indeck energy - alexandria, llc aug17-2015.pdf · indeck energy – alexandria, llc swppp 1 general...

Indeck Energy - Alexandria, LLC Storm Water Pollution Prevention Plan (SWPPP) for 2015 Multi-Sector General Permit (2015 MSGP)

August, 2015 Prepared for:

Indeck Energy - Alexandria, LLC 151 Smith River Road Alexandria, NH 03222

Prepared by:

Epsilon Associates 3 Clock Tower Place, Suite 250 Maynard, MA 01754

Indeck Energy – Alexandria, LLC SWPPP 1

GENERAL FACILITY INFORMATION

Facility Name Indeck Energy – Alexandria, LLC

Facility and Mailing Address 151 Smith River Road, Alexandria NH 03222 (Grafton County)

Facility Coordinates (WGS 84) 43.5610 (lat.), 71.7810 (long.)

SIC Code 4911 (Electric Services)

Number of Storm Water Outfalls 1

Outfall Coordinates (WGS 84) 43.5611 (lat.), 71.7815 (long.)

Receiving Water Body1 Smith River, EPA ID #NHRIV700010702-22

Receiving Water Impairment Mercury (subject to the Northeast Regional

Mercury TMDL, = 0.3 ppm in fish tissue) pH (no TMDL established)

Receiving Watershed Pemigewasset, EPA ID #01070001

MSGP Industrial Sector Sector O (Steam Electric Generation)

Pollutant Benchmark Total Iron (Benchmark: 1.0 mg/L)

Primary Contact

Bryan Coutu, Plant Manager (603) 744-6355 (office), (603) 393-3699 (cell) [email protected]

Alternate Contact (Off-Site / Corporate)

Thomas Krysiak (716) 874-9088 (office), (716) 225-6478 (cell) [email protected]

1 EPA Receiving Water Reference:

http://ofmpub.epa.gov/tmdl_waters10/attains_waterbody.control?p_list_id=NHRIV700010702-

22&p_cycle=2010


Table of Contents

ContentsTable of Contents ........................................................................................................................... 2

1.0 FACILITY AND SWPPP OVERVIEW .................................................................................... 4

1.1 Certification by Designated Accountable Person .............................................................. 6

1.2 SWPPP Maintenance and Revision ................................................................................... 7

1.3 Stormwater Pollution Prevention Team ............................................................................ 8

2.0 STORMWATER SYSTEM AND CONTROLS ......................................................................... 9

2.1 Industrial Activities Exposed to Stormwater ...................................................................... 9

2.2 Non-Stormwater Discharges ........................................................................................... 10

2.3 Salt Storage .................................................................................................................... 10

2.4 Endangered Species Determination ................................................................................ 17

2.5 Historic Properties Determination .................................................................................. 17

2.6 Infiltration Best Management Practices ........................................................................... 17

2.7 General Facility Maintenance ........................................................................................ 18

2.8 Training ......................................................................................................................... 19

3.0 MONITORING AND REPORTING .................................................................................... 20

3.1 Evaluation for Unauthorized Non-Stormwater Discharges .............................................. 21

3.2 Notice of Intent .............................................................................................................. 21

3.3 Monthly Facility Inspections .......................................................................................... 21

3.4 Quarterly Stormwater Sampling ..................................................................................... 22

3.4.1 Quarterly Visual Inspections ................................................................................... 23

3.4.2 Benchmark Monitoring ........................................................................................... 23

3.5 Annual Impaired Waters Monitoring .............................................................................. 25

3.6 Annual Summary Report ................................................................................................ 26

3.7 Previous Sampling Data ................................................................................................. 27

3.8 Corrective Actions ......................................................................................................... 27

3.8.1 SWPPP Review and Revision Requirements ............................................................ 28

3.8.2 Corrective Actions and Deadlines ........................................................................... 28


APPENDICES

Appendix A: Site Map

Appendix B: Notice of Intent and Acknowledgment

Appendix C: Wood Ash Analysis

Appendix D: Monthly Facility Inspection Forms

Appendix E: Quarterly Visual Sample Inspection Forms

Appendix F: Benchmark Monitoring Results / Impaired Waters Monitoring Results

Appendix G: Annual Summary Reports

Appendix H: Endangered Species Notifications

Appendix I: Non-Stormwater Discharge Inspection Forms

Appendix J: Corrective Actions and Miscellaneous Documentation

TABLES

Table 1-1: SWPPP Cross-Reference

Table 1-2: SWPPP Revision Log

Table 1-3: Stormwater Pollution Prevention Team

Table 2-1: Industrial Activities Potentially Exposed to Stormwater

Table 3-1: Testing and Inspection Schedule

Table 3-2: Receiving Water Impairment

Table 3-3: Previous Sampling Data


1.0 FACILITY AND SWPPP OVERVIEW

The Indeck Alexandria facility is an electric generating station comprised of a wood-fired boiler (traveling grate stoker, Zurn design) and auxiliary equipment including a steam turbine, hydraulic loading systems, transformers, wood chip piles, a two-celled cooling tower, a diesel fire pump and a standby diesel generator. The rated electric output of the main boiler is approximately 16 MW. Operation commenced in October, 2009.

The Station is located in the Town of Alexandria, Grafton County, New Hampshire, on a 27-acre site bounded by the Smith River, adjacent private properties and the Smith River Road (aka Old Route 104). The portion of the site used for power plant operations is approximately 7 ½ acres. The Smith River, which runs directly adjacent to the west of the facility, drains to the Pemigewasset Watershed (EPA Watershed #01070001).

The portion of the Smith River is classified as an Impaired Water due to pH levels and elevated levels of mercury2. EPA and NHDES have established a mercury “total maximum daily load” (TMDL) value for this watershed, known as the Northeast Regional Mercury TMDL. In New Hampshire, this corresponds to 0.3 ppm mercury in fish tissue3. Monitoring and testing details are provided in Section 3 of this Plan.

A site plan depicting stormwater conveyance systems is included within Appendix A of this Plan, and additional details are provided in the following sections. In general, the facility consists of a main building (containing offices and the electric generating equipment), wood chip piles, a wood chip delivery/processing/conveyance system, cooling towers, a drum storage building, two process water ponds and a stormwater pond. The facility’s stormwater discharge to the Smith River environment (via one point-source outfall) is regulated under EPA’s National Pollutant Discharge Elimination System (NPDES) program – specifically, the 2015 Multi-Sector General Permit (MSGP).

Indeck Alexandria is subject to Sections 1-7 of the 2015 MSGP, as well as Section 8, Industrial Sector O (Steam Electric Generating Facilities). The facility is classified under SIC Code #4911 (electric generating facilities) and the facility’s electric generating system consists of a wood fired steam boiler and steam turbine which meets the applicability requirements of Industrial Sector O. Section 5 of the 2015 MSGP requires preparation of a Stormwater Pollution Prevention Plan (SWPPP). This Plan is compliant with the SWPPP requirements therein, as detailed in Table 1-1.

Note: Although the facility conducts minor ancillary processes on site to support the electric generation process (e.g., storage of a limited number of whole logs), it has not been assigned a SIC code other than 4911 (electric generation) by any U.S. government agency.

2 http://ofmpub.epa.gov/tmdl_waters10/attains_waterbody.control?p_list_id=NHRIV700010702-

22&p_cycle=2010

3 http://www.epa.gov/region1/eco/tmdl/pdfs/ne/Northeast-Regional-Mercury-TMDL.pdf.


Table 1-1 SWPPP Cross-Reference

Category Sub‐Category Section of 2015 MGSP

Section of SWPPP

Stormwater Pollution Prevention Team N/A 5.2.1 1.3

Site Description

Activities at the Facility

5.2.2

1.0

General Location Map Appendix A

Site Map Appendix A

Summary of Potential Pollutant Sources N/A 5.2.3 2.1, 2.3, 3.1, 3.7

Description of Control Measures N/A 5.2.4 2.1

Schedules and Procedures

Control Measures Used to Comply with Effluent Limits 5.2.5.1 2.7, 2.8

Routine Facility Inspections

5.2.5.2

3.3, Appendix D

Quarterly Visual Assessment of Stormwater Discharges 3.4, Appendix E

Benchmark Monitoring

5.2.5.3

3.4, Appendix F

Effluent limitations guidelines monitoring

N/A (no numeric effluent limits)

State or tribal specific monitoring N/A

Impaired waters monitoring 3.5, Appendix G

Other monitoring as required by EPA N/A

Documentation to support eligibility

considerations under other federal laws

Documentation regarding endangered and threatened species and critical habitat

protection 5.2.6.1 2.4

Documentation regarding historic properties 5.2.6.2 2.5

Signature requirements N/A 5.2.7 1.2

Industrial Sector O‐ specific requirements

Drainage Area Site Map 8.O.5.1 Appendix A

Good Housekeeping Measures 8.O.5.2 2.7

New Hampshire‐ specific requirements

Maintenance of Infiltration Best Management Practices 9.1.4.2 2.6


1.1 Certification by Designated Accountable Person

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information contained therein. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information contained is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

In accordance with Appendix B, Subsection 11 of the Multi-Sector General Permit, I certify that I am a duly authorized representative of Indeck Alexandria, LLC, with responsibility for the overall operation of the facility.

This Plan represents current facility operations and will be revised accordingly when changes occur at the facility, or when any of the corrective action thresholds from Part 4 of the 2015 MSGP are triggered. Any subsequent changes to this Plan will be signed, dated and noted in the revision history (Table 1-2).

Signature:

Name: Bryan Coutu

Title: Plant Manager

Date:


1.2 SWPPP Maintenance and Revision

Hardcopies of this SWPPP will be distributed to the Stormwater Pollution Prevention Team, with the master copy to be maintained by Bryan Coutu, Plant Manager. Furthermore, the 2015 MSGP is available for reference on U.S. EPA’s web site at: http://water.epa.gov/polwaste/npdes/stormwater/upload/msgp2015_finalpermit.pdf

As required by the Section 5.4 of the MSGP, this SWPPP will be made publicly available during the duration of the MSGP, using one of the following methods:

Provide a URL in the Notice of Intent where the SWPPP can be found, and maintain the current SWPPP at this URL. To remain current, post any SWPPP modifications, records and other reporting elements required for the previous year at the same URL as the main body of the SWPPP.

Include the SWPPP details within the Notice of Intent as specified therein. To remain current, report any modifications to this SWPPP information through submittal of a “Change NOI” form.

The SWPPP update shall be prepared no later than 45 days after conducting the December monthly facility inspection for each year.

The SWPPP will also be revised if any pertinent changes occur at the facility, if additional instructions are received from U.S. EPA / NH DES, or if any conditions occur as described in Section 3.8 which require a review and revision of the SWPPP. Revisions are tracked in Table 1-2.

Table 1-2 SWPPP Revision Log

Revision Date Description Signature 1 August 2015 Initial preparation N/A

2

3

4

5

6

7

8


1.3 Stormwater Pollution Prevention Team

The Stormwater Pollution Prevention Team at Indeck Alexandria consists of the staff members listed below. These personnel have overseen development of this SWPPP, and will maintain stormwater control measures and take corrective actions where required. Each person will have access to this Plan and the team will implement modifications as required.

