupid. Thank you.
MR. PERRY: Any comments from the panel.
Thank you.
The next speaker is Shirley E. Clark.
MS. SHIRLEY E. CLARK: My name
is Shirley Clark and I am president of Save the Valley
and the residence of Hanover, Indiana which is just
five miles from the proposed plant.
As anyone in Hanover can tell you, there
are many days when we are a direct line from the flue
for the Clifty Creek Power Plant which incidentally
is partly owned by the L.G.& E.
And as anyone who has read the recent pub-
-105-
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APPENDIX E, Continued
lished statement by the Jefferson County Medical Socie-
ty they will tell you that this plant constitutes a
major hazard to all of us living in the Hanover-Madison-
Milton areas.
It is now proposed by Louisville Gas and
Electric to have an additional coal fired plant be built
five miles from us on the Kentucky side. Only one mile
from the proposed Marble Hill Nuclear Power Plant, a
fact that was not mentioned in the impact statement.
Any single person can imagine adversaries
in our whole area with the redoubled production of
sulfur gases and with the additional factor of some
thirty-four million gallons of water per day to be
released into the atmosphere by the proposed nuclear
plant.
Gentlemen, the people of this area have done
nothing to deserve the environmental deterioration at
the proposed plant will inevitably bring.
We ask you not only for ourselves, but for
generations yet unborn not to issue a permit to Louis-
ville Gas and Electric for construction of the coal
burning power plant in Wise's Landing.
MR. PERRY: Comments from the panel.
Thank you.
The next speaker will be Paul Scully.
-106-
BETTY M. Wl L5ON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
PAUL SCULLY: Paul Scully from Madison.
I'm speaking as an individual and also as a fellow who
has worked with the Medical Profession for the last fou
years.
I have done considerably research of srub-
ber technology, in fact on every scrubber in the United
States.
I have followed for a number of years the
plans of proliferation of power plants, coal fired unit*
in the Ohio River basin area, and I've also followed
with a great deal of interest the scrubber technology
not only in the United States but in fact throughout th«
world.
There has been an incredible amount of
misinformation stated here this evening.
This document is published by Teko Environ-
mental in Cincinnati, Ohio, and it's published for the
Environmental Protection agency. It is a summary of
every scrubber in the United States. Everyone that is
operational, everyone that is planned and how many
hours they operate a month, the reliability factor, the
utilization factor and I'm sure you gentlemen are aware
of this.
statements have been made here tonight that
there are hundreds of scrubbers successfully used and
-107-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
this is no great difficulty from a. technological
standpoint, and gentlemen/ I can tell you that in
that book there is not one single successful scrubber
in the United States that is operating on a large full
fired utility.
The gentleman from L.G.& E. sitting here
have heard this before and I have never heard this
statement rebutted. Successful means a unit that has
operated for one year and that is not a long period of
time for an installation to be called successful.
Yet, the shocking thing is that in the
draft of the environmental impact statement repeated
reference is made to use of high efficiency scrubbers
on this proposed plant.
On page seventy-one a stdement is made and
I "At least ninety percent of the SO2 will be removed,"
This same reference is made in a number of other times
and I won't cite them all, in the interest of time,
but page fifty-seven also says that the equipment,
"Will remove ninety percent of the SO2."
Nowhere in this entire document is there
any reference even remotely suggesting to support
the numerous stetements referencing the fact that this
large coal fired power plant will be constructed on
the basis that at least ninety percent of the SO2
-108-
BETTY M. WILSON
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APPENDIX E, Continued
It is operating today at best at fifty
percent, it's a failure month after month after month
of scaling the lining and plug this and plug that.
The back charge does not work, and I would love for
one of you to show me one, not four or five, or eight,
just one large full fired generator that has a success-
ful scrubber that has operated ninety percent efficienc
for one year, because there aren't any.
In 1973 EPA issued a document and it des-
cribed the status at that time there were forty-four
scrubber systems planned in the United States, and I
think it's interesting to take a quick look at what
happened to those forty-four.
