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Location Matters in Coal Ash Storage

TVA wraps up studies to determine whether coal ash impoundments and landfills at its current and former fossil plants are in compliance with the CCR Rule. With one exception, they are.

When you’re buying a house or starting a business (or even looking for a great new lunch spot), it all boils down to three things: location, location, location.

The same is true for utilities, especially those who are committed to safe storage of coal combustion residuals, which are the products left over from the process of burning coal to make electricity.

“TVA has been committed to the dry storage of coal combustion residuals since 2009 and has been actively working to transition from CCR impoundments to dry, lined landfills,” explains Rachel Combs, manager of Strategic Asset Management for Generation, Construction, Projects & Services.

Kingston fossil plant

Kingston Fossil Plant

In 2015, the U.S. Environmental Protection Agency issued guidance in the area of location, introducing what is now known as the CCR Rule, a list of requirements designed to mitigate stability and groundwater risks posed by CCR units. The CCR Rule also creates transparency by requiring CCR facility recordkeeping, notifications, and posting of related information on the internet.

All utilities—TVA included—are required to report on the placement of any landfills and/or surface impoundments storing CCR based on five criteria that define restrictions based on their location. Utilities must demonstrate that new or existing impoundments or landfills can meet these restrictions to stay in operation, as set forth in the rule. (If not, the unit/s must be closed.)

The rule restricts the operation of CCR units:

  1. Within five feet of the uppermost aquifer
  2. In wetlands
  3. In unstable areas, such as karst areas*
  4. Near active or recently active fault zones
  5. In seismic impact zones

As Combs explains, the CCR rule required that TVA spend the past 42 months studying to determine if the landfills and surface impoundments at its current and former fossil plants met those criteria, posting results on as required under the law.

“Since 2015, when EPA published its CCR Rule, TVA has worked to determine whether its existing impoundments and landfills are located in areas EPA has determined are off limits,” Combs says. “TVA and its contractors have completed a significant amount of work to identify and review the location demonstrations required by the CCR Rule.”

Because the existing impoundments at Allen and Gallatin are already slated for closure, TVA did not complete the location demonstrations for the impoundments at those sites. For all other units where TVA did complete the studies, TVA reports that all CCR units subject to the rule—with the exception of those at Paradise Fossil near Drakesboro, Ky.—meet the location criteria in the CCR Rule. Paradise will cease using and close the impoundments by the timeframes set forth in the CCR Rule. You can read the results here.

Beyond the data, TVA remains true to its mission. “We are committed to operating dry and closing our wet impoundments,” Combs says. “And environmental stewardship remains our number one priority.”

* Karst is a landscape formed from the dissolution of soluble rocks including limestone, dolomite and gypsum. It is characterized by sinkholes, caves, and underground drainage systems.

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