S t o r m Wate r Pol lut ion Preven t ion P lan ( S W P P P ) C o m p l e t e n e s s Check l i s t

Permittee: So~rthwcslenr Llectric Poucl Cornpan\ Farilly Name: John \\ ' Turk. JI Power Plant TracUng humher: .\RHO0 1064

1 ec = Complete No = lncnn~plete/Oelicient N1h = \ o t .\pplicable to project

\'en Yo N1.i A. Facility Information.

I Facllrn; Sanic 2. General Perniit hurnber

R. Stormwater Pollution Prevention l'ranl

\

I . ldcntifies spec~fic positrons or indivrduirls

1. Oullinc tl~err responsibrlirres

<'. Facility Description

I

1

Pan 4 h l

3. Phys~cal Address K

x I ~ e s c r i ~ t i o n of mdustr~nl aclivitres cond~rctsd ;rt site (process (lescnpt~on) Pan 4 6 3

4 . SIC ('ode

O. Site . l a p

1 Size of Property

? Locat~on of Significant Struclurcs and Imperiivus Smfaces.

3 Drainage tlow

4. Stnrctioal Contols

5. Recclvlng water 111 the ~rnmediatc VICIIIIQ h Storrnwaler Con\eyences. e g ditches. plpcs, >wales

7 . Potentral Pollut~on Sil~lrccs

8 ~\ lon~lor~rig l.ocations 9 Stornrwater lnlctsioutfalls iritl~ outfall k and outlrrie orarea dralrung to 10. h1S3 systems 11. Locatioris and descripcrons of non-stonn\rater drschages.

- I I l,ocatror~ ot'i~idustrrnl activ~tler r\pohcd to piecip~tation ~ncluding

\ I a. Fuelirig statlons \ 1 b. Vehicle / cqoipment marritenance or clranirig areas

c Loading 1 unloading areah d. \\;late treatment. storage or drsposal areas e Llquid storage ranks

h. 1 ransfcr ,brns (br bulk silbstances i Machlncn

13. locatriiris and source5 of nm-on to the s ~ t c Illat contarns pollutanls

\

F. Dcscriptioll of Potential Pollutant Sources

I' Procusz~r~g areas

Y 2. Inventor?. of Lxpoqcd blater~alh \ 5 Sprlls and Leaks.

- I San~plirig Data . Rrsh Ident~fication and Potential Pollutant Sources

\

I;. Cor~trol hlcacure$

g access roadi lo he ~rsrd lo move rdu rnate~ials, produc~. wdile

1. Dest M,magenient Practrce (BPvlPs) 2 Minrrni~e Exposrire 3 Good I louseLeeping 4 Prcvenlatiic hla~utsnance 5 Spill Prc\errtion and Itcsponse Procedlrre3 6 Enrployee I ralnlng 7 Ilrosron and Scdrrr~erit Cont~ol 8. h1an;igenient of Run-on and Runofl 9 Salt Storage Plles

Part 4 6 4 c

Pan 4 (1 4 d

I'm 4 6 J e Parr 3 6 3 f

Part -I h 3 $

Pdrt 4 6 4 h Part 4 6 4 I

P,ln 4 h 4 J

P'llt 4 6 4 k

Part 4 0 4 l Pa11 4 6 4 I Pan 4 6 3 1 Par1 4 6 4 I Part J 6 4 I ['art 4 6 3 I P a n 4 6 4 1

Pan 1 6 4 1 Pnrl 4 6 3 1 Part 4 6 4 rn

Pan 4 h 5 2 -- Pan 4 6 5 7 Part -I 6 5 4 Par1 4 6 i 5

Par1 3 6 h l Part 4 6 6 2 I'd11 3 6 6 i Pdrt 3 6 6 4 P a r t 4 6 6 5 Pan 4 0 h 6 Pnrl 4 0 0 7 l'drt 4 6 6 8

[\ I 1 (;. ,iuthorizrd Xon-Stormwater Dlwharges. Pdrt l 0 7

H. 303(d) and I hlDI,'5

:Ire pollulan~\ Irbled on [lie .3llZ(cl I lrst or 111 tlrc I hlDLs Ibl the receiirng Part 4 6 8 --

Par13 6 8 Pan 1 6 18

I. F;valuation and In\prctions.

Page 1 of 2

Storm Water Pollution Prevention Plan (SWPPP) C o m p l e t e n e s s Checklist

Permittee: Sourh\\esrcm Eleclnc Power Con~piui) Fac i l e Name: John \V. Turk. Jr. Power Plant Tracking humber: >\RHO0 1064

Ycs = Complcte Yo = IncompletrIDeficier~l N/,\ = N o t Applicable to project

I . Visual S ~ l c lnspect~ons ihiin~rnun~ 4!)ear) 2. ('o~l~pliance S ~ t c Evaluation:. (Oncelyem )

-11. Signed Plan certification.

