Additional Information Regarding American Electric Power's Philip Sporn Power Plant in New Haven, West Virginia

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EPA has posted additional information on American Electric Power's (AEP) Philip Sporn Power Plant in New Haven, West Virginia beyond the usual assessment documents (draft report, comments, final report, cover letter, and action plan). EPA worked with state officials and AEP to address issues raised in the draft report to provide the basis for further action.

As of December 2010, the EPA believes that AEP has successfully completed the recommendations from the Final Assessment Report on the Fly Ash and Bottom Ash Impoundments at the Philip Sporn Power Plant (dated December 9, 2009). The studies related to these recommendations and descriptions of the actions EPA and AEP took regarding the impoundments at this facility are described in more detail below.

Draft EPA Site Assessment Report (PDF) (2 pp, 20MB)
On October 9, 2009, EPA's engineering contractor, Dewberry and Davis, notified EPA that a condition rating of “poor” might be warranted for the two coal ash impoundments at this facility. Dewberry concluded that there was no threat of imminent failure at either of these units, but recommended that AEP conduct liquefaction, slope stability and vibration studies. On October 16, 2009, Dewberry transmitted to EPA the draft assessment report that gave these units a preliminary condition rating of “poor,” primarily due to the lack of adequate studies to insure long term safe operation.
AEP’s Reports/Studies in Response to EPA’s Draft Site Assessment Report (PDF) (10 pp, 760K)
EPA provided AEP and officials from the State of West Virginia Dewberry’s draft report and has been in contact with AEP and West Virginia dam safety officials to exchange additional information and discuss further actions. On November 2 and 9, AEP provided EPA with the following reports:

AEP’s Initial Response to the primary recommendations contained in EPA’s Draft Assessment Report;
AEP’s Liquefaction Studies;
AEP’s proposed action plan in response to downstream sloughing, erosion, and surface irregularities;
AEP’s Slope Stability Analysis in support of proposed slope improvement work;
AEP’s White Paper on factors at AEP’s Sporn Ash Disposal Facilities as compared to those at TVA’s Kingston facility.

AEP indicated that they are willing to conduct the slope stability and vibration studies, but believed that additional liquefaction tests would not be necessary based on the fact that AEP had already conducted “generic” liquefaction studies that showed that the impoundments at Philip Sporn would be structurally sound over the long term.

Dewberry and Davis’ Analysis of AEP’s Report/Studies (PDF) (6 pp, 75K)
EPA directed Dewberry and Davis to review the AEP materials noted above and submit a memorandum discussing whether the requested studies noted in the draft report were still needed. Dewberry concluded that the impoundments did not pose an imminent threat, but continued to believe that a liquefaction study should be conducted for the two impoundments.
Information Request Letter (PDF) (10 pp, 456K)
EPA posted a formal information request letter which EPA sent to AEP on November 13, 2009 requesting it to conduct liquefaction, stability and vibration studies. This request, issued under the authority of the Clean Water Act, sets specific requirements for these studies and establishes due dates. The subsequent modification (PDF) (1 pg, 39K) to this information request letter is also being made available.
Peer Review Evaluation (PDF) (3 pp, 548K)
EPA directed another of its engineering contractors to conduct a peer review of the Dewberry draft report on the Philip Sporn facility, as well as a review of the conclusions reached in Dewberry’s November 10, 2009 memorandum. This peer review, conducted by CHA, concluded that appropriate engineering judgment was exercised by Dewberry.
Final EPA Site Assessment Report (PDF) (97 pp, 7MB)
On January 28, 2010 EPA posted the final report on AEP’s Philip Sporn. Both the fly ash and bottom ash impoundments were given condition ratings of “fair” by Dewberry based on the additional studies AEP provided.
Stability Analysis (PDF) (586 pp, 36MB)
EPA reviewed the stability analysis (dated 1/18/2010, certified 2/11/2010) submitted by American Electric Power (AEP) that was conducted on the Eastern Dike of the Philip Sporn Fly Ash Pond. This was the first of three components of EPA’s information request order to AEP that EPA believed were needed to confirm the safety and stability of the Fly Ash Pond located at their Philip Sporn power plant.