Table 1-3 Stormwater Pollution Prevention Team

Name Responsibility

Bryan Coutu Plant Manager

Team Leader – coordinate inspections, maintenance, corrective actions, monitoring, recordkeeping, reporting and training

Pete Coutu Maintenance Manager

Assist storm water compliance tasks as coordinated by Plant Manager

Jim Murphy Operations Manager Thomas Krysiak (Off-Site / Corporate) Jim Schneider (Off-Site / Corporate)


2.0 STORMWATER SYSTEM AND CONTROLS

The stormwater conveyance systems at the facility are as follows:

The northern edge of the facility drains to two trenches, one on either side of the main access road. The endpoints of these trenches are two culverts that traverse underneath the paved roadway and parking lot. The two culverts converge into one outfall (Outfall 002) that empties to the Smith River.

Most of the Facility grounds (excluding the northern edge) are graded such that stormwater flows to trenches encircling the perimeter of the facility. The trenches ultimately drain to a large stormwater retention pond at the southern end of the property. This pond permeates into the ground and drains to ground water, therefore it is not a stormwater outfall subject to the MSGP per EPA’s guidance.

A stormwater diagram is provided in Appendix A. There have been no significant spills or leaks in the three years preceding this Plan.

2.1 Industrial Activities Exposed to Stormwater

Table 2-1 details the facility’s industrial activities that may be exposed to stormwater, as well as the corresponding pollutants and control measures. Significant spills and leaks may occur at the following areas (see Appendix A for locations):

Hydraulic Truck Dumpers (tanks and piping) Chemical and Oil Delivery Areas 34.5 kV and 4160 V Transformers (enclosed by containment berm) Vehicle Refueling Area

Many facility processes (e.g., storage of ammonia, sulfuric acid or boiler treatment chemicals) are not exposed to stormwater and are therefore not discussed in this Plan. Other than the wood chip pile, no general materials (e.g., process supplies) are stored or stockpiled in areas exposed to stormwater. Furthermore, the site does not contain any landfills, scrap yards, surface impoundments, open dumps, or general refuse sites that may be exposed to stormwater.

The oil storage units 55-gallons or larger (including the transformers, diesel tanks, hydraulic tanks and drums) are also a component of the facility’s Spill Prevention, Control and Countermeasure (SPCC) Plan, implemented separately under 40 CFR 112, which provides spill prevention practices including a delivery procedure, secondary containment drainage procedure, inspections, testing, training and other measures. Furthermore, NH DES regulation Env-Or 306.05 specifies that stormwater that is contaminated with oil (i.e., in secondary containment areas) shall be discharged to an enclosed container for transport to an authorized location.

With regard to process water, Indeck Alexandria is designed to be a “zero discharge facility”. It is not connected to a municipal water system. The process water is initially delivered as deionized


water or drawn from the river. Water entering any process drains or floor drains proceeds to the outdoor low level waste pond, and is then routed to the cooling tower and returned to the process system (or dissipated as steam). If process water must be removed due to an unusual event, it is collected by a contractor. The facility’s potable water is drawn from wells, and sanitary waste is discharged to an onsite septic tank. It should also be noted that the facility has a 8,000-gallon aqueous ammonia tank and a 6,000-gallon sulfuric acid tank, however, these are located indoors and are not exposed to stormwater.

2.2 Non-Stormwater Discharges

The following non-stormwater discharges are permitted under Section 1.1.3 of the 2015 MSGP:

Discharges from emergency/unplanned fire-fighting activities; Fire hydrant flushings; Potable water, including water line flushings; Uncontaminated condensate from air conditioners, coolers/chillers, and other compressors

and from the outside storage of refrigerated gases or liquids; Irrigation drainage; Landscape watering provided all pesticides, herbicides, and fertilizers have been applied in

accordance with the approved labeling; Pavement wash waters where no detergents or hazardous cleaning products are used (e.g.,

bleach, hydrofluoric acid, muriatic acid, sodium hydroxide, nonylphenols), and the wash waters do not come into contact with oil and grease deposits, sources of pollutants associated with industrial activities, or any other toxic or hazardous materials, unless residues are first cleaned up using dry clean-up methods (e.g., applying absorbent materials and sweeping, using hydrophobic mops/rags) and the facility has implemented appropriate control measures to minimize discharges of mobilized solids and other pollutants (e.g., filtration, detention; settlement);

Routine external building washdown / power wash water that does not use detergents or hazardous cleaning products (e.g., those containing bleach, hydrofluoric acid, muriatic acid, sodium hydroxide, nonylphenols);

Uncontaminated ground water or spring water; Foundation or footing drains where flows are not contaminated with process materials; and Incidental windblown mist from cooling towers that collects on rooftops or adjacent

portions of the facility, but not intentional discharges from the cooling tower (e.g., “piped” cooling tower blowdown; drains).

2.3 Salt Storage

A salt/sand mixture pile, used for de-icing, is kept within a designated “dome tent” structure (covered and enclosed on three sides) at the east end of the site, as shown in Appendix A. It is only used and replenished during icy conditions. The mixture is delivered by truck and transferred within the facility by a Bobcat loader or similar equipment. If salt is inadvertently exposed to stormwater, runoff may enter the perimeter trench system and lead to Outfall 002.


Table 2-1 Industrial Activities Potentially Exposed to Stormwater

Industrial Activity Potential Pollutant(s) Control Procedures

Wood Chip Deliveries

Total Suspended Solids (TSS) (coarse)

Hydraulic Oil (from truck dumping tanks and

piping systems)

Misc. vehicle oil and fluids

Other pollutants may be present in wood at

trace levels – see wood ash analysis in

Appendix C. The wood chips have

essentially the same constituents as the

surrounding wooded environment.

Wood chips are stored on paved, impervious surfaces.

Conveyors and processing areas are covered. A stormwater

trench runs along the perimeter of the paved area to collect

runoff, and the trench terminates at a stormwater pond in a

wooded area at the south end of the facility. Fabric filters

are laid across the stormwater trench at selected locations

to collect dust.

Hydraulic Oil is stored within weatherproof tanks which sit

upon metal drip pans. The area is inspected for oil leaks on

a daily basis. Storm water is removed from the pans only

after visual inspection indicates there is no oil

contamination.

Whole logs are stored in piles in a designated area outside

the main fence line at the southern end of the facility near

the stormwater pond, which would typically capture any

stormwater runoff from the log piles.

Wood-bound pollutants are shown by analysis to be within

allowable trace levels by state regulations.

Wood Chip Transfers,

Processing and Conveyance

Whole Log Storage and

Transfers


Low Level Waste Pond


The following pollutants may be present at

low levels (e.g., from process chemicals or

boiler water treatment):

ammonia, sulfuric acid, Drewamine 1791

(morpholine), Drewphos (Phosphate and

Sodium Hydroxide, Drewplex ( Sodium

Chloride), diesel fuel, lubrication oil,

hydraulic oil

Pond has an impervious liner and accepts water from the

facility’s process drains and floor drains. Contents of pond

are routed to cooling towers (which may then be emitted to

the air as vapor) – there is no stormwater runoff.

Waste Water Pond for

Quenching Total Suspended Solids (TSS) (coarse)

Stormwater in the immediate area is graded toward the

trenches which lead to the stormwater retention pond. The

Waste Water pond accepts blow down water from the

Scrubber. This Waste Water is trucked off-site by a

contractor. There is no stormwater runoff.

Salt/Sand Deliveries Salt



The salt/sand pile is kept within a designated “dome tent”

structure (covered and enclosed on three sides). It is only

used and replenished during icy conditions. Runoff may

enter the perimeter trench system and lead to either the

retention pond or Outfall # 002.

Salt/Sand Spreading


Transformer Maintenance

and Operation Transformer Oil

Transformers are closed, weatherproof systems. Partial

secondary containment, with a capacity of several hundred

gallons, is provided by concrete berms. Transformers are

inspected for leaks on a daily basis and would have

immediate and obvious effects if there were a leak. Storm

water is pumped out of the berms only after visual

inspection indicates there is no oil contamination. Any

maintenance is conducted manually by personnel familiar

with the equipment.

In the event of a spill, runoff may enter Outfall #002 or

proceed westward, downhill toward the Smith River.

Fire Pump Tank Deliveries

Diesel Fuel Oil

Lubricating Oil


Deliveries take place on paved, impervious surfaces

directly outside the receiving tank. Deliveries are

conducted in accordance with SPCC procedures to

minimize the risk of spills. The storage tanks are indoor or

fully enclosed.

Any spills or runoff would follow paved ground slopes to

the trench system and to the storm water retention pond.

Bulk Lube Oil Tank

Deliveries

Standby Generator Fuel

Deliveries

Vehicle Refueling Tank

Deliveries

Diesel Fuel Oil


Deliveries are conducted in accordance with SPCC

procedures to minimize the risk of spills. The storage tank

is inside a containment basin and also within a lean-to

structure (covered and enclosed on three sides)

Any spills or runoff would follow the eastern perimeter

trench to the stormwater retention pond.


Standby Generator

Maintenance and Operation Diesel Fuel Oil, Lubrication Oil

The standby generator is in a weatherproof enclosure with

a double-walled fuel tank providing full secondary

containment. The generator is inspected on a daily basis.

Any maintenance is conducted manually by qualified

personnel. Spills/runoff would either proceed to the

perimeter trench system and to the storm water retention

pond, or downhill westward to the Smith River.

Delivery of Maintenance

Fluids and Water Treatment

Chemicals (55-gallon drums)

Ammonia, sulfuric acid, Drewamine 1791

(morpholine), Drewphos (Phosphate and

Sodium Hydroxide, Drewplex ( Sodium

Chloride), diesel fuel, lubrication oil,

hydraulic oil

55-gallon drums are delivered or removed manually, using

drum carts for transport, either by in-house personnel or a

licensed waste contractor. Fluid transfers are conducted

manually by qualified personnel. When not being used,

drums are stored either in indoor areas or within the

designated outdoor shed, and on top of spill containment

pallets.

Removal of waste

(55-gallon drums)

Usage of Maintenance Fluids

and Water Treatment

Chemicals

Aqueous Ammonia

Deliveries 29% Aqueous Ammonia

Deliveries take place on paved, impervious surfaces

directly outside the receiving tank. Deliveries are

conducted in accordance with SPCC procedures to

minimize the risk of spills. Furthermore, any spills or

runoff would likely follow ground slopes to the nearby

perimeter trench system that runs to the storm water

retention pond. Sulfuric Acid Deliveries 98% Sulfuric Acid


Fly Ash Collection

Total Suspended Solids (TSS)

Other pollutants may be present at trace

levels – see wood analysis in Appendix C.

The wood products have essentially the same

constituents as the surrounding wooded

environment.

The ash is kept behind sliding metal doors that are

normally kept shut. Collection takes place on paved,

impervious surfaces directly outside the ash bunkers.

Any runoff would likely follow paved ground slopes to the

trench system that leads to the storm water retention pond. Bottom Ash Collection

River Water Withdrawal Pump Lube Oil

Pump mechanism is within interior of building and is

inspected daily.

Vehicular traffic and parking

Total Suspended Solids (TSS) (coarse),

misc. vehicle oil and fluids

The main parking area is graded toward the main building,

away from the stormwater perimeter conveyance system.

Furthermore, airborne dust is drawn indoors to process

areas by negative suction. Any vehicle maintenance takes

place indoors.

Some runoff may enter the northern stormwater collection

trenches which proceed to Outfall #002.

Vehicle Refueling Diesel Fuel Oil

The diesel storage tank is inside a containment basin and

also within a lean-to structure (covered and enclosed on

three sides) The fueling is performed manually by facility

personnel, and fuel usage is tracked with a gauge.

