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· Environmental Upgrades · CCR Summary · A.B. Brown Summary · Recent News · Articles and Analysis · A.B Brown 1 · A.B. Brown 2 · F.B. Culley 2 · F.B. Culley 3 · Warrick 4
Environmental Upgrades Planned as of June 19, 2019
It faces major expenditures to meet the CCR regulations. There is a big potential for pond dewatering and beneficiation of ponded flyash. Environmental improvements as outlined in the NPDES permit amended February 2018 specify that a dry bottom ash transport water system must be installed prior to December 2020, and the FGD waste water system must be upgraded to a chemical-precipitation biological system by February 2021 or a zero liquid discharge (ZLD) system by December 2023. Vectren has been selling its dry flyash since 2009. Last year it started discussions with a potential partner to explore beneficiation of the ponded ash. In April 2019 the State of Indiana denied Vectren the permit to proceed with a large natural gas fired power plant. It had planned to upgrade the Culley plant and retire the Brown plant because of the scrubber problems. Now it will have to consider extending the life of the Brown units. The A.B. Brown 1 & 2 units use sodium carbonate double alkali scrubbers. The high maintenance costs of these scrubbers will probably now be addressed since the remaining life has been extended. Each Brown unit has a separate scrubber that was installed when the plants were built in 1979 and 1986. An independent consultant conducted a condition assessment of the Brown scrubbers and concluded the alkaline scrubbers have an expected life cycle of 16 years. They are now beyond that expected useful life. Given their current condition, the consultant recommended retirement of both scrubbers within the next 5-10 years. Brown Unit 1 will be 45 years old and Brown Unit 2 will be 38 years old in 2024. The recommended replacement is one forced oxidation scrubber to remove SO2 from both units. The estimated capital cost is nearly $340 million. Along with a new forced oxidation scrubber in order to comply with the Effluent Limitations Guidelines (ELG) rule, the new scrubber will require a waste water treatment system. AB Brown Unit 1 has experienced the effects of cycling first hand as Solid Particle Erosion (SPE) damaged a turbine by-pass valve allowing foreign particles to enter the turbine causing a three month outage and a $3.8 million repair during the summer of 2016. The issue appears to have occurred in the main steam outlet header where scale appears to have flaked off the internal header due to multiple thermal transitions related to unit cycling. Turbine valves are now being inspected and changed out more frequently to prevent a similar occurrence. CCR Summary 06-19-2019 Vectren has been selling its dry flyash since 2009. Last year it started discussions with a potential partner to explore beneficiation of the ponded ash. In April 2019 the State of Indiana denied Vectren the permit to proceed with a large natural gas fired power plant. It had planned to upgrade the Culley plant and retire the Brown plant because of the scrubber problems. Now it will have to consider extending the life of the Brown units Presently Vectren sells 0.5% of all flyash generated yearly in the U.S. The potential for beneficiation can be assumed to be 30 years of accumulation or the equivalent of 15% of present annual flyash generation potential. The impounded ash is mixed with FGD wastewater overflow and various waste streams. The fact that the Brown units use sodium carbonate scrubbers should be considered in the estimated value of the impounded ash. The problems with the Brown scrubbers and the denial of a permit for the gas plant should lead Vectren to consider keeping Brown in operation and provide thermal beneficiation for ash. At the same time it has considered and could reconsider making ammonium sulfate. It may also want to consider making hydrochloric acid and extracting rare earths at the same time. A.B Brown has two units totaling over 400 MW. The Upper Pond held a total of 4.2 million cubic yards (500,000 cubic yards of water and 3.7 million cubic yards of ash) and the lower pond held 2.6 million cubic yards . Vectren must stop putting ash into the Brown pond by 2020. Vectren recently merged with Center Point Energy and is therefore part of a large corporation. A.B. Brown Summary • A.B. Brown Generating Station is a 650 MW coal and natural gas fired power plant located in Posey County, Indiana. The plant is owned by Southern Indiana Gas & Electric Co., a subsidiary of Vectren. According to a 2015 inspection report from the Indiana Department of Environmental Management, some fly ash from the plant's coal-fired units is sent by barge to Missouri for use by Holcim Cement, but the majority of ash is disposed of in on-site ash ponds. Filter cake from the plant's flue gas desulfurization process is sent to an on-site restricted waste landfill.
