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ALLEN FOSSIL PLANT ASH IMPOUNDMENT CLOSURE ENVIRONMENTAL IMPACT STATEMENT Shelby County, Tennessee

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ALLEN FOSSIL PLANT ASH IMPOUNDMENT CLOSURE ENVIRONMENTAL IMPACT STATEMENT Shelby County, Tennessee Document Type: EIS-Administrative Record Index Field: Final EIS Project Name: ALF Ash Impoundment Closure Project Project Number: 2016-29 ALLEN FOSSIL PLANT ASH IMPOUNDMENT CLOSURE ENVIRONMENTAL IMPACT STATEMENT Shelby County, Tennessee Prepared by: TENNESSEE VALLEY AUTHORITY Chattanooga, Tennessee March 2020 Direct Comments to: W. Douglas White NEPA Compliance Tennessee Valley Authority 400 West Summit Hill Drive, WT11B-K Knoxville, TN 37902 Email: [email protected] This page intentionally left blank Cover Sheet COVER SHEET Allen Fossil Plant Ash Impoundment Closure Environmental Impact Statement Proposed Action: The Tennessee Valley Authority (TVA) has prepared this Environmental Impact Statement to assess the effects and address environmental, cultural, and socioeconomic concerns associated with the closure of surface impoundments containing coal combustion residuals (CCR) at the Allen Fossil Plant (ALF). Type of document: Environmental Impact Statement Lead agency: Tennessee Valley Authority Contact: W. Douglas White Tennessee Valley Authority 400 West Summit Hill Drive, WT11B-K Knoxville, TN 37902 Abstract: TVA needs to make a decision regarding the method of closure of the surface impoundments at ALF as well as how to dispose of CCR removed from the impoundments under the Closure-by-Removal option. In addition to No Action, TVA considered two action alternatives that addressed closure of the impoundments as well as associated component actions related to transport of borrow material, the mode of transport of CCR to potential receiving landfills, and the construction and operation of a potential beneficial re-use facility that would process CCR from ALF. The proposed closure of the impoundments would help support the goal established by the TVA Board of Directors to eliminate wet ash storage at its coal plants and would make the ALF closure area land available for future economic development projects in the greater Memphis area. Both closure alternatives would include the Closure-by-Removal of the impoundments at ALF, offsite transport of CCR and onsite transport of borrow material for site restoration. Impacts associated with these alternatives primarily include temporary short-term impacts during closure activities and minor to large impacts associated with the air emissions, noise emissions, safety risks and disruptions to environmental justice communities that would be associated with the offsite transport of CCR and onsite transport of borrow along public roadways. Transport and disposal of CCR to an offsite landfill is preferred over transport to a beneficial re-use processing facility as construction and operation of a facility would increase the duration of closure which would delay the future economic development of the site and result in greater impacts to the community associated with the air emissions, noise emissions, safety risks and disruptions to the public associated with the extended closure time frame. Final Environmental Impact Statement This page intentionally left blank Summary Summary Background This Environmental Impact Statement (EIS) addresses the potential environmental effects associated with the closure of surface impoundments containing Coal Combustion Residuals (CCR) at the Allen Fossil Plant (ALF). ALF is located in Shelby County, Tennessee, southwest of Memphis, on the south bank of McKellar Lake and east of the Mississippi River. The Tennessee Valley Authority (TVA) purchased the plant in 1984. ALF’s three coal-fired units were retired on March 31, 2018. Two project areas for ash impoundment closures have been identified at ALF including the East Ash Pond Complex project area and the West Ash Pond project area. The East Ash Pond Complex project area includes dredge cells on the western end, the east ash pond in the central part, a stilling pond and the Coal Yard Runoff Pond. The West Ash Pond project area includes the West Ash Pond and the Metal Cleaning Pond. Collectively, there are approximately 3.5 million cubic yards (yd3) of CCR remaining in the surface impoundments and below the Coal Yard Runoff Pond and Metal Cleaning Pond at ALF. With a long-standing commitment to safe and reliable operations and to environmental stewardship, TVA began in 2009 its plan to convert from wet to dry management of CCR. On April 17, 2015, the U.S. Environmental Protection Agency (EPA) published the final Disposal of Coal Combustion Residuals from Electric Utilities Rule (CCR Rule) in the Federal Register (80 Federal Register 21302). The CCR Rule establishes national criteria and schedules for the management and closure of CCR facilities. In June 2016, TVA issued a