Any spills or runoff would follow the eastern perimeter

trench to the stormwater retention pond.


Garbage Dumpster

(Portable) Miscellaneous Industrial Waste

Dumpsters used are weatherproof and kept covered. Trash

is accumulated and collected by personnel trained in

hazardous waste management, away from any stormwater

conveyance.

External Washdown

(Building and Pavement) TBD (commercially available products)

No detergents or hazardous cleaning products will be used

during external washdowns. Washdowns will not be

performed when toxic materials may be present.

Landscape Watering TBD (commercially available products)

All pesticides, herbicides and fertilizer are applied in

accordance with the approved labeling.

Ash Yard

Total Suspended Solids (TSS) (coarse),

misc. vehicle oil and fluids

Storm Water drains form the ash yard to the perimeter

trench and to the stormwater retention pond.


2.4 Endangered Species Determination

A review of the U.S. Fish and Wildlife Services (FWS) tool at http://ecos.fws.gov/ipac/ indicated that one threatened species, the Northern Long-Eared Bat, may exist in proximity to the facility. This is a non-aquatic (terrestrial) species which would not feasibly be affected by the stormwater discharge. Furthermore, no listed critical habitats are located within the affected area. A review of U.S. National Marine Fisheries Service (NMFS) maps at http://www.nmfs.noaa.gov/pr/species/criticalhabitat.htm has also indicated that the facility is not in proximity to any NMFS-listed species.

This information was submitted to U.S. EPA, who subsequently confirmed on Aug. 10, 2015 that the facility is eligible for coverage under the 2015 MSGP according to “Criterion A” with regard to endangered species protection (no listed species in the action area). A copy of this correspondence is provided in Appendix H of this Plan.

2.5 Historic Properties Determination

Indeck Energy – Alexandria, LLC has previously determined under the 2008 MSGP that there have been no impacts on historic properties. The 2015 MSGP represents a renewal of prior coverage without any relevant changes in operations (including no subsurface work), and the facility therefore has no potential to have an effect on historic properties. The facility is therefore eligible for 2015 MSGP coverage under “Criterion A” for historic properties: “Your stormwater discharges and allowable non-stormwater discharges do not have the potential to have an effect on historic properties and you are not constructing or installing new stormwater control measures on your site that cause subsurface disturbance.”

2.6 Infiltration Best Management Practices

The only significant on-site stormwater infiltration occurs at the stormwater retention pond at the south of the facility. As shown in Appendix A, most of the Facility grounds (excluding the northern edge) are graded such that stormwater flows to trenches encircling the perimeter of the facility, which ultimately drain to the retention pond. This pond permeates into the ground and drains to ground water. Any dust that may reach the pond would primarily come from the wood chip piles on site, and would have essentially the same characteristics as the surrounding wooded environment, and therefore not create a condition of pollution.

The infiltration Best Management Practices (BMPs) primarily consist of perimeter trench maintenance to minimize particulate matter reaching the pond. As stated within Table 2-1, this includes usage of fabric filters which will be replaced as required. It is also verified that drainage is occurring as expected in order to prevent mosquito breeding; and that there is no evidence of industrial pollutants reaching the pond.

The above BMPs are verified by monthly visual inspections (Section 3.3 of this SWPPP; records and a template form are kept in Appendix D). Inspections, maintenance and


corrective actions are conducted under the direction of Bryan Coutu, Plant Manager. If required, corrective actions are performed consistent with Section 3.8 of this Plan.

A condition of “no exposure” should always exist for the infiltrated stormwater at the pond. In the event that a certification of no exposure can no longer be made, then the infiltration must cease for that portion of the runoff or the discharge must be permitted or registered as appropriate. The following may be required:

Infiltration BMP that meets the definition of a Class V well or that infiltrates stormwater via a subsurface structure (i.e. concrete chambers, dry well, leach field, etc.) will need an underground injection control (UIC) registration from NHDES; and

Permitting as a groundwater discharge as required in Env-Wq 402, if the stormwater will or may contain regulated contaminants.

The SWPPP must be modified immediately if new infiltration BMPs are proposed or if existing infiltration BMPs will cease.

Notify the NHDES Groundwater Discharge Permit Coordinator immediately if any infiltration BMP may need to be permitted or registered during the permit term. Notify the NHDES Wastewater Engineering Bureau immediately of any plans to discharge any new non-stormwater discharges during the permit term (excluding the allowable non-stormwater discharges listed in Section 2.2.) Any such notifications must be addressed to: NH Department of Environmental Services Wastewater Engineering Bureau, Permits & Compliance Section P.O. Box 95 Concord, NH 03302-0095.

2.7 General Facility Maintenance

Good housekeeping practices are implemented to keep the site clean and well organized. An operator makes regular tours (every two hours during business hours) to clears away indoor and outdoor waste, garbage and debris. Materials are stored in appropriate containers and trash bins are kept shut. No polymers and/or other chemical treatments as part of erosion or sediment controls.

The facility’s Spill Prevention, Control and Countermeasure (SPCC) Plan, implemented separately under 40 CFR 112, provides a number of facility-wide good housekeeping procedures, including but not limited to the following topics:

Delivery Vehicles Oil/Chemical Loading and Unloading Areas Storage Tanks Oil-Bearing Equipment in Switchyards Spill Reduction Measures


The facility also maintains separate procedures for (e.g., truck dumping and ash loading). Finally, additional good housekeeping (e.g., inspections of ponds and trash collection) and preventive maintenance inspections are embedded within the monthly inspection form included with this SWPPP (Section 3.3 / Appendix D).

2.8 Training

Training on pertinent aspects of this Plan is as directed in the facility’s Spill Prevention, Control and Countermeasure (SPCC) Plan, implemented separately. As stated therein, onsite discharge prevention training is provided to each employee (except for admin assistants) each year. This also serves as a spill prevention meeting where any recent events are discussed, as well as the required training under this Stormwater Pollution Prevention Plan. Training records are maintained in employees’ personnel files.


3.0 MONITORING AND REPORTING

The monitoring, inspection, testing and reporting activities conducted per the 2015 MSGP are summarized in Table 3-1, and further described in the following sections.

Table 3-1 Monitoring and Reporting Schedule

Frequency Activity (to be conducted by a member of the

Stormwater Pollution Prevention Team) Section of

Plan Records Location

One-Time Evaluation for Unauthorized Non-Stormwater Discharges

3.1 Appendix I

One-Time Submit Notice of Intent (electronic) 3.2 Appendix B

Monthly

Facility Inspections (to be kept on file) At least once per year, inspection must be conducted while a discharge is occurring Prepare any required SWPPP update within 45 days of each December inspection – see Section 1.2.

3.3 Appendix D

Quarterly

Stormwater discharge sampling from Outfall 002 during a qualifying storm event or snowmelt discharge. The storm event must have occurred at least 72 hours (3 days) since the previous discharge. Collect grab samples during the first 30 mins. of the storm event if possible. At least one quarterly sample must capture snowmelt discharge. Conduct: 1. Visual Assessment (to be kept on file) 2. Benchmark Monitoring for Total Iron

(1.0 mg/L benchmark). Submit report to EPA (electronic) within 30 days after receiving lab results.

Benchmark monitoring may be discontinued after 4 quarters, depending on results

3.4 Appendix E

Appendix F

Annual

Impaired Waters Monitoring for pH, during a qualifying storm event or snowmelt discharge. Submit report to EPA (electronic) within 30 days after receiving lab results. The storm event must have occurred at least 72 hours (3 days) since the previous discharge. Collect grab samples during the first 30 mins. of the storm event if possible.

3.5 Appendix F

Annual Submit Summary Report to EPA (electronic) by Jan. 30 (starting 2017)

3.6 Appendix G


3.1 Evaluation for Unauthorized Non-Stormwater Discharges

On August 14, 2015, an evaluation for unauthorized non-stormwater discharges was conducted by Bryan Coutu, Plant Manager. This evaluation was conducted during dry weather conditions while the electric generation process was in operation. The areas shown on the non-stormwater inspection form (Appendix I) were visually inspected.

This evaluation did not observe any non-stormwater discharges to be occurring, therefore no additional actions were deemed necessary as a result of the inspection. This concurs with the facility’s operating experience and engineering judgment, which is that no non-stormwater discharges are feasible during normal operations, other than those specifically permitted under the 2015 MSGP (listed in Section 2.2 of this Plan).

3.2 Notice of Intent

A Notice of Intent for the 2015 MSGP is being submitted per EPA’s instructions using EPA’s electronic NPDES eReporting tool (NeT). A copy of the NOI, EPA’s acknowledgment letter and any other correspondence will be kept on file with Appendix B of this Plan.

3.3 Monthly Facility Inspections

Facility inspections must be conducted at least once each calendar month, during normal operating hours4. At least once each calendar year, the inspection must be conducted during a period when a stormwater discharge is occurring. Inspections must be performed by a member of the stormwater pollution prevention team.

A site-specific inspection form is provided in Appendix D of this Plan, which lists the facility’s stormwater control measures, activities that may be exposed to stormwater and other information required by the 2015 MSGP. The form will be completed by the inspector and completed forms will also be stored in Appendix D of this Plan. Any corrective action required as a result of a monthly facility inspection must be performed consistent with Section 3.8 of this Plan.

In general, the inspector must examine or look out for the following:

Industrial materials, residue or trash that may have or could come into contact with stormwater;

Leaks or spills from industrial equipment, drums, tanks and other containers; Offsite tracking of industrial or waste materials, or sediment where vehicles enter or

exit the site; Tracking or blowing of raw, final or waste materials from areas of no exposure to

exposed areas;

4 Although routine facility inspections are generally performed quarterly under the 2015 MSGP,

Industrial Sector O (Steam Electric Generation) specifically requires a monthly inspection.


Control measures needing replacement, maintenance or repair; Loading or unloading areas, switchyards, fueling areas, bulk storage areas, ash

handling areas, areas adjacent to disposal ponds and landfills, maintenance areas, liquid storage tanks, and long term and short term material storage areas.

Inspectors must also consider the results of visual and analytical monitoring (if any) for the past year when planning and conducting inspections.

3.4 Quarterly Stormwater Sampling

Once per quarter, a stormwater discharge sample will be collected from Outfall 002 in order to conduct the visual inspections (Section 3.4.1) and benchmark monitoring (Section 3.4.2) required under the 2015 MSGP. Sampling requirements begin in the first full quarter following either September 2, 2015 or the date of discharge authorization, whichever date comes later. These samples must be collected in such a manner that the samples are representative of the stormwater discharge. At the facility’s discretion, additional samples may be taken during separate runoff events and used to determine the average benchmark parameter concentration for facility discharges.

All required monitoring must be performed on a storm event that results in an actual discharge (“measurable storm event”) that follows the preceding measurable storm event by at least 72 hours (three days). The 72-hour (3-day) storm interval does not apply if the facility is able to document that less than a 72-hour (3-day) interval is representative for local storm events during the sampling period. In the case of snowmelt, the monitoring must be performed at a time when a measurable discharge occurs.

For each monitoring event, except snowmelt monitoring, the facility must identify the date and duration (in hours) of the rainfall event, rainfall total (in inches) for that rainfall event, and time (in days) since the previous measurable storm event. For snowmelt monitoring, the facility must identify the date of the sampling event.

Exceptions to quarterly sampling are shown below. The required total number of samples must still be collected. The facility must also report a “no data” or “NODI” code within EPA’s electronic NetDMR system for any of the regular reporting periods that there was no monitoring.

