Tennessee Valley Authority - tva.gov Content/Environment/CCR/Sites... · • TVA is seeking input...

Remedial Investigation

Interim Response Actions

Environmental Impact Statement

Environmental Investigation+

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+

Tennessee Valley Authority welcomes you to the

ALLEN FOSSIL PLANT COMMUNITY INFORMATION

SESSION

ALLEN FOSSIL PLANT

Closure + Development

TODAY'S TOPICS

Environmental Impact Statement• TVA is seeking input on the scope

of its evaluation for the closure of the East Ash Pond Complex, the West Ash Pond, and the Metal Cleaning Pond

• TVA is analyzing options for disposal of ash in a beneficial re-use process and in an offsite landfill

• One project purpose and need is to make land available for future economic development projects in the greater Memphis area

• Public comment period is until November 25, 2019

Environmental Investigation• Details on how TVA is investigating

and assessing the extent of impacts on soil and groundwater from management and disposal of Coal Combustion Residuals (CCR) at the Allen Fossil Plant

• Outlines the activities that will be underway at the site to better evaluate what must be done to safely manage the storage and disposal of CCR

Remedial Investigation• TDEC is directing an ongoing

groundwater remedial investigation (RI) at the Allen Fossil Plant focused on the East Ash Disposal Area

• The RI at the Allen Fossil Plant was started following the detection of elevated arsenic in groundwater near the East Ash Disposal Area

• Information on the remedial investigation and interim action for addressing the arsenic issue

Interim Response Actions• Information on the Groundwater

Remediation system which will control and treat arsenic in groundwater found in two areas north and south of the East Ash Disposal Area

• Details on how pond dewatering is being performed to remove standing water and ash pore water prior to removal of the CCR

Current Groundwater Conditions

Current Environmental Activities

Investigation + Evaluation

ALLEN FOSSIL PLANT

OVERVIEW

Facility Overview

1956 Allen Fossil Plant constructed by Memphis Light Gas & Water

1965 TVA began leasing the plant and purchased it in 1984

741 megawatts net capacity

3 Coal-fired units (closed)

2018 Ceased operations and replaced by TVA Allen Combined Cycle plant

2019 Begin dewatering East Ash Disposal Area

East Ash Pond Complex

_̂

Allen Fossil Plant

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November 2018Project No. 172676009

Client/Project

1Figure No.

Title

Tennessee Valley AuthorityAllen Fossil Plant Memphis, Shelby County, Tennessee

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Environmental Study Area

Legend


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ALF NEPA Map

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TDEC Order CCR Units:

• West Ash Pond

• East Ash Pond


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ALLEN FOSSIL PLANT

HISTORIC TIMELINE

1956

1965

1984

1991

2005

2018

1978

1960s

Allen Fossil Plant constructed by Memphis Light Gas & Water

TVA begins leasing the Allen Fossil Plant

TVA purchases the Allen Fossil Plant

East Ash Disposal Area temporarily deactivated to facilitate construction of USACE levee

Dredge cell and diversion trench constructed within the East Ash Disposal Area

Ceased operations and replaced by TVA Allen Combined Cycle plant

Compared with the former Allen Fossil Plant the new plant reduces carbon emissions by 60%, nitrogen oxides by 90%, and sulfur dioxide by nearly 100%

West Ash Disposal Area deactivated

North perimeter dike constructed as a flood control levee

ALLEN FOSSIL PLANT

TVA's commitment• TVA is committed to protecting human health and the environment and doing the right thing for the

people of Memphis

• TVA is committed to the remediation of arsenic impacts at the Allen Fossil Plant

• TVA is committed to economic development in Memphis

• TVA has suspended use of the groundwater production wells at the Allen Combined Cycle Natural Gas Plant and has contracted with MLGW to obtain cooling water for the plant

TVA's strategy Short-term Allen Fossil Plant CCR strategy:

• Implement groundwater Interim Response Action

• Dewater East Ash Disposal Area

• Perform supplemental Investigations

Long-term ALF CCR strategy:

• Conduct National Environmental Policy Act evaluation to determine closure alternative

• Perform groundwater remediation

• Restore site for industrial use

TVA'S COMMITMENT AND STRATEGY

Conceptual Future Redevelopment

ALLEN FOSSIL PLANT

COAL COMBUSTION RESIDUALS COMPLIANCE ORDER

What is the TDEC Order and why was it put in place?On August 6, 2015, the Tennessee Department of Environment and Conservation (TDEC) issued Commissioner’s Order No. OGC15-0177 to the Tennessee Valley Authority (TVA) for Coal Combustion Residuals (CCR) Compliance pursuant to the provisions of Tennessee’s solid waste management and disposal laws.

This order establishes a transparent, comprehensive process to investigate, assess, and remedy unacceptable risks resulting from the management and disposal of CCR at TVA coal-fired power plants within the state.

Did you know…In 2018, Allen’s three coal-fired units were retired and replaced with natural gas generators that will help ensure low-cost and reliable electricity for the greater Memphis area.

What is the EIP?What it is and why we do it TDEC has requested certain information about Allen’s CCR management.

What TVA has already done TVA has ongoing programs and monitoring that can help answer TDEC’s questions.

Proposed EIP Activities The Environmental Investigation Plan (EIP) lays out the proposed investigation TVA is conducting to provide additional information that TDEC has requested.

What are coal combustion residuals?

Coal combustion residuals, commonly known as coal ash, are created when power plants burn coal to produce electricity.

These residuals include fly ash and bottom ash/slag and are collected separately from different areas of the facility.

Fly ash originates from the flue gas electrostatic precipitators and bottom ash from the boilers.

Slag Fly Ash

ALLEN FOSSIL PLANT

ENVIRONMENTAL IMPACT STATEMENT ASH IMPOUNDMENT CLOSURE

Alternative A

• No Action

Alternative B (Preferred)

• Closure-by-Removal of the East Ash Pond Complex, West Ash Pond and Metal Cleaning Pond

• Disposal of CCR to an Offsite Landfill Location

Alternative C

• Closure-by-Removal of the East Ash Pond Complex, West Ash Pond and Metal Cleaning Pond

• Disposal of CCR in a Beneficial Re-Use Process and Offsite Landfill Location

Why it is being done• Support TVA’s commitment to eliminate

wet CCR storage at its coal plants by closing CCR surface impoundments

• Meet federal and state requirements including the U.S. Environmental Protection Agency’s CCR Rule and National Environmental Policy Act

• Make land available for future economic development projects in the greater Memphis area

Projects studied• Closure of the East Ash Pond Complex

• Re-evaluation of the West Ash Pond for Closure-by-Removal

• Closure of the Metal Cleaning Pond

• Possible Use of CCR in a Beneficial Re-use Process

• Evaluation of Existing Off-Site Permitted Landfills that will Accept CCR Materials from ALF

• Evaluation of Existing Offsite Backfill Sources

How it might get done

Alternatives Considered in the EIS

ALLEN FOSSIL PLANT

ENVIRONMENTAL IMPACT STATEMENT—PROCESS/SCHEDULE

Publication of the Notice of Intent in the Federal Register

November 30, 2018

Notify interested parties about availability of Draft EIS for comments

Complete October 4, 2019

Review public scoping comments, identify alternatives, conduct studies and develop Draft EIS

Complete Fall 2019

Revise Draft EIS based on comments from the public and agencies

Complete Late 2019

Notice of availability of Final EIS will be published

Complete Early 2020

TVA will publish a ROD after making a final determination concerning projects addressed in the EIS

Estimated Spring 2020

Public Provides input on EIS scope

November 30, 2018–January 31, 2019

45 days

Notice of Intent

Release Draft EIS

Prepare Draft EISPublic Scoping Period

Official Public Comment Period

Finalize EIS Release Final EIS Record of Decision (ROD)

Public Meetings October 8 + 30, 2019

Community Information Session January 17, 2019

Meetings provide an opportunity for public to discuss Draft EIS with Project Team and provide comments

ALLEN FOSSIL PLANT

ENVIRONMENTAL IMPACT STATEMENT—COMMENTS

How to Provide Comments on the EISWritten comments can be left here or mailed to the address on the Comment Form.

