To:
Hupp, M illan[h up p.m illan@ epa.gov]; Bennett, T a te [B e nnett.T ate@ epa.gov]; G raham ,
A m y[g ra ha m .a m y@ ep a.go v]; Konkus, Jo h n [konkus.john@ epa.gov]
Cc:
'Beil, Stephen A .'[S tephen.B ell@ nreca.coop]; Barry H art[b hart@ am ec.org]; Viguet,
M ark[m viguet@ aeci.org]
From: W ilkinson, Joe
Sent:
W ed 4/12/2017 1:08:19 PM
Subject: Associated E lectric C ooperative O verview
Invitation THEC tour with EPA.PDF
Fact sheets for tour at THEC.pdf
We're honored to host the EPA April 20 at Thomas Hill Energy Center. You'll find Associated Electric Cooperative and its member systems are proud of their environmental stewardship, which is balanced with our mission of providing an affordable, reliable power supply to rural electric cooperatives.
Invitation
Attached you'll find the invitation we've developed to use after you have made an announcement of the upcoming visit. The second page contains a map to the plant and information regarding the tour.
Information about Associated
Attached fact sheets provide information on what we do, why and how, and features our proactive and innovative record of environmental compliance.
Why our mission is to keep electricity affordable and reliable:
2
2 What we do
2
2 A recent survey shows that 41% of the members we serve make less than $40,000 a
year, and 16% of those make less than $25,000 a year. You'll find these demographics in the fact
sheet "Members score co-op system among best utilities."
2
2 Also included is a service map of the cooperatives and region we serve
How we produce that electricity:
2
2 Associated uses a mix of resources to keep electricity clean, affordable and reliable
A number o ffact sheets show how we balance mission with environmental stewardship:
17cv01906 Sierra Club v. EPA
ED 001523B 00002877-00001
Environmental commitment
2 AECI reduces emissions and meets energy needs
Carbon costs
AECI moves head on CCR rule for coal ash
Putting ash to good use
AECI reduces mercury emissions years ahead of time
J Another piece of the past erased and replaced (tells of our award-winning mining
land reclamation)
Co-ops protect members and mammals (partnership helps ensure transmission reliability while meeting regulations)
You can find more about Associated on our website, www.aeei.org. which also includes a "Clean" section about our stewardship and our 2016 annual report.
Finally, we're preparing information specific to Thomas Hill Energy Center that we will send later today.
Security Requirements
I would like to know if the EPA has a protocol for security that you'd like us to follow. Our plans are to use our internal security staff in addition to a contracted firm that provides security at the plant. We are also in contact with Missouri Highway Patrol and the Randolph County Sheriff. But we want to make sure that we follow any protocol you have.
Advance Meeting
I also want to confirm an advance meeting at Thomas Hill Energy Center at 3:00 pm on April 19. We are assuming that this is 3:00 central, please let me know if that's not the case. I'd also like to know who will be attending the walkthrough and if there are particular things you'd like
17cv01906 Sierra Club v. EPA
ED 001523B 00002877-00002
to discuss or see during the walkthrough. From Associated, I will be in attendance in addition to my Communications Manager, the plant manager at Thomas Hill and our head of security. Thank you for the opportunity to work with you. Please let me know what I can do to make this event a success. Joe
www.aeci.org jwilkinsoTi@aeci.org
17cv01906 Sierra Club v. EPA
ED 001523B 00002877-00003
,\ K'.k h-i' I I'iii-r.-v l 'i'i'ivr.iiivi
AECI's mission;
Associated's mission is to provide an eronomical and
AECI's vision;
... "! ' ic Cooperative w ill i '
i
tance excelk =.
>recognize and regard high
perfotroanoa Through innovation,
/ork and continuous improve.
merit we achieve effi derides and meet our members' expectations
Cor,.. I . ir ,, "i cife .....
I w ifi our local communities
I
ity o f life. This begins with pno\ " i o
and reliable power and continues as w e represent Ass
community.