Adverse Weather Conditions: When adverse weather conditions prevent the collection of samples during the quarter, the facility must take a substitute sample during the next qualifying storm event. Documentation of the rationale for no visual assessment for the quarter must be included with the SWPPP records. Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local flooding, high winds, electrical storms, or situations that otherwise make sampling impractical, such as extended frozen conditions.


Climates with Irregular Stormwater Runoff: If freezing conditions exist that prevent runoff from occurring for extended periods, then samples for the quarterly visual assessments may be distributed during seasons when precipitation runoff occurs.

Areas Subject to Snow: In areas subject to snow, at least one quarterly visual assessment must capture snowmelt discharge, taking into account the exception described above for climates with irregular stormwater runoff.

3.4.1 Quarterly Visual Inspections

The visual assessment must be made of a sample in a clean, colorless glass or plastic container, and examined in a well-lit area. The inspector must visually inspect or observe the sample for the following water quality characteristics:

Color Odor Clarity (diminished) Floating solids Settled solids Suspended solids Foam Oil sheen; and Other obvious indicators of stormwater pollution.

The results of the visual assessments will be documented in Appendix E of this Plan. A blank form is also provided in Appendix E.

The visual assessment findings are not submitted to EPA, unless specifically requested to do so. However, the findings are summarized in the annual report (see Section 3.6). Whenever the visual assessment shows evidence of stormwater pollution, corrective action procedures are initiated as described in Section 3.8 of this Plan.

3.4.2 Benchmark Monitoring

Industrial Sector O of the 2015 MSGP specifies a benchmark of 1.0 mg/L of total iron for the facility’s stormwater discharges at Outfall 002. Benchmark monitoring must be conducted quarterly for the first four full quarters of permit coverage, commencing no earlier than September 2, 2015, in order to determine the overall effectiveness of control measures. The benchmark concentrations are not effluent limitations; a benchmark exceedance, therefore, is not a permit violation. However, if corrective action is required as a result of a benchmark exceedance, failure to conduct required corrective action is a permit violation. Results must be submitted to EPA within 30 days using EPA’s electronic NetDMR system. Benchmark monitoring records will also be stored in Appendix F of this SWPPP.


40 CFR 136 indicates that any of the following test methods may be used to test for Total Iron levels:

EPA Test Method 200.5, 200.7, 200.8, or 200.9 Standard Test Method 3111 B-1999, 3111 C-1999, 3113 B-2004, 3120 B-1999,

3125 B-2009 or 3500-Fe-1997 ASTM Method D1068-05 (A or B), D1068-05 (C), D1976-07, D5673-05, D4190-08

or D1068-05 (D) AOAC Method 993.14 or 974.27 USGS Method I-3381-85 Method 8008, 1,10-Phenanthroline Method using FerroVer Iron Reagent for Water.

1980. Hach Company. Method AES0029, Direct Current Plasma (DCP) Optical Emission Spectrometric

Method for Trace Elemental Analysis of Water and Wastes. 1986-Revised 1991. Thermo Jarrell Ash Corporation.

Open File Report 98-165, Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory

After collection of four quarterly samples, if the average of the four monitoring values for any parameter does not exceed the benchmark, the facility has fulfilled the monitoring requirements for that parameter for the permit term. After collection of four quarterly samples, if the average of the four monitoring values exceeds the benchmark, the facility must, in accordance with Section 3.8 of this Plan, review the selection, design, installation, and implementation of the control measures to determine if modifications are necessary to meet the effluent limits in this permit, and either:

Make the necessary modifications and continue quarterly monitoring until the facility has completed four additional quarters of monitoring for which the average does not exceed the benchmark; or

Make a determination that no further pollutant reductions are technologically available and economically practicable and achievable in light of best industry practice, in which case the facility must continue monitoring once per year. The facility must also document the rationale for concluding that no further pollutant reductions are achievable, and retain all records related to this documentation with the SWPPP.

If an exceedance of the four quarter average is mathematically certain, review the control measures and perform any required corrective action immediately (or document why no corrective action is required), per Section 3.8 of this Plan, without waiting for the full four quarters of monitoring data,. If after modifying the control measures and conducting four additional quarters of monitoring, the average still exceeds the benchmark (or if an


exceedance of the benchmark by the four quarter average is mathematically certain prior to conducting the full four additional quarters of monitoring), the facility must again review the control measures and take one of the actions above.

Natural background pollutant levels: If it is determined that exceedance of the benchmark is attributable solely to the presence of that pollutant in the natural background, the facility is not required to perform corrective action or additional benchmark monitoring provided that:

The average concentration of the benchmark monitoring results is less than or equal to the concentration of that pollutant in the natural background; and

The facility documents and maintains with this SWPPP, the supporting rationale for concluding that benchmark exceedances are in fact attributable solely to natural background pollutant levels. The facility must include in the supporting rationale any data previously collected (including literature studies) that describe the levels of natural background pollutants in the stormwater discharge.

Natural background pollutants are those substances that are naturally occurring in soils or ground water. Natural background pollutants do not include legacy pollutants from earlier activity on site, or pollutants in run-on from neighboring sources which are not naturally occurring, such as other industrial sites or roadways. However, the EPA Regional Office may determine that the facility is eligible to discontinue monitoring for pollutants that occur solely from run-on sources.

Blank forms to document general corrective actions, corrective maintenance and benchmark monitoring exceedances are provided in Appendix J of this Plan.

3.5 Annual Impaired Waters Monitoring

The portion of the Smith River to which the facility discharges is designated by EPA as Impaired for the following parameters:

Table 3-2 Receiving Water Impairment

Parameter Total Maximum Daily Load (TMDL)

Mercury 0.3 ppm in fish tissue (outfall monitoring not required)

pH No TMDL established (outfall monitoring required annually)


EPA’s reference for this water body is available at: http://ofmpub.epa.gov/tmdl_waters10/attains_waterbody.control?p_list_id=NHRIV700010702-22&p_cycle=2010

The facility must monitor all pollutants for which the waterbody is impaired and for which a standard analytical method exists (see 40 CFR Part 136) once per year at Outfall 002 discharging stormwater to impaired waters without an EPA-approved or established TMDL. Discharges to impaired waters with an EPA-approved or established TMDL are not required unless specifically required by EPA.

Therefore, beginning in the first full quarter following September 2, 2015 or the date of discharge authorization, whichever date comes later, the facility must monitor pH levels at Outfall 002 once per year (mercury monitoring is not required.)

Results must be submitted to EPA within 30 days using EPA’s electronic NetDMR system. Impaired waters monitoring records will also be stored in Appendix F of this SWPPP. As with the quarterly sampling described in Section 3.4, monitoring must be performed on a storm event that results in an actual discharge (“measurable storm event”) that follows the preceding measurable storm event by at least 72 hours (three days). The 72-hour (3-day) storm interval does not apply if the facility is able to document that less than a 72-hour (3-day) interval is representative for local storm events during the sampling period. In the case of snowmelt, the monitoring must be performed at a time when a measurable discharge occurs.

40 CFR 136 indicates that any of the following test methods may be used to test for pH levels:

EPA Test Method 150.2 Standard Test Method 4500-H+ B-2000 ASTM Method D1293-99 (A or B) AOAC Test Method 973.41 USGS Test Method I-1586-85 or I-2587-85 Industrial Method Number 378-75WA, Hydrogen ion (pH) Automated Electrode

Method, Bran & Luebbe (Technicon) Autoanalyzer II

3.6 Annual Summary Report

Submit an Annual Report to EPA by January 30th for each year of permit coverage (starting Jan. 30, 2017) containing information generated from the past calendar year, using EPA’s electronic NPDES eReporting tool (NeT). Include the following information:

A summary of the past year’s monthly facility inspection documentation; A summary of the past year’s quarterly visual assessment documentation;


For any four-sample (minimum) average benchmark monitoring exceedance, if after reviewing the selection, design, installation, and implementation of control measures and considering whether any modifications are necessary to meet the effluent limits in the permit, the facility determines that no further pollutant reductions are technologically available and economically practicable and achievable in light of best industry practice, the rationale for why the facility believes no further reductions are achievable;

A summary of the past year’s corrective action documentation (see Section 3.8 of this Plan). If corrective action is not yet completed at the time of submission of the annual report, the facility must describe the status of any outstanding corrective action(s). Also describe any incidents of noncompliance in the past year or currently ongoing, or if none, provide a statement that the facility is in compliance with the permit;

A signed certification statement.

3.7 Previous Sampling Data

The most recent prior sampling results under the 2008 MSGP are shown in Table 3-3, which demonstrates that the facility discharge was consistently below the Total Iron benchmark (1.0 mg/L) and the discharge pH was not significantly different than the rain water (which was tested for comparison as a best management practice); therefore the 2008 MSGP did not indicate a condition of pollution at the facility. Furthermore, the wood ash analysis presented in Appendix C indicates that the wood fuel stored and used at the facility does not contain pollutants in any significant levels and should have essentially the same characteristics as the wooded environment.

Table 3-3 Previous Sampling Data

Date:

Rain Water

pH Outfall

pH

Outfall Iron mg/L

Snow Melt Y/N

2/24/2015 6.89 6.9 0.32 Y5/26/2015 6.76 6.79 0.52 N7/1/2015 6.83 6.88 0.57 N

7/14/2015 6.45 6.78 0.38 N

3.8 Corrective Actions

Corrective action requirements are provided in Part 4 of the 2015 MSGP and are summarized below. Any corrective action-related documentation will be stored in Appendix J of this SWPPP. Blank forms to document general corrective actions, corrective maintenance activities and benchmark monitoring exceedances are also provided in Appendix J.


3.8.1 SWPPP Review and Revision Requirements

When any of the following conditions occur or are detected during an inspection, monitoring or other means, or EPA informs the facility that any of the following conditions have occurred, this SWPPP will be reviewed and revised, as appropriate, (e.g., sources of pollution; spill and leak procedures; non-stormwater discharges; the selection, design, installation and implementation of control measures) so that the effluent limits are met and pollutant discharges are minimized:

An unauthorized release or discharge (e.g., spill, leak, or discharge of non-stormwater not authorized by this permit to a water of the U.S.) occurs at the facility.

The facility’s control measures are not stringent enough for the discharge to meet applicable water quality standards or the non-numeric effluent limits in the MSGP.

A required control measure was never installed, was installed incorrectly, or not in accordance with the MSGP, or is not being properly operated or maintained.

Whenever a visual assessment shows evidence of stormwater pollution (e.g., color, odor, floating solids, settled solids, suspended solids, foam).

Construction or a change in design, operation, or maintenance at the facility that significantly changes the nature of pollutants discharged in stormwater from the facility, or significantly increases the quantity of pollutants discharged.

The average of four quarterly sampling results (see Section 3.4) exceeds an applicable benchmark. If less than four benchmark samples have been taken, but the results are such that an exceedance of the four quarter average is mathematically certain (i.e., if the sum of quarterly sample results to date is more than four times the benchmark level) this is considered a benchmark exceedance, triggering this review.

Note: A benchmark exceedance does not trigger a corrective action if the facility determines that the exceedance is solely attributable to natural background sources, or makes a finding that no further pollutant reductions are technologically available and economically practicable and achievable in light of best industry practice (see Section 3.4).

When run-on to the facility causes a benchmark exceedance, in addition to reviewing and revising, as appropriate, the SWPPP, the facility should notify the other operators contributing run-on to the facility’s discharges to abate their pollutant contribution. Where the other operators fail to take action to address the stormwater run-on, the EPA Regional Office should be contacted.