You can also provide comments by:

Email: [email protected]

Web: www.tva.gov/nepa

Mail: Attn: W. Douglas White NEPA Specialist Environmental Compliance & Operations

Tennessee Valley Authority 400 W. Summit Hill Drive Knoxville, TN 37902

All comments received by November 25, 2019 will become part of the EIS record

ALLEN FOSSIL PLANT

ENVIRONMENTAL IMPACT STATEMENT—POTENTIAL LANDFILL SITES

• Located within 600 miles for Rail - or -

• Located within 30 miles for Truck

• Existing permitted landfill

• Large commercial operator

• Ability to accept CCR

• Ability to dedicate a portion of the landfill to this project

• Serviced by an existing rail spur or port (if located more than 30 miles from Allen Fossil Plant)

• Sufficient capacity

• No geographic restrictions on waste origin that exclude Allen Fossil Plant

Landfills were screened based on the following criteria:

Facility Commercial Carrier City, State Distance to Allen Fossil Plant

Transport Method

South Shelby Landfill Republic Services Memphis, Tennessee 14 miles Truck

Tunica Landfill Waste Management Robinsonville, Mississippi 20 miles Truck

North Shelby Landfill Republic Services Millington, Tennessee 21 miles Truck

Arrowhead Landfill Green Group Holdings Uniontown, Alabama 240 miles Rail

Taylor County Disposal Landfill Waste Industries Mauk, Georgia 380 miles Rail

Lee County Landfill Republic Services Bishopville, South Carolina 565 miles Rail

Potential Landfill Locations

ALLEN FOSSIL PLANT

Criteria Truck Transport Rail Transport

Safety Minor impact due to Increased risk of accidents and road damage due to increased vehicles on roadways

Minor impact due to Increased risk of accidents and derailments

Risk would be greater than transport by truck due to increased distance traveled

Distance 30-mile radius 600-mile radius

Closure Period 8-years

Average 240 truck trips per day during closure period

15 years

100 rail cars (1 train) every 9 days during closure period

Environmental Impacts

Minor, localized air, greenhouse gas and noise emissions

Minor, localized air and noise emissions (yet less than transport by truck)

Marginally greater emissions of greenhouse gases due to longer travel distance

Transportation Impact

Moderate and localized impact to existing transportation system

Minimized with the development and implementation of a Traffic Management Plan

Minor impact to existing regional railway system

Infrastructure Improvements

Sufficient roads already exist Require upgrades to local rail system to support railcar storage and staging

ENVIRONMENTAL IMPACT STATEMENT—TRUCK VS RAIL TRANSPORT OF CCR

ALLEN FOSSIL PLANT

ENVIRONMENTAL IMPACT STATEMENT—POTENTIAL BACKFILL (BORROW) SOURCES

Potential Backfill Source Locations and Haul Routes

TVA will use clean soil to backfill the East Pond after the CCR has been removed.

TVA will implement the following measures to minimize impacts associated with the transport of backfill material (i.e., clean soil or borrow material) to Allen Fossil Plant and the offsite transport of CCR from the plant:

Measures to minimize fugitive dust and exhaust emissions

• Require all contractors to keep construction equipment properly maintained

• Require the use of Best Management Practices such as covered loads and watering unpaved haul roads

Measure to minimize noise impacts

• Minimize the use of backfill source locations that require access from lower volume roadways

Measures to minimize traffic impacts

• Develop a traffic management plan that considers

– Alternate access locations to/from Allen Fossil Plant (i.e., Plant Road vs. Riverport Road to the west)

– Staging and management of trucks entering/exiting

– Select backfill source locations that do not require use of local, low volume roads

– Potential alternate routing during train operations on Rivergate Road, and installation of temporary signals at key intersections

Potential Haul Routes

Potential Backfill Source Locations

Haul Route

Low Income Population

Minority Population

Legend

ALLEN FOSSIL PLANT

TDEC ORDER ENVIRONMENTAL INVESTIGATION PLAN

General Information

Geotechnical Civil/Mapping Activities

Hydrogeologic Environmental

• Exploratory Drilling • Coal Combustion Residuals Material Quantity

• Hydrogeologic Investigation

• CCR Material Characteristics

• Slope Stability • Groundwater Investigation

• Seepage Investigation

• Background Soil Investigation

Below are the main areas of technical focus in the EIP, divided by study area. More information on the activities within each area has been provided at the stations around the room.

The evaluation of existing site data serves as the foundation to support the additional studies planned for each focus area.

This event is to provide information about the Environmental Investigation Plan (EIP) for the decommissioned Allen Fossil Plant.

The following acronyms appear frequently on the boards:

The information boards are color-coded according to the technical focus area they cover in the EIP. For instance, if they contain general information regarding the EIP process, the information board will be color-coded in blue.

• Environmental Investigation Plan (EIP)

• Environmental Assessment Report (EAR)

• Coal Combustion Residuals (CCR)

• Tennessee Department of Environment and Conservation (TDEC)

• Tennessee Valley Authority (TVA)

• Sampling and Analysis Plan (SAP)

• Environmental Protection Agency (EPA)

• Remedial Investigation (RI)

ALLEN FOSSIL PLANT

ENVIRONMENTAL INVESTIGATION PLAN

Process/Schedule

September 24, 2018

April 27, 2016

October 15–January 31 2018 2019

Complete Summer 2021

Complete Fall/Winter 2019

Complete Fall 2020

Complete Winter 2020

Complete Summer 2021

Complete Fall 2021

TD

EC

Ord

er

EIPInvestigation Conference

All Interested Parties Meeting



Summarize + Respond to Comments +

Revise EIP + TDEC approval

Implement EIP

Environmental Assessment Report

(EAR)

Corrective Action/Risk Assessment

(CARA) Plan

TDEC Approval of Closure Method and

Associated Other Remediation

Revision Cycle Address TDEC Comments

Community Information Session November 1, 2018 and January 17, 2019

ALLEN FOSSIL PLANT

EXPLORATORY DRILLING (1 of 3)

Exploratory drilling helps us better understand what is in and under each CCR unit.

It tells us:

• What is there: material types (CCR, soil) and properties (strength, permeability, etc.)

• Where it is (material locations)

• Where the water level(s) are (material saturation)

The EIP includes an evaluation of existing geotechnical data. This includes a review of design and construction records, inspection records, field data (including 150+ borings and 70+ water level instruments), laboratory data, and engineering analyses.