Fifteen of them had become operational
achieving various degrees of success. Not one achiev-
ed ninety percent for a year.
Five are about to start up or are in the
start-up stages. One was delayed by a fire in the
scrubber. Two were converted from SO2 scrubbers to
flyhead scrubbers. Four were only test units and have
been shut down. Two were a total failure and were
abandoned.
One was shut down due to lack of regenera-
tion facility but has now been restarted.
One is being re-evaluated. Two were
-110-
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APPENDIX E, Continued
canceled and never built. Eleven still have not been
finally committed, and quote, "May never been construct-
ed" .
That is of the forty-four that were there
four years ago.
Today, in the United States, there are
thirty-two operation scrubbers, and as the gentleman
from Trimble County I think he recounted how many
more were planned, the total number with contract
awards, letter of intent, people thinking about doing
it, totals one hundred and thirty-two, but there are
over a thousand generators utilities in the United
States, and there are thirty-two of them have scrubbers
and there are zero of them that have scrubber efficiency
which have achieved ninety percent for one year.
One who is not familiar with the start of
the scrubber technology might be easily misled since
there is not the slightest suggestion that there
might be difficulty with running the machinery at such
a high level efficiency for the scrubbers.
The evidence shows a much different pic-
ture.
We are well aware of the EPA effort to
encourage finance research and development to solve
S02 problem and I sincerely hope that they will be
-111-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, CONTINUED
immensely successful, the cold hard facts today
indicate that it is totally unreasonable to suggest
a ninety percent S02 removal as is available.
We who live in this area surely could not
be expected to be engulfed in the tens of thousands
of more tons of chemical pollution on the basis that
L.G.& E. thinks they can achieve at the high level.
EPA own report had no case that ever showed
this ninety percent magic number.
We do not quarrel with the fact that the
scrubbers have in fact worked successfully for short
periods of time on small generators.
It's a well known fact of having one unit
of L.G.& E.'s own facility which is a standby unit
to be used when they need high level energy in their
area, but it's not a unit that is operating regularly,
and it's a very small unit.
But here we are not talking about ten
megawatts or sixty megawatt units. But rather a
huge generating station where a series of five hundred
ninety-five megawatts generators are planned.
It's quite interesting to know that almost
the entire electric utility industry with the exception
of perhaps Kansas City Power and Light and L.G.& E.,
all of them steadfastly maintain that scrubbers
-112-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
technology available today is not yet reliable enough
to be considered commercially feasible.
H.J. Young, who is a senior vice president
of Edision Electric Institute has repeatedly been quoted
to respect that currently available S02 control
equipment is not adequately reliable and the statements
have been approved by almost every major utility compan;
in the nation with the exception of two I named.
I don't believe the citizens of this valley
should be subjected to serious health hazard on the
basis that L.G.& E. or EPA hopes that the technology
will get better by the time the plant is built.
One might well ask the question why such
a large interest in sulfur dioxide emissions in this
area.
The Ohio River Energy Study, and this
study was mandated by the United Stales Congress, a
mandate EPA to do this study, was released a few
months ago, and I attached it for reference, a few
pages of it.
It brings into sharp focus the problems
that we have there already in this area. There
are nineteen coal fired plants in the State of Indiana.
if you put all nineteen of those plants together, the
Clifty creek plant, the IKE plant across the river
-113-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
the IKE Plant , Clifty Creek Plant, Wise's Landing
Plant in erect, it states that the three hour average
concentration will be two thousand eight hundred ninety-
eight micrograms per cubic meter, which of course,
constitutes a serious violation of the Ambient Air
Quality secondary standards of only thirteen hundred,
but then on page fifty-six it stetes that this gross
violation would have occurred anyway even if the Trimble
County Plant were not in operation as the concentration
contributed by this plant was only zero point one, a
tenth of one microgram.
We have got twenty-nine hundred units here,
and we get the incredible story that the Trimble County
Plant will only add a tenth of one microgram.
I am not too good at arithmetic, but I've
got a nine dollar calculator and that tells me that
one thirty thousands of the problem, and I simply
don't understand that, but it makes me wonder about the
credibility of the numbers.