3.8.2 Corrective Actions and Deadlines

Immediate Actions


If corrective action is needed, the facility must immediately take all reasonable steps necessary to minimize or prevent the discharge of pollutants until a permanent solution is installed and made operational, including cleaning up any contaminated surfaces so that the material will not discharge in subsequent storm events.

Note: In this context, the term “immediately” requires the facility to, on the same day a condition requiring corrective action is found, take all reasonable steps to minimize or prevent the discharge of pollutants until a permanent solution is installed and made operational. However, if a problem is identified at a time in the work day when it is too late to initiate corrective action, the initiation of corrective action must begin no later than the following work day. “All reasonable steps” means that the facility has undertaken initial actions to assess and address the condition causing the corrective action, including, for example, cleaning up any exposed materials that may be discharged in a storm event (e.g., through sweeping, vacuuming) or making arrangements (i.e., scheduling) for a new BMP to be installed at a later date. If it is concluded that a corrective action is, in fact, not necessary, this will be documented in the SWPPP.

Subsequent Actions If the facility determines that additional actions are necessary beyond the Immediate Actions above, the facility must complete the corrective actions (e.g., install a new or modified control and make it operational, complete the repair) before the next storm event if possible, and within 14 calendar days from the time of discovery of the corrective action condition. If it is infeasible to complete the corrective action within 14 calendar days, the facility must document why it is infeasible to complete the corrective action within the 14-day timeframe. The facility must also identify the schedule for completing the work, which must be done as soon as practicable after the 14-day timeframe but no longer than 45 days after discovery. If the completion of corrective action will exceed the 45 day timeframe, the facility may take the minimum additional time necessary to complete the corrective action, provided that the facility notifies the EPA Regional Office of the intention to exceed 45 days, the rationale for an extension, and a completion date, which must also be included in the corrective action documentation. Where corrective actions result in changes to any of the controls or procedures documented in the SWPPP, the SWPPP must be modified accordingly within 14 calendar days of completing corrective action work.

Corrective Action Documentation The facility must document the existence of any of the Immediate or Subsequent conditions listed above within 24 hours of becoming aware of such condition. The facility is not required to submit the corrective action documentation to EPA, unless specifically requested to do so. However, the findings must be summarized in the annual report to EPA (section 3.6 of this Plan). The following information must be included in the documentation:


Description of the condition triggering the need for corrective action review. For any spills or leaks, include the following information: a description of the incident including material, date/time, amount, location, and reason for spill, and any leaks, spills or other releases that resulted in discharges of pollutants to waters of U.S., through stormwater or otherwise;

Date the condition was identified; Description of immediate actions taken (see above) to minimize or prevent the

discharge of pollutants. For any spills or leaks, include response actions, the date/time clean-up completed, notifications made, and staff involved. Also include any measures taken to prevent the reoccurrence of such releases

A statement, signed and certified in accordance with Appendix B, Subsection 11 of the MSGP.

The facility must also document the corrective actions taken or to be taken as a result of the conditions requiring SWPPP review and revision (see Section 3.8.1 of this Plan) (or, for triggering events where it is determined that corrective action is not necessary, the basis for this determination) within 14 days from the time of discovery of any of those conditions. The facility must provide the dates when each corrective action was initiated and completed (or is expected to be completed). If applicable, document why it is infeasible to complete the necessary installations or repairs within the 14-day timeframe and document the schedule for installing the controls and making them operational as soon as practicable after the 14-day timeframe. If the facility notified EPA regarding an extension of the 45 day timeframe, the facility must document the rationale for an extension.

Appendix A

Site Map

SM

ITH

RIV

ER

RO

AD

STORMWATER

RETENTIONPOND

RIVER WATERWITHDRAWAL

STATION

STACK

PARKING

PA

RK

ING

WASTEWATERPOND

(LINED)

LOW LEVEL WASTE POND (LINED) –TO COOLING TOWERS

PUMPHOUSE

WOOD CHIP PILES (LOCATION VARIES)

WOOD CHIPPROCESS

AREA(COVERED)

TRANSFORMERS(BERMED)

ENTRYGATE

DRUM STORAGE SHED (NEW AND WASTE MATERIALS)

STANDBYGENERATOR

TRUCKSCALE

STEAMTURBINE

(2ND FLOOR)

BOILER

BARN

OFFICE

PROPERTY LINE (27 ACRE PROPERTY)

FENCE LINE

INDOOR/BUILDING AREA(NOT EXPOSED TO PRECIPITATION)

PROPANE GAS TANK

STORMWATER CONVEYANCE

COVERED SAND/SALT

STORAGE TENT

STORMWATER MONITORING POINTCULVERT TO SMITH RIVER“OUTFALL #002”

TRENCH

TRE

NC

H

TRE

NC

H

TRUCKDUMPER

TRUCKDUMPER

RA

MP

TRENCH

BOUNDARY OF IMPERVIOUS ROAD

LOADING/UNLOADING AREA

CO

NV

EY

OR

CONVEYOR

WOOD CHIPTRANSFER

AREA

SMITH RIVER IS DESIGNATED AS EPA IMPAIRED WATER FOR:- MERCURY (TMDL = 0.3 ppm in Fish Tissue)- pH (No TMDL Established)

NH3

H2SO4

FLYASH

BOTTOMASH

PIP

E

PIPE

PIP

E

FIREPUMP

UNPAVED ROAD

COVERED VEHICLE REFUELING AREA (DIESEL TANK)

0 25 50 100

SCALE (FT.)

WHOLE LOG STORAGE PILES (LOCATION VARIES)LUBE

OIL TANK

ASHYARD

Smith River Rd

Borough Rd

Ragged Mtn Hwy

Private

Stoney Ln

Solar Acres Rd.

Crouse Lyle Av Priva

te

Aerial Locus MapIndeck Energy Alexandria, NH

G:\Projects2\NH\2688\2688_Quad_Map.mxd

Smith River

LEGEND

River

Basemap: 2003 Orthophotography, NH GRANIT

Scale 1:24,0001 inch = 2,000 feet °0 1,000 2,000500Feet

Project Site

Smith River Rd

Borough Rd

Ragged Mtn Hwy

Private

Stoney Ln

Solar Acres Rd.

Crouse Lyle Av Priva

te

USGS Quad Locus MapIndeck Energy Alexandria, NH

G:\Projects2\NH\2688\2688_Quad_Map.mxd

Smith River

LEGEND

River

Basemap: USGS Quadrangles, NH GRANIT

Scale 1:24,0001 inch = 2,000 feet °0 1,000 2,000500Feet

Project Site

Appendix B

Notice of Intent and Acknowledgement

Appendix C

Wood Ash Analysis

Wood Ash Metals Indeck Energy - Alexandria NH LLC - Wood Ash

Date Arsenic Cadmium Chromium Copper Lead Mercury Molybdenum Nickel Selenium Vanadium Zinc01/08/09 4.1 15.2 19 82 81 0.04 5.8 16 4.00 13 51601/21/09 5.0 13.7 16 106 88 0.04 2.9 16 4.10 11 97402/02/09 6.4 13.4 17 100 88 0.04 2.7 17 4.60 13 91002/02/09 5.7 13.2 18 99 85 0.04 3.5 17 4.10 13 84202/02/09 5.1 9.5 13 77 67 0.03 4.7 14 4.50 8 72303/16/09 3.7 N N N 51 N N N N N N04/15/09 1.9 N N N 49 N N N N N N04/16/09 4.1 14.1 12 169 64 0.04 4.3 16 4.70 8 102905/07/09 2.0 N N N 36 N N N N N N

Average 4.2 13.2 16 106 68 0.04 4.0 16 4.33 11 832

Low 1.9 9.5 12 77 36 0.03 2.7 14 4.00 8 516

High 6.4 15.2 19 169 88 0.04 5.8 17 4.70 13 1029

NH Standards 41.0 39.0 1200 1500 300 17.00 75.0 420 100.00 NS 2800

* All values appear as mg/kg on a dry weight basis unless otherwise indicated.N = Not Tested; NS = No Standard

Date Sample No. Lab Name Location1/8/2009 WMR342809-01 Maine Environmental Laboratory Yarmouth, ME

1/21/2009 WMR345109-01 Maine Environmental Laboratory Yarmouth, ME

2/2/2009 WMR345609-01 Maine Environmental Laboratory Yarmouth, ME2/2/2009 WMR345609-02 Maine Environmental Laboratory Yarmouth, ME2/2/2009 WMR345609-03 Maine Environmental Laboratory Yarmouth, ME3/16/2009 WMR347309-01 Maine Environmental Laboratory Yarmouth, ME4/15/2009 WMR349509-01 Maine Environmental Laboratory Yarmouth, ME4/16/2009 WMR349709-01 Maine Environmental Laboratory Yarmouth, ME5/7/2009 WMR352209-01 Maine Environmental Laboratory Yarmouth, ME

Indeck Energy, Alexandria Testing Results June 2, 2009

Wood Ash Nutrients Indeck Energy - Alexandria NH LLC - Wood AshDate Calcium Magnesium Phosphorus Available K % CaCO3 % LOI % Solids pH Boron Zinc Ammonia-N Nitrate/Nitrit TKN

01/08/09 126145 11110 9000 24800 44.80 22.63 48.36 12.45 72 516 N N N01/21/09 147344 13740 13120 N 50.40 25.80 52.96 12.36 40 974 N N N02/02/09 157104 13780 10740 45600 54.40 27.83 52.64 12.45 28 910 N N N02/02/09 150179 13149 10110 52700 51.60 28.92 47.47 12.45 63 842 N N N02/02/09 117630 11337 8150 43100 37.50 47.69 32.50 12.42 24 723 N N N03/16/09 N N N N N N 46.13 N N N 5000 209 740004/15/09 N N N N N N 47.14 N N N 9400 173 1100004/16/09 172976 14587 14160 65200 35.90 37.59 44.48 12.33 24 1029 N 190 N05/07/09 N N N N N N 50.39 N N N 2100 113 1900

Average 145230 12951 10880 46280 45.77 31.74 46.90 12.41 42 832 5500.00 171.25 6766.67Low 117630 11110 8150 24800 35.90 22.63 32.50 12.33 24 516 2100.00 113.00 1900.00High 172976 14587 14160 65200 54.40 47.69 52.96 12.45 72 1029 9400.00 209.00 11000.00

* All values appear as mg/kg on a dry weight basis unless otherwise indicated.N = Not Tested; NS = No Standard

Date Sample No. Lab Name Location1/8/2009 WMR342809-01 Maine Environmental Laboratory Yarmouth, ME1/21/2009 WMR345109-01 Maine Environmental Laboratory Yarmouth, ME2/2/2009 WMR345609-01 Maine Environmental Laboratory Yarmouth, ME2/2/2009 WMR345609-02 Maine Environmental Laboratory Yarmouth, ME2/2/2009 WMR345609-03 Maine Environmental Laboratory Yarmouth, ME3/16/2009 WMR347309-01 Maine Environmental Laboratory Yarmouth, ME4/15/2009 WMR349509-01 Maine Environmental Laboratory Yarmouth, ME4/16/2009 WMR349709-01 Maine Environmental Laboratory Yarmouth, ME5/7/2009 WMR352209-01 Maine Environmental Laboratory Yarmouth, ME


Wood Ash Metals Indeck Energy - Alexandria NH LLC - Bottom AshDate Arsenic Cadmium Chromium Copper Lead Mercury Molybdenum Nickel Selenium Zinc

02/02/09 1.5 1.8 39 35 14 0.03 10.1 15 0.70 7802/02/09 2.4 0.3 200 88 5 0.02 3.1 884 0.50 4904/08/09 3.0 21.5 17 97 91 0.04 1.5 17 3.60 67004/15/09 2.2 1.5 19 79 24 0.03 1.4 19 1.90 88Average 2.3 6.3 69 75 34 0.03 4.0 234 1.68 221

Low 1.5 0.3 17 35 5 0.02 1.4 15 0.50 49

High 3.0 21.5 200 97 91 0.04 10.1 884 3.60 670

NH 41 39 NS 1500 300 17 75 420 100 2800* All values appear as mg/kg on a dry weight basis unless otherwise indicated.N = Not Tested; NS = No Standard

Date Sample No. Lab Name Location2/2/2009 WMR345709-01 Maine Environmental Laboratory Yarmouth, ME2/2/2009 WMR3457.2 Maine Environmental Laboratory Yarmouth, ME4/8/2009 WMR348309-01 Maine Environmental Laboratory Yarmouth, ME4/15/2009 WMR350309-01 Maine Environmental Laboratory Yarmouth, ME


Appendix D

Monthly Facility Inspection Forms

Indeck Energy – Alexandria, LLC

Stormwater Industrial Facility Inspection Report General Information

Facility Name Indeck Energy – Alexandria, LLC

NPDES Tracking No.