SUMMARY PAGE FOR MSDS

Manufacturer Trade Name Common Name

Sulfuric Acid Sulfi~ric Acid

Description

Chemtrade Logistics

Water treatment (pH adjustment)

Occidental Chemical Corp.

Caustic Soda Sodium 25% Hydroxide

Water treatment (pH ad.ji~st~nent)

Occidental Chemical Corp.

Caustic Soda Sodium 50% Hydroxide

Water treatment (pH adjustment)

Univar USA Inc.

4- 1 9% Aqueous Ammoniun~ Ammonia Hydroxide

Boiler nater pH control

GE Betz Inc. Klaraid IC 1 187 Ferric Sulfate Solittion

Coagulant for precipitation at sand tilters

GE Betz Inc. Klaraid PC 1 192 Coagulant Aid Coagulant for precipitation at sand tilters

Avista Technologies

Roc lean L2 1 1 RO Membrane Cleaning Agent

Membrane cleaning agent for Reverse Osnlosis s>.stem

Avista Technologies

Roc lean P303 RO Membrane Cleaning Agent

Membrane cleaning agent for Reverse Osmosis system

Avista Technologies

RoClean L403 RO Membrane Cleaning Agent

Membrane cleaning agent for Reverse Osmosis systeln

Avista Technologies

VlTEC 3000 NSF Anti-Scalant Reverse osmosis me~nbrane anti-scalant

ROCIDE IS2 Biocide Biocide for Reverse Os~nosis systeln

Avista Technologies

GE Betz Inc. Polyfloc AEI 123 Flocculant Wastewater flocculant

GE Betz Inc. Depositrol BL5400 Deposit Control Agent - HEDP

Cooling tower water treatment suspension agent

GE Betz Inc.

GE Betz Inc.

Gengard GN8004 DispersantIPolymer Corrosion inhibitor

Spectri~s DT1404 Sodiu~n Bisulfite De-chlorination for cooling tower

Chemtrade Logistics

Sodium Bisultite Sodium Bisultite (Generic)

De-chlorination-cooling tower bloudown & water treatment

GE Betz Inc. Spectrus OX 120 1 Oxidizing Biocide Water-based microbial control agent

Brenntag Southwest

GE Betz Inc.

GE Betz Inc.

GE Betz Inc.

GE Betz Inc.

GE Betz. Inc.

Verde Environmental

Sodium Hypochlorite Oxidizing Biocide Water-based microbial control (Chlorine) agent

Spectrus IVX 1 I00 Non-Oxidizing Cooling to\\er biocide Biocide

Foamtrol AF 1-1-10 Oil-Based Antifoal11 Cooling tower anti-foaming Agent agent

Foamtrol AF2290 Silicon-Based Cooling tower anti-foaming Antifoam Agent agent

Flogard MS620 1 Water-Based Cooling tower system Corrosion Inhibitor corrosion inhibitor

GENGARD Phosphoric Acid Cooling tower system GN7300 Corrosion Inhibitor corrosion inhibitor

Micro-Blaze Oil-consuming Biodegradable oil-consuming surfactant n~icrobiological surfactant

Rev. D. O!~t~rm W&&r Pellutim Pmvantian Btsn (SWPT) J o b W. Turk Jr. Power Plant Qember 1,2012

Section 4: Site Map Detailed site I facility map(s) are located in Appendix A.

