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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                               6 1918

                              UBRARY

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   EPA 904/9-78-017                                    NPDES Application Number:
                                                      KY0041971
                          Repos/fo/y Maferia/
                                      Collection
                              FINAL
                 ENVIRONMENTAL IMPACT STATEMENT
or?

                              for
                                                                   CO
            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
                Trimble County Generating Station              O § CD g -g £ i
                    Trimble County, Kentucky                     w w -"B g c5'
                                                               -S?
                           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
                                   xii

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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.
                                     2-1

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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

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                                  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

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       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

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      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

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       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

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                                                                                  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.

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 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

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                           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

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                            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

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                            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

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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

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 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

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                                                                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

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                                                                            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

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                                                                                                      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)

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                                                                            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

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     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

-------
     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.
                                     3-36

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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
                                   3-40

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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.
                                    3-44

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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.
                                   3-50

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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).

                                    3-51

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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.

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     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
                                     3-54

-------
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

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                                 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

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     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

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                                                                              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.

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                                                                        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

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                                                                      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

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                                                                        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

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                                                                        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

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                                                                           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

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                                                                           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

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                                                                          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

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                                                                       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

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                                                                        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

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                                                                          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

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                                                                        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

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                                                                        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

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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

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             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
.0
.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

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       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)
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7)
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b)
bl
6)
6)
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b)
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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,
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19,
19,
19,
19,
19,
19,
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(333,
(333,
(333,
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I 85,
( 8b«
( 85,
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( fl5,
( 93,
( 93,
( 93,
( 93,
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( Hb,
( Hb,
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2)
2)
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2)
21
2)
b)
b)
b)
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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.
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( 19,
19,
19,
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19.
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(333.
(333,
(277.
( Hb.
( Bb,
( 93.
( 93,
( 93,
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( 93,
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( 8b.
I 85.
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21
2)
2)
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21
b)
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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,
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bb,
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n
7)
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b)
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.04UK-04
.Ob93t-04
.Os2bt-04
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.02»Ut-04
. 74'«
(270.
(270.
( 19,
( 19,
( bH,
( bB,
( b8.
I 68.
( bd.
( 19,
(18d.
(188,
( Ittrt.
(260,
(260,
(277,
( 2 / 7 ,
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( 73,
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( 7.1,
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7)
7)
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bl
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t)
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4)
b)
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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)
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b)
1)
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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)
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8)
8)
8)
d)
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8)
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4)
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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)
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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
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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.
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7.
7.
7.
/.
7.
fi.
ft.
6.
b.
b.
b.
b.
b.
b.
b.
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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)
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7)
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8)
b)
8)
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8)
8)
8)
8)
8)
8)
4)
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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
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to is
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21
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30
31
32
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34
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1 . 1 2 7 fit -03
4.43^ If -04
8.44»i5t- -04
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'•».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
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7.4H?9t -04
6. 1 ?'t -04
6. 7b2bt -04
H, 147 It -04
1 .Ub24t -03

1 ! J2>">2t-0 J
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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.
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. 32/bf -04
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, 7204(r'-04
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. -"43IF-03
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(164.
(164.
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KM

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( 174,
(174,
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(169,
(169.
( 169,
( 169.
(169.
(169.
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(174.
(174,
(174,
(174,
( 174,
(164,


