AEP reduces, reuses or recycles as much of its waste as possible and tries to dispose
of the remainder with the least adverse effect on the environment. For example,
the company has recycled more than 180 million pounds of metal, 5.8 million pounds
of paper, 2.6 million gallons of oil and more than 470,000 light bulbs during the
last five years. We do not track the total weight of our general refuse but we do
track special waste streams, such as hazardous wastes, polychlorinated biphenyl
(PCB) and other products that have serious environmental consequences if not properly
disposed.
We report to the U.S. EPA under the Toxic Release Inventory Program (TRI) the transfers
and releases of toxic chemicals that occur off-site. For AEP this report typically
includes metals found in ash, emissions, waste put in landfills, ammonia and acids.
One of two waste-related enforcement actions AEP received in 2007 related to construction
of a landfill at our Mountaineer Plant. After substantial rainfall, landfill run
off inadvertently carried soil and fly ash from the plant into nearby waterways
and neighboring properties. There was no fine associated with the Mountaineer enforcement
action. We also self-reported an error we found in how material from the Conesville
Plant scrubbers had been disposed of and took corrective action. We conducted a
root-cause analysis and changed some of our processes in the short-term while we
develop a long-term solution to address these issues and prevent future recurrences.
Mercury, a toxic heavy metal, is released when coal is burned. The amount of mercury
emitted from our power plants depends on the type of coal and the emission control
equipment installed. AEP's Pirkey Plant in Texas was ranked as one of the two highest
emitters of mercury in the United States last year, for the third straight year
(based on 2005 data), because the lignite it burns tends to have higher mercury
levels compared with other types of coal. Pirkey's SO2 scrubber removes significant
amounts of the mercury in the flue gas.
Concerns about the environmental and public health implications of mercury emissions
led the U.S. EPA to establish the
Clean Air Mercury Rule. AEP has been working toward meeting the requirements
of that rule, which had a compliance deadline of 2010. The necessary emission reductions
will come largely from installing SO2 scrubbers and NOx SCR systems which, in combination,
can achieve significant mercury reductions. Additional controls may be needed as
well.
The EPA's mercury rule was challenged by a number of states and environmental groups
when it was issued in 2005. In February 2008, the District of Columbia Circuit Court
of Appeals sent the rule back to the EPA for reconsideration. The ultimate impact
of this ruling is unclear.
Even with the uncertainty created by the recent legal challenge, we will still make
significant mercury emission reductions at our power plants that have been equipped
with scrubbers and SCR systems. We will move ahead with installing the mercury monitoring
equipment required by the Clean Air Mercury Rule. We expect this equipment to provide
detailed information on actual emissions – which may assist in the development
of the new regulatory requirements.
Once again, there are trade-offs. One challenge is that removing mercury from air
emissions results in higher levels of mercury elsewhere, such as in approved solid
waste landfills and in wastewater treatment ponds. AEP's power plants with scrubber
systems must manage an increased amount of mercury in waste water within the limits
of their water quality permits. In some states we expect regulators to begin including
very low effluent limitations for mercury in renewed or modified wastewater permits.
We have accelerated our evaluation of new technologies that might meet these requirements,
but they are still in very early stages.
PCBs have been used since the 1930s. However, they are a suspected human carcinogen
and are heavily regulated by federal and state agencies. AEP still has equipment
in use, such as transformers and capacitors, that contain PCBs. We are eliminating
them through planned phase-outs.
Since 2000 we have disposed of more than 12,000 PCB and PCB-contaminated transformers
and more than 4,500 PCB capacitors. We will continue to replace known PCB transformers
at our power plants during planned outages and as part of required maintenance during
the next decade. We have approximately 427 pieces of equipment to replace. We also
have approximately 700 PCB capacitors in service at 11 electrical substations. We
are developing plans to remove them.
During all property transactions involving facilities or sites where PCBs were known
or could be assumed to have been in use, we conduct a thorough site assessment to
deter mine if there is any PCB contamination. In 2007, AEP con ducted 27 site assessments
that resulted in eight PCB reme diation projects which were completed without incident.
In 2007, we had approximately 1,625 documented spills from oil-filled electrical
equipment. A small portion of these (6.2 percent) were significant enough to be
reportable to regulatory agencies and an even smaller number (2.3 percent) involved
PCBs. Most were small spills caused by downed electrical equipment from car accidents,
bad weather, van dalism or equipment failure. We clean these in a timely manner
and report them, as appropriate.
AEP burns an estimated 76 million tons of coal per year, generating significant
quantities of byproducts that need to be recycled or disposed of. As a member of
the Coal Combustion
Products Partnership, we promote the beneficial use of coal combustion products.
Some of these can, for example, be used to treat acid mine drainage and return sur
rounding land closer to pre-mined condition.
We are working with the Ohio Department
of Natural Resources to use coal combustion products (CCPs) to reclaim a
1950s surface mine that was abandoned, leaving behind acid mine drainage and a dangerous
100-foot-high wall. Acid mine drainage is a liability for AEP. While there are costs
associated with this reclamation project, it will result in significant long-term
savings compared with the cost of perpetually treating the runoff. It also will
improve the water quality of nearby Wills Creek.
In 2006, the most recent year for which data are available, AEP produced nearly
8.4 million tons of coal ash products. Use of CCPs resulted in approximately $18.6
million in avoided costs that would otherwise have been incurred to build and operate
landfills for these byproducts. More information about coal combustion byproducts
and their uses.
Although there are many beneficial uses for coal combustion products, we are reminded
by stakeholders that environmental impacts also must be considered when determining
how and where this ash will be used. We have heard these concerns and we are listening.
We will do a better job of taking these considerations into account.
Nuclear energy will likely play an increasingly important role in the nation's energy
future, especially in a carbon-constrained world. However, the storage of nuclear
waste presents a significant challenge.
For example, AEP's Cook
Nuclear Power Plant in Bridgman, Mich., generates emissions-free energy.
Cook Plant has been shipping its low-level nuclear waste to a storage facility in
Barnwell, S.C. However, this option will no longer be available after June 2008
to companies that are not part of the Atlantic Interstate Low Level Waste Compact.
Consequently, Cook Plant will need to store its low level waste on-site in High
Intensity Containers (HICs) built in the 1990s. Cook currently generates enough
low-level waste to fill seven of these HICs annually, on average, but will implement
process improvements designed to reduce the number of HICs needed to four per year,
thus reducing our storage needs.
Beginning in 2011, Cook Plant will employ on-site dry cask spent nuclear fuel storage
until a permanent facility becomes available. The Cook on-site storage facility
was originally designed to hold five years of waste; the changes made recently have
extended its life to approximately 20 years – a necessity because a permanent
storage facility for spent nuclear fuel and other high-level waste remains elusive.
We are disappointed and frustrated that the federal government has made no significant
progress in meeting its obligation to take and store high-level nuclear waste. Since
the enactment of the Nuclear Waste Policy Act of 1982, we and other nuclear generator
operators have paid into a fund administered by the U.S. Department of Energy (DOE). In exchange, DOE is responsible
for licensing, building and operating a permanent high-level nuclear waste storage
facility.
The DOE has not met its 1998 deadline to begin taking spent nuclear fuel. We and
other utilities have sued the DOE and a court ruled in our favor. The ruling requires
that we prove the amount of our damage claims against the DOE periodically. For
nuclear power to be a viable, long-term part of our energy future, the current impasse
over permanent storage of high-level nuclear waste needs to be resolved.