Figure 2 - Aerial photo of plant

Storm Water Pollution Prevention Plan

John W. Turk Jr. Power Plant 3 7 1 1 Highway 3 5 5 South

Fulton, AR 7 1838

ADEQ PERMIT NO. ARROOOOOO

5 SOUTH WESTERN ELECTRIC

S WPPP Preparation Date: October 1,201 2

Contents Section 1 : Facility Information ........................................................................................................ 3 Section 2: Storm Water Pollution Prevention Team ........................................................................ 4 . . Section 3: Facility Descrlptlon ........................................................................................................ 5 Section 4: Site Map .......................................................................................................................... 7 Section 5: Description of Potential Pollutant Sources ..................................................................... 8

Section 5.1 : Industrial Activities ................................................................................................. 8 Section 5.2. Inventory of Exposed Materials ............................................................................ 14 Section 5.3. Spills and Leaks ..................................................................................................... 22 Section 5.4. Sampling Data ....................................................................................................... 22 Section 5.5. Risk Identification and Summary of Potential Pollutant Sources ......................... 23

Section 6: Measures and Controls ................................................................................................. 23 Section 6.1 : Best Management Practices (BMP's) .................................................................... 23

............................................................................................ Section 6.2. Minimizing Exposure 25 Section 6.3. Good Housekeeping .............................................................................................. 26 Section 6.4. Preventative Maintenance ...................................................................................... 27 Section 6.5. Spill Prevention and Response Procedures ........................................................... 27 Section 6.6. Employee Training ................................................................................................ 29 Section 6.7. Erosion and Sediment Control ............................................................................... 29 Section 6.8. Management of Run-of and Runoff ....................................................................... 29

Section 7: Authorized Non-Storm Water Discharges .................................................................... 29 Non-Storm Water Discharge Assessment and Certification ...................................................... 31

Section 8: Documentation of Permit Eligibility Related to the 303(d) list (Impaired Water ..................................................................... Bodies) and Total Maximum Daily Loads (TMDL) 32

....................................... Section 9: Attainment of Water Quality Standards After Authorization 32 ....................................................................................... Section 10: Evaluations and Inspections 32 ........................................................................................ Section 10.1 : Visual Site Inspections 32

17 Section 10.2. Comprehensive Site Compliance Evaluation ...................................................... 2 2 17 Section 1 1 : Recordkeeping and Internal Reporting Procedures .................................................... 2 2

................................................................................................................ Section 12: Certification 34

Appendices

Appendix A . Site I Facility Map Appendix B . Visual Inspection Forms Appendix C . Comprehensive Site Compliance Evaluation Appendix D . ARROOOO Annual Report & DMR Form Appendix E -Record of Plan Updates I Changes

Section 1 : Facility lnformation Name of Facility: John W. Turk Jr. Power Plant Street: 371 1 Hiqhway 355 South City: Fulton County: Hempstead State: AR ZIP Code: 71 838 Perrr~it Tracking Nurr~ber: ARROOB277 Phone (24-Hour): (903) 831-1 600 Facility Operator: Soutliwesterr~ Electric Power Corr~pany (SWEPCO)

428 Travis Street, Shreveport, LA 71 101 (31 83 673-3640

Facility Owners: 73% SWEPCO 12% Arkansas Electric Cooperative Corp. 428 Travis Street, Shreveport, LA 71 101 1 Cooperative Way, Little Rock, AR 72219 (31 8) 673-3640 1501) 570-2200 8% East Texas Electric Cooperative 7% Oklahoma Municipal Power Authority. 2905 Westward Drive, Nacoqdoches, TX 2701 W 1-35 Frontaqe Rd., Edmond, OK 75963, (936) 560-9532 7301 3 , (405) 340-5047

Latitude: Lonqitude: 1. 33' 38' 45.301 " N (deg, minutes, seconds) 1. 93' 49' 45.300" W (deg, minutes, seconds)

2. 33.64591 7O N (decimal)

3. 3723205 N (UTM)

2. 93.82925' W (decimal)

3. 576897 E (UTM)

Discharge lnformation

Estimated area of industrial activity at site exposed to stormwater: 800 (acres)

Does this facility discharge stormwater into an MS4? Yes [XJ No

Name@) of water@) that receive stormwater from your facility Bridqe Creek, thence to the Red River

Are any of your discharges directly into any segment of an "impaired" water? Yes [XJ 110

If Yes, identify name of the impaired water (and segment, if applicable NIA

Identify the pollutant(s) causing the impairment:

For pollutants identified, which do you have reason to believe will be present in your discharge?

For pollutants identified, which have a completed TMDL?