4) 1
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b) 6.9S31E-04
b) '
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b)
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41
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4)
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. 3722E-03
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.4319E-03
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.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,
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(1/4,
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(174,
(174,
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( 169,
(169,
( 169.
(169,
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( lt.9.
( 16V,
(174,
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(277,
(277,
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4)
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bl
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41
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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
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b)
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5)
6)
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-------
                                                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,
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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)
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4)
4)
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4)
4)
4)
4)
4)
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4)
4)
4)
4)
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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
•
•
•
•
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•
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•
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•
•
*
•
*
•
•
•
•
•
•
•
•
•
.952RF.
0
0
0
0
0
0
0
0
u
0
0
0
0
0
0
0
0
0
u
0
0
0
0
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0
0
0
0
-065
.7904F-071
.9923t
.S47bF
.136HE
•
*
•
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.6797F
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-111
-191
0
u
0
-111
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-062
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-Ob8
-Ob3
-Ub2
-07J
-1 (j'l
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.9?4bF-294
•
•
n
0
0.
0.
0.
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0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
. 0.
0.
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0.
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0.
0.
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. 0.
. 0.
0.
.952at-06b.
.7904E-071.
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.b476t-lll.
.13b8t-191.
0.
. 0.
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.6/97E-083.
.29946-062.
. 9324E-051 •
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.8306E-058.
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.0010t-062.
.2282E-0/3.
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.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.
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0.
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0.
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0.
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0.
0.
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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.
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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

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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

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                   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

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                      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

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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

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                      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

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                                   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

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                          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

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                                       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

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                      RESPONSE TO COMMENT DOCUMENT  D
Comment Number           	Response
                  Comment noted.  The Applicant has been given a  copy  of
                  this letter.
                                    5-17

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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

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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/
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                                         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

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  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

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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

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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

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                                                              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

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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

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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

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 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

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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

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 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

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 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

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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

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        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

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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

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                                                                                                                           Prepared by IMMR for ORBES
                                                          EMISSION INVENTORY FOR KENTUCKY POWER PLANTS (1)


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(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

-------
      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

-------
                        -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

-------
                         -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

-------
                                     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

-------
 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

-------
   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

-------
    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

-------
    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

-------
     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

-------
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

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Million Cub..    * ''
26
                                                                                            i
                                      COMMENT DOCUMENT - H, CONTINUED
                                                                                            I

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                      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

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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

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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

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                   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

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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

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                      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

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             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

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                      RESPONSE TO COMMENT DOCUMENT K
Comment Number                     	Response
       1          Comment noted.  No response required,
                                     5-69

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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

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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

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                                        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

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                                       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

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                      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

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             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

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  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

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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,,

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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

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*\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

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 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

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        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
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       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

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                      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

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                  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

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                  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

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                                        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

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                                  -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

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                                 -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

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                                  -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

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                                  -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
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                                 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
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                               -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
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                               -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
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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.
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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.


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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

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                                  5-106

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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.
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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
                                5-108

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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

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                                -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


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                                  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

-------
                                                          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.

-------
    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

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                  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

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                  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

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                  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

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                    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

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                      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

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                                            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

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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

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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

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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

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                                         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

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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

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       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

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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

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                                         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

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                     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

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  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

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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

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                      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

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                           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

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 .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

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                      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

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                 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

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   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

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  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

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       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

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       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

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                      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

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               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

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               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

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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

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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

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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

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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

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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

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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

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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

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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

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 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

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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

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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

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                     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

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               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

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               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

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               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

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               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

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               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

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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

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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

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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

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 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

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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

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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

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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

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                      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

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               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

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                     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

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                      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

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                                                        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

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                    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

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                          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

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  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

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                      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

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                 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

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                 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

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                   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

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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

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                      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

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                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

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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

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     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      -. '

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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

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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

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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

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                      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

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                     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

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  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

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            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

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        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

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      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

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     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

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        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

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   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

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  •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

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   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

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    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

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                                                   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

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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

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     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

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                                                     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."
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         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).
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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

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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-

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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".
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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.
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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."
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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.

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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.
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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.
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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.

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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

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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.
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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
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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.
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                              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
                            5-281

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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?