Business strategy
Focus on core business
Commitment to fi nancial strength and fl e x ib ity , | 1 | ; ,, ................ | I
I ir " ------ ------a............. gic alliances
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00001
A Touchstone Energy" (Cooperative
Power supply facts
I
AECI
All co-ops average
Source: ACSI, June 2016
IOU
Municipal
average
68
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00002
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00003
Nodaway
Power Plant
_____ \
Cow Branch
Wind Farm ^
Conception Wind Farm
Biuegrass Ridge Wind Farm
Lost Creek Wind Farm
Thomas Hill Energy Center
Flat Ridge 2 Wind Farm Barber Co., Kan.
Chouteau Power Plant
KAMO Power /
t
Osage
Wind Farm
Essex Power Plant
1 Coal plants A Gas plants Q Gas/oi! plants
Dell Power Plant Dell, Ark.
\
w Madrid Power Plant
Cooperatives served by KAMO Power and Sho-Me PowerElectric Cooperative
2018 Associated Electric Cooperative Inc. All rights reserved.
17cv01906 Sierra Club v. EPA
-27-2016
ED 001523B 00002878-00004
Associated E ectric Cooperative is part o f a three-tiered system united by the common purpose o f serving electric cooperative members w ith affordable and reliable electricity. Associated is owned by six generation and transmission cooperatives (G&Ts) that formed it in 1961 to provide them a wholesale power supply. These six G&Ts are owned by 51 distribution cooperatives in Missouri, southeast Iowa and northeast Oklahoma. These local electric cooperatives are owned by more than 875,000 member-consumers.
2,353CIoWal
Natural gas 2,753 MW
2016
2017 Associated Electric Cooperative Inc. All rights reserved.
17cv01906 Sierra Club v. EPA
Take Control $ Save A Cooperative Effort for Energy Efficiency
Visit www.aeci.ora
1-102017
ED 001523B 00002878-00005
Sulfur d io x id e Nitrogen oxides
- ' 4
2016
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00006
A K mi h -i i uh h k iv ;\ t 'i 'iip i r.u
140 12 100
80
60
40 index 2000=100
20
S2emissions v
\ MO, emissions
\V-
-
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
17cv01906 Sierra Club v. EPA
COZ Emissions, Million Tons
A E C IC 2 emissions tonnage & intensity decrease
1.2
1.1
S 1.0 ,2 v\
I 0.9
o
U
0.8
\
/X
.. .....
C 0 2ta"is >
n
y Ss
20
It
18
17
16
15
14
13
0.7
12
7000 2001 ?002 2003 2004 2005 2006 2007 200R 2009 2010 2.011 2012 2013 2014 2015
I
ED 001523B 00002878-00007
t
K> %AJ jJtif I d It,,
VSfa w ere w as one ol coal units to reduce ir
ill equipm ent on large s io n s .
Associated w as nationally recognized b\ rrterior fo r innovative a r t successful m ine nedama-
17cv01906 Sierra Club v. EPA
Land & N atural R esources
Transmission Siting and Perm itting
A v ia n Protection
Endangered S p e c ie s
Vegetation Management
W aste & Chem ical M anagem ent
Coal Ash
PCBs in E le c tric a l Equipm ent
HazMat Transport
ED 001523B 00002878-00008
Controlling carbon will increase your cost c
Associated Electric Cooperate
holesale power supplier, has ir. , " i
ir : i 1 "
. i reductia......... : i " -
..... dioxic
vironmental control 1> ............... ty caste Associated Electric abou
Those costs will increase as your wholesale po/ver generator works to meet additional environmental regulations on air emim sions, water quality and coal ash handling and storage - as well as new rules to reduce carbon emissions.
The Environmental Protection Agency issued its fi nal carbon tier Plan, Aug. 3,2015, calling for a 32 per.
rent reduction in cartoon emissions nationwide by 2030.
States that rely on real for affordable, reliable electricity were hit especially hard. Missouri mast meet a 37 percent reduction target; l ra , 42 percent reduction; and Oklahoma, 31 percent below 2012 levels.
