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A recent letter from Region 4 of the U.S. Environmental Protection Agency has weighed in on several aspects of a proposed landfill project at LG&E’s Trimble County Generating Plant, located at Wise’s Landing on the Ohio River.
The letter, dated May 22 and directed to the Louisville District of the U.S. Army Corps of Engineers, outlines the utility company’s permit application for the project. Permits for projects that have potential to impact any national waterways must be approved by the Corps, according to spokeswoman Carol Labashosky. The EPA and the Corps have a Memorandum of Agreement that provides the federal agency to review permit applications submitted to the Corps.
“It’s really nothing new when the EPA gets involved,” Labashosky said. “The agency gets an extra look [at permits during the application process] to make sure [applicants] are complying with the Clean Water Act.”
Labashosky said the project is still in the early phases of the application process. At this point, the Corps is preparing to review public comments on the project, which were accepted by the Corps through May 25.
“That could take at least several months,” she said. “There is a lot of public interest in this project.”
The May 22 letter, signed by Gwendolyn Keyes Fleming, administrator for EPA Region 4, which includes Kentucky, provides an overview of the project, which Fleming states “would have direct impacts ... on a watershed drained by an unnamed tributary to Corn Creek that has been documented as having excellent water quality and a diverse biological community.”
The main concern, basically, is that the size of the proposed landfill is larger than required for the amount of waste LG&E anticipates to be dumped there. The permit application indicates the company expects to dispose of 910,000 cubic yards of ash waste from the generating plant in the landfill.
However, the company also estimates that much of the waste – which is 53 percent gypsum, 38 percent fly ash and 7 percent bottom ash – could be reused, therefore reducing the actual amount of waste to be disposed of in the landfill.
According to a table provided by LG&E officials in the permit application, the company shows two scenarios in which at least 93 percent of the gypsum waste could be reused and, therefore, diverted from the landfill. The company also estimates that anywhere from 11 percent to 75 percent of the fly ash and bottom ash could be reused and diverted.
The reuse diversion from the landfill would reduce the amount of anticipated waste by nearly half in the first scenario and as much as 83 percent in the second, according to the EPA.
In March, LG&E did submit a revision to its permit application, reducing the size of the proposed landfill from 265 acres to 218 acres. In the revision, the company also reduced the amount of surrounding land it expects will be impacted by the facility from 585 acres to 329 acres and reduced impact to wetlands from 2 acres to 1.14 acres. These reductions, the EPA points out, were based on the company’s original annual estimates of 910,000 cubic yards of waste.
The EPA wants LG&E to revise its permit application again, based on the smaller waste-disposal numbers rather than the original numbers, according to Fleming’s letter.
Likely, the revision would mean reducing even further the size of the landfill and the surrounding acreage that would be affected by the project. According to the letter, the surrounding land would be excavated for fill to cover each layer of waste in the landfill according to required specifications.
It is the disturbance of the surrounding land from such excavation that is the EPA’s main concern, Fleming states,
In an April 25 letter the the Corps from James D. Giattina, director of the EPA’s Water Protection Division, the excavation – not the landfill itself – would directly cause damage to Corn Creek and several of its tributaries.
“Information available to the EPA suggests that the aquatic resources proposed to be impacted as a result of this project may be among the highest quality ... in this region of the Commonwealth,” Giattina states, adding that the EPA recommends “denial of this project as currently proposed.”
Labashosky said that, so far, LG&E has revised it’s proposal several times since it was first made public in October.
The company “has modified their proposal, reducing the proposed impacts to streams ... and also have changed their proposed project boundaries, narrowing it down to avoid as many impacts to ‘waters of the U.S.’ as possible,” she said.
“Our objective is to balance environmental requirements with the need to meet the energy demands of our customers in the most reliable and cost-effective manner, as required by state statute,” said Brian Phillips, a media spokesman for LG&E. “We’re optimistic that we can address the [EPA’s] concerns in a manner that allows the permitting process to move forward. We’re aware of the issues raised and are working through them with the appropriate agency.”
Phillips said the company still believes that the Trimble County site is “the most appropriate” for the landfill.