Date of Inspection Start/End Time

Inspector’s Name(s)

Inspector’s Title(s)

Inspector’s Contact Information

Inspector’s Qualifications

Weather Information

Weather at time of this inspection? Clear Cloudy Rain Sleet Fog Snow High Winds Other: Temperature: Have any previously unidentified discharges of pollutants occurred since the last inspection? Yes No If yes, describe: Are there any discharges occurring at the time of inspection? Yes No If yes, describe: Identify if maintenance or corrective action is needed. If so, refer to Section 3.8 of the SWPPP and the

recordkeeping forms provided in Appendix J.

Structural Control Measure

Control Measure is Operating Effectively?

If No, In Need of Maintenance, Repair, or Replacement?

Maintenance or Corrective Action Needed and Notes

1 Trench/piping to Outfall 002

Yes No Maintenance Repair Replacement

2 Outfall 002 Yes No Maintenance Repair Replacement

3 Perimeter trenches/ piping to retention pond (incl. fabric filters)


4 Stormwater retention pond (also ensure proper drainage is occurring)


5 Low level waste pond Yes No Maintenance Repair Replacement

6 Waste water pond Yes No Maintenance Repair Replacement

7 Transformer Berms Yes No Maintenance Repair Replacement

8 Outdoor salt/sand enclosure



Structural Control Measure

Control Measure is Operating Effectively?

If No, In Need of Maintenance, Repair, or Replacement?


9 Outdoor drum storage enclosure


10 Outdoor vehicle refueling tank enclosure


Areas of Industrial Materials or Activities Exposed to Stormwater Identify if maintenance or corrective action is needed. If so, refer to Section 3.8 of the SWPPP and the

recordkeeping forms provided in Appendix J.

Area/Activity Inspected? Controls Adequate (appropriate, effective and operating)?


1 Wood chip storage areas Yes No N/A

Yes No

2 Wood chip conveyors and processing areas

Yes No N/A

Yes No

3 Truck dumpers / hydraulic tanks

Yes No N/A

Yes No

4 Whole log storage areas

Yes No N/A

Yes No

5 Drum delivery/pickup areas

Yes No N/A

Yes No

6 Vehicle refueling area / access road

Yes No N/A

Yes No

7 Outdoor vehicle and equipment washing areas

Yes No N/A

Yes No

8 Ash waste pickup area Yes No N/A

Yes No

9 Water treatment chemical delivery area

Yes No N/A

Yes No

10 Fire pump fuel and lube oil delivery areas

Yes No N/A

Yes No

11 Standby generator fuel delivery area

Yes No N/A

Yes No

12 Misc. outdoor trash collection (bins are shut)

Yes No N/A

Yes No

13 River water withdrawal station

Yes No N/A

Yes No

14 Ash Yard (incl. fabric filters)

Yes No N/A

Yes No

15 Misc. other storage, erodible or construction areas

Yes No N/A

Yes No


Area/Activity Inspected? Controls Adequate (appropriate, effective and operating)?


16 Misc. dust generation and vehicle tracking

Yes No N/A

Yes No

17 Areas where spills or leaks have occurred in past 3 years (if any)

Yes No N/A

Yes No

Discharge Points At discharge points, describe any evidence of, or the potential for, pollutants entering the drainage system. Also describe observations regarding the physical condition of and around all outfalls, including any flow dissipation devices, and evidence of pollutants in discharges and/or the receiving water. Identify if any corrective action is needed.

Non-Compliance Describe any incidents of non-compliance observed and not described above:

Additional Control Measures Describe any additional control measures needed to comply with the permit requirements:


Notes

Use this space for any additional notes or observations from the inspection:

CERTIFICATION STATEMENT

“I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.” Print name and title: __________________________________________________________________ Signature: _________________________________________________Date:_____________________

Appendix E

Quarterly Visual Sample Inspection Forms

MSGP Quarterly Visual Assessment Form (Complete a separate form for each outfall you assess)

Name of Facility: Indeck Energy – Alexandria, LLC NPDES Tracking No.

Outfall Name: "Substantially Identical Discharge Point"?

Yes (identify substantially identical outfalls): No

Person(s)/Title(s) collecting sample:

Person(s)/Title(s) examining sample:

Date & Time Discharge Began:

Date & Time Sample Collected: If sample not taken within first 30 minutes, explain why.

Date & Time Sample Examined:

Substitute Sample? No Yes (identify quarter/year when sample was originally scheduled to be collected):

Nature of Discharge: Rainfall Snowmelt

If rainfall: Rainfall Amount: No of inches_ Previous Storm Ended > 72 hours Before Start of This Storm?

Yes No* (explain):

Pollutants Observed

Color None Other (describe): ______________________

Odor None Musty Sewage Sulfur Sour Petroleum/Gas Solvents Other (describe): ______________________

Clarity Clear Slightly Cloudy Cloudy Opaque Other

Floating Solids No Yes (describe): ______________________

Settled Solids** No Yes (describe): ______________________

Suspended Solids No Yes (describe): ______________________

Foam (gently shake sample) No Yes (describe): ______________________

Oil Sheen None Flecks Globs Sheen Slick Other (describe): ______________________

Other Obvious Indicators of Stormwater Pollution

No Yes (describe): ______________________

* The 72-hour interval can be waived when the previous storm did not yield a measurable discharge or if you are able to document (attach applicable documentation) that less than a 72-hour interval is representative of local storm events during the sampling period.

** Observe for settled solids after allowing the sample to sit for approximately one-half hour.

Identify probably sources of any observed stormwater contamination. Also, include any additional comments, descriptions of pictures taken, and any corrective actions necessary below (attach additional sheets as necessary).

Certification Statement (Refer to MSGP Subpart 11 Appendix B for Signatory Requirements)

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

A. Name: B. Title:

C. Signature: D. Date Signed:

Appendix F

Benchmark Monitoring Results / Impaired Waters Monitoring Results

Appendix G

Annual Summary Reports

Appendix H

Endangered Species Notifications

1

Fefer, Daniel

From: Neely, Bryan <[email protected]>Sent: Monday, August 10, 2015 12:09 PMTo: [email protected]; Fefer, DanielCc: [email protected]: Proceed with 2015 MSGP Notice of Intent Submittal, Indeck Energy - Alexandria, LLC,

NH

This email is in response to the Criterion C Eligibility Form (Form) submitted to U.S. EPA as part of the industrial stormwater Multi‐Sector General Permit (MSGP) requirements. EPA has determined that because there are no discharge‐related activities planned for your facility, the northern long‐eared bat is not within your facility’s action area. Therefore, your facility is eligible for coverage under MSGP Criterion A (no listed species in the action area), and you may proceed with submitting your Notice of Intent (NOI) form for MSGP coverage under Criterion A. Bryan Neely | Senior Environmental Scientist Direct: 720.881.5844 | Main: 303.217.5700 | Fax: 303.217.5705 [email protected] Tetra Tech │Complex World, Clear Solutions™ 350 Indiana Street, Suite 500 | Golden, CO 80401 | www.ttwater.com PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system.

1

Fefer, Daniel

From: Fefer, DanielSent: Tuesday, August 04, 2015 10:08 PMTo: '[email protected]'Cc: Bryan Coutu ([email protected]); [email protected]: Criterion C Eligibility Form: Indeck Energy - Alexandria LLCAttachments: Criterion C Eligibility Form.pdf; SpeciesList.pdf

Dear U.S. EPA, On behalf of Indeck Energy – Alexandria, LLC, please find attached the facility’s completed Criterion C Eligibility Form as required under the 2015 MSGP. As stated therein, no adverse impacts to threatened species are likely. The Official Species List provided by the U.S. Fish and Wildlife Service is also attached for reference. Sincerely, Daniel Fefer Senior Scientist Epsilon Associates, Inc. 3 Clock Tower Place, Suite 250 Maynard, Massachusetts 01754 Cell: 617.905.6602 [email protected] https://twitter.com/EpsilonAssoc www.epsilonassociates.com

Criterion C Eligibility Form Instructions:

In order to be eligible for coverage under criterion C, you must complete the following form and you must submit it to EPA following the instructions in Section VII a minimum of 30 days prior to filing your NOI for permit coverage. After you submit your form, you may be contacted by EPA with additional measures (e.g., additional stormwater controls or modifications to your discharge-related activities) that you must implement in order to ensure your eligibility under criterion C.

If after completing this worksheet you cannot make a determination that your discharges and discharge-related activities are not likely to adversely affect listed threatened or endangered species or designated critical habitat, you must submit this completed worksheet to EPA, and you may not file your NOI for permit coverage until you receive a determination from EPA that your discharges and/or discharge-related activities are not likely to adversely affect listed species and critical habitat.

Note: Much of the information needed for this form can be obtained from your draft SWPPP which will be needed when you file your NOI.

SECTION I. OPERATOR, FACILITY, AND SITE LOCATION INFORMATION. 1) Operator Information

a) Operator Name: _____________________________________________

b) Point of Contact

First Name: _________________________ Last Name: _________________________

Phone Number: ___________________________________

E-mail: ___________________________________________

2) Facility Information

a) Facility Name: _____________________________________________

b) Check which of the following applies:

I am seeking coverage under the MSGP as a new discharger or as a new source

I am seeking coverage under the MSGP as an existing discharger and my facility has modifications to its discharge characteristics (e.g., changes in discharge flow or area drained, different pollutants) and/or discharge-related activities (e.g., stormwater controls)

Indicate the number of years the facility has been in operation: _________ years

Provide your NPDES ID (i.e., permit tracking number) from your previous MSGP coverage: ________________

I am seeking coverage under the MSGP as an existing discharger and there are no modifications to my facility.