Each piece of information has been evaluated to confirm that it was collected and analyzed properly in the past. This existing data are very valuable to understand the CCR unit conditions.

Slope StabilityMaterial

Quantity 3D Model

Groundwater Flow Model

CCR Material Characterization

Site Geotech InformationWhat TVA has already done

• Additional borings within the interior of the CCR units

• Install temporary wells in CCR material

• Targeted borings in specific areas along unit borders

• Laboratory testing

• Share data with hydrogeological, environmental, and civil/mapping discipline teams

EIP Activities

The field geologist/engineer will prepare boring logs to describe the recovered samples.

What are borings

Drilled holes from which to take samples of CCR and soil

What it is and why we do it

ALLEN FOSSIL PLANT

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Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data. Page 01 of 01

Notes

1.2.

Coordinate System: NAD 1983 StatePlane Tennessee FIPS 4100 FeetImagery Provided by Terraserver (2016) & TVA (2015)

1:1,800 (At original document size of 22x34)

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Proposed BoringsEast Ash Disposal Area

4

Tennessee Valley AuthorityAllen Fossil Plant

175567295Memphis, Tennessee Prepared by TR on 2018-05-22

Technical Review by JD on 2018-05-22

Project Location

Client/Project

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Current Impoundment (Approximate)

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Client/Project

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Title

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What are Water Level Instruments/Piezometers?

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Slotted PVC well pipe that allows water to enter at a selected depth in the boring

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West Ash Disposal Area 17 Borings

2 Borings with Temporary Wells and No Rock Coring

15 Borings with No Rock Coring


ALLEN FOSSIL PLANT

SLOPE STABILITY (1 of 3)

Example of existing slope stability analysis

Inputs: Surface and subsurface geometry/zones, engineering properties, water levels/pressures, external loads

Outputs: Factor of safety against sliding

• Compare existing models to new data from the Exploratory Drilling Sampling and Analysis Plan

– If models are representative, no changes

– If not, update models and reanalyze

• New analyses (for some units) for normal and earthquake conditions

• Compare slope stability results to acceptance criteria

EIP Activities

What it is and why we do itThese analyses tell us if the slopes of the CCR units are stable. Multiple locations around each CCR unit are checked for stability.

Normal (long-term) conditions and earthquake conditions are evaluated.

What TVA has already doneSlope stability has been analyzed many times over the years, for various conditions and at multiple units.

The existing analyses were reviewed as part of the evaluation of existing geotechnical data.

Each analysis was reviewed for adequate documentation, appropriate methods, and representative conditions.

CCR Unit Normal Earthquake

East Ash Disposal Area E E/PWest Ash Disposal Area E P

E = Existing analysis P = Proposed analysis

Existing and proposed analyses satisfy EIP requirements

Fill - Sandy Silt Core

Silt and Sandy Silt

Lean and Fat Clay

Sandy SiltHydraulic Ash

Compacted Ash

Hydraulic AshFill - Sandy Silt Shell Fill - Sandy Silt Shell

Fill - Coarse Sand

Fill - Sandy Silt ShellRiprap

PZ-13

PZ-12

Stilling PondNormal Pool Elevation: 225.7 ft

Material Type Fill - Sandy Silt Shell Fill - Sandy Silt Core Sandy SiltLean and Fat Clay Silt and Sandy Silt Hydraulic Ash Compacted Ash Fill - Coarse Sand Riprap

Tennessee Valley AuthorityAllen Fossil Plant East Ash Disposal AreaMemphis, TennesseeSection E-E'

Static Slope Stability Analysis

Factor of Safety: 1.66

Existing Geometry;Long-Term, Maximum Storage Pool Loading;Effective Stress Analysis;Drained Strengths

Sat. Unit Wt.124 pcf125 pcf125 pcf115 pcf115 pcf105 pcf123 pcf120 pcf120 pcf

Cohesion0 psf0 psf0 psf0 psf0 psf0 psf0 psf0 psf0 psf

Friction Angle31 °31 °30 °26 °28 °25 °34 °34 °38 °

Horn Lake Cutoff

Divider Dike

Wet Unit Wt.120 pcf125 pcf125 pcf110 pcf110 pcf95 pcf110 pcf115 pcf120 pcf

Eastern Perimeter DikeAsh PondNormal Pool Elevation: 229.9 ft

Note: The results of the analysis shown here are based on available subsurface information, laboratory test results and approximate soil properties.The drawing depicts approximate subsurface conditions based on historical drawings or specific borings at the time of drilling. No warranties canbe made regarding the continuity of subsurface conditions.

Project No. 172675014

PZ-12R

Distance (feet)-410 -400 -390 -380 -370 -360 -350 -340 -330 -320 -310 -300 -290 -280 -270 -260 -250 -240 -230 -220 -210 -200 -190 -180 -170 -160 -150 -140 -130 -120 -110 -100 -90 -80 -70 -60 -50 -40 -30 -20 -10 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 210 220 230 240 250 260 270 280 290 300 310 320 330 340 350 360 370

Ele

vatio

n (fe

et)

150

160

170

180

190

200

210

220

230

240

250

260

270

280

290

ALLEN FOSSIL PLANT

Existing instrumentation East Ash Disposal Area

Water level instrumentation• New instruments are added

– due to Exploratory Drilling Sampling and Analysis Plan

– due to Hydrogeological Investigation Sampling and Analysis Plan (monitoring wells)

What TVA has already doneTVA has multiple types of water level instruments on site, as well as a number of monitoring wells, to track water levels in many areas. These instruments have been installed over many years, for various purposes. About 70 water level instruments are currently installed.


What it is and why we do itSlope stability is influenced by water levels and pressures (among other factors).

Monitoring water levels also supports the hydrogeologic investigation and the CCR material quantity estimate (saturated vs. unsaturated material).

ALF_PZ1Clay

ALF_PZ2Clay

Fill

STN-3ALF_PZ3Clay Fill

ALF_PZ4Silt Fill

ALF_PZ5Clay andSand

ALF_PZ6Sand Fill

ALF_PZ7Silt Fill

ALF_PZ8Silt Fill

ALF_PZ9Clay

STN-10Silt Fill

ALF_PZ11Sand Fill

ALF_PZ12 ClayALF_PZ13Silt Fill

ALF_PZ14Clay Fill

ALF_B_2A_PZ5Silt

ALF_B_2A_PZ4Clay

ALF_B_2A_PZ1Sand

ALF_B_2B_PZ3Clay

ALF_E_2D_PZ3Silt

ALF_E_2E_PZ6Silt

ALF_B_2A_PZ3Sand

ALF_B_2A_PZ2Clay

ALF_B_2B_PZ2Sand

ALF_B_2B_PZ1Sand

ALF_E_2D_PZ4Clay

ALF_E_2D_PZ2SiltALF_E_2D_PZ1Sand

ALF_E_2E_PZ5Clay

ALF_E_2E_PZ4Silt

ALF_E_2E_PZ3Silt

ALF_E_2E_PZ2Sand

ALF_E_2E_PZ1Sand

ALF_PZ15Silty Sand

ALF_PZ11SSand Fill

ALF_PZ9RSandy Silt

ALF-203Sand

ALF-204Sand andClay

P-6Sand,Clay, Silt

ALF-204Sand andClay

P-5 ALF-206Sand andClay

ALF-213Sand,Clay, Silt


ALF-202Silty Sandand Sand


ALF_PZ12R Clay and Sand

ALF-201ASand

ALF-201BSand

ALF-202ASand

ALF-202BSand

ALF-203ASand

ALF-203BSand

ALF-204ASand

ALF-204BSand

ALF-205ASand

ALF-205BSand

ALF-212ASand

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0 150 300 450 600Feet

Existing InstrumentationEast Ash Disposal Area

1 - Public Meeting




Project Location

Client/Project

Figure No.