Ultimately, the rule will reduce use o f coal - which generated 63 percent o f members' energy in 2016, and shift generation to natural gas plants and new renewable energy projects.
As expected, the Clean Rower Plant plan was challenged.
More than 20 states - including Missouri, Iowa, Oklahoma and A rka n sa s-fi led suit against the plan. The National Rural Electric Cooperative Association also fi led suit.
M issouri Departm ent o f N atural Resources geologist John Pate examines cuttings near Thomas H ill Energy C enter to determ ine w hat bedrock the d rillin g has reached. F hrt o f the carbon storage research project, supported b y ARE! and other u ltiiitie s, was conducted a t Thomas H ill Energy C enter in north-central M issouri.
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00009
\ )
rovai ;new
Arkansas is another major renewable gaierating resource. V \liile
hydropcwer is one of our bwestoDst resources, it is a limited com modity dependent on rainfall and the capacity of lakes and clams to
store the v
Carbon capture and storage research
Associated has participated in research to ft nd ways of
the amount of carton dioxide re
e.
Associated partnered with other Missouri utilities and the U.S. - , I 1 1 I rgy in a t, eject to determine tie feasibility of s i ........ . ............ .. - /," , a A , ' ............ llio ria s Hill Energy Center shwved it v\as a viable site for storage. More testing and finding are needed to ooriti
2017 Associateci Electric Cooperative Inc. All rights reserved
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00010
CI moS ahd onOCR rule for
WillefurtherimptCMngairqualityin 2016, AssociatedElectricQooperatitalsoaooomplishedanumbercf
prqects lelated toERA'sQcalOonhjsticnFsiduals rule ihatgjlathandiingcfflyashandtottomash. EFA's
finalCCRrulewaseffectryeOct. 19,2015, andemail ismuchstricterthanthe2010draft.
cbing thswork n-hou
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00011
Putting ash to good use & safe disposal
A ssociated E lectric C o o p e ra tiv e Inc.
Associated works to m eet n a if ash regulations, reduce costs
The Environmental Protection /Agency finalized its coal combustion residual rule Dec. 19,2014, governing coal ash handling and disposal at coal plants.
There was good news in the new rule: Coal ash remained categorized as a nonhazardous waste, enabling Associated Electric to continue to recycle both fly ash and bottom ash, which it's done for 20 years. Recycling ash reduces landfill use benefiting the environment - and brings in revenue to help keep members costs affordable.
This was a big win for cooperatives, which had advocated for keeping coal designated as nonhazardous. Cooperatives continue to work with legislators to make this designation a certainty, which the law did not provide.
However, the final rule also includes stricter seism ic zone requirements that were not present in the 2010 proposed rule, and those requirements could cost millions o f dollars d ie to retrofits or closure o f ash retention ponds at New Madrid Power Plant, as well as result in significant cost increases for transporting the ash for disposal.
The New Madrid Power Plant is about the only plant in the country affected by the new seismic requirements, which increased requirements from a 500-year earthquake event to the much stricter 2,500-year earthquake event. Associated is working
and legislators to address The seismic requirements also may affect Associated's ability to use its fairly new utility landfill at New Madrid, which was built in 2008 and permitted for 10 cells. One cell is being used. Opening a seoond cell designed to meet the new criteria will oost about $TGQridlliiafna0l{bediif@dacD^$&3nttilieKufHi1p1aa^iUxstikJ>d3BsU^Btut o ffs ite . Seismic zone requirements are part o f several new criteria in the rule that w ill increase ash-handling costs, as wall as the oost
more information on back
EPA inspected Associated's facilities in 2010. and Thomas Hill Energy Center earned EPA's highest safety rating. New Madrid Pcwer Plant received EPA's second highest rating and is implementing recommendations for improving ero sion control and vegetation management.
Associated uses coal ash to rm ine redam atbn and sells it fo r other uses, including cement substitute, reducing foe amount disposed.