Are any of your stormwater discharges subject to effluent guidelines? Yes No

If Yes, which guidelines apply? Sector 0 - Steam Electric Generatinq Facilities Primary SIC Code: 491 1

NAlCS Code: 221 112

Section 2: Storm Water Pollution Prevention Team

Staff NameslPositions I lndividuallPosition Res~onsibilities Plant Environmental Coordinator

I management practices, conduct monthly inspections, and conduct storm water

Serve as team leader; coordinate development, implementation, and updates to the plan; ensure plan requirements are satisfied. Develop plan; plan updates; provide technical support, and conduct the Comprehensive Site Compliance

Chemists Evaluation. Day-to-day observations of compliance with plan provisions, implement best

Coal Yard Superintendent sampling and documentation. In the Coal Yard and Landfill area: day-to-day observations of compliance with plan provisions, implement best management practices, conduct or assign monthly

Energy Production Supervisors inspections. Day-to-day observations of compliance with plan provisions, implement best

Maintenance Supervisors management practices. Day-to-day observations of conipliance with plan provisions, implement best

AEP Environmental Services management practices. Provide environmental regulatory compliance & technical support to facilities.

Rev. 0. Swm Warn Pollution Prevention Plaa tSWP3) John W. Turk Jr. Power Plant, OcZober 1,2012

Section 3: Facility Description

Turk Power Plant is a coal-fired, steam electric power generating facility with a net generating capacity of 600 megawatts. Commercial operations are expected to begin on December 15,2012. The overall facility includes a boiler, turbinelgenerator, coal pile, Class 3 N landfill, cooling tower, air quality control systems and supporting equipment and facilities. The plant is considered a "base-load" plant, meaning that it generally operates at full capacity on a continuous basis. For the specific plant layout, reference the Site I Facility Map in Appendix A.

Figure 1 - Simplified schematic of a coal-fired power plant

1. Cooling water source 2. Cooling water pump 3. Three-phase transmission l i e

4. Step-up transformer 5. Electrical generator 6. High pressure steam turbine 7. Condensate and feedwater pumps 8. Surfhe condenser 9. Low pressure steam turbine 10. Steam control valve

1 1. Low pressure steam turbine 20. Fan 12. Deaerator 2 1. Reheater 1 3. Feedwater heater 22. Combustion air intake 14. Coal conveyor 23. Economizer 15. Coal hopper 24. Air preheater 16. Coal pulverizer 25. Bag House 1 PM Control 17. Boiler steam drum 26. Fan 18. Bottom ash hopper 27. Flue gas desulfurization scrubber

19. Superheater 28. Flue gas stack

Fundamental Processes for Facility Operatio11

Fuel Supply: the plant operates by receiving, storing, processing, and burning sub-bituminous coal from the Powder River Basin in Wyoming. Coal is received via rail car on a rail spur from the Union Pacific railroad. Each coal train is approximately 135 cars in length. The rail cars are indexed one at a time through the rotary coal car dumper house, which rotates each rail car approximately 160" allowing the coal to dump from the rail car into a coal hopper at sub-grade level. From the coal car dumper house, coal is transported via a system of partially covered conveyor belts to the coal p~le. Coal which is routed to the coal pile is puslied by dozers o~ i to the coal pile in order to store the coal for use at a later date. From the coal pile, coal is transported by conveyors and is then pulverized into a fine powder and then blown via high velocity air into the boiler for combustion in order to produce steam. The burning of coal produces coal ash. Coal ash is handled as either fly ash or bottom ash. Fly ash is removed from the flue gas stream by Pulse Jet Fabric Filters (bag house), and is then either disposed of in the facility's ash landfill, or reused in the process. Bottom ash is disposed of in the facility's ash landfill.

Steam Process: .the boiler heats water into high purity, high terr~perature steani used to in-~part mechanical energy to the turbinelgenerator. Water from the Little River is purified to an "ultra-pure" condition suitable for producing high purity steam. This is accomplished by a series of water treatment steps including: sand filtration, multi media mixed bed filtration and reverse osmosis, which ultimately yields "ultra-pure" water. This water is then introduced into the steam cycle where it is heated in the boiler to generate steam. After imparting the mechanical energy to the turbinelgenerator, the steam is cooled and condensed to water, and is then returned to the boiler (recycled) for conversion back into stream.

Electricity Generation: electricity is generated in the hydrogen-cooled generator. The generator is connected to the steam turbine and consists of a stator and rotor which spins, thereby imparting an electric current by moving the induced magnetic field around the copper coils. The electrical current is routed via bus connection to step-up transformers which increase the voltage, where it is then routed to various substations for distribution on the grid.