Indicate the number of year the facility has been in operation: _________ years

Provide your NPDES ID (i.e., permit tracking number) from your previous MSGP coverage: ________________

Criterion C Eligibility Form Page 1 of 11

c) Facility Address:

Address 1: ___________________________________________________________

Address 2: ___________________________________________________________

City: ________________________________ State: ________ Zip Code: ______________________

d) Identify the primary industrial sector to be covered under the 2015 MSGP:

SIC Code ______ or Primary Activity Code _____

Sector _______ and Subsector ________

e) Identify the sectors of any co-located activities to be covered under the 201r MSGP:

Sector _______ Subsector _______






f) Estimated area of industrial activity exposed to stormwater: __________________ acres

g) Provide a general description of the industrial activities that are taking place at thisfacility:

3) Receiving Waters Information

List all the stormwater outfalls from your facility. For each outfall, provide the following receiving water information:

Outfall ID Design Capacity (if known)

Latitude (decimal degrees)

Longitude (decimal degrees)

Name of the receiving water that receives stormwater from the outfall and/or from the MS4 that the outfall discharges to

Type of Waterbody (e.g., lake, pond, river/stream/creek, estuarine/marine water)

_ _ _ . _ _ _ _ _ _ _ . _ _ _ _

_ _ _ . _ _ _ _ _ _ _ . _ _ _ _

_ _ _ . _ _ _ _ _ _ _ . _ _ _ _

_ _ _ . _ _ _ _ _ _ _ . _ _ _ _

_ _ _ . _ _ _ _ _ _ _ . _ _ _ _


SECTION II. ACTION AREA Ensure that your action area is described in Attachment 1, as required in Step 2.

SECTION III. LISTED SPECIES AND CRITICAL HABITAT LIST Note: For the purposes of this permit, “terrestrial species” would not include animal or plant species that 1) spends any portion of its life cycle in a waterbody or wetland, or 2) if an animal, depends on prey or habitat that occurs in a waterbody or wetland. For example, shorebirds, wading birds, amphibians, and certain reptiles would not be considered terrestrial species under this definition. Please also be aware that some terrestrial animals (e.g., certain insects, amphibians) may have an aquatic egg or larval/juvenile phase.

Ensure that the listed species and critical habitat list is included in Attachment 2, as required in Step 3.

Review your species list in Attachment 2, choose one of the following three statements, and follow the corresponding instructions:

The species list includes only terrestrial species and/or their designated critical habitat. No aquatic or aquatic-dependent species or their critical habitat are present in the action area. You may skip to Section IV of this form. You are not required to fill out Section V.

The species list includes only aquatic and/or aquatic-dependent species and/or their designated critical habitat. No terrestrial species or their critical habitat are present in the action area. You may skip to Section V of this form and are not required to fill out Section IV.

The species list includes both terrestrial and aquatic or aquatic-dependent species and/or their designated critical habitat. You must fill out both Sections IV and V of this form.

SECTION IV. EVALUATION OF DISCHARGE-RELATED ACTIVITIES EFFECTS Note: You are only required to fill out this section if your facility’s action area contains terrestrial species and/or their designated critical habitat. If your action area only contains aquatic and/or aquatic-dependent species and/or their designated critical habitat, you can skip directly to Section V.

Most of the potential effects related to coverage under the MSGP are assumed to occur to aquatic and/or aquatic-dependent species. However, in some cases, potential effects to terrestrial species and/or their critical habitat should be considered as well from any discharge-related activities that occur during coverage under the MSGP. Examples of discharge-related activities that could have potential effects on listed terrestrial species or their critical habitat include the storage of materials and land disturbances associated with stormwater management-related activities (e.g., the installation or placement of stormwater control measures).

A. Select the applicable statement(s) below and follow the corresponding instructions:

There are no discharge-related activities that are planned to occur during my coverage under the MSGP. You can conclude that your discharge-related activities will have no likely adverse effects, and:

- If there are any aquatic or aquatic-dependent species and/or their critical habitat in your action area, you must skip to Section V, Evaluation of Discharge Effects, below.

- If there are no aquatic or aquatic-dependent species you may skip to Section VI and verify that your activities will have no likely adverse effects. You must submit this form to EPA as specified in Section VII of this form. You may select criterion C on your NOI form and may submit your NOI for permit coverage 30 days after you have submitted this Criterion C Eligibility Form. You must also provide a description of the basis for the criterion you selected on your NOI form, including the species and critical habitat list(s) in your action area, as well as any other documentation supporting your eligibility. You must also include this completed Criterion C Eligiblity Form in your SWPPP.


There are discharge-related activities planned as part of the proposal. Describe your discharge-

related activities in the following box and continue to (b) below.

Describe discharge-related activities:

B. In order to ensure any discharge-related activities will have no likely adverse effects on listed species and/or their designated critical habitat, you must certify that all the following are true:

Discharge-related activities will occur: • on previously cleared/developed areas of the site where maintenance and operation of

the facility are currently occurring or where existing conditions of the area(s) in which the discharge-related activities will occur precludes its use by listed species (e.g., work on existing impervious surfaces, work occurring inside buildings, area is not used by species), and

• if discharge-related activities will include the establishment of structures (including, but not limited to, infiltration ponds and other controls) or any related disturbances, these structures and/or disturbances will be sited in areas that will not result in isolation or degradation of nesting, breeding, or foraging habitat or other habitat functions for listed animal species (or their designated critical habitat), and will avoid the destruction of native vegetation (including listed plant species).

If vegetation removal (e.g., brush clearing) or other similar activities will occur, no terrestrial listed species that use these areas for habitat would be expected to be present during vegetation removal.

If all the above are true, you can conclude that your discharge-related activities will have no likely adverse effects, and:

- If there are any aquatic or aquatic-dependent species and/or critical habitat in your action area, you must skip to Section V, Evaluation of Discharge Effects, below.

- If there are no aquatic or aquatic-dependent species you may skip to Section VI and verify that your activities will have no likely adverse effects. You must submit this form to EPA as specified in Section VII of this form. You may select criterion C on your NOI and may submit your NOI for permit coverage 30 days after you have submitted this completed form. You must also provide a description of the basis for the criterion you selected on your NOI form, including the species and critical habitat list(s), and any other documentation supporting your eligibility. You must also include this completed Criterion C Eligibility Form in your SWPPP.

- If any of the above are not true, you cannot conclude that your discharge-related activities will have no likely adverse effects. You must complete the rest of this form (if applicable), and must submit the form to EPA for assistance in determining your eligibility for coverage.


SECTION V. EVALUATION OF DISCHARGE EFFECTS Note: You are only required to fill out this section if your facility’s action area includes aquatic and/or aquatic-dependent species and/or their critical habitat.

In this section, you will evaluate the likelihood of adverse effects from your facility’s discharges. The scope of effects to consider will vary with each facility and species/critical habitat characteristics. The following are examples of discharge effects you should consider:

• Hydrological Effects. Stormwater discharges may adversely affect receiving waters from pollutant parameters such as turbidity, temperature, salinity, or pH. These effects will vary with the amount of stormwater discharged and the volume and condition of the receiving water. Where a stormwater discharge constitutes a minute portion of the total volume of the receiving water, adverse hydrological effects are less likely.

• Toxicity of Pollutants. Pollutants in stormwater may have toxic effects on listed species and may adversely affect critical habitat. Exceedances of benchmarks, effluent limitation guidelines, or state or tribal water quality requirements may be indicative of potential adverse effects on listed species or critical habitat. However, some listed species may be adversely affected at pollutant concentrations below benchmarks, effluent limitation guidelines, and state or tribal water quality standards. In addition, stormwater pollutants identified in Part 5.2.3.2 of your SWPPP, but not monitored as benchmarks or effluent limitation guidelines, may also adversely affect listed species and critical habitat.

As these effects are difficult to analyze for listed species, their prey, habitat, and designated critical habitat, this form helps you to analyze your discharges and make a determination of whether your discharges will have likely adverse effects and whether there are any additional controls you can implement to ensure no likely adverse effects.

A. Evaluation of Pollutants and Controls to Avoid Adverse Effects. In this section, you must document all of your pollutant sources and pollutants expected to be discharged in stormwater. You must also document the controls you will implement to avoid adverse effects on listed aquatic and aquatic-dependent species. You must include specific details about the expected effectiveness of the controls in avoiding adverse effects to the listed aquatic-and aquatic-dependent species. Attach additional pages if needed.

Potential Pollutant Source Potential Pollutants

Controls to Avoid Adverse Effects on Listed Aquatic and Aquatic-Dependent Species. Include information supporting why the control(s) will ensure no adverse effects, including any data you have about the effectiveness of the control(s) in reducing pollutant concentrations. You may also attach photos of your controls to this form.

e.g., vehicle and equipment fueling

e.g., • Oil & grease • Diesel • Gasoline • TSS • Antifreeze

e.g., • Fueling operators (including the transfer of fuel from

tank trucks) will be conducted on an impervious or contained pad or under cover

• Drip pans will be used where leaks or spills of fuel can occur and where making and breaking hose connections

• Spill kit will be kept on-site in close proximity to potential spill areas

• Any spills will be cleaned-up immediately using dry clean up methods

• Stormwater runoff will be diverted around fueling areas using diversion dikes and curbing


Potential Pollutant Source Potential Pollutants Controls to Avoid Adverse Effects on Listed Aquatic and Aquatic-Dependent Species.


Potential Pollutant Source Potential Pollutants Controls to Avoid Adverse Effects on Listed Aquatic and Aquatic-Dependent Species.

Check if you are not able to make a preliminary determination that any of your pollutants will be controlled to a level necessary to avoid adverse effects on aquatic and/or aquatic-dependent listed species and their designated critical habitat. You must check in Section VI that you are unable to make a determination of no likely adverse effects, and must complete the rest of the form. You must submit your completed form to EPA for assistance in determining your eligibility for coverage.


B. Analysis of Effects Based on Past Monitoring Data. Select which of the following applies to your facility:

I have no previous monitoring data for my facility because there are no applicable monitoring requirements for my facility’s sector(s).

I have no previous monitoring data for my facility because I am a new discharger or a new source, but I am subject to monitoring under the 2015 MSGP. You must provide information to support a conclusion that your facility’s discharges are not expected to result in benchmark or numeric effluent limit exceedances that will adversely affect listed species or their critical habitat:

My facility has not had any exceedances under the 2008 MSGP of any required benchmark(s) or numeric effluent limits.

My facility has had exceedances of one or more benchmark(s) or numeric effluent limits under the 2008 MSGP, but I have addressed them during my coverage under the 2008 MSGP, or in my evaluation of controls to avoid adverse effects in (A) above. Describe all actions (including specific controls) that you will implement to ensure that the pollutants in your discharge(s) will not result in likely adverse effects from future exceedances.

Check if your facility has had exceedances of one or more benchmarks or numeric effluent limits under the 2008 MSGP and you have not been able to address them to avoid adverse effects from future exceedances, or if you are a new discharger or a new source but you are not sure if you can avoid adverse effects from possible exceedances. You must check in Section VI that you are unable to make a determination of no likely adverse effects. You must submit your completed form to EPA for assistance in determining your eligibility for coverage. You may not file your NOI for permit coverage until you are able to make a determination that your discharges will avoid adverse effects on listed species and designated critical habitat.

SECTION VI VERIFICATION OF PRELIMINARY EFFECTS DETERMINATION Based on Steps I – V of this form, you must verify your preliminary determination of effects on listed species and designated critical habitat from your discharges and/or discharge-related activities :

Following the applicable Steps in I – V above, I have made a preliminary determination that my discharges and/or discharge-related activities are not likely to adversely affect listed species and designated critical habitats.

Following the applicable Steps in I – V above, I am not able to make a preliminary determination that my discharges and/or discharge-related activities are not likely to adversely affect listed species and designated critical habitats.