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                                                    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

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                  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

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                  t
65O5 LonQview Lane-Louisville. Kentucky -4O2O7
            Phone 5O2 893 762O
          Art • Deeign • Photography

               COMMENT DOCUMENT - DD, CONTINUED

                  5-290

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         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

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                                                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

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                                  17

                     '•> (. .
           7i /-. t    - 6 l^i- *  v




         ' rf-1 < < .   ,--» A' t
,. /.
X-vt
                r-

                /
                                  ./•
                           t A «
                                        •d
                                       -V.
                                     >c
                                    CV
                    COMMENT
                                    DOCUMENT - DD, CONTINUED
                        5-293

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                      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

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                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

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                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

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                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

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                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

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                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

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                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

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        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

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                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

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                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

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                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

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                      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

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                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

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                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

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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

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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

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  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

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                              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

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     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

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                              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

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                      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

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                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

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                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

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                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

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                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

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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

-------
                       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
              •^/ ~\
                // —-^    y
^•James E. "Doughy PE, PG ^
 JEH/hm
 cc:  Irene P. Long
      M. R. McCann
             SOIL
  SUBSURFACE
          5-321
COMMENT  DOCUMENT
FOUNDATION
                                                                   GG

-------
                       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

-------
                                                   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

-------
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
                                                                                                               3  (!)  H 5
    There shall be no discharge  of floating solids or visible  foam in other  than trace amounts.                 n w  M •-<
                                                                                                               25       ^
                                                                                                               O       >
    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
                                                                                                                  o     **

                                                                                                                *—*       o

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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
                                                                                                               •s w  ^
    There shall be no discharge of  floating  solids or visible foam in other than trace amounts.                ? -  >
                                                                                                                 ^T  ^

    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.                          ~~
                                                                                                               »j     fD
                                                   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
o
I—I
X
o
o
c
0>
Q.
                                                                                                                      fS OJ   >
                                                                                                                      <-t oo   ye
                                                                                                                      3 !9   H
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.
                                                                                                      •< O
                                                                                                      O •"•»
   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.

-------
-o
-a
o
o
fO
Q.
    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.
                                                                                                                        " ' X

                                                                                                                       '••*•"'
                                                                                                                       •fl -8   "O
                                                                                                                       *p a   >

                                                                                                                       -I »   50
                                                                                                                       S »   H
                                                                                                                       »-*«

                                                                                                                       " Ln   i-i
c
•  o
"< N)
5 o

-------
o
o
3
    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_
                                                                                                          f+
                                                                                                                     n
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
   o
   >-*i
O  KJ

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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.
                                                                                                                   •0-3   TJ >

                                                                                                                   I*   I"
                                                                                                                   H.     ~ m

                                                                                                                   ?  ^j  — o
                                                                                                                   —       »—i
                                                                                                                           x
                                                                                                                   3*  s.
                                                                                                                   i<       3>
                                                                                                                   O       "
                                                                                                                   O  M
                                                                                                                   *-  O    O

    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.
                                                                                                         &»
                                                                                                         rt oo
                                                                                                         ?0
                                                                                                               O
                                                                                                               o
                                                                                                               vO
                                                                                                                O
                                                                                                                r+
                                                                                                                      C
                                                                                                                      fD
                                                                                                                      Q.

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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.
                                                                            =  -3

                                                                            Z *•£
                                                                               Is
    \_f  Serial number assigned for identification and monitoring purposes.
    2/  Geometric mean.
                                                                                 C
                                                                                 ro
                                                                                 Q.

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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
                                                                                                                  re o>
                                                                                                                  •1 oo
                                                                                                                             >

                                                                                                                             73
                                                                                                                             H
O
i—i

X
o
o
                                                                                                                       z
                                                                                                                       o  o
                                                                                                                      o
                                                                                                                      o
 Saaples taken in compliance with the monitoring requirements  specified  above  shall be taken at th-


 following location(s):  Plant intake.
(0

Q.
\J Serial number assigned for identification and monitoring purposes.

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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

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                                                            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

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                                                           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

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                         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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                                                  QFPROPERTY
                           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

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                         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.

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 946.7 (REV. 6-61)
                                  DATE
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                                                                                                REVISIONS

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                                                      ENTRE DEPTH OF PENETRATION

                                                      NOT SHOWN

-------
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                                                         SILURIAN
                                                  lS:::i-:-:-;-:>*:«
        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

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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

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                         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

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                                            •—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

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 PAGE NOT
AVAILABLE
DIGITALLY

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                         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

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                                                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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                                        ORATING EL.456.O
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  .-.10!.'.
V5SB.
                           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.