Title

LegendExisting Piezometer Open Standpipe (Screened Interval)

Existing Piezometer Vibrating Wire (Tip Interval)



Allen Fossil Plant

CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

ALF_PZ1Clay

ALF_PZ2Clay

Fill

STN-3ALF_PZ3Clay Fill

ALF_PZ4Silt Fill

ALF_PZ5Clay andSand

ALF_PZ6Sand Fill

ALF_PZ7Silt Fill

ALF_PZ8Silt Fill

ALF_PZ9Clay

STN-10Silt Fill

ALF_PZ11Sand Fill

ALF_PZ12 ClayALF_PZ13Silt Fill

ALF_PZ14Clay Fill

ALF_B_2A_PZ5Silt

ALF_B_2A_PZ4Clay

ALF_B_2A_PZ1Sand

ALF_B_2B_PZ3Clay

ALF_E_2D_PZ3Silt

ALF_E_2E_PZ6Silt

ALF_B_2A_PZ3Sand

ALF_B_2A_PZ2Clay

ALF_B_2B_PZ2Sand

ALF_B_2B_PZ1Sand

ALF_E_2D_PZ4Clay

ALF_E_2D_PZ2SiltALF_E_2D_PZ1Sand

ALF_E_2E_PZ5Clay

ALF_E_2E_PZ4Silt

ALF_E_2E_PZ3Silt

ALF_E_2E_PZ2Sand

ALF_E_2E_PZ1Sand

ALF_PZ15Silty Sand

ALF_PZ11SSand Fill

ALF_PZ9RSandy Silt

ALF-203Sand

ALF-204Sand andClay

P-6Sand,Clay, Silt

ALF-204Sand andClay

P-5 ALF-206Sand andClay





ALF_PZ12R Clay and Sand

ALF-201ASand

ALF-201BSand

ALF-202ASand

ALF-202BSand

ALF-203ASand

ALF-203BSand

ALF-204ASand

ALF-204BSand

ALF-205ASand

ALF-205BSand

ALF-212ASand

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0 150 300 450 600Feet

Existing InstrumentationEast Ash Disposal Area

1 - Public Meeting




Project Location

Client/Project

Figure No.

Title





Allen Fossil Plant

CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

ALLEN FOSSIL PLANT


Existing instrumentation West Ash Disposal Area

ALF_PZ30_ASilt Fill

ALF_PZ30_BSand

ALF_PZ33_ASand

ALF_PZ33_BSand ALF_PZ36_A

CCRALF_PZ36_B

Silt

ALF_PZ36_CSand

ALF-207Sand and

Silt

ALF-208Sand and

Silt

ALF-209Sand

ALF-207ASand

ALF-208ASand

ALF-209ASand

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Existing InstrumentationWest Ash Disposal Area

1 - Public Meeting




Project Location

Client/Project

Figure No.

Title




Former Disposal Area (Approximate); Dashed

Allen Fossil Plant

CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

ALF_PZ30_ASilt Fill

ALF_PZ30_BSand

ALF_PZ33_ASand

ALF_PZ33_BSand ALF_PZ36_A

CCRALF_PZ36_B

Silt

ALF_PZ36_CSand

ALF-207Sand and

Silt

ALF-208Sand and

Silt

ALF-209Sand

ALF-207ASand

ALF-208ASand

ALF-209ASand

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0 150 300 450 600Feet

Existing InstrumentationWest Ash Disposal Area

1 - Public Meeting




Project Location

Client/Project

Figure No.

Title




Former Disposal Area (Approximate); Dashed

Allen Fossil Plant

CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

ALLEN FOSSIL PLANT

ALLEN FOSSIL PLANT DRAFT

COAL COMBUSTION RESIDUALS MATERIAL QUANTITY

• Review existing surveys, drawing, and borings

• Develop 3-dimensional models of CCR units

• Update 3-dimensional models with new boring data and water levels

• Confirm CCR volumes

What it is and why we do itRecent surveys of the site tracked the location and quantity of coal combustion residuals (CCR) to aid overall site management.

What TVA has already done• As built drawings and records

• Aerial surveys performed for specific projects

• Historical boring logs beginning in 1958

• In 2015 TVA completed 26 soil test borings, 14 cone penetration test soundings, and 5 test pits for the East and West Ash Disposal Areas

Proposed EIP Activities

Example of a 3-dimensional model developed and used to calculate volumes

East Ash Disposal Area topographic map

West Ash Disposal Area topographic map

N

N

West Ash Disposal Area

COAL COMBUSTION RESIDUALS MATERIAL QUANTITY

• Review existing surveys, drawing, and borings

• Develop 3-dimensional models of CCR units

• Update 3-dimensional models with new boring data and water levels

• Confirm CCR volumes

What it is and why we do itRecent surveys of the site tracked the location and quantity of coal combustion residuals (CCR) to aid overall site management.

What TVA has already done• As built drawings and records

• Aerial surveys performed for specific projects

• Historical boring logs beginning in 1958

• In 2015 TVA completed 26 soil test borings, 14 cone penetration test soundings, and 5 test pits for the East and West Ash Disposal Areas

EIP Activities

Example of a 3-dimensional model developed and used to calculate volumes

East Ash Disposal Area topographic map

West Ash Disposal Area topographic map

East Ash Disposal Area East Ash Disposal Area

N

N

ALLEN FOSSIL PLANT

HYDROGEOLOGIC INVESTIGATION

What it is and why we do itHydrogeologic investigations help us better understand how groundwater moves in a particular area, as well as its interaction with the surrounding soils and rocks.

These investigations consist of installing groundwater monitoring wells to collect information about groundwater.

Background and downgradient wells are used to study water quality changes.

What TVA has already done• Existing network of 66 groundwater

monitoring wells

• Wells are screened at shallow, intermediate and deep intervals

• In 2019, installed 8 new groundwater monitoring wells near West Ash Disposal Area and 1 new background monitoring well

What is a groundwater monitoring well? A well specially designed and installed to obtain representative groundwater quality samples and hydrogeologic information.

Groundwater monitoring well

ALLEN FOSSIL PLANT

What it is and why we do itGroundwater samples are collected frequently to test for a number of quality measures. By testing groundwater regularly, TVA can track compliance with regulatory permits and requirements.

• Bimonthly groundwater sampling for 1 year (6 events)

• Collect groundwater samples from 16 groundwater monitoring wells

EIP Activities

Groundwater well locations West Ash Disposal Area

What TVA has already done• Groundwater monitoring has been performed

routinely since 1988

• Samples are analyzed for CCR related constituents

GROUNDWATER INVESTIGATION

Allen Fossil Plant

CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

West AshDisposal Area

ALF-209B

ALF-208B

ALF-207B

ALF-219ALF-219BALF-219A


ALF-210BALF-210

ALF-209ALF-209A

ALF-208ALF-208A ALF-207

ALF-207A

ALF-210A

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1.2.3.