The gentleman from Kentucky told us a little
while ago in his opening statement that his numbers
showed seven hundred seventeen by memory of the thousand'
eighteen where it would be caused by L.G.& E. Plant,
but the Environmental impact statement says with the
draft statement, if I read it correctly, and I don't
-115-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
understand that it says zero point one raicrogram.
This gentleman says the number is seven
thousand times higher than that, so you can see why
we wonder.
The twenty-four hour concentration I won't
recite, but it's even more incredible because it says
that the Trimble County Plant will only contribute one
fifty thousands of the problem. That is a figure which
is beyond my comprehension.
The obvious question to be raised by these
figures cited in the EIS is that if the contribution
of this proposed plant is indeed so small and the
impacting area is just ten miles away, would it then
not be practical to have this plant located south of
Louisville, its own service area where it could provide
jobs and taxes and so many other benefits to the cus-
tomers it serves. It would be most interesting to hear
the response of Jefferson County Air Pollution Control
Board for this procedure.
The facts clearly suggest that L.G.& E. is
lowering itself of all S02 pollutants in the Louis-
ville area on a mandate from this same Air Pollution
Board and they are doing this partially by planning to
remove or shut down part of their existing power plant
operations and moving them into Trimble County site.
-116-
BETTY M WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
I sympathize with the gentleman who wants
better schools, and a better quality of life for your
children and I would work twenty-four hours a day
with you to achieve that, but I wouldn't do it at the
sacrifice of the health of my children, nor those
that are going to follow you in this area.
We can't separate the citizens on one side
of the river from those on the other side of the river.
We are all hopefully Americans whether we are Kentuck-
ians or Indianians or what we are, chemical pollution
doesn't know any boundaries, doesn't know that there is
a river down there.
It is interesting to note that the proposed
L.G.& E. Plant apparently would have a bypass in this
scrubber system. Kansas City Power and Light as a
unit, at least one of them has no bypass because it's
near downtown Kansas City, and the Bruce Mansfield
Plant in Shippingport has no bypass.
When it doesn't work, you shut it down.
One has to ask why this area should not be
given the same protection if indeed some of the criti-
cal needs of the technology of scrubbers is here and
there is no great mystery to making them work, they
either are not familiar with the state-of-the-arta and
certainly we should insist there be no bypass and if
-117-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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APPENDIX E, Continued
the unit works we can turn it off.
The history of scrubbers in this country
is replete in shutdown of scrubbers for periods of
much greater duration than one month, and yet in the
environmental impact statement the reference is made to
L.G.& E. should keep a thirty day supply of coal on
hand. - - Low sulfur coal, excuse me, on hand in the
event that a scrubber has to be shut down.
So in summary I can only conclude that I thilnk
the gross injustice would be done to permit the building
of this plant facility on the basis that either EPA or
L.G.& E. hopes or thinks that scrubber technology will
somehow improve enough to guaranty a minimum of ninety
percent SO2 because if in fact that unit works fifty
percent efficiency, we would then have just as much
more SO2 from L.G.& E. as we now have from the Clifty
Creek monster.
Five hundred and some million pounds a year
over a million and a half pounds a day.
Nowhere have I heard well if it doesn't work
we will shut it down, or that we won't need a bypass
on it because either the scrubber works or the system
won't run.
The Clean Air Act was enacted to protect our
health and we surely demand more equitable treatment
-118-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
than that. The laws exacted by Congress certainly did
not envision large coal burning plants ten miles apart,
and this is especially true, gentlemen, with one of the
plants that emits a million and a half pounds SO2 a
day .
We need the help of EPA, we need the help
of you gentlemen and I'm rather astounded that the
scrubbers history and scrubber technology in this coun-
try is not better known.
I attached a simple summary of the ordinance
report which list emissions of every qualified plant in
the State of Kentucky and every coal fired plant in the
State of Indiana, and I can only repeat that the plants
that we already have is emitted two hundred and eighty-
six thousand tons of SO2 a year, and the total allowable
is only seven hundred sixty-one thousand, so we already
have thirty-five percent, over thirty-five percent from
just one single utility right here in our own back
yard.
