David K. Paylor Virginia State Board of Health March 17, 2016

Residue generated from burning coal. Generally disposal is onsite disposal or beneficially reused Ash has a large variety of constituents, it mostly consists of silicon oxide, iron oxide, and aluminum oxide. Trace amounts of arsenic, selenium, mercury and other metals Ash composition varies widely depending on the coal type and origin, burning regime and air pollution control equipment 2 What is Coal Ash:

Landfill 8 Active Landfills in Virginia Surface Impoundment 12 active surface impoundments at 7 facilities operated by 3 owners Beneficial Reuse Structural fill, concrete, wall board, agricultural 3 Management Alternatives

Regulated Ponds in Virginia 4

5 Virginia’s Ash Impoundments CompanyLocation# of Active Units DominionBremo Bluff2 DominionChesapeake Energy1 DominionChesterfield2 DominionPossum Point 1 2 American Electric PowerGlen Lyn1 American Electric PowerClinch River2 Celanese, llcNarrows1 Mead WestvacoCovington1 1 Recently discovered an additional inactive impoundment at this site

Impoundments constructed with a natural clay liner Ash transported with water to impoundment 6 Surface Impoundment Operations Solids settle, overflow water discharged to surface water under a VPDES permit

Background EPA Final Rule on Disposal of Coal Combustion Residuals In 2008, a large coal ash spill occurred at the Tennessee Valley Authority (TVA) power plant in Kingston, TN This spill prompted EPA to assess coal ash surface impoundments and gather information from facilities managing coal ash nationwide. In 2010, EPA proposed regulations under RCRA to address the risks from the disposal of CCRs generated from the combustion of coal at electric utilities and independent power producers. During the course of the proposed rule-making, the Dan River coal ash spill occurred from the Eden, N.C. Duke facility and was included in the cases considered by EPA in the rule-making Rule establishes national minimum criteria for the disposal of CCR in landfills and surface impoundments. Final Rule Effective Date October 19, 2015

Surface Impoundments 2015 EPA Final Rule on the Disposal of Coal Combustion Residuals Provides operational and closure standards for new and existing surface impoundments Provides closure requirements for inactive impoundments Inactive impoundments are those that have not accepted CCR after October 19, 2015 and contain free liquids and are on the property of the generator Rule provides station owner with two closure options – capping in place or removal For either option first step is to remove water from the ponds Virginia Solid Waste Management Regulations Virginia Waste Management Board adopted and incorporated EPA Final Rule (December 4, 2015) Provides technical requirements for closure and post-closure of surface impoundments Provides a permitting process

Proposed Dewatering Discharges Dewatering needs to occur regardless of type of closure Dewatering will entail: Initial draw-down of the impounded waters Approximately 150 MG to occur over days Maximum flow of 2.88 MGD Continued dewatering over the closure period Spring of 2018 Compliance with effluent limits prior to discharge

Surface Impoundments Solid Waste Permit Provisions Review and Approval of Closure/Cap Groundwater Monitoring Surface Water Monitoring Cost-Estimates and Financial Assurance Post-Closure Plan/Cap Maintenance Public Participation Process

Dominion – Possum Point Power Station Existing 1845 MW natural gas and oil fired steam electric generating station Ceased using coal in March 2003 Five ash ponds Ash Pond A, B, C Complex Ash Pond D Ash Pond E

Major Areas of Concern Public Process & Extension of Comment Period Sufficiency of Permitting Documentation Technology-Based Effluent Limits Protection of Water Quality & Beneficial Uses - Effluent limits not protective - Not adequate protection of fishery and wildlife - No limits on discharge volume - Discharge will contribute to the existing impairment - Insufficient monitoring - Ash Pond D toe drain