17cv01906 Sierra Club v. EPA
I
ED 001523B 00002878-00012
o f constructing new ash facilities. The rule affects all ash pends, used mostly for processing the coarser bottom ash from the coal units at Associated.
Associated staff continues to develop its compliance plan. At New Madrid Fewer Plant, options include retrofitting two imlined ash ponds; closure o f those ash ponds; or converting to a dry system for bottom ash.
Working ahead to ensure compliance A t New Madrid, Associated proactively converted to a
dry system for handling fly ash and increased groundwater monitoring. Additional groundwater monitoring wells w ill be needed at both plants.
Converting to a d ry system for handling bottom ash at New Madrid Fewer Plant w ill cost about $30 million. The rule has less impact at Thomas Hill Energy Center, which also proactively converted to a dry fly ash-handling system and is closing its ash retention pend. Associated also built a pad for bottom-ash handling to comply with the new rules.
The rule allows for continued beneficial use o f ash for mine reclamation, which is done at Thomas Hill.
Groundwater monitoring was expected and is required for all ash ponds and landfills under the new rule. Associated w ill install additional groundwater monitoring walls at both plants, analyze the data and report findings regularly.
The OCR rule is tied to Clean V\fater Act Effluent Limitation Guidelines, finalized in September 2015, that will affect water discharged from power plants. A 2013 draft added pollutants that may require more water treatment or modifications to ash handling.
Staff continues to review the 745-page CCR rule, as well as the new effluent guidelines, oonduct more detailed seismic analysis at New Madrid and research lowest-cost options for compliance.
The final rule was published April 17,2015, in the Federal Register. Compliance starts six months to 48 months from April 17, depending on the criteria. Legal and legislative action also is expected, so some uncertainty w ill continue as it has since 2008, when the large coal ash spill at TVA's Kingston facility prompted EPA to develop the rule.
Closed trucks take dry fly ash from the plant.
Associated manages coal ash byproducts at its plants by using a combination o f "beneficial use" mine reclamation, recycling and reselling, and long-term storage using permitted lined ash ponds and utility waste landfills.
Associated has sold bottom ash, a heavier material from the bottom o f the cyclones, from both T horns Hill and New Madrid plants since 1994 for use as an aggregate in roof shingles. From 2002 through 2014, it recycled about 983,000 tens o f bottom ash to bring in $1.25 million in revenue.
Since 1998, it has sold fly ash from Thomas Hill Umt3 a pulverized unit that produces ash lower in carbon, for use in making ooncrete. It's also partnered with a University o f Missouri scientist to create a super-strong "green" brick now licensed for manufacturing
From 1998 through 2014, Associated sold about 825,000 tons o f fly ash, bringing in about S6 million in revenue. Recycling the ash reduoes landfill disposal also
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00013
time s * m
pornSofdfoourmctihnrdegsiarhlfifvioperdhlihaaobsolaedl,wsraaeylniasdbbqleeueeanlleiptycaotrrtifcoliiftefyt*bealacunlctuerdewaitthAspsrootceiactteindgEthleecntraictuCroaolpreesraotuivrece, swthhiachtopurircmksemitsbeelrfsodnepend
O ften, Associc
ctric has taken th e lead w ith
innovative, cost.e ffe ctive and proactive solu tio n s. It did
ne or tne ti
th e same th in g w hen it cam e to m eeting the M ercury
A ir Toxics Standards, effective in A p ril 2 01 6 for the
IIU f l)
n cm
c o o p e ra tiv e .
ne raune on fo
ciate
Staff sta rte d e arly to craft its com pliance plan, and
the parts worked together to put A ssociated's emis.
sions of m ercury, p a rticu la te and hydrogen chloride well
nt rr
i it? urinb wslen e
below th e new requirements set by the E nvironm ental
ion '
entation of refin*
Protection Agency. In 2 0 1 6 A ssociated fin
ished $ 35 m illion in p ro j ects and met two important
AECI reduces mercury 85 percent
pxreteofrrercury 1000
ogy. 1 his was ac
in Thomas Hill l fizecl unit, also c rig nercurv emissioi
i\
ines. F irst, it
AECI's emissions
was compliant when the
800
rule took effect. It then met
we
the 1 8 0 .day deadline in Oc
O, IlliO l
tober 2016 to demonstrate that com pliance, which
600 -
of refine
idem Kst
rdlisn.
required subm itting scores
till je na
of te stin g data and c e rtific a . 400
tions.