• A.B. Brown Generating Station is among the U.S. Environmental Protection Agency's list of potential damage cases, indicating that coal ash disposal at the site has potentially polluted groundwater or surface water at levels which threaten human health and the environment.
• Both of A.B. Brown’s ponds are unlined. They cover 156 acres, with approximately 53 acres impounded in the Lower Ash Pond and the remaining 103 acres impounded in the Upper Ash Pond. The Lower Dam became operational in 1978 and since then no significant amount of material has been removed. • The Upper Dam was constructed in 2002 to better manage the separation of water and solids within the ponds. The Upper Pond is used to store liquid wastes that include: fly ash, bottom ash, boiler slag, boiler chemical cleaning wastes (once per 7-8 years), flue gas deposits, flue gas desulfurization (FGD) belt filter wash down, water sump wastes, pyrites, material removed from the coal pile runoff pond (once per year), plant floor drain wash down, reverse osmosis system reject and rainfall/runoff from the area surrounding the pond (Lockheed Martin, 2009b). The Lower Ash Pond is used for storage of scrubber and water treatment blowdown as well as any discharge from the Upper Pond (Lockheed Martin, 2009a). In 2009, Vectren reported that the fly ash and bottom ash had been disposed of exclusively in the Upper Ash Pond since 2002 (Retherford, 2009). • In October 2015, the lower pond was approximately 53 feet deep and the upper pond was 62 feet, the height of a 5 - 6 story building. The lower pond surface was at an elevation of 442.3 feet above sea level and the upper pond surface was at 458.3 feet (ATC Group Services, 2016a). The Ohio River bank lies downhill from AB Brown at 350 feet above sea level (US Geologic Survey, n.d.). A professional licensed engineer from the environmental consulting firm ATC performed a visual inspection of the ponds in the fall of 2015. The inspector estimated that the Upper Pond held a total of 4.2 million cubic yards (500,000 cubic yards of water and 3.7 million cubic yards of ash) and the lower pond held 2.6 million cubic yards (300,000 cubic yards of water and 2.3 million cubic yards of ash) (ATC Services Group, 2016a). On February 10, 2016, Vectren filed a public notice with the Indiana Department of Natural Resources of its intent to decommission the Upper Dam at A.B. Brown. The word ‘decommission’ refers to any dam that is going to be removed or changed so it will no longer function as a dam. The plan for dam decommissioning, written by environmental consulting firm ATC, would not completely remove the upper dam. It would build a 10-foot wide trapezoidal breach in the southern end of the Upper Dam with a breach elevation of 455 feet above sea level. The plan describes other steps they would take to lower the upper pond and allow it to drain into the Lower Pond (ATC Group Services, Feb 2016). Given that the upper pond surface is currently at 458.3 feet and its maximum depth is 62 feet, it appears that much of the upper pond’s contents would be left in place after the pond lowering measures and construction of the breach. The decommissioning plan includes construction of an additional buttress on the lower dam to “provide reinforced stability for the Lower Ash Pond”. The buttress would make the lower dam thicker, but not higher. The plan states that these changes are needed “in order to meet stringent CCR criteria”, referring to the EPA’s rule for Coal Combustion Residuals (ATC Group Services, Feb 2016). As mentioned above, the Lower Pond already holds more than its estimated maximum volume, so it is not clear how it will hold the additional material from the Upper Pond after the Upper Dam is decommissioned • The restricted waste landfill at A.B. Brown is located immediately north of the ash ponds. It began operation in 1979 and was expanded in 1992. The original landfill was unlined. The expansion has a compacted clay liner as required for type III restricted waste landfills (EPRI, 2009b; Indiana Department of Environmental Management, n.d.). The old and new landfills together cover 85.5 acres of which 70.5 acres has undergone closure or partial closure with a cover of soil or soil and geomembrane, which is a man-made liner for preventing water from getting through. In this case, the geomembrane will help prevent rain or snowmelt from seeping into the landfilled waste. As of October 2015, 28 acres of the 85 acre landfill had the geomembrane cap (ATC Group Services, 2016b). A 15-acre active section lacks any cover (ATC Group Services, 2016b). In the landfill’s permit, cover is required on an annual basis (Breyenton, 2015). The A.B. Brown landfill holds approximately 6.8 million cubic yards of dry coal combustion residuals, primarily waste from flue gas desulfurization (FGD).