Coordinate System: NAD 1983 StatePlane Tennessee FIPS 4100 FeetImagery Provided by Terraserver (2016) & TVA (2015)Existing Monitoring Wells is referenced from TVA Drawing 10W858-03Allen Fossil Plant Reservation.


0 200 400 600 800Feet

Proposed West Ash Disposal Area Monitoring Wells

9



Technical Review by LP on 2018-10-01

Project Location

Client/Project

Figure No.

Title

LegendExisting Groundwater Monitoring Well

Groundwater Monitoring Well – 2019

Gauging Station

Approximate Levee Centerline

Approximate Extent of Levee

Approximate Extent of Culvert (26 Inch Wide)

TVA Property Boundary


Allen Fossil Plant

CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee


ALF-209B

ALF-208B

ALF-207B



ALF-210BALF-210

ALF-209ALF-209A


ALF-207A

ALF-210A

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0 200 400 600 800Feet


9




Project Location

Client/Project

Figure No.

Title



Gauging Station






Allen Fossil Plant

CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee


ALF-209B

ALF-208B

ALF-207B



ALF-210BALF-210

ALF-209ALF-209A


ALF-207A

ALF-210A

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0 200 400 600 800Feet


9




Project Location

Client/Project

Figure No.

Title



Gauging Station






Allen Fossil Plant

CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee


ALF-209B

ALF-208B

ALF-207B



ALF-210BALF-210

ALF-209ALF-209A


ALF-207A

ALF-210A

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0 200 400 600 800Feet


9




Project Location

Client/Project

Figure No.

Title



Gauging Station






ALLEN FOSSIL PLANT

BACKGROUND SOIL INVESTIGATION

What it is and why we do itThe constituents found in CCR are also found in nature. This investigation would detect CCR constituent levels in background soils.

These levels can be compared to other soils to determine if they are higher than natural levels and used to determine if CCR constituents are naturally occurring in native soils.

Proposed soil sampling locations

_̂Allen Fossil Plant

CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

"J

"J

"J

"J

"J

"J!(

&?

&?

&?

&?

&?!H

!H

!H

!H !H

!H

!H

!H

!H

!H!H

!H!H

ALF-210B

ALF-204

ALF-205

ALF-210

ALF-202

ALF-201

ALF-210A

ALF-BG-01 ALF-BG-02

ALF-BG-03

ALF-BG-04

ALF-BG-05

ALF-BG-06

ALF-BG-07ALF-BG-08

ALF-BG-09 ALF-BG-10

ALF-BG-11

ALF-BG-12

ALF-BG-13

ALF-215

ALF-214

ALF-216

ALF-201

ALF-210


Notes

1.2.3.

Coordinate System: NAD 1983 StatePlane Tennessee FIPS 4100 FeetImagery Provided by TVA (2018 & 2015)TVA property boundary is referenced from TVA Drawing 421 P 504 AllenFossil Plant Reservation.


0 500 1,000 1,500 2,000Feet

Background Sampling Locations

FIGURE 5-1



Technical Review by TM on 2019-02-22

Project Location

Client/Project

Title

($$¯

Legend!H Proposed Background Soil Sampling Location - Offsite

!H Proposed Background Soil Sampling Location - TVA Property

&? 2017 Remedial Investigation Background Soil Sampling Location

"J Existing Background Groundwater Monitoring Well

"J Existing Downgradient Monitoring Well

!( Proposed Bachground Monitoring Well





CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

"J

"J

"J

"J

"J

"J!(

&?

&?

&?

&?

&?!H

!H

!H

!H !H

!H

!H

!H

!H

!H!H

!H!H

ALF-210B

ALF-204

ALF-205

ALF-210

ALF-202

ALF-201

ALF-210A

ALF-BG-01 ALF-BG-02

ALF-BG-03

ALF-BG-04

ALF-BG-05

ALF-BG-06

ALF-BG-07ALF-BG-08

ALF-BG-09 ALF-BG-10

ALF-BG-11

ALF-BG-12

ALF-BG-13

ALF-215

ALF-214

ALF-216

ALF-201

ALF-210


Notes

1.2.3.



0 500 1,000 1,500 2,000Feet


FIGURE 5-1




Project Location

Client/Project

Title

($$¯











CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

"J

"J

"J

"J

"J

"J!(

&?

&?

&?

&?

&?!H

!H

!H

!H !H

!H

!H

!H

!H

!H!H

!H!H

ALF-210B

ALF-204

ALF-205

ALF-210

ALF-202

ALF-201

ALF-210A

ALF-BG-01 ALF-BG-02

ALF-BG-03

ALF-BG-04

ALF-BG-05

ALF-BG-06

ALF-BG-07ALF-BG-08

ALF-BG-09 ALF-BG-10

ALF-BG-11

ALF-BG-12

ALF-BG-13

ALF-215

ALF-214

ALF-216

ALF-201

ALF-210


Notes

1.2.3.



0 500 1,000 1,500 2,000Feet


FIGURE 5-1




Project Location

Client/Project

Title

($$¯










What TVA has already done• Background soil samples were collected

from 4 locations during the Remedial Investigation in 2017

• Background soil samples were collected from 10 locations for analysis of CCR constituents in 2019

Background Soil Sampling Location - Offsite

Background Soil Sampling Location - TVA Property

Background Monitoring Well

ALLEN FOSSIL PLANT

SEEPAGE INVESTIGATION

What it is and why we do itDikes on the property are checked frequently to identify active seeps.

The soils and water at active seep areas are tested for CCR constituent levels.

Historic seep locations

• Conduct seepage investigation to identify active seeps

• Collect soil and water samples at identified seeps

• Analyze samples for CCR constituents

• Comparative analysis against background soils

• Report the analytical results in the Environmental Assessment Report (EAR)

EIP Activities


CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

!(

!(

!(

!(

!( !( Seep No. 1

Seep No. 2

Seep No. 3

Seep No. 4

Seep No. 5

Seep No. 6

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0 300 600 900 1,200Feet

Historical Seeps (Approximate Location)

8




Project Location

Client/Project

Exhibit No.

Title

($ $¯Legend

!( Historical Seeps (Approximate Location)

!( Inactive Seep (Approximate Location)



Seep No. Northing Easting Approx. Size Field Notes and Status1 294801.59255 732225.28610 5' to 15' in length No flow; inactive; currently monitored2 296219.09365 729287.61382 50' x 50' Mitigated w/ graded filter3 296498.59604 726116.33309 20' x 20' No flow; inactive; mitigated - sod placement4 296105.30024 729466.32180 25' x 20' Currently monitored

5 294922.68974 728939.86058 5' x 450' in lengthFlow directed to East Ash Pond, and subject to

NPDES discharge permit

6 294903.00770 729104.89995 5' x 10'Flow directed to East Ash Pond, and subject to


East Ash Disposal Area


What TVA has already done• TVA has conducted annual dike inspections at

ALF since 1970


CrittendenCross

Lee

St. Francis

DeSoto

Marshall

Tate

Tunica

Shelby

Benton

FayetteArkansas

Mississippi

Tennessee

!(

!(

!(

!(

!( !( Seep No. 1

Seep No. 2

Seep No. 3

Seep No. 4

Seep No. 5

Seep No. 6

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0 300 600 900 1,200Feet

Historical Seeps (Approximate Location)

8




Project Location

Client/Project

Exhibit No.