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                     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.

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                  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.

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                 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.
                                   ***  *** ***
                                      -2-
                                 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


                     -3-
                                 BETTY M. WILSON

                              REGISTERED PROFESSIONAL REPORTER

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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-
                               BETTY M  WILSON
                            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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             APPENDIX E, Continued


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-
                                 BETTY M  WILSON



                              REGISTERED PROFESSIONAL REPORTER

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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


                               REGISTERED PROFESSIONAL REPORTER

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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


                            REGISTERED PROFESSIONAL REPORTER

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             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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19

20

21

22

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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        3
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24




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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       21
       25
             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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       24
       25
             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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99
             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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       22
             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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       25
            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-
                                 BETTY M. WILSON


                              REGISTERED PROFESSIONAL REPORTER

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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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       24
       25
             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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11

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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21
             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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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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             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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25
             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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       19
             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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25
            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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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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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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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

-------
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       20



       21


       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

                  REGISTERED PROFESSIONAL REPORTER

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24
             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

                              REGISTERED PROFESSIONAL REPORTER

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       25
            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

                  REGISTERED PROFESSIONAL REPORTER

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       25
            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


                              REGISTERED PROFESSIONAL REPORTER

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       24
              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-
                                 BETTY M. WILSON


                              REGISTERED PROFESSIONAL REPORTER

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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-
                                 BETTY M  WILSON


                              REGISTERED PROFESSIONAL REPORTER

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       20
            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-
                               BETTY M WILSON
                            REGISTERED PROFESSIONAL REPORTER

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   25
            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


                 REGISTERED PROFESSIONAL REPORTER

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       25
             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


                  REGISTERED PROFESSIONAL REPORTER

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       25
            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


                              REGISTERED PROFESSIONAL REPORTER

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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-
                               BETTY M. WILSON


                            REGISTERED PROFESSIONAL REPORTER

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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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16

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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
                             REGISTERED PROFESSIONAL REPORTER

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       21
            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

                  REGISTERED PROFESSIONAL REPORTER

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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-
                                 BETTY M. WILSON


                              REGISTERED PROFESSIONAL REPORTER

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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


                              REGISTERED PROFESSIONAL REPORTER

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25
               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-
                       BETTY M. WILSON


                    REGISTERED PROFESSIONAL REPORTER

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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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       24
              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

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« 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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       25
              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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       25
             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

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— 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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25
             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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       25
              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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             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-
                                 BETTY M. WILSON

                              REGISTERED PROFESSIONAL REPORTER

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       '24
              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



                   REGISTERED PROFESSIONAL REPORTER

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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-
                               BETTY M, WILSON


                                  PROF t" SS/ONAL RFPOWTtW

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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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       25
              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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              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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              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,



                        -124-


                      BETTY M.  WILSON
                    REGISTERED PROFESSIONAL REPORTER

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       25
              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.


                          -125-
                      BETTY M. WILSON

                   REGISTERED PROFESSIONAL REPORTER

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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-



                          -126-
                       BETTY M. WILSON



                    REGISTERED PROFESSIONAL REPORTER

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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-
                                 BETTY M. WILSON


                              REGISTERED PROFESSIONAL REPORTER

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       25
              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-
                                  BETTY M. WILSON

                               REGISTERED PROFESSIONAL REPORTER

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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-
                                  BETTY M. WILSON

                               REGISTERED PROFESSIONAL REPORTER

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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-
                          BETTY M. WILSON


                       REGISTERED PROFESSIONAL REPORTER

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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-
                      BETTY M. WILSON
                   REGISTERED PROFESSIONAL REPORTER

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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
                  REGISTERED PROFESSIONAL REPORTER

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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-
                                  BETTY M. WILSON


                               REGISTERED PROFESSIONAL REPORTER

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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-
                      BETTY M. WILSON


                   REGISTERED PROFESSIONAL REPORTER

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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
                                     -138-
                                  BETTY M. WILSON


                               REGISTERED PROFESSIONAL REPORTER

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