Recent News
Vectren’s Plan to Build Natural Gas
Generator Denied in April 2019 The Indiana Utility Regulatory Commission denied Vectren’s proposal Wednesday for an 850-megawatt gas-fueled plant costing an estimated $781 million. The Evansville Courier & Press reports the IURC cited the potential financial risk to Vectren customers, who would have paid for the plant over 30 years at a time when the energy industry is rapidly changing. Vectren sought approval to build the plant to replace its coal-burning A.B. Brown Generating Station, in Posey County, and most of its F.C. Culley plant in Warrick County. Could this mean a delay in closing the Brown station? In Wednesday's order, the IURC approved a plan to retrofit Vectren’s coal-fired generation unit, Culley Unit 3 [270 MW], to ensure it remains in compliance with EPA rules related to coal ash and waste handling. Also related to Culley Unit 3, the IURC ruled that certain costs associated with ash pond closure are recoverable through an environmental cost adjustment. The IURC also approved recovery of certain past pollution control investments at Vectren’s power plants through the new environmental cost adjustment. "We appreciate the IURC’s continued, thorough review of our electric generation transition plan," said Lynnae Wilson, Vectren chief business officer, Indiana electric. "Economic and reliability factors are driving a transition from coal-based generation, and the selection of replacement resources will continue to be our focus. The case was filed at a time of significant changes in generation technology. While a large generation resource offered significant economic efficiencies, the IURC has directed us to increase our focus on the benefits of a more diverse resource mix." Vectren to Close Flyash Pond in 2020 In May 2019 it was announced that one of the same contaminants found in groundwater near a coal ash pond at Vectren's A.B. Brown power plant also has been found in well water nearby on private property. The contaminant, boron, is one of several detected by Vectren's own groundwater monitoring wells around the coal ash pond. Work to shut down the pond and remove much of the ash could begin as early as next year, said Angila Retherford, vice president of environmental affairs at Vectren, a CenterPoint Company. That closure is required by federal law based on elevated levels of several contaminants detected in the groundwater, Retherford said. Those are boron, lithium and molybdenum. Vectren must stop putting coal ash into the pond after October 2020 and begin closing it. A private analysis of the property owner's well water and soil was paid for by the Courier & Press and conducted by Environmental Management Consultants, Inc. It found similarly elevated levels of the contaminants in the water samples: 7.39 milligrams per liter of boron and 991 milligrams per liter of sodium. The EPA health protection advisory level for sodium is 20 milligrams per liter and for Boron is 4 milligrams per liter.
This document is the approval for reimbursement via rates for environmental improvements mainly involving the CCR. But there is also testimony of experts such as Paul Farber on the economics of adding ammonia scrubbers. https://earthjustice.org/sites/default/files/files/45052--FINAL%20ORDER--4-24-19.pdf
Articles and Analysis Earth Justice Brown Data
Ashtracker Data for A. Brown Wells
Since 2009, Vectren has been recycling nearly all of its dry fly ash rather than placing it in a pond, which has helped avoid the need for a new landfill. The ash is shipped by barge to a facility in Missouri where it is used in cement manufacturing. Vectren has begun discussions with a potential partner to determine if ash within its ponds can be excavated and recycled over several years for beneficial re-use of the material rather than retiring the ponds in place.