Title

($ $¯Legend

!( Historical Seeps (Approximate Location)

!( Inactive Seep (Approximate Location)



Seep No. Northing Easting Approx. Size Field Notes and Status1 294801.59255 732225.28610 5' to 15' in length No flow; inactive; currently monitored2 296219.09365 729287.61382 50' x 50' Mitigated w/ graded filter3 296498.59604 726116.33309 20' x 20' No flow; inactive; mitigated - sod placement4 296105.30024 729466.32180 25' x 20' Currently monitored

5 294922.68974 728939.86058 5' x 450' in lengthFlow directed to East Ash Pond, and subject to


6 294903.00770 729104.89995 5' x 10'Flow directed to East Ash Pond, and subject to




ALLEN FOSSIL PLANT

COAL COMBUSTION RESIDUALS MATERIAL CHARACTERISTICS (1 of 2)

What it is and why we do itThe different CCR materials on site are tested for levels and types of chemical constituents. This helps us understand whether they leach from (or leave) the ash and enter the water in the CCR units.

Proposed temporary wells East Ash Disposal Area

• Collect CCR material samples from borings in units

• Collect pore water samples from temporary wells in units

• Analyze samples for CCR constituents

• Comparative analysis against existing data

• Report the analytical results in the Environmental Assessment Report (EAR)

EIP Activities

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What TVA has already done• 1995 — Slag fines analyzed for leachability and

trace metals

• 2002 — Slag fines and fly ash analyzed for leachability and total metals; slag analyzed for leachability

• 2013 — Slag, slag fines and fly ash analyzed for leachability and total metals

• 2017 — Ash and pore water samples collected from 21 locations within the East Ash Disposal Area

ALLEN FOSSIL PLANT

COAL COMBUSTION RESIDUALS MATERIAL CHARACTERISTICS (2 of 2)

Proposed temporary wells West Ash Disposal Area

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ALLEN FOSSIL PLANT

TVA'S ADVANCED TECHNOLOGY FOR IMPOUNDMENT MONITORING CENTER

TVA’s Advanced Technology for Impoundment Monitoring (ATIM) Center

$2 million to develop the ATIM center

helps to identify and respond to any coal ash issues before they become an emergency

More than 11,000 real‑time sensors to monitor ash impoundments send data (24/7/365) to a centralized computer monitoring system

LED wall displays Geographic Information System (GIS) maps, weather, earthquakes, sensor data

Operations has real‑time data or can watch what’s happening at TVA impoundments via live video

System sends alerts on any irregularities

Only facility of its kind in the utility industry in the U.S.

ATIM Center

Automated Instrumentation

ALLEN FOSSIL PLANT

Remedial investigation objectives:

• Evaluate sources

• Delineate CCR constituents in groundwater, focusing on arsenic, fluoride, and lead

• Evaluate Alluvial aquifer

• Evaluate connections between aquifers

What is Remedial Investigation?A Remedial Investigation (RI) is a scientific study intended to:

1 Gather the data necessary to evaluate the nature and extent of environmental impacts at a property

2 Establish cleanup goals

3 Identify preliminary corrective actions

Remedial investigation work performed:

• 46 wells added during the RI (for a total of 66 wells)

• 7 groundwater events

• 315 samples analyzed

• Deep stratigraphic borings were drilled to characterize the upper Claiborne confining unit (clay)

• Pumping test by United States Geological Survey (USGS)


Groundwater monitoring well

REMEDIAL INVESTIGATION

A RI is performed to collect data to characterize environmental conditions that may have been affected by site operations. The RI at the Allen Fossil Plant was performed following the detection of elevated arsenic in groundwater near the East Ash Disposal Area. The RI is being performed in coordination with the TDEC Division of Remediation, and concurrently with the TDEC Order, but is focused on the groundwater near the East Ash Disposal Area.

ALLEN FOSSIL PLANT

REMEDIAL INVESTIGATION TIMELINE

Process/Schedule

May 2017

TVA Begins Voluntary Groundwater Investigation

July 2017

TDEC Requests Remedial Investigation

Work Plan

September 2017

TDEC Approves Remedial Investigation

Work Plan

November 2017

Remedial Investigation Completed

March 2018

Remedial Investigation Report Submitted to TDEC

August 2018

Supplemental Remedial Investigation Work Plan

Submitted to TDEC

May 2019

Updated Remedial Investigation Report Submitted to TDEC

December 2018

Supplemental Remedial Investigation Completed

Continued Groundwater Monitoring and Reporting

ALLEN FOSSIL PLANT

REMEDIAL INVESTIGATION— DELINEATE CCR CONSTITUENTS (1 of 2)

The horizontal extent of arsenic, fluoride, and lead in groundwater is limited to two primary areas: north and south of East Ash Disposal Area.

ALF-203

Arsenic (>10 ug/L)

ALF-202

1,800 – 4,070 ug/L

246 – 282 ug/L

ALF-203

ALF-202Fluoride

(> 4 mg/L)

Lead (> 15 ug/L)

Horizontal delineation (arsenic) north and south areas

Horizontal delineation (fluoride and lead) north and south areas

• Arsenic above the USEPA drinking water standard was found north and south of the East Ash Disposal Area in the shallow Alluvial aquifer

• The highest concentrations were found within the upper 40 feet

• Fluoride and Lead above the USEPA drinking water standards are located within the arsenic areas

ALLEN FOSSIL PLANT

Vertical distribution of arsenic, fluoride, and lead in groundwater• The highest concentrations were detected within the upper 40 feet of the Alluvial aquifer

• Arsenic, fluoride and lead were not detected above USEPA drinking water standards in any deep wells

• The Memphis aquifer (sand) has not been affected and sample results meet USEPA drinking water standards

Arsenic (>10 ug/L)

Fluoride (>4 mg/L)

Lead (>15 ug/L)

Vertical Delineation - North Area2. Delineate As,

F and Pb ingroundwater

Highest concentrations upper 40 feet

Arsenic (>10 ug/L)

Fluoride (>4 mg/L)

Vertical Delineation – South Area2. Delineate As,

F and Pb ingroundwater

No Lead (>15 ug/L) Highest concentrations upper 40 feet

REMEDIAL INVESTIGATION— DELINEATE CCR CONSTITUENTS (2 of 2)

Cross section–north of East Ash Disposal Area

Cross section–south of East Ash Disposal Area

Conceptual Cross Section—geological formation thicknesses are approximate


ALLEN FOSSIL PLANT

PLANT DECONSTRUCTION

The Allen Fossil Plant was constructed in the 1950s by the Memphis Light, Gas and Water Company (MLGW). TVA purchased the plant and property in 1984. Allen’s three coal-fired units were retired on March 31, 2018.

On October 4, 2019, TVA issued a Final Environmental Assessment (EA) and Finding of No Significant Impact (FONSI) for decontamination and deconstruction of its Allen Fossil Plant.

The EA evaluated the potential environmental effects of the future disposition of the physical structures associated with the retired coal-fired plant units, including the powerhouse, coal handling facilities, and surrounding support buildings.