Final Programmatic Environmental Impact Statement (PEIS) that analyzed methods for closing impoundments that hold CCR materials at all TVA fossil plants and identified specific screening and evaluation factors to help frame the evaluation of closures at these facilities. Subsequent environmental reviews of CCR impoundment closures tier from the PEIS (TVA 2016b). TVA evaluated the characteristics of the impoundments being considered for closure in this EIS and determined that the nature of activities identified under the proposed closure actions are consistent with the conditions and environmental effects described in the PEIS; accordingly, closure of impoundments at ALF can draw from the analysis results in the PEIS. The primary action that TVA is considering is the closure of the surface impoundments at ALF, including the East Ash Pond Complex, the Coal Yard Runoff Pond, the West Ash Pond and the Metal Cleaning Pond. TVA is also evaluating the impact of associated component actions that may be undertaken in support of the primary action, including those related to transport of borrow material, the mode of transport of CCR to potential receiving landfills, and the construction and operation of a potential beneficial re-use processing facility that would process CCR from ALF. Purpose and Need for Action The purpose of the proposed action is to support the implementation of TVA’s goal to eliminate all wet CCR storage at its coal plants by closing CCR surface impoundments across the TVA system, and to assist TVA in complying with the EPA’s CCR Rule and other applicable federal and state statutes and regulations. In addition, the proposed actions will make the ALF closure area land available for future economic development projects in the Final Environmental Impact Statement Summary-1 Allen Fossil Plant Ash Impoundment Closure EIS greater Memphis area. Unlike other TVA power plants, much of the land within the project area is not owned by TVA, but by third parties including the City of Memphis, Shelby County, and MLGW. ALF is also located in a heavily industrialized area, which means that redevelopment is of particular interest as the land holds significant economic potential for the non-TVA owners due to its location within the Frank C. Pidgeon Industrial Park as well as its access to the Port of Memphis via McKellar Lake. Alternatives Evaluated in the EIS The following alternatives are considered in detail in this EIS: • Alternative A – No Action Alternative • Alternative B – Closure of the Metal Cleaning Pond, Closure-by-Removal of the East Ash Pond Complex and the West Ash Pond; Disposal of CCR in an Offsite Landfill Location • Alternative C – Closure of the Metal Cleaning Pond, Closure-by-Removal of the East Ash Pond Complex and West Ash Pond; Disposal of CCR in a Beneficial Re- Use Process & Offsite Landfill Location Under the No Action Alternative, TVA would not close the East Ash Pond Complex (which includes the Coal Yard Runoff Pond) or the Metal Cleaning Pond, and the West Ash Pond would remain in its current closed state. No closure activities (i.e., no excavation or transport activities) would occur. However, the No Action Alternative is inconsistent with TVA’s plans to convert all of its wet CCR systems to dry systems and is inconsistent with the general intent of EPA’s CCR Rule. In addition, under the No Action Alternative, the ALF closure area land would not be made available to its owners for future economic development projects in the greater Memphis area. Consequently, this alternative would not satisfy the project Purpose and Need and, therefore, is not considered viable or reasonable. It does, however, provide a benchmark for comparing the environmental impacts associated with implementation of Alternatives B and C. Under Alternative B, the primary actions include the closure of the East Ash Pond Complex (along with the Coal Yard Runoff Pond), the West Ash Pond and the Metal Cleaning Pond via Closure-by-Removal. Closure-by-Removal involves excavation and relocation of the CCR from the ash impoundments in accordance with federal and state requirements. TVA would stabilize residual ponded areas and then remove CCR material, underlying impacted soil, and support structures within the impoundment footprint. Closure activities would include: • Excavation of ash using a tracked excavator • Mechanical moisture conditioning the excavated ash by dumping, scooping, and windrowing the ash within the existing footprint of the impoundment or pond until it is sufficiently dried for hauling • After drying, ash would be hauled to an existing, offsite permitted landfill • Over-excavation of soil within the CCR unit footprint • Upon completion of closure activities, impoundments would be restored to a natural soil and vegetated state Summary-2 Final Environmental Impact Statement Summary In addition, component actions under Alternative
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