ADEQ. Site Visit Report. Date of Site Visit: August 9,2012. Facility Name: Hot Spring Power Company. Permit Numbers: AR

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1 Date of Site Visit: August 9,2012 Facility Name: Hot Spring Power Company Permit Numbers: AR Site Visit Report Front Gate Coordinates: Latitude: 34 25' 48"; Longitude: 92 50' 03" Names and Numbers of Personnel Present for Site Visit: Name Company Phone # Shane Byrum ADEQ byrum@adeq.state.ar.us Loretta Reiber ADEQ reiber@adeq.state.ar.us Eleanor Lilley ADEQ lilley@adeq.state.ar.us Christopher Randall ADEQ randall@adeq.state.ar.us John Morgan Hot Spring Power john.morgan@gdfsuezna.com Rob Smith Hot Spring Power rob.smithla),gdfsuezna.com Outfall Information Effluent Description Receiving Stream Outfall 001 Combined discharge of cooling tower blowdown and low volume wastewater Ouachita River Monitoring Coordinates Latitude: 34 25' 48.7"; Longitude: 92 49' 59.6" Outfall Coordinates Latitude: 34 25' 41.4"; Longitude: 92 51' 31.0" Treatment Units Any changes requested by permittee to limits, terms, etc. for this outfall? oil/water separator (low volume wastewater) sodium bisulfite injection (cooling tower blowdown) No changes requested by permittee at site visit Page 1 of 14

2 Effluent Description Receiving Stream Internal Outfall 01 A Cooling tower blowdown Mixing tank prior to final outfall sample point Monitoring Coordinates Latitude: 34 25' 48.8"; Longitude: 92 49' 59.3" Outfall Coordinates Latitude: 34 25' 48.8"; Longitude: 92 49' 59.3" Treatment Units Any changes requested by permittee to limits, terms, etc. for this outfall? Effluent Description Receiving Stream sodium bisulfite injection No changes requested by permittee at site visit Internal Outfall 01 B Low Volume Wastewater Mixing tank prior to final outfall sample point Monitoring Coordinates Latitude: 34 25' 48.8"; Longitude: 92 49' 59.3" Outfall Coordinates Latitude: 34 25' 48.8"; Longitude: 92 49' 59.3" Treatment Units Any changes requested by permittee to limits, terms, etc. for this outfall? Oil/Water Seperator No changes requested by permittee at site visit Proposed Revisions to the Permit I. Internal Outfalls 01 A and 0 I B are removed from the permit. 2. Flow monitoring requirements of cooling tower blowdown and low volume wastestreams were retained and moved from Part IA to Part II. 3. FAC mass and concentration limits at Internal Outfall OIA were removed and replaced with mass limits at the final Outfall 001 based on the combined wastestream formula and the operation of three generating uni ts. 4. ph limit at Internal Outfalls 01 A and 0 I B was removed since compliance is demonstrated at the final Outfall TSS and Oil & Grease mass and concentration limits at Internal Outfall 0 I B were removed and replaced with mass limits at the final Outfall 001 based on the combined wastestream formula. 6. Concentration limits for TSS and O&G were removed from Outfall 00 I and replaced with mass limits based on the combined wastestream formula. 7. Monitoring frequencies for TSS, O&G, ph, and F AC were reduced based on historical compliance meeting the limits. Page 2 of 14

3 8. The critical dilution and dilution series for whole effluent toxicity testing changed due to new USGS published 7Q 10 value for Ouachita River and updated facility flow. The critical dilution changed from 22% effluent to 5% effluent. 9. A condition was added in Part II requiring the facility to submit either engineering calculations or analytical test results prior to using any cooling tower maintenance chemical containing priority pollutants that demonstrate the pollutant is not or will not be present in the final discharge as a result of using the chemical. 10. SWPPP requiremen~s were removed from this permit since stormwater is covered under IGP Tracking No. ARR issued on 5/ Whole effluent toxicity conditions have been updated. 12. Parts II, III, and IV have been updated. 13. The permit is being transferred from Hot Spring Power Company to Arkansas Electric Cooperative Corporation on September 6, Issues Discussed All of the above listed proposed changes were discussed at the site visit with Mr. Morgan and Mr. Smith following a tour of the facility. John Morgan accompanied ADEQ personnel on the facility tour. Several photos were taken and are shown on the following pages. The monitoring coordinates of the final outfall were taken with a handheld Garmin GPS unit. Page 3 of 14

4 Generating Units 1 and 2 are on the left and right of photo. Heat recovery generating unit is between Units 1 and 2 in the middle. Page 4 of 14

5 Unit 2 combustion turbine. Page 5 of 14

6 Department of Environmental Qual ity Unit 2 output to the grid. Page 6 of 14

7 Department of Environmental Qua li ty Unit 1 and Heat Recovery Generator output to grid. Page 7 of 14

8 Internal Monitoring points 01 A (cooling tower blowdown) and OIB (low volume wastewater) just prior to mixing tank and final outfall sampling location. Page 8 of 14

9 Totalizing flow meter on final outfall 001. Flow rate at time of site visit was 4.25 gpm (0.006 mgd) Page 9 of 14

10 Pipe with red valve is the Sodium Bisulfite injection point. Dosage is automatically determined by the flow of blow down from cooling tower. Page 10 of 14

11 Department of Environmental Qua lity Sodium Bisulfite is used to dechlorinate the cooling tower blowdowd. NALCO NAt CHLORINE SCAVENGER 2\ CFR H 'l.3\o Boiler Water Additives, 21 CFR \16.\10 Components of paper and ~an1 in contact with aqueous and fatty foods anc1 2\ CFR \16.\80 Components of paper and ~ard In con\act with dry foods.. Hazardous WQ1IdIen\s may be liste<! under State Right-to Know KOSKER~ This product has been certified as KOSHEMARE\IE for year-round use ~l\jo\ng "THE PASSOVER SEASON by the C~ RABB\M\CAl. COUNCtl WARNING! Harmful, if swallowed. Contains Sulfite. Causes asthmatic signs and symptoms in hyper-reactive individuals. Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. In case of contact with eyes, rinse immediately with plenty of water and seek medical advice. After contact with skin, wash immediately with plenty of water. Wear suitable protective clothing. STATE RIGHT-TO-KNOW: Sodium Bisulfite Water J ArrENTI~ For more information refer 10 the material safety data sheet Empty contiilneb may contain residual product. DO NOT reuse containers unless PIOpef1y reconditioned Page 11 of 14

12 The facility uses a closed cycle recirculating cool ing water system with a 12-cell mechanical draft counter flow cooling tower system. Page 12 of 14

13 Mixing tank where cooling tower blowdown and low volume wastewater combine then discharge via Outfall 001. Page 13 of 14

14 V -notch weir in mixing tank where the low volume and blowdown wastestreams combine. This is sampling location for all parameters for the final outfall 001. After going through the weir the effluent travels in pipeline by gravity to Ouachita River. Page 14 of 14