Thank you.
MR. PERRY: I have one question. I have
heard a series of speakers that have said about the
scrubbers that don't work and the technology is bad - -
MR. SCULLY: I didn't say the scrubbers
don't work, I said no one has said that the scrubbers
-119-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
-------
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23
APPENDIX E, Continued
actually worked on a very large installation. Scrubbers
do work, they work for hours, they work for days, they
work for months, but no one yet will say , they worked
successfully for one year in a large facility.
MR. PERRY: I take it that is one of your
complaints without the proposed course of action.
MR. SCULLY: Well, I think the entire - -
I read the environmental impact statement, I am certain-
ly not a scrubber expert, nor a utility expert, I am
a hard working business man.
That environmental impact statement totally,
the logic of it totally is surrounded by the fact you
are going to scrub out ninety percent of the S02 or
else your own numbers - -
MR. PERRY: (Interrupting) My question is
this, assuming that scrubbers don't work for purposes
of our discussion and you and a number of other speak-
ers have gone along with this line of argument, but
I have yet to hear a solution other than scrubbers.
MR. SCULLY: Oh, there is lots of solu-
tions.
MR. PERRY: what are they?
MR. SCULLY: First solution I would propose
to you is that we have an enormous amount of low sulfur
coal in this country, we don't need to burn four point
-120-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
three percent sulfur coal, you can cut the problem
eighty percent by burning low sulfur coal the first
day. And you don't need a scrubber to do that. If
you put the scrubber on using low sulfur coal the
magnitude of your problem will be shrunk eighty per-
cent because you only have to scrub out this much
instead of scrubbing out that much (indicating).
MR. ZELLER: I think that is very impor-
tant point Mr. Scully in terms of talking about - - firs
of all, let me assure you that I - - the reports that yo
quoted are public documents and very many people have
access to those, but when we talking about, you know,
efficiency, we are talking about a great many other
things are involved.
First of all, there are things that you
mentioned low sulfur coal, there is coal washing, there
is blending and wouldn't you agree that it is entirely
possible that if we - - if the scrubbers only worked
fifty percent efficiency that using a certain kind of
coal that you could meet ambient air quality standards
of sulfur dioxide whether that was ninety percent - -
MR. SCULLY: (Interrupting) That would
depend, sir, on what is down the street. If I've
got five other plants down the street, the answer
would be probably not. If I didn't have five others
-121-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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25
APPENDIX E, Continued
down the street, the best plan to do is don't have
power plants ten miles apart.
MR. ZELLER: Thank you. There are other
regulations, of course, you know, that apply to
siting that are applicable and you may well know
such as prevention of significant deterioration and
many other factors involved.
MR. SCULLY: But your own research and
your own data, your own EPA recommends twenty-one,
twenty-eight, thirty miles and they are not - - they
disagree between the twenty-eight and thirty miles,
but no one in the world would ever suggest that you
put two huge plants ten miles apart.
MR. ZELLER: Well, there are really
situation where power plants are not always sited
exactly where you and I would like them but, you know,
I don't want to get into an argument here, but you - -
EPA certainly does not have the regulatory authority
to say where a power plant is built.
Now, it does have authority to say if you
build one you have to meet certain requirements.
MR. SCULLY: But isn't it reasonable,
sir, if you were going to - - if we are talking about
the health of the people in this whole valley and this
county and our county and surrounding counties that at
-122-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
least we would have, let's use the word a reasonable
shot at success, and reasonable means that something
is going to work.
MR. ZELLER: Mr. Scully, I think it's
very late and very complicated to be arguing scrubber
technology and I think it's probably, you know, suf-
ficient to say we have several other disagreements
in the scrubber technology and what certain people
think will work and so forth.
MR. SCULLY: Believe me, I hope they
work.