Coolinq Water Process: raw water from the Lit.tle River is pumped throughout the plant where it provides for the cooling of equipment and for condensing boiler steam into water. The vast majority of cooling water is used to condense the boiler steam into water. This process of condensing steam occurs in a non-contact condenser where circulating water absorbs sufficient heat from the steam which has just traveled through the steam turbine to convert the steam back into high-purity water. During condensing of the steam, a vacuum is created on the downstream side of the turbinelgenerator, acting to draw the steam from the high-pressure conditions in the boiler to the low-pressure conditions in the condenser, increasing .the energy of the steal11 as it travels through the turbine, and significantly increasing the efficiency of the steam-electric generating process. The cooling water system at Turk includes a cooling tower, which is utilized to augment the cooling of the condenser water via a mechanical draft system which has the capability of cycling (re-using) the water within the tower to more efficiently remove waste heat from the system. Cooling water is also used for non-contact cooling of other equipment such as oil coolers, hydraulic system cooling, and instrumentation, as well as for non-cooling purposes such as service water, fire fighting water, and as a dust suppressing agent on the coal pile, coal conveyors, and landfill.

Rev. 0, Storm Water Pollutfan Prevention P h fSWP3)' John W. Turk k. Power Plant October 1.20 12,

Section 4: Site Map Detailed site I facility map(s) are located in Appendix A.

Figure 2 - Aerial photo of plant

Section 5: Description of Potential Pollutant Sources This sectior~ provides descriptions of potential sources (activities and materials) which may reasonably be expected to add significant amounts of pollutants to storm water discharges.

Section 5.1 : Industrial Activities The following is a description of .the major industrial activities whicli may poter~tially be significant sources of storni water pollutants:

Coal handling and storaqe: the plant receives approximately 2.3 million tons of coal annually via rail. The coal trains enter the plant on the plant-owned rail spur. The rail spur passes through the rotary coal car dumper house where each individual rail car is rotated along its axis approximately 160 degrees, allowing the coal to dump into the coal hopper below. The coal car d1.1mper house, transfer tower and crusher house are equipped with a water and dust suppressant spraying system in order to control fugitive coal dust emissions .from the coal unloadi~ig & coal conveyor system. With the exception of the open-top rail cars and activities associated with operation of the coal pile, none of the coal handling processes is exposed to storm water. The coal pile run off pond, which is permitted by the facility's NPDE permit captures & treats storm water run off from the coal piles and coal yard area.

Potential pollutants (parameter(s) of concern: TSS, copper, iron, aluminum, nickel, selenium.

Ash handling and storage: coal ash is generated from combustion of coal in the boiler. Ash is removed .frolii the boiler as either fly ash or bottom ash. Ash handling activities are located in areas that drain to a process water pond or to a storm water detention pond. Bottom ash and fly ash are disposed of in the on-site Class 3 N landfill.

Landfill (ADEQ Permit No. 031 1-S3N): the landfill is permitted to receive fly ash, bottom ash, and other wastes described in the solid waste landfill permit. Fly ash disposed in the ash landfill may be sprayed with water in order to reduce fugitive emissions as well as to solidify .the ash to prevent storm water pollu'tion. The water used to stabilize the fly ash in the landfill is immediately absorbed by the ash and does not become runoff. The landfill area storm water detention pond captures and treats storm water run off from the landfill area roads and slopes. The leachate collection pond captures and treats storm water that has contacted waste in the landfill cell(s).

Fly ash is the ash which remains suspended in the boiler combustion gas flow (flue gas) and is removed by the pulse jet fabric prior to the flue gas being ernitted to the atmosphere through the stack. Fly ash is transported via vacuuni from tlie fly ash recycle system to the waste ash silo. From the waste ash silo, the ash is loaded into trucks where it is disposed in the on-site ash landfill.

Bottom Ash is the ash which falls to the bottom of the boiler due to its physical size (i.e. it is too heavy to remain suspended in the flue gas), and is similar in size and appearance to course sand. The bottom ash is quenched in the bottom of the boiler and will be disposed of in the on-site Class 3 N landfill.

Potential pollutants (parameter(s) of concern in coal ash: TSS, chromium, copper, iron, zinc, aluminum, selenium, oil & grease, pH.