The Former Allen Fossil Plant will be Deconstructed.

TVA’s preferred alternative is Full Demolition of the Allen Plant resulting in a usable property.

This is a key step in the process to make the Allen site available for future redevelopment.

Decommissioning is already underway and deconstruction will start in 2022.

ALLEN FOSSIL PLANT

DECONSTRUCTION OF FORMER ALLEN FOSSIL PLANT

A change is underway at TVA as energy efficiency has reduced demand and the company shifts away from coal and toward cleaner sources of generation such as nuclear, renewables, and natural gas.

Old facilities are being turned into new opportunities in the most environmentally sustainable way. D4 is how most everything is reused and/or recycled, and sites are returned to grassy fields.

Decommissioning Prepare Site

• Drain oils, fuels, and solvents

• Salvage usable equipment

• Remove residual ash & coal dust from boilers and plant structures, ducts, hoppers, & bunkers

Deactivation Remove Energy Sources

• Reroute power and services

• Makie the plant “cold, dark and dry” by de-energizing, isolating, and air-gapping equipment so that it is safe to decontaminate and demolish

Decontamination Remove Regulated Materials

• Universal waste disposal

• Asbestos abatement of all structures to be demolished

Remove Plant and Structures Demolition

• Carefully deconstruct buildings and structures

• Dispose, reuse, and recycle building components and materials

• Restore the disturbed area to provide conditions suitable for redevelopment

ALLEN FOSSIL PLANT

D4—SCOPE AND TIMELINE

Allen Fossil D4 Scope and Timeline

1940 1945 1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020 2025ALLEN FOSSIL PLANT UPDATE - 10-08-19 | 3

TVA begins Decommissioning

2018

TVA begins Decontamination and Demolition

2022

ALLEN FOSSIL PLANT

PLANT UPDATE

Allen Fossil Plant UpdateOctober 8, 2019

Allen Fossil Plant

ALLEN FOSSIL PLANT UPDATE - 10-08-19 | 2

Commissioning Date:1959Retirement Date:March 2018Size of facility:Approx. 500 acresFormer Output:741 megawattsAmount of CCR material:Approx. 3.5 million cubic yardsCCR Units to be Closed:East Ash Pond ~100 acresWest Ash Pond ~20 acres

ALLEN FOSSIL PLANT

Allen Environmental Stewardship




1948-1950

McKellar Lake created by City of

Memphis

McKellar Lake

PLANT UPDATE

ALLEN FOSSIL PLANT



1956-59

ALF constructed and operated by

MLGW

West Ash Pond

Allen Fossil Plant (ALF)



North Perimeter Dike constructed to

control flooding

1958-60

USACE Levee

PLANT UPDATE

ALLEN FOSSIL PLANT



TVA begins leasing ALF from MLGW

1965



Ash is sluiced to newly constructed

East Ash Pond

1969

East Ash Pond

PLANT UPDATE

ALLEN FOSSIL PLANT



West Ash Pond is deactivated

1978

West Ash Pond



1984

TVA Purchases the Allen Fossil Plant

PLANT UPDATE

ALLEN FOSSIL PLANT



2014

Begin Evaluation of Closure Options for East and West Ponds



2015

West Ash Pond

Prior to the effective date of the CCR Rule, the West Ash Pond was retrofitted to not

allow stormwater accumulation

PLANT UPDATE

ALLEN FOSSIL PLANT



2015

TVA entered into an agreement with the City

of Memphis, Shelby County, Port Authority

and MLG&W



TVA begins TDEC Order Activities

2017

PLANT UPDATE

ALLEN FOSSIL PLANT



Allen Fossil Plant ceased operations and

is replaced by Allen Combined Cycle Plant

2018

Allen Combined Cycle Plant• $975 million natural gas plant• Reduced emissions• Over 1,100 megawatts• Solar farm onsite• Equipped to use biogas from

wastewater treatment



2018

CCR Sluicing to the East Ash Pond ceases

PLANT UPDATE

ALLEN FOSSIL PLANT


TVA begins Decommissioning

2018

TVA begins Decontamination and Demolition

2022


PLANT UPDATE

Conceptual Future Condition


East Ash Pond: Closure-by Removal

West Ash Pond: Closure-by Removal

ALF Plant: Deconstructed

ALLEN FOSSIL PLANT

For More InformationAllen Fossil Planthttps://www.tva.gov/Energy/Our-Power-System/Coal/Allen-Fossil-Plant

Air Quality – Water Quality – Ash Storagehttps://www.tva.com/Environment/Environmental-Stewardship

TDEC Orderhttps://www.tva.com/tdec

Groundwater Monitoring www.tva.com/ccr


PLANT UPDATE

West Ash Pond• Groundwater Study

– 18 Monitoring Wells– One year of

sampling planned• Background Soil

Study

TDEC Order Environmental Investigation


ALLEN FOSSIL PLANT

East Ash Pond• 27 new wells• 22 soil borings with 60

groundwater samplescollected

• 59 pore water samplescollected

• Deep soil borings• USGS pumping test



PLANT UPDATE

East Ash Pond• Two areas of groundwater

identified with elevatedArsenic

• Impacts are limited toupper 40 feet of theAlluvial aquifer

• No impacts to theMemphis Sand Aquifer



ALLEN FOSSIL PLANT

• CCR is removed for offsite disposalor beneficial reuse

• 7 to 10 years

Pond Closure: CCR Removal


• Backfill with clean soil, coversurface, and prepare for site re-useand development

• Continue to monitor groundwaterquality

Pond Closure: Site Restoration


PLANT UPDATE

ALLEN FOSSIL PLANT

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ALLEN FOSSIL PLANT

PLANT UPDATE

• Groundwater extraction• 360 gallons per minute• Treated water is tested and

discharged to the City’s sanitary sewer for further treatment

Interim Response Action: Groundwater


ALLEN FOSSIL PLANT

PLANT UPDATE

• Free water and pore water are removed and treated

• Discharged to Outfall 002

Pond Closure: Dewatering


To Outfall 002

99.999% RELIABILITY

18 YEARS IN A ROW

28,000 JOBS$3.6 BILLIONIN MEMPHIS SINCE 2012

TVA ECONOMIC DEVELOPMENTHELPED CREATE

$800 MILLIONANNUAL OPERATINGCOST REDUCTION

$1 BILLIONANNUAL FUEL

COST REDUCTION

MLGWWHOLESALE RATES

FLAT, STABLE AND LOW

ALLEN COMBINED CYCLE PLANTHOME TO

LARGEST TVA OWNEDSOLAR FACILITY

* since 2005 levels

ADDED

41 MEGAWATTSOF NEW LOAD AND

22 MEGAWATTSOF PROJECTED LOAD GROWTHIN PARTNERSHIP WITH MLGW

MORE THAN60% CARBONREDUCTION

Memphis is important to TVA. We have been honored to partner with Memphis and MLGW for more than 85 years. We invest over $70 Million each year in the Memphis community, including $17 Million in tax equivalent payments. We also own and operate our $1 Billion Allen Combined Cycle plant, one of the most advanced and efficient gas generating facilities in the U.S. The plant ensures high reliability, low cost and cleaner air.

