American Electric Power (AEP) requested proposals from qualified bidders to conduct beneficial use (BU) of the coal combustion residuals (CCR) stored in two inactive units at the Glen Lyn Plant in Glen Lyn, Virginia. The objective of the Request for Proposals (RFP) was to gather the following information:

• Identify viable options of beneficial use of the landfilled and/or impounded CCR at the Glen Lyn Plant

• Quantify the volume of CCR that may be suitable for beneficial use

• Establish the anticipated duration of a beneficial use project

• Evaluate transportation impacts and consideration for on-site and/or off-site beneficial use options

• Define the potential market demand for beneficially used materials, and,

• Provide anticipated costs associated with on-site or off-site beneficial use of CCR

Table ES-1 on page i of the report shows the volume of CCR (cubic yards) and area (acres) of the two units considered for beneficial use at the Glen Lyn Plant.

This Initial Biennial Report describes the site investigation process conducted to gather CCR unit characterization data, the RFP solicitation process completed by AEP, and provides summaries and evaluation of proposals received from the bidders. Bids were evaluated to determine viability of the proposed beneficial use technologies and processes, establish the quantity of CCR to be beneficiated, identify potential transportation impacts, and estimate costs associated with beneficial use processing and end-product distribution. Market demand for the end-product was also evaluated and proposed beneficial use costs were compared to costs associated with construction of an onsite landfill.

Development of the RFP and this Biennial Report supports AEP’s response to the Commonwealth of Virginia House Bill No. 443 (HB 443), enacted in 2020 and codified into legislation under section § 10.1-1402.04 of the Code of Virginia requiring closure by removal of the CCR units at the Glen Lyn Plant and disposal of the CCR materials either through an encapsulated beneficial use or placement of materials in a compliant on-site or off-site landfill. Considerations for the viability of a proposed beneficial use options include regulatory compliance, time required to achieve closure, risk feasibility, stakeholder input, and evaluation of potential overall project cost savings when compared to the lowest cost alternative disposal option.

Site Investigation

Site investigations were conducted in March and June of 2022 to collect samples from the existing closed CCR units at the Glen Lyn Plant and characterize the material for potential beneficial use. A total of 21 borings were advanced and 61 samples were analyzed for conformance to ASTM C618 fly ash standards, typical cement kiln requirements, and additional chemical and physical parameters consistent with previously completed beneficial use studies. Results from the site investigations indicated that due to elevated moisture and carbon contents, and insufficient material fineness, additional processing would likely be required for beneficial use of the material.

RFP Process

AEP developed a solicitation process to obtain proposals from qualified contractors able to perform the full scope of work beneficiating the CCR material from the Glen Lyn Plant. The solicitation process included identification and outreach to regional and national beneficial use vendors, preparing a comprehensive RFP package to obtain accurate and competitive pricing, and reviewing and evaluating proposals received by bidders. The full scope of work required to complete the project included both civil/construction elements and beneficial use tasks. Bidders provided proposals and pricing for excavation of CCR materials, processing the materials in preparation for beneficial use, and design, planning, construction, and operation of on-site or off-site beneficial use systems. Costs associated with transportation and marketing of the end-product were also included.

The solicitation process and related timelines are included in Exhibit ES-1 and Exhibit ES-2 on pages ii and iii of the report.

Following receipt of bidder proposals, a rigorous review of the offerings was conducted, incorporating the evaluation factors shown in Exhibit ES-3 on page iii of the report.

Table ES-2 on page iv of the report provides a summary of CCR Rule encapsulated beneficial use compliance criteria and whether the individual bidders meet each of the criteria. Only one of the two bidders who provided complete responses to the RFP were able to provide sufficient evidence that their proposed technology or process met the encapsulated beneficial use criteria requirement in the RFP.

CCR Beneficial Use Technologies and Products

Bidders proposed three different beneficiation options for encapsulating the CCR material at the Glen Lyn Plant. Bidder #1 proposed use a new technology utilizing decomposition reactors to combine the CCR material with imported raw materials to create a reactive pozzolan material for use in concrete ready-mix production. Bidder #2 proposed to transport unprocessed CCR material from the Aux Pond off-site for use as cement kiln feed. Bidder #3 proposed a thermal curing process to produce a concrete aggregate product; however, the bid was incomplete and non-compliant with the RFP requirements and therefore not further evaluated as a viable option.

CCR Beneficial Use Quantity and Project Duration

A summary of the volume of CCR to be beneficiated and the anticipated project duration is provided in Table ES-3 on page iv of the report. Bidder #1 proposed to utilize CCR from both the Existing Landfill and Aux Pond, completing all work within 11.5 years. Bidder #2’s proposal considered use of a limited quantity of CCR from the Aux Pond over a project duration of 5 years.

Transportation Considerations

Bidders proposed to transport their end-product to market by use of truck, rail, or a combination of truck and rail transport. Use of a barge or other waterborne vessel is proposed by Bidder #1 for shipping material to the international market, if deemed necessary.