Loading and Unloading Areas which are exposed to stormwater:

Acid, Caustic, Bleach and Water Treatment Chemical Unloading Area: the plant receives routine shipments of Sulfuric Acid, Sodium Hypochlorite (12.5 % bleach), Sodil-~m Hydroxide (caustic soda) and totes and drums of chemicals which are used in the water treatment process. The deliveries are received by tanker truck or a box van. The acid, caustic and water treatment chemical UI-~loadiqg area is located on the west side of the water treatment building. This area has a concrete unloading pad with secondary containment. The other chemical unloading area is on the southeast corner of the cooling tower chemical building. This unloading area also has a concrete unloading pad with secondary containment. Plant pumps andlor plant-supplied air pressure are used to transfer the material from tanker trucks to individual storage tanks adjacent to the unloading area. Company policy and US Department of Transportation rules dictate that trained plant personnel be present during the entire chemical unloading process and that the specific ~~nloading procedures be followed.

Potential pollutants (parameter(s) of concern): sulfuric acid, sodium hypochlorite and sodium hydroxide (chemicals, COD, pH).

Coal Yard & Plant Mobile Equipment Fuel Unloading Area: the plant receives shipments of diesel fuel and gasoline which are used for refueling vehicles, tractors, dozers, and other equipment with internal-combustion erlgines. The deliveries are received by tanker truck at the UI- loading areas adjacent to the above ground storage tanks. Each tank is equipped with its own fill pipe connection. The unloading area in the coal yard has a concrete secondary containment. The adjacent ditch drains to the coal pile run off pond. If a spill occurs outside of the containment, the volume of the drainage ditch and pond acts as containment until clean up can occur. The unloading pad in the HAZMAT area has a roof and a functional concrete drive through secondary containment.

Potential pollutants (parameter(s)) of concern: diesel, gasoline, petroleurr~ by-products, used oil, oil & grease, COD.

Coal Yard Lubricatinq Oil Unloading Area: the coal yard receives shipments of various specialty lubricants which are used in the heavy equipment (tractors and dozers). Deliveries are received by containers or tank trucks and are stored inside of the Coal Handling Service Building. The adjacent ditches drain to the coal pile run off pond. If a spill occurs, the volume of the drainage ditches and pond acts as containment until clean up can occur.

Potential pollutants (parameter(s)) of concern: oil, oil &grease, COD

Fire Pump Diesel Tank Unloading Area: the diesel powered fire pump double- walled tank is located inside of the fire pump building just west of the fire water tank.

Emerqency Diesel Generator (EDG) Tank Unloadinq Area: the emergency diesel generator double-walled tank is located beneath the EDG bullding, located just north of the fire water tank.

Potential pollutants (paranieter(s)) of concern: diesel fuel, oil & grease, COD.

Used Oil Loadinq Areas: the plant accumulates used oil in designated used oil drums, totes and above ground storage tanks. The used oil is sold to used oil marketers. Tank trucks are used to pump the accumulated used oil from the drums, totes and tanks. The used oil loading area is inside of the secondary concrete containment in the HAZMAT area.

Potential pollutants (parameter(s)) of concern: oil, oil & grease, COD.

Dust Suppressant Chemical Unloadinq Areas: the plant receives shipments of dust suppression chemicals which are used as a dust suppressant in the coal handling processes. Deliveries are received via tank truck into two double-walled tanks located north of the coal car dumper house, and into one tank on the southeast side of the reclaim tunnel. The location of each tank is considered an individual unloading area.

Potential pollutants (parameterjs)) of concern: surfactantlchemicals, detergents, COD.

Unloading Areas for Drums, Totes, and Other Containers of Potential Storm Water Pollutants: the plant receives numerous bulk containers with solid or liquid contents which would be potential stormwater pollutants if improperly handled. Examples include drums of lubricating oil, totes of sodium hypochlorite, drums of aqueous ammonia, and various sized containers of other materials which may be delivered via truck to various locations on the plant grounds. The shipping and receiving ramp at the warehouse has a functional concrete secondary containment.

Potential pollutant (parameter(s)) of concern: oil, chemicals, oil & grease, COD, pH, TSS

Fly Ash Loadinq Area: fly ash which is stored in the waste ash silo is loaded into trucks by way of an unloading chute on the bottom of the waste ash silo. Trucks drive into and under the ash silo and are loaded from the chute into the awaiting truck. The ilnloading system is equipped with a dust control system that minimizes fugitive dust created by the loading process.

Potential pollutants (parameter(s)) of concern in fly ash: TSS, chromium, copper, zinc, iron, aluminum, selenium, oil & grease.

Activated Carbon lniection System (ACIS) Unloadinq Area: activated carbon is injected into the flue gas stream to reduce mercury emissions. The activated carbon is unloaded by trucks into the ACIS silo, which is on the southwest side of the 1.1nit. The adjacent ditches drain to the south storni water pond. If a spill occurs, the volume of the drainage ditches and pond acts as containment until clean up can occur. The silo's bin vent filter reduces fugitive dust emissions from the silo.