MR. ZELLER: Well, I hope there is some
indication that they will, again, the issues is, you
know, is whatever is necessary in terms of, you know,
SO2 standards, and that, you know the scrubbers, or
low sulfur coal or coal washing or blending, there are
many other possibilities.
MR. PERRY: A combination of both.
MR. ZELLER: Yes, a combination.
MR. SCULLY: That is not suggested in the
environmental impact statement, not at this one, where
Mr. Royer sat at our Rotary Club and told us that you
don't plan on burning low sulfur coal, he told me he
planned to burn four point three percent sulfur coal.
MR. ZELLER: Well, we have - - again,
-123-
BETTY M. WILSON
REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
we have had a lot of numbers and a lot of efficiencies
that I don't want to put out some more, but I think
Mr. Smither in his statement quoted yxi something like
about eighty-four percent removal with scrubbers based
on a coal at a certain level of sulfur which this much
I can assure you, Mr. Scully, that the regulations are
very, very specific in terms of emissions from this
plant meeting S02 requirements, and EPA will certainly
see that that is done.
Now, there is a very serious problem that
you mentioned Clifty Creek and that was addressed
earlier.
MR. SMITHER: Most state regulations
and EPA regulations require that the standard be
achieved.
MR. ZELLER: Yes, sir.
MR. SMITHER: They require that the stan-
dards be achieved if testing and testing has to be
approved at a hundred and eighty days as a maximum,
if it isn't, it doesn't operate.
MR. SCULLY: Have you ever seen - -
MR. SMITHER: (Interrupting) We're not
talking about - - we are talking about a new one and
the new ones today are not quite the same.
. SCULLY: I ask you to qualify that,
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APPENDIX E, Continued
yes, they are.
MR. ZELLER: Yes, I have seen - -
MR. SMITHER: (Interrupting) They are not
quite the same new as they are - - I think most people
have a tendency to give more time for existing facili-
ties right or wrong, I think it is true, for existing
facilities to come into compliance, I'm not saying
that is right or wrong, but I think it is a true state-
ment.
MR. SCULLY: The facts are that the Clean
Air Act was initiated by our representatives in Congress
to protect the air and nobody suggested we want pure
air, that is - - that is shear - - that is not going
to happen not with the progress and all we have with
that, but I think when we were talking about just
basic human health, primary or secondary air standards,
we ought to be able to meet them.
MR. SMITHER: If you will look - - if you
remember the statistics that I provided you with respect
to my statement, the majority of the problem is not the
proposed L.6.& E. Plant.
MR. SCULLY: I didn't say that it was.
MR. SMITHER: The majority of the problem
is the existing situation.
MR. SCULLY: That was the air is there.
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APPENDIX E, Continued
MR. PERRY: We are getting a little bit
- - it is getting a little bit late and there are other
speakers who would like to speak. Mary Clashrian.
MRY CLASHRIAN: I am Mary Clashrian, I
live at 801 First Street, Madison, Indiana.
I am more concerned about my health and
life than I am about tax bases or schools, and I am
surprised that other people put the priorities in the
reverse direction.
I feel that when a physician in Madison,
Indiana take a full page ad in the Madison Courier to
warn you of your health hazards with regards to any more
pollution in the air, there must be a reason, because
indeed they are reducing their own income if they are
trying to keep you well instead of getting you in their
office with emphysema or other lung problems.
I am concerned about the competence and the
unbiwent of government agencies that are involved,
because for example right here this evening we had the
members of the Environmental Protection Agency indi-
cating that the figures released by the Environmental
Research and Development Agency were not correct, or not
valid, or they were unwilling to accept them.
Both of these agencies are agencies of the
U.S. Government, and we, the helpless citizens are sit-
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APPENDIX E, Continued
ting around hoping that, the agency will protect us
and I wonder, will they?
Region V of the Environmental Protection
Agency has for at least the past six years been per-
mitting delays in Indiana-Kentucky Electric Plant which
is still violating the air quality standards and I
say to you what are you talking about one hundred and
eighty days? They have been doing this for six years
at least.
John Smither has stated that if all of the
four L.G.& E. generating units proposed are used, air
quality will not meet these standards.