Certification Information I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.


Attachment 1 Include a map and a written description of the action area of your facility, as required in Step 2. You may choose to include the map that is generated from the FWS’ on-line mapping tool IPaC (the Information, Planning, and Consultation System) located at http://ecos.fws.gov/ipac/.

The written description of your action area that accompanies your action area map must explain your rationale for the extant of the action area drawn on your map. For example, your action area written description may look something like this:

The action area for the (name of your facility)’s stormwater discharges extends downstream from the outfall(s) in (name of receiving waterbody) (# of meters/feet/kilometers/miles). The downstream limit of the action area reflects the approximate distance at which the discharge waters and any pollutants would be expected to cause potential adverse effects to listed species and/or critical habitat because (insert rationale). The action area does/does not extend to the (name of receiving waterbody)’s confluence with (name of confluence waterbody) because (insert rationale).

Note that you action area written description will be highly site-specific, depending on the expected effects of your facility’s dishcarges and discharge-related activities, receiving waterbody characteristics, etc.


http://ecos.fws.gov/ipac/

Attachment 2 List or attach the listed species and critical habitat in your action area on this sheet, as required in Step 3. You must include a list for applicable listed NMFS and FWS species and critical habitat. If there are listed species and/or critical habitat for only one Service, you must include a statement confirming there are no listed species and/or critical habitat for the other Service. For FWS species, include the full printout from your IPaC query. Note: If your Official Species List from the USFWS indicated no species or critical habitat were present in your action area, include the full consultation tracking code at the top of your Official Species List in your NOI submittal in the question “Provide a brief summary of the basis for the criterion selected in Appendix E.” If an Official Species List was not available on IPaC, list the contact date and name of the Service staff with whom you corresponded to identify the existence of any USFWS species or critical habitat present in your action area.


United States Department of the Interior

FISH AND WILDLIFE SERVICENew England Ecological Services Field Office

70 COMMERCIAL STREET, SUITE 300CONCORD, NH 03301

PHONE: (603)223-2541 FAX: (603)223-0104URL: www.fws.gov/newengland

Consultation Code: 05E1NE00-2015-SLI-1383 August 03, 2015Event Code: 05E1NE00-2015-E-01807Project Name: Indeck Energy - Alexandria, LLC

Subject: List of threatened and endangered species that may occur in your proposed projectlocation, and/or may be affected by your proposed project

To Whom It May Concern:

The enclosed species list identifies threatened, endangered, proposed and candidate species, aswell as proposed and final designated critical habitat, that may occur within the boundary ofyour proposed project and/or may be affected by your proposed project. The species list fulfillsthe requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of theEndangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 ).et seq.

New information based on updated surveys, changes in the abundance and distribution ofspecies, changed habitat conditions, or other factors could change this list. Please feel free tocontact us if you need more current information or assistance regarding the potential impacts tofederally proposed, listed, and candidate species and federally designated and proposed criticalhabitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 ofthe Act, the accuracy of this species list should be verified after 90 days. This verification canbe completed formally or informally as desired. The Service recommends that verification becompleted by visiting the ECOS-IPaC website at regular intervals during project planning andimplementation for updates to species lists and information. An updated list may be requestedthrough the ECOS-IPaC system by completing the same process used to receive the enclosedlist.

The purpose of the Act is to provide a means whereby threatened and endangered species andthe ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2)of the Act and its implementing regulations (50 CFR 402 ), Federal agencies are requiredet seq.to utilize their authorities to carry out programs for the conservation of threatened andendangered species and to determine whether projects may affect threatened and endangeredspecies and/or designated critical habitat.

A Biological Assessment is required for construction projects (or other undertakings havingsimilar physical impacts) that are major Federal actions significantly affecting the quality of thehuman environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2)(c)). For projects other than major construction activities, the Service suggests that a biologicalevaluation similar to a Biological Assessment be prepared to determine whether the project mayaffect listed or proposed species and/or designated or proposed critical habitat. Recommendedcontents of a Biological Assessment are described at 50 CFR 402.12.

If a Federal agency determines, based on the Biological Assessment or biological evaluation,that listed species and/or designated critical habitat may be affected by the proposed project, theagency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Servicerecommends that candidate species, proposed species and proposed critical habitat be addressedwithin the consultation. More information on the regulations and procedures for section 7consultation, including the role of permit or license applicants, can be found in the "EndangeredSpecies Consultation Handbook" at:

http://www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF

Please be aware that bald and golden eagles are protected under the Bald and Golden EagleProtection Act (16 U.S.C. 668 ), and projects affecting these species may requireet seq.development of an eagle conservation plan(http://www.fws.gov/windenergy/eagle_guidance.html). Additionally, wind energy projectsshould follow the wind energy guidelines (http://www.fws.gov/windenergy/) for minimizingimpacts to migratory birds and bats.

Guidance for minimizing impacts to migratory birds for projects including communicationstowers (e.g., cellular, digital television, radio, and emergency broadcast) can be found at:http://www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/towers.htm;http://www.towerkill.com; andhttp://www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/comtow.html.

We appreciate your concern for threatened and endangered species. The Service encouragesFederal agencies to include conservation of threatened and endangered species into their projectplanning to further the purposes of the Act. Please include the Consultation Tracking Number inthe header of this letter with any request for consultation or correspondence about your projectthat you submit to our office.

Attachment

2

http://ecos.fws.gov/ipac, 08/03/2015 05:16 AM 1

Official Species List

Provided by: New England Ecological Services Field Office

70 COMMERCIAL STREET, SUITE 300

CONCORD, NH 03301

(603) 223-2541

http://www.fws.gov/newengland Consultation Code: 05E1NE00-2015-SLI-1383Event Code: 05E1NE00-2015-E-01807 Project Type: WATER QUALITY MODIFICATION Project Name: Indeck Energy - Alexandria, LLCProject Description: Segment of Smith River adjacent to existing generating facility (MSGP) Please Note: The FWS office may have modified the Project Name and/or Project Description, so itmay be different from what was submitted in your previous request. If the Consultation Codematches, the FWS considers this to be the same project. Contact the office in the 'Provided by'section of your previous Official Species list if you have any questions or concerns.

United States Department of InteriorFish and Wildlife Service

Project name: Indeck Energy - Alexandria, LLC


Project Location Map:

Project Coordinates: MULTIPOLYGON (((-71.77778800835158 43.55901326855547, -71.77915143541456 43.55867460020551, -71.78026723436476 43.55865905052759, -71.78095380973075 43.55881012548775, -71.7810269511354 43.55885372639833, -71.78118744691106 43.559136259175474, -71.78241498753434 43.56020827436855, -71.7830398517117 43.560575009762054, -71.7851389348376 43.56124675615861, -71.78521907648923 43.56131459064708, -71.78522777896774 43.56141922557919, -71.78515994447928 43.561499367230816, -71.78505530954716 43.56150806970933, -71.78291410340181 43.560819339515206, -71.78224420985455 43.56042339914954, -71.78098893603558 43.55932716446704, -71.78083352006152 43.559064244882705, -71.780254800681 43.55893361873797, -71.77917114136059 43.558948720520775, -71.77788960487685 43.55926843182684, -71.77673811392324 43.55978509689474, -71.77665864781116 43.55977976313387, -71.77659553743251 43.55973117926737, -71.77657185581114 43.55962888858862, -71.77662744080867 43.559539812720956, -71.77778800835158 43.55901326855547)))




Project Counties: Grafton, NH | Merrimack, NH




Endangered Species Act Species List

There are a total of 1 threatened or endangered species on your species list. Species on this list should be considered in

an effects analysis for your project and could include species that exist in another geographic area. For example, certain

fish may appear on the species list because a project could affect downstream species. Critical habitats listed under the

Has Critical Habitat column may or may not lie within your project area. See the Critical habitats within your

project area section further below for critical habitat that lies within your project. Please contact the designated FWS

office if you have questions.

Mammals Status Has Critical Habitat Condition(s)

Northern long-eared Bat (Myotis

septentrionalis)

Threatened




Critical habitats that lie within your project areaThere are no critical habitats within your project area.



Appendix I

Non-Stormwater Discharge Inspection Forms

INDECK ENERGY ALEXANDRIANON-SW Discharge Inspection

Facility Name:

Inspected by: Date/Time:

Comment on any and all items that may contribute to non-SW discharge at the facility.INSPECTION ITEM Comments

Outfall #2Is there a discharge?ColorOdorFlowSludgeWeather conditions

AST :Check that all AST are containedMobile Equip Fuel TankLube Oil ShackPump HouseEDGTransformer yard

Bulk Stowage Tanks : Check that BST are contained.Acid TankNH3 TankPump House

Boiler House Contained

Process Water Ponds: Contained and show no signs of leakageLLWPWWPCooling Tower Basin

Stormwater Retention Pond:Shows no sign of pollution

Yard Condition:Ash YardWood Yard

COMMENTS:

Appendix J

Corrective Actions and Miscellaneous Documentation

INDECK ENERGY – ALEXANDRIA, LLC

EPA Additional MSGP Documentation Template, June 4, 2015 12

Corrective Action Documentation

Description of Condition: For Spills and Leaks:

Description of Incident: Material: Date/Time: Amount: Location: Reason for Spill: Discharge to Waters of U.S.:

Date: Immediate Actions: Actions Taken within 14 Days: 14 Day Infeasibility: 45 Day Extension: Description of Condition: For Spills and Leaks:

Description of Incident: Material: Date/Time: Amount: Location: Reason for Spill: Discharge to Waters of U.S.:

Date: Immediate Actions: Actions Taken within 14 Days: 14 Day Infeasibility: 45 Day Extension:

Instructions:

Within 24 hours of becoming aware of a condition identified in Parts 4.1 or 4.2 of the 2015 MSGP, document the existence of the condition and subsequent actions. Note that this information must be summarized in the annual report (as required in Part 7.5 of the 2015 MSGP).

INDECK ENERGY – ALEXANDRIA, LLC

EPA Additional MSGP Documentation Template, June 4, 2015 13

Benchmark Exceedances

Date: Pollutant Exceeded and Results: Quarter 1 (Sample date: ) Result: Quarter 2 (Sample date: ) Result: Quarter 3 (Sample date: ) Result: Quarter 4 (Sample date: ) Result: Average Result: Benchmark Value: Document how benchmark exceedance(s) responded to:

Corrective action review completed (ensure documentation is included in section G of this Template)

Finding that the exceedance was due to natural background pollutant levels

Pollutant(s): Attach data and/or studies that tie the presence of the pollutant causing the exceedance in your discharge to natural background sources in the watershed.

Determination from EPA Regional Office that benchmark monitoring can be

discontinued because the exceedance was due to run-on Pollutant(s):

Attach documentation from EPA Regional Office.

Finding that no further pollutant reductions are technologically available and economically practicable and achievable in light of best industry practice consistent with Part 6.2.1.2. Pollutant(s):

Attach documentation supporting this finding.

Instructions:

Include in your records documentation of any four quarter average benchmark exceedances and how they were responded to, including either: ― (1) corrective action taken (Parts 4.2 and 6.2.1.2), ― (2) a finding that the exceedance was due to natural background pollutant levels (Part 6.2.1.2), ― (3) a determination from the EPA Regional Office that benchmark monitoring can be discontinued because

the exceedance was due to run-on, or ― (4) a finding that no further pollutant reductions were technologically available and economically

practicable and achievable in light of best industry practice consistent with Part 6.2.1.2 of the 2015 MSGP.

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