Potential pollutant (parameterjs) of concern): carbon fines (TSS, chromium, copper, zinc, iron, aluminum, oil & grease).

Lime Unloadinq Areas: pebble lime is unloaded at the lime silo andlor outside of the reagent prep building, either by railcar or truck. The silo's bin vent filters & other systems reduce fugitive dust emissions. Most of the area around the lime silo & the reagent prep area drain to the south storm

water pond. If a spill occurs, the volume of the drainage ditches and pond acts as containment until clean up can occur. The silo's bin vent filter reduces fugitive dust emissions .from the silo.

Potential pollutants (parameter(s)) of concern: lime residue, TSS, pH, and oil & grease

Anhydrous Ammonia Unloading Area: anhydrous ammonia is unloaded by tanker truck into the tank. The concrete unloading pad drains directly into the tank's concrete secondary containment sump. The tank and containment areas are routinely inspected.

Potential pollutants (parameter(s)) of concern: an-~monia, l-~itrate, nitrogen, and pH)

Miscellaneous LoadinqlUnloadinq Areas: over time, various projects will occur which involve receipt of bulk materials (top soil, crushed rock, sand, asphalt paving material, etc ...) to be unloaded and temporarily stockpiled until needed. Similarly, there will be intermittent instances when material will need to be loaded onto truckslraillother modes of transportation for removal from the plant (waste shipments, recycling shipments, product return shipments, etc ...). These loading and unloading areas w~l l be strategically placed to accomplish the work. Most of the areas of the facility either drain to the process water system or to the storm water pond system.

Potential pollutants (parameter(s)) of concern: sediment, oil, TSS, oil & grease.

Outdoor Storaqe of Material o r Products: the plant stores numerous materials and products outdoors. In addition to the coal and ash storage described above, Section 5.2 (Inventory of Exposed Iblaterials) identifies each unique material or product which is stored outdoors and provides details regarding relevant containment s.tructures, volume andlor size, container construction material (where applicable), and direction of surface .flow if the material were to become entrained in storm water.

Potential pollutants (parameter(s)) of concern: numerous--refer to Section 5.2 .

Outdoor Manufacturing and Processing: as part of routine, general plant operations, manufacturing does not occur outdoors. Other than the handling of coal and ash outdoors (as described above), the plant does not routinely manufacture items or process materials outdoors. However, on the occasion when construction, manufact~.~ring, or processing activities do occur outdoors, an evaluation will be made for consideration of storm water impact and the appropriate best management practices will be incorporated. And if required, a construction storm water permit and associated construction storm water pollution prevention plan will be obtained and implemented

Potential pollutants (parameter(s)) of concern specific to manufacturing or processing activities: TSS, metals, oil & grease, chemicals, pH).

Dust o r Particulate Generatinq Processes: dustlpa~ticulate generating processes are as follows:

Coal Handlinq: Coal entering the plant via rail car is a potential source of stormwater pollution. Coal particles (dust) may be blown from the open-top rail cars by high winds and deposited on the ground. From the unloading of coal in the Coal Dumper House until burned in the boiler, the coal handling process has the potential to generate coal dust. However, there are numerous control systems in place which eliminate or suppress the generation of coal dust from the various coal

handling processes. Various control measures w~l l be employed (water andlor surfactant sprays, enclosures, rain covers, baghouse, and settling pond) to help prevent coal dust .from beconii~ig a storm water pollutant.

Potential pollutants (parameter(s)) of concern: TSS, copper, iron, aluminum, nickel, selenium.

Cooling Tower Operation: is part of the unit's cooling system used to dissipate heat from the process. Water treatment chemicals are injected into the cooling tower basin to control water quality. The water discharged from the cooling tower is regulated by .the facility's IVPDES permit. Proper operation and drift elimination equipnient is used to eliminate or r~iir~imize cooling water mist from contacting the ground and introducing potential storm water contaminants. The adjacent ditches drain to the north storm water pond. If a spill occurs, the volume of the drainage ditches and pond acts as containment until clean up can occur.