AECOM was hired in 2015 to find a solution to closing the inactive Culley West Pond. The program was to close the pond and dewater solids which would be used in the embankment with a completion date of 2018. https://www.vectren.com/assets/downloads/planning/ccr/FB-Culley-West-NOI.pdf
West Demonstration to be completed by 4/16/20. There is documentation relative to new pond liners by AECOM.
https://www.vectren.com/reporting/ccr Vectren will request approval to retrofit its largest, most-efficient coal-fired generation unit, Culley unit 3 (270 MW), to ensure it remains in compliance with EPA (Environmental Protection Agency) rules related to coal ash and waste water handling. The filed plan leads to a 60% reduction in carbon emissions by retiring three coal-fired generation units and exiting ownership of another in 2023: two 245-MW units at A.B. Brown, a 90-MW unit at the F.B. Culley plant in Warrick County and exiting co-ownership of 150 MW of Warrick unit 4, a unit currently co-owned with Alcoa through 2023. Vectren is exploring options related to closing its ash ponds within the planning period, another item triggered by EPA mandates. Since 2009, Vectren has been recycling nearly all of its dry fly ash rather than placing it in a pond, which has helped avoid the need for a new landfill. Discussions have begun to determine if ash in the ash ponds can be extracted and recycled as well. https://www.vectren.com/assets/cms/html/smartenergyfuture/images/factsheet_generation.pdf
This consultant study from 2009 is very extensive but outdated
On January 17, 2014, as a result of the compliance issues, Vectren filed a petition with the IURC for approval of modifications to four of its coal-powered electricity generating facilities - Brown units 1 and 2, Culley unit 3, and Warrick. The petition sought approval of several clean energy projects and issuance of a CPCN to construct, install, and use clean coal technology (CCT). Among other projects, Vectren requested approval for a soda ash injection system for sulfur trioxide (SO3) mitigation at Brown units 1 and 2 and a hydrated lime injection system for SO3 mitigation at Culley unit 3. B&V's report found that the only feasible plans to meet environmental regulations were (1) replacing one or more of Vectren's current units with new natural gas-powered facilities and retiring the remaining facilities, or (2) upgrading the current coal-powered facilities. B&V evaluated twenty-one potential scenarios involving various gas-powered replacement options and a range of potential market and environmental scenarios. B&V concluded that of the twenty-one scenarios, only one offered a small savings over the Mandated Projects proposal. B&V found that the cost savings under this one scenario were "marginal" and conditional on a future market scenario with low natural gas prices and high carbon prices. Accordingly, B&V concluded that Vectren's plan to modify the existing facilities was the best https://casetext.com/case/citizens-action-coal-of-ind-inc-v-s-ind-gas-elec-co-1
Brown Units 1 & 2, though the newest coal plants in Vectren South’s coal fleet, were built with dual alkali scrubbers used to remove SO2 emissions. Dual alkali scrubbing has been abandoned by the utility industry in favor of forced oxidation scrubbing technology. Vectren South believes the AB Brown plant has the only dual alkali scrubbers left in any generating facility in the United States. These scrubbers have high operation and maintenance costs, are slow to react compared to forced oxidation scrubbers and create a corrosive environment that impacts other plant equipment and facilities. The dry bottom ash system and FGD wastewater treatment system improvements. Vectren South witness Retherford describes the environmental requirements for bottom ash transport water and FGD waste water. As outlined in our NPDES permit which was renewed in April 2017 and amended February 2018, a dry bottom ash transport water system must be installed prior to December 2020, and the FGD waste water system must be upgraded to a chemical-precipitation biological system by February 2021 or a zero liquid discharge (“ZLD”) system by December 2023. Vectren South will also need to close the West Ash Pond at Culley as the pond is currently not accepting ash and is inactive. A portion of the pond will be closed by removing ash and consolidating it in a location of the pond which will be closed in place. As space is very constrained at Culley, and a new pond is needed to accept plant water run-off, this method allows for placement of a new plant pond within the footprint of the portion of the West pond that is closed by removing ash with minimal changes to existing yard drains, coal pile run-off, and other waste water sources. What is the estimated cost for the dry bottom ash, FGD waste water treatment, west pond closure and new plant run-off pond? The cost is $95 million for these investments.
