Protecting our community’s drinking water
Under our existing regulatory framework, we have monitored groundwater at some of our power plants since the 1980s to ensure drinking water resources for our community meet safe drinking water standards.
- The data which is reported to the Kentucky Department for Environmental Protection demonstrates water quality surrounding our power plants has remained, and continues to remain, safe for recreational use and does not indicate any threat to drinking water supplies.
- Water quality is also monitored, tested and affirmed by each respective local water utility that provides service to the nearby areas.
Complying with the EPA’s more stringent regulations
We continue to take aggressive measures to assure our communities’ land and water resources are protected, and we continually invest in our facilities to comply with ever-changing local, state and federal environmental regulations. This includes regular and recurring monitoring, measuring and reporting our facilities’ performance to the appropriate regulatory agencies.
In 2017, we installed additional groundwater monitoring wells along the immediate perimeter of our impoundments, and we recently installed new additional groundwater monitoring wells where necessary at our facilities to further evaluate conditions. These installations are in compliance with the EPA’s CCR Rule.
While there are indications that levels of certain constituents at some locations do not currently meet the tightened groundwater protection standards under the CCR Rule, this is, in part, why we launched plans to move toward dry management over a decade ago, as well as close our existing CCR impoundments as provided in filings with the Kentucky Public Service Commission in January 2016. We are confident that our planned measures will ensure compliance with applicable requirements.
As a result of the more stringent CCR Rule standards, we, along with other utilities across the country, launched aggressive projects to systematically close out all of their remaining wet management facilities – also referred to as ash ponds and surface impoundments. To date, one-half of our facilities have been closed, with the other half either under contract for closure or in the initial commercial phase of closure.
We are operating our power plants’ new CCR treatment and dry management facilities at all four of our coal-fired stations. We also are in the final stages of construction and commissioning new state-of-the-art process water treatment facilities at Ghent, Mill Creek and Trimble County.
What are groundwater monitoring reports
Utilities that operate ash ponds and surface impoundments, under the CCR Rule, publish annual documents called groundwater monitoring and corrective action reports. These annual reports contain information and data obtained during the previous calendar year and are published online by the utility.
In compliance with the CCR Rule, utilities have been gathering groundwater quality data around CCR impoundments and their facilities to establish background concentration levels of certain constituents that are naturally occurring in local groundwater.
It’s important to keep in mind the raw data in the reports cannot be relied on to determine whether a CCR impoundment is impacting groundwater. That determination is made through a regimented monitoring phase established by the CCR Rule and following a statistical evaluation of the data and confirmation that certain levels of constituents are higher than what’s naturally occurring for that area. There’s also additional monitoring and testing done to make sure the increased results were not caused by laboratory error or by a source other than the CCR impoundment.
- If the data indicates certain constituent levels near a CCR impoundment are higher than the naturally-occurring levels, the next stage in the process is to initiate “assessment monitoring” to determine whether there is an impact on groundwater quality. The substances evaluated in assessment monitoring are those considered to be constituents of concern.
- During assessment monitoring, additional samples are taken to determine whether the CCR impoundment may be exceeding groundwater protection standards, which are established to protect human health and the environment.
- These samples will then be analyzed using statistical methods to determine whether any constituents of concern are detected at a statistically significant level (SSL) over the established groundwater protection standards.
The data in these groundwater monitoring reports are only from the initial stages of groundwater monitoring under the CCR Rule. Due to the close proximity of the groundwater monitoring wells to the CCR impoundments, the monitoring results should not be interpreted to mean the groundwater poses a health risk. That determination is made following a regimented, statistical evaluation of a wider scope of groundwater data to determine whether any risk exists. If utilities determine constituent levels exceed the tightened standards under the CCR Rule, any groundwater impacts will be addressed.