Potential pollutants (parameter(s)) of concern: process wastewater, COD, TDS, Chlorine

Other Surfaces Exposed to Air Emissions from a Manufacturing Building or Process Area:

Other Surfaces Exposed to Air Ernissions or Processes: Due to the nature of the electricity generating process of a coal burning power plant, virtually all roofs and other surfaces are potentially continually exposed to air emissions or processes. The boiler stack extends approximately 600 feet above the ground surface and may emit fly ash from the combustion of coal (some fly ash is not removed by the pulse jet fabric filter). Although this emission point is permitted by a Title V Air Permit, it represents a potential source of particulate emission deposi.tion on all surfaces of the plant. The auxiliary boiler stack extends approximately 340 feet above ground surface and it may elnit a small amount of particulate matter from the combustion of natural gas.

On-Site Waste Treatment, Storage, or Disposal: the following waste treatment, storage, and disposal activitieslareas are exposed to storm water:

Solid Waste Class 3N Landfill: Permit # 031 1-S3N is for disposal of fly ash, bottom ash and other wastes specified in the solid waste landfill permit. The ash landfill is constructed to drain storm water outside of the cells into storm water drainage ditches .that drain to the landfill area storm water detention pond. The storm water is ultimately discharged through storm water outfall # S004.

Potential pollutants (parameter(s)) of concern: TSS, chromium, copper, iron, zinc, aluminum, selenium, oil & grease, and pH.

Trash Dumpsters: are used to accumulate general plant trash. The plant generally has two sizes of dumpsters; a 40 cubic yard roll-off dumpster and a 5 cubic yard dumpster.

Potential pollutants (parameter(s)) of concern: TSS, metals, oil & grease, COD, and pH).

Scrap Metal Dumpsters: typically consist of 20 cubic yard roll-off dumpsters used to accumulate scrap metal prior to pick-up by a scrap metal recycler.

9 Potential pollutants (parameter(s)) of concern: petrole~.~m products, metals, oil & grease.

Te~nporarv Waste ContainerslTanks: large tankslcontainers are occasionally used for treatment andlor temporary storage of a variety of wastes. For example, approximately every 5-8 years, 20,000 gallon frac tanks are used to accumulate chemical cleaning wastewaters generated from cleaning of the boiler andlor condenser. These are enclosed tanks and are provided with containment, but are potentially exposed to storm water. Other tankslcontainers which may be intermittently used for outdoor treatment or storage of waste are evaluated for stormwater pollution protection, as applicable.

Potential polluta~its (parameter(s)) of colicern: chemicals, TSS, metals, oil & grease, and pH.

Miscellaneous Waste Treatment: waste may be occasionally treated on site, as allowed by waste regulations, in containers or tanks. For example, wastewater generated from cleaning of chemical or water tanks would be neutralized in temporary containers prior to off-site shipment. The waste and equipment used for treatment are evaluated for stormwater pollution protection, as applicable.

Potential pollutants (parameter(s)) of concern: various chemicals in containersltanks, TSS, metals, 011 & grease, COD, and pH.

Vehicle and Equipment Fueling, Maintenance andlor Cleaning: the following vehicle and equipment fueling, maintaining and cleaning activities are potentially exposed to stormwater:

Vehicles and heavy equipment, landscape maintenance equipment, and other equipment are refueled from several tanks throughout the facility. The tanks are equipped with SPCC Plan compliant hoses & nozzles and are located within a common containment structure which is accessible from the plant access roads as well as the coal pile area. Additionally, small portable fuel containers are filled from the dispensers in these areas. Bulk fuel unloading also occurs locally to the facility's bulk tanks by tank truck deliveries.

Potential pollutants (parameter(s)) of concern: fuel, oil, oil & grease, metals).

Maintenance of vehicles and heavy equipment: Vehicle maintenance generally occurs in the maintenance shop (not exposed to storm water). Heavy equipment niai~itenance generally occurs in one of the two Coal Yard tractor sheds, but may also occur outdoors if necessary.

Potential pollutants (parameter(s)) of concern: fuel, lubricants, solvents, various automotive fluids, oil & grease, COD, chemicals, and pH.

Equipment fuelinq, maintenance & cleaninq: Equipment (including but not lirr~ited to internal- combustion engines, space heaters, emergency generator, fire purlip, lawn and landscaping equipment, all-terrain vehicles, etc ...) is either fueled locally (with portable fuel containers) or at the fueling area in tlie Coal Yard and HAZMAT area. Equipment is generally maintained and cleaned in the Maintenance Shops, but may also be maintained outdoors as conditions require.

Potential pollutant (parameter(s) of concern): fuel (fuel, oil & grease, COD).