A.B. Brown 1
Plant Name: A
B Brown average coal sulfur content : 2.82 high coal sulfur content ': 3.13
low coal sulfur content : 2.46 Important basis for analyzing tons of flash and variations from year to year
part addition: fabric filter? part original equipment: Cold Side ESP part manufacturer: Buell Emission Control Div. part temperature: 130 part air flow ft3 min: 833600 Particulate Emissions TPY Low: 353.726875 total particulate emissions TPY Low: 707.45375 Particulate Emissions TPY High: 1768.634375 total particulate emissions TPY High: 2600.9183391875 PM 2 1/2 TPY Low: 247.6088125 total PM TPY Low: 495.217625 PM 2 1/2 TPY High: 1556.39825 total PM TPY High: 2287.9054275
SO2 Control & Emissions: FGD: fgd startup: 1979 fgd supplier: FMC
fgd reagent: sodium carbonate fgd process: dual alkali fgd process efficiency: 90% fgd lining: ceramic fgd dewatering type: belt filter
Individual Stacks:
SO3 tons (2007): 1058.719 with with SCR and scrubbers SO2 phase 1 allowances: SO2 phase 2 allowances: 5327 SO2 lb/mmbtu 1989 historical: 0.85 SO2 acid rain phase: 2 Reagent tons 2018: 43.1 (nearest 0.1 thousand tons) Estimated removal efficiency 2005: 87.187 Design SO2 efficiency %: 85 (nearest 0.1 % by weight) Design SO2 lbs/hr: 2960 SO2/NOX Region 2: No 2012 SO2 Allocation: 4494 2014 SO2 Allocation: 2422 Monitoring:
CEM: cem startup: 6/1/93 cem supplier: Enviroplan cem das supplier: Enviroplan cem flow supplier: EMRC & Kurz NOx Control & Emissions:
Important in terms of ammonia in the ash (Post Combustion) nox pc technology: SCR nox pc supplier: Black & Veatch nox pc architect: Black & Veatch nox pc startup: 2003 nox pc catalyst supplier: CERAM nox pc dampers supplier: Bachmann nox pc expansion joints suppliers: nox pc cem supplier: Sick-Maihak Mercury Removal: startup date: If activated carbon used then this data is potentially important
FLY_ASH_UNIT_TOTAL: 68.15 FLY_ASH_LANDFILL: FLY_ASH_PONDS: 132.60 FLY_ASH_ONSITE: FLY_ASH_SOLD: FLY_ASH_OFFSITE: FLY_ASH_TOTAL: 132.6
BOTTOM_ASH_LANDFILL: BOTTOM_ASH_PONDS: 33.15 BOTTOM_ASH_ONSITE: BOTTOM_ASH_SOLD: BOTTOM_ASH_OFFSITE: BOTTOM_ASH_TOTAL: 33.15
SLUDGE_LANDFILL: 204.2 SLUDGE_PONDS: SLUDGE_ONSITE: SLUDGE_SOLD: 9.3 SLUDGE_OFFSITE: SLUDGE_TOTAL: 213.5
GYPSUM_LANDFILL: GYPSUM_PONDS: GYPSUM_ONSITE: GYPSUM_SOLD: GYPSUM_OFFSITE: GYPSUM_TOTAL: 0
OTHER_BYPRODUCT_LANDFILL: OTHER_BYPRODUCT_PONDS: OTHER_BYPRODUCT_ONSITE: OTHER_BYPRODUCT_SOLD: OTHER_BYPRODUCT_OFFSITE: OTHER_BYPRODUCT_TOTAL: 0 The same data is provided for SEARCH RESULTS:
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