An L.G.& E. representative, Robert Somers
wants that to be considered.
No consideration has even been given or
suggested concerning the proposed Marble Hill Plant
which would be - - which is proposed to be built by
Public Service of Indiana which has now the third
limited work authorization and if built will pour
thirty-six million gallons of water in steam on top
of the sulfur dioxide that the coal plant already
in existence and those that might be built.
None of us has been trained to breathe only
the air from one plant at a time. Today, the Ohio
River basin energy study released their March, 1978
-127-
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REGISTERED PROFESSIONAL REPORTER
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APPENDIX E, Continued
news l*ter in which they said to back up my position
as a result of the first year's activity it has become
apparent to the Corps team of the Ohio River Basin
Energy Study air pollution problems must be viewed from
a regional or perhaps interstate standpoint as well as
from a plant by plant standpoint.
This is particularly true with the Ohio
River Basin since Meteorological data has shown the
prevalence of persistent wind that allows for the
continuation of pollutants in air masses which them-
selves can travel many if not hundreds of miles.
This realization of a need for regional
analysis when siting energy facilities is reinforced
by on going studies from Technocron Incorporated.
ToffhnttrTrifm Studies are aimed at estimating
the impact associated with protected growth for the
electrical generating factor in the United States.
This suggests the need for a re-evalua-
tion of the present air pollution law to ascertain the
need to incorporate a regional if not interstate
analysis when siting an energy facility.
As a living breathing citizen of this
valley/ I beg you protect my health and the health
of my innocent neighbors. We have no vested interest,
all we ask is to be allowed to live, thank you.
-128-
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APPENDIX E, Continued
obviously if they cannot meet those environmental
standards, they cannot build.
MR. PERRY: I would like to say one
comment that the EPA legal structure of the laws under
which we operate do not authorize us to be a land
use agency as such, we don't have our own zoning and
planning board, and I think that is what Mr. zeller
was trying to say.
MR. ZELLER: Yes.
MR. ZOELLER: As long as that plant meets
your specifications and it could be built say in the
Wise's Landing area.
MR. ZELLER: Yes, sir.
MR. ZOELLER: If that plant was built
hypothetically on land that they now own but they do
not have a permit to build, if that plant is built
meeting your paper requirements and if those paper
requirements are not followed, what muscle or author-
ity does EPA have of doing something about violations
of that plant?
Does EPA have any muscle after the invest-
ment is made and after the power lines are built, after
the millions are invested and then if those violations
are apparent, is there any mechanism or does the EPA
have any power to exercise?
-130-
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APPENDIX E, Continued
DR. ROTH: in this particular case the
State of Kentucky has the promise for the air program,
we carry on all our own enforcement program. This meets
minimum requirements under EPA program.
If for some reason the state defaults and
this is a requirement that these conditions are perman-
ent, if we default then EPA is under Federal Law, is
obligated and at the present time is very active in
quite severe penalty policy for enforcing violations
of air pollution.
MR. ZOELLER: Have those powers been exer-
cised in any known case?
DR. ROTH: Yes, sir, they have. We
have one instance of an action of the state that there
was a penalty of a quarter of a million dollars plus
the demand that the particular plant correct its
problems.
MR. ZOELLER: Did they correct their
problems?
MR. ROTH: Yes, they are operating in
compliance today.
MR. ZOELLER: Thank you.
MR. PERRY: I think Mr. Zeller may have
some further comment.
MR. ZELLER: No, I don't have any further
-131-
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APPENDIX E, Continued
comment, but just to simply say yes there are options
available for similar criminal penalties in terms of
enforcing air pollution and the EPA has exercised that
authority in great many ixtttances.
MR. ZOELLER: EPA does file in the Courts
actions to correct violations.
MR. ZELLER: Yes.
MR. ZOELLER: Thank you.
MR. PERRY: Last speaker is Mr. Paul
Butler.
MR. PAUL BUTLER: Thank you, gentlemen.