M eeting IV
quire.
ments took a concentrated
200 -
e ffo rt from s ta ff throughout
n an ri
th e cooperative, particu.
aintei tance
larly by th e e nvironm en tal,
health and safety depart.
...
, '
,. ,
ment, laboratoryJ and instru.
2008 2010 2012
Oeralt/tesociated has reduced its metcu
prared,to. base!ireanssms inA)10, b,eo,
ment controls teams at each injffifmmsionantPds, endistetwii
2014
2016
unr
)\ pan ng the
ne.halt
of the coal plants.
)f the
' ' ;| s t
[ i rig i / 1 / ' 1 * / i n
-
Associated began reducing mercury emissions long
before th e E nvironm ental P rotection Agency proposed
its first mere > " 5in 2005.
HPe errv ing uni no, hich re
nstanc
d\\l
uni'
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00014
Al
Better than before
J
w ere graded to approximate original contours, topsoil replaced and v
For acreage to be released, Associated m ust oomplete three
Phase I: Backfilling and rough grading, replacement o f topsoil and initiai seeding.
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00015
Working together, AssociatedElectric Cooperative and the Association o fMissouriElectric
\
... .
nth ...
c ilfe ; " .... - 1 tat
for endangered species, like the Indiana bat, and ensures reliable transmission formembers.
.The innovative agreem ent w as mated by the C onservation Federation o f M issouri, w hich presented the association w ith its esteem ed O n s e t'. vation O rganization o f the Y ear award.
M em ber cooperatives also received
ste w a rd sh ip . .The integrated high.voltage trans
m ission system owned by Associated
. j ......... t live and its six ow ner generation and transm ission coopera tives is vital to providing reliable pow er
While much c f th e n also face enviionme
sratives. But, like m any other aspects o f the u tility industry, the planning, construction and m aintenance o f that transm is
sion system feces ire
ie n g e s .
: I
i! i transm ission lir > i
ti : " i - ,, '> ( Indiana bat, cooperatives i 1 -
fo r m em bers and the mammal.
Co-ops go to bat for members and mammals
live phase in the m igrating Indiana
bat's life cycle. In the past the
i i i/Vilc i
vice prohibited any brush o r tree clearing 'firm A pril 1 to w hen hate m i ilrl hp nnpopnt
Associated s but when one i
The member-owned integrated high-voltage transm ission system is vital to providing reliable pow er to mem bercoop eratives. Like m any otheraspects o f the u tility industry, the planning, construction a nd m aintenance o f that tra n sm is sio n system faces increasing challenges.
transm ission
ro t t
11
payn- i
i
i
lie ra no bats had been
| ,! , ,
vOUld
litigation, in the ft i >
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00016
i feiiiai
17cv01906 Sierra Club v. EPA
ED 001523B 00002878-00017
e Energy* C o o p erativ e -. ..-
Welcome
Scott Pruitt, administrator U.S. Environmental Protection Agency
to the Thomas Hill Energy C en ter
5 6 9 3 Highway F, So.fwp* H 1 t/lwooj' i
April 2 0 , 2017
1 0 a,m ,
Invitation required for admittance
RSVP
17cv01906 Sierra Club v. EPA
ED 001523B 00002879-00001
.r .!! I ergy Center is an industrial en
" t! . `otect
1 ... =nt to er - i
es
n i t v r cial precautions ... jye - ^ ! isitors.
A t the conclusion of th e event (tim e p e rm ittin g ], to u rs may be offered.
17cv01906 Sierra Club v. EPA
ED 001523B 00002879-00002