As a customer of TVA, MLGW receives the full benefits of a low-cost public power system with 99.999% reliability. TVA’s public power model allows us to partner with the customers we serve and make investments into their communities. To learn more, visit tva.com/Memphis.

Serving the people of Memphisto make life better

tva.com/Memphis | facebook.com/TVA | @TVAnews | @TVA

99.999% RELIABILITY

18 YEARS IN A ROW





COST REDUCTION

MLGWWHOLESALE RATES




* since 2005 levels

ADDED








99.999% RELIABILITY

18 YEARS IN A ROW





COST REDUCTION

MLGWWHOLESALE RATES




* since 2005 levels

ADDED








99.999% RELIABILITY

18 YEARS IN A ROW





COST REDUCTION

MLGWWHOLESALE RATES




* since 2005 levels

ADDED








ALLEN FOSSIL PLANT

INTERIM RESPONSE ACTION: GROUNDWATER TREATMENT PROCESS

Equalization Tank

North and South Well

Fields

Flocculation Tank

Post-Clarification

Reaction Tank

FeCl Acid Base

Filter Cake

Polymer

Offsite Disposal

T.E. Maxson Wastewater Treatment

Plant

Press

GROUNDWATER INTERIM RESPONSE ACTION - TREATMENT PROCESSAllen Fossil Plant

Multi-Media Filters

Bag Filter

Groundwater is pumped from extraction wells.

Groundwater is mixed to achieve a homogeneous blend prior to treatment.

Water pH is adjusted to neutral and ferric chloride is added to bind with arsenic and facilitate particle settling.

Polymer is added to create larger particles from smaller particles of iron salts and arsenic.

Larger particles settle out, forming a sludge. Water goes to the Post-Clarification Tank.

Sludge thickens by settling over time.

Thickened sludge is pressed and dewatered to form a solid filter cake.

Prior to filtration, water pH is adjusted to meet discharge requirements.

Filters consisting of sand, gravel, or other media further remove small particles from the water.

Final filtering step prior to discharge.

Water is returned to the Equalization Tank.

Filter cake is disposed at an offsite landfill.

Thickener

Clarifier

ALLEN FOSSIL PLANT

POND CLOSURE: DEWATERING EAST ASH POND—WATER TREATMENT PROCESS

Weir Tanks

EAST ASH POND - WATER TREATMENT PROCESSAllen Fossil Plant

Sand and Bag Filters

For each water stream, weir tanks are used for bulk solids removal

Modular Tank

Alumina Adsorption

Media

Outfall 002Stilling Pond

East Ash Pond

Final pH Adjustment

Free WaterPore WaterStorm Water

LEGEND

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pH adjustment and coagulant addition (in-line) Large stilling pond allows

settling of solids

Large tank used for settling and equalization when stilling pond has been removed from service

Final pH adjustment (in-line) and discharge to outfall after compliance check

Filtration of solids using sand and bag filters

Special media filters to capture dissolved arsenic during pore water removal

ALLEN FOSSIL PLANT

INTERIM RESPONSE ACTION: GROUNDWATER TREATMENT PROCESS

Equalization Tank

North and South Well

Fields

Flocculation Tank

Post-Clarification

Reaction Tank

FeCl Acid Base

Filter Cake

Polymer

Offsite Disposal

T.E. Maxson Wastewater Treatment

Plant

Press

GROUNDWATER INTERIM RESPONSE ACTION - TREATMENT PROCESSAllen Fossil Plant

Multi-Media Filters

Bag Filter

Thickener

Clarifier

ALLEN FOSSIL PLANT

POND CLOSURE: DEWATERING EAST ASH POND—WATER TREATMENT PROCESS

Weir Tanks

EAST ASH POND - WATER TREATMENT PROCESSAllen Fossil Plant

Sand and Bag Filters

Modular Tank

Alumina Adsorption

Media

Outfall 002Stilling Pond

East Ash Pond

Final pH Adjustment

Free WaterPore WaterStorm Water

LEGEND

Aci

d

Coa

gula

nt

ALLEN FOSSIL PLANT

ENVIRONMENTAL IMPACT STATEMENT—PROJECT AREA


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ALLEN FOSSIL PLANT

REMEDIAL INVESTIGATION—EVALUATE ALLUVIAL AQUIFER + CONNECTIONS

(Clay)


Groundwater Flow and Lake Levels

DRAFT

Groundwater flow is predominantly horizontal (not ver�cal)

3. Install wellsand evaluate

Alluvial Aquifer

Evaluate Alluvial aquiferEvaluating the groundwater flow directions helps to understand and predict migration of CCR constituents.

• To evaluate groundwater flow directions near the East Ash Disposal Area, 22 shallow, intermediate, and deep wells were installed and monitored (46 total)

• The outcome was that groundwater flows horizontally and is affected by McKellar Lake

Evaluate connections between aquiferThe Memphis aquifer (sand) is a source for regional drinking water. This deep aquifer is located beneath the shallow Alluvial aquifer, but these aquifers are separated by a clay layer, the upper Claiborne confining unit. TVA, with help from United States Geological Survey, evaluated the connection between these two aquifers and concluded:

Site-Wide Groundwater Quality

Conceptual Cross Sec�on - geological forma�on thicknesses are approximate.

4. Evaluateconnec�ons

between aquifers

?

?

Memphis Aquifer (Sand)

Alluvial AquiferUpper Claiborne Confining Unit (Clay)

TVA ACCTVA ALFMcKellar Lake

Shallow Impacts

Memphis Aquifer (Sand)

Shallow Impacts

• The upper Claiborne confining unit (clay), where present, is low-hydraulic conductivity clay up to 69 feet thick and lies between the Alluvial and Memphis (sand) aquifers

• The stratigraphy of the upper Claiborne confining unit (clay) is offset in the southeast corner of the East Ash Disposal Area. Further evaluation was conducted

• A hydraulic connection between the Alluvial aquifer and Memphis aquifer (sand) was observed under pumping conditions

Concentrations below USEPA drinking water standards



ALLEN FOSSIL PLANT

REMEDIAL INVESTIGATION—NEXT STEPS

What are the next steps?

Proposed groundwater interim response action

• Design, construct and operate Groundwater Extraction/Treatment Systems

• Purpose is to control groundwater during pond closure


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ALF-205B

ALF-204B

ALF-201B

ALF-214B

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ALF-205A

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Notes1.2.

Coordinate System: NAD 1983 StatePlane Tennessee FIPS 4100 FeetImagery Provided by TerraServer (2016) & TVA (2015)


0 250 500 750 1,000Feet

Deep Stratigraphic Boring Location Map

3-3


175577013Memphis, Tennessee Prepared by LT on 2019-02-14

Technical Review by JJ on 2019-02-14

Project Location

Client/Project

Figure No.

Title

($$¯

Legend

")Sewer Manhole Location of Force Main Transition toGravity

!( Performance Monitoring Well (PMW) (Shallow)

!( Performance Monitoring Well (PMW) (Intermediate)

!( Performance Monitoring Well (PMW) (Deep)

!( IRA Extraction Well (EW)

Monitoring Well (Shallow)

Monitoring Well (Intermediate)

Monitoring Well (Deep)

!H Production Well (Memphis Sand)

Sanitary Sewer Pipes

East Ash Pond Boundary

!( Deep Stratigraphic Boring

McKellar Lake Gauging Station#0


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