Bidder #1 proposed trucking approximately half of their end-product to the local ready-mix market within 250 miles of the Glen Lyn Plant. To meet the anticipated off-take volumes, Bidder #1 anticipates 75 pneumatic trucks trips per day on a 24-hour-per-day, 5-day-a-week hauling schedule. Bidder #1’s beneficial use process also requires significant importation of raw materials, with 139 triple-axle trucks anticipated per day for delivery of materials. The other half of Bidder #1’s ready-mix material would be transported by rail to an extended domestic market within 1,000 miles of the Plant.

The number of railcars required to meet this market has not yet been defined and coordination with the railroad has not yet occurred. All materials sent to the international market will be transported via rail to a port in Virginia and loaded onto barges or other waterborne vessels.

Bidder #2 proposes to haul unprocessed CCR material via truck to a cement kiln located in central Virginia. Bidder #2 estimates that 18 trucks per day will be utilized 9 months of the year to meet their proposed annual production rate.

CCR Beneficial Use Market

The two bidders providing complete proposals offered varying approaches for marketing the beneficiated CCR from the Glen Lyn Plant. Each bidder considered a different end-product and prepared a specialized marketing plan.

Bidder #1 intends to market their end-product across several local ready-mix markets, an extended domestic ready-mix market including gulf coast states, and an international market should oversaturation occur or if other domestic marketing challenges are encountered. The local ready-mix market identified by Bidder #1 includes Knoxville, Tennessee; Charlotte, North Carolina; and the Research Triangle in North Carolina. The extended ready-mix market states include Texas, Mississippi, Alabama, and Florida, while the international market includes the Middle East, Caribbean, and South America. Marketing of Bidder #1’s end-product domestically for bulk sale is largely dependent upon receiving code certifications allowing it’s use in vertical construction projects in the United States. These certifications are not required for use as a building material in the international markets identified by Bidder #1.

Bidder #2 proposes to market unprocessed CCR to a central Virginia cement kiln at a rate of 80,000 to 100,000 tons of material per year, which represents the maximum annual intake rate for all CCR materials delivered to the kiln for use as a feedstock. Additional cement kilns were considered for marketing of CCR from the Glen Lyn Plant; however, anticipated transportation costs associated with trucking or railing material to these facilities limited the economic viability of that option.

Project Costs

Bidder #1’s anticipated beneficial use cost is approximately $25.02 per cubic yard (CY). This unit rate largely consists of construction, operation and maintenance of the on-site beneficiation system, construction of truck and rail load-out systems, and transportation costs of importing raw materials. The unit rate also includes leasing an off-site staging area, waste disposal costs, demolition of the beneficiation system, and costs associated with typical roadway maintenance. Bidder #1 indicated that all transportation costs associated with the sale of their ready-mix would be covered by the end-user, therefore these costs have not been included in the unit rate. A $1 per ton credit for sale of the ready-mix sold is included in this unit rate.

Bidder #2’s anticipated beneficial use cost is approximately $35.53 per CY. This unit rate includes construction, operation and maintenance of a truck load-out area, and associated transportation costs for off-site hauling of CCR to a cement kiln. An $8 per ton credit for CCR sold as of cement kiln feed is reflected in the unit rate provided.

The costs associated with construction of an on-site landfill are based on two designs currently under consideration and range from approximately $26 to $45 per CY of CCR material excavated from the existing CCR units at the Glen Lyn Plant. The unit rate includes construction and installation costs associated with landfill design and permitting, operational costs associated with transporting and placing of CCR from the Glen Lyn Plant in the new landfill, and anticipated closure costs.

Conclusion and Recommendations

AEP completed a site investigation and developed an RFP solicitation process to identify viable options for the beneficial use of the CCR materials at the Glen Lyn Plant’s Existing Landfill and Aux Pond in response to HB 443. Two complete bids were received and evaluated for this purpose.

Bidder #1 presented a potential cost savings when compared to the on-site landfill options but was unable to provide sufficient evidence that their end-product is fully compliant with the CCR Rule definition of encapsulated beneficial use and has not received the necessary certifications to allow for the use of their product in vertical construction in the United States. To further consider Bidder #1’s technology as a viable option, a beneficial use demonstration should be considered using CCR material from the Glen Lyn Plant following the United States Environmental Protection Agency’s (EPA) Leaching Environmental Assessment Framework (LEAF) protocols to establish leachability of metals and other constituents from their proposed end-product.

Bidder #2 proposed to beneficially use the CCR material as cement kiln feed; however, the annual off-take volume is significantly limited, and this option does not present a potential cost savings on a per cubic yard basis when compared to current on-site landfill estimates. Kiln feed may be considered during CCR unit closure activities to reduce landfill airspace requirements through a direct contract between AEP and the kiln to reduce costs and limit conflicts with unit closure operations.

Through completion of the RFP solicitation process and continued communication with bidders, it has been determined that several factors present limitations to beneficial use options at Glen Lyn. These factors include, but are not limited to, site constrains, regional market competition for beneficially used CCR material, and limited existing rail and natural gas infrastructure available on-site. Based on the review and analysis of information collected throughout the development of this Initial Biennial Report, there is currently not a viable beneficial use process providing a clear cost savings when compared to the identified lowest-cost approved alternative, an on-site landfill.