I didn't hear about this meeting until just about two
days ago so I am very ill-prepared in terms of facts -
not ill-prepared in the way I feel about the situation,
All my life I have been driven past the
IKE Plant and see that smoke pouring out. I had no
idea how many thousands of millions of tons of pollu-
tants have come out of those stacks.
I am twenty-eight years old. Now/ you
gentlemen from the EPA, and you gentlemen from L.G.& E.
are telling me that if I continue to live in Madison
for the rest of my life you are going to pour millions
of more tons of pollutants into my lungs.
Now, I quit smoking cigarettes because I
value as precious and sacred every single second of
-132-
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APPENDIX E, Continued
my life. I went to a war for this country, gentlemen,
I went to a war that we lost because we had no inten-
tions of winning it, that we lost because there was
an economic war.
I do not joke, Mr. Zeller as you do, about
this situation. When a man comes up here and makes a
serious point such as Mr. Grote did just a while
ago, and you just dismiss him with a joke, no, sir.
MR. ZELLER: I apologize to Mr. Grote
if I offended him, it was not intentional.
MR. BUTLER: I am quite certain you
didn't, Mr. Zeller. I am quite certain that the
gentlemen from L.G.& E. are putting in this plant
don't intend to be offensive, I am quite certain that
the men who dropped the bombs or B52's over the
Vietnam War did not intend to be offensive, gentlemen.
Now, I have a lot of plans for the future.
I have plans for business in Madison. The very nature
of that business is such that if there are two big
power plants plus the steam rolling in from Marble
Hill and causing all this stuff to drop on Madison,
if these things are happening, the nature of the
business is such that the tourists won't come in,
the artists won't come in, the business is not just
going to be here.
The quality of life in Madison is just
-133-
BETTY M. WILSON
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APPENDIX E, Continued
going to go nowhere, our historic buildings are going
to have mud all over them if not disfigured at all,
this town will die and it is much too beautiful to die,
thank you.
MR. PERRY: Is there anyone else who
wishes to make a comment submit a written statement
who has not already done so?
MRS. JER1 HANCOCK: My name is Jeri
Hancock, I am a registered nurse and I am the mother
of two small children and we own a farm.
I am very, very concerned with the health
of my children. Some of the men from Trimble County
have got up here and expressed the economical gain
that we could get from this.
I want to say that the health of my
children is a much higher priority than any economic
gain that we could get from this power plant.
I assure you that I will be glad to see my
son in a much better school, the school he is in now
is really, jaally bad, but I would much rather see him
healthy than in a new school.
with these two small children they have
been having allergy problems which have required very
extensive treatment and Doctor Breitweiser
can document this. In this area, that is the - - a
-134-
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APPENDIX E, Continued
air quality standard and a resource standard and so
on and so forth. It is totally a different situation
here.
MR. PERRY: Any other comments from the
panel. If not, I wish to thank all of you on behalf
of the Commonwealth of Kentucky and the Environmental
Protection Agency for your attendance, participation
and cooperation in this evening's hearing.
The comment period on the draft environment
impact statement for this project will remain open
through the close of business on Monday, April 10, 1978.
This will allow anyone wishing to submit
additional statements sufficient time to do so.
Further submissions must be in writing
to be included in the official record and should be
sent to the attention of John E. Hagan, Chief, EIS
Branch, EPA, Region IV, 345 Courtland Street, Northeast,
Atlanta, Georgia, 30308.
The EPA will take into consideration the
evidence and statements presented tonight at this
hearing and any other statements submitted between now
and April 10, and will make a determination regarding
the permit based on these comments and all other com-
ments in the record.
After making that determination, we will
-136-
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APPENDIX E, Continued
PUBLIC MEETING
BEDFORD, KENTUCKY
MARCH 28, 1978
I, Bruce D. Handy, do hereby certify
•that I attended and took a stenographic record
of the proceedings in the above-entitled meeting
and that the foregoing is a true and correct copy
of the same and the whole thereof, according to
the best of my ability.
Vl
Court Reporter
Bruce D. Handy
Dated: April 7, 1978
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