The stability analysis conducted on the Philip Sporn fly ash pond shows that the seismic slope stability safety factors are in excess of 1.2 for the conservatively modeled conditions applied to critical sections of the dike. Based on current engineering standards of practice and West Virginia Dam Safety Regulations, the minimum recommended factor of safety for seismic slope stability of an embankment is 1.2. The design of this impoundment meets and exceeds the minimum required factor of safety. Higher factors of safety mean the dike is designed to handle higher loads than would be anticipated. The analysis looks at different cross-sections of the impoundment to obtain a representative picture. For each section, there was a different factor of safety — each of which exceeds the 1.2 minimum. Factors of safety varied from 1.33 to 2.51, depending on the impoundment section analyzed.

The two other components of EPA’s information request include: 1) vibration study on embankments at both the Fly Ash Pond and Bottom Ash Pond due June 30, 2010; and 2) liquefaction study for the Eastern Dike of the Fly Ash Pond due September 30, 2010. EPA will make these reports available to the public after receipt and review. EPA recognizes AEP’s continued cooperation to demonstrate the safety and integrity of its coal combustion residual impoundments at the Philip Sporn power plant.
Vibration Analysis (PDF) (681 pp, 39MB)
EPA reviewed the vibration analysis (dated May 27, 2010) submitted by American Electric Power (AEP) that was conducted on the Fly Ash Disposal Facility and Bottom Ash Disposal Facility of the Philip Sporn power plant. This was the second of three components of EPA’s information request order to AEP that EPA believed was needed to confirm the safety and stability of the impoundments located at their Philip Sporn power plant.

The vibration analysis makes the following conclusions that provide support for the structural integrity and safe operation of the impoundments:
1. No vibrations due to railway traffic were detected at test locations on the Eastern Dike of the Fly Ash Disposal Facility.
2. Liquefaction of fly ash material under the Eastern Dike of the Fly Ash Disposal Facility due to railway induced vibration is improbable.
3. Proposed repairs will significantly reduce the potential for shallow sloughing along the Fly Ash Disposal Facility’s Western Dike.
4. Railway vibrations will not have a significant/consequential impact on the slope stability of the dikes for the Bottom Ash and Fly Ash Disposal Facilities.
The final component of EPA’s information request includes a liquefaction study for the Eastern Dike of the Fly Ash Pond due September 30, 2010. EPA will make this report available to the public after receipt and review. EPA recognizes AEP’s continued cooperation to demonstrate the safety and integrity of its coal combustion residual impoundments at the Philip Sporn power plant.
Liquefaction Study (PDF) (758 pp, 63.3MB)
EPA reviewed the liquefaction study (dated September 16, 2010) submitted by American Electric Power (AEP) that was conducted on the Eastern Dike of the Fly Ash Disposal facility at the Philip Sporn power plant. This is the final component of EPA’s information request order to AEP that EPA believed was needed to confirm the safety and stability of the impoundments located at their Philip Sporn power plant.

The liquefaction study makes the following conclusions that provide support for the structural integrity and safe operation of the impoundments:
1. Based on site specific subsurface exploration, laboratory sampling, and engineering analysis, liquefaction of the fly ash foundation materials beneath the Fly Ash Disposal Facility — Eastern Dike is not predicted during the design earthquake event. Slope stability analysis using site specific material parameters and stress conditions developed for the design earthquake reveal stability factors in excess of 1.5.
2. No liquefaction zones are predicted for the Fly Ash Disposal Facility — Eastern Dike. Liquefaction of the fly ash foundation material below the upper section of the Eastern Dike is unlikely.
3. No remedial actions related to liquefaction potential are currently recommended.
This study is the final component of EPA’s information request to AEP. EPA recognizes AEP’s cooperation throughout this process of demonstrating the safety and integrity of its coal combustion residual impoundments at the Philip Sporn power plant.

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Additional Information Regarding American Electric Power's Philip Sporn Power Plant in New Haven, West Virginia

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