August 20, Jeff Horn, Plant Manager - NAES Plum Point Energy Station P.O. Box 567 Osceola, AR Plum Point Energy Station Inspection

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1 August 20, 2013 Jeff Horn, Plant Manager - NAES Plum Point Energy Station P.O. Box 567 Osceola, AR RE: Plum Point Energy Station Inspection AFIN: NPDES Permit No.: AR Dear Mr. Horn: On May 22 and 23, 2013, I performed a compliance inspection of the wastewater treatment facility and reconnaissance Landfill (ARG160042) and Industrial (ARR000704) Stormwater inspections in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. These inspections revealed the following items: AR Since approximately October 1, 2012, and continuing through May 2013, facility personnel estimate that 43.2 million gallons of water was pumped from the coal pile runoff pond to the river intake water clarifiers thus bypassing the coal pile runoff water treatment plant and Outfall 01D. This bypass was not reported to the Department as required by Part III.B.4 and Part III.D.6. of the permit effective at that time. On December 6, 2011, in a letter to the Department reporting a similar bypass situation, the facility stated that a request for re-circulating/recycling coal pile runoff water was included in the permit renewal application and an engineering study was underway to assess the issues with the coal pile runoff pond and ancillary equipment. On December 15, 2011, the Department responded via letter stating that this request could not be located, however the request would be considered if sufficient information demonstrating compliance with ELGs was submitted. No additional request or information related to this matter was received by the Department. The current permit (effective May 1, 2013) does not contain any provisions for re-circulation/recycling coal pile runoff water and thus the bypass reporting provisions still apply. Additionally, if the facility anticipates the routine need to re-circulate/recycle coal pile runoff water as describe above and in the aforementioned letter, a request for permit modification (including supporting documentation) should be submitted. 2. A portion of the coal pile runoff appears to be overflowing the coal pile runoff collection system and thus does not enter the coal pile runoff pond. Instead, this water is entering the general stormwater conveyance ditches and is carried to the south stormwater pond.

2 Jeff Horn, Plum Point Energy Station Page 2 This was occurring south of the coal pile in the vicinity of the conveyor leading to the plant (Photos 1 & 2). ARG There was an overflow of leachate from the collection ditch on east side of landfill. This bypasses the leachate collection system and violates A.C.A (a)(2) which states, It shall be unlawful for any person to place or cause to be placed any sewage, industrial waste, or other wastes in a location where it is likely to cause pollution of any waters of this State. ARR The facility s site map is in need of updating to match current conditions at the facility and to ensure all items required by Part 4, Item 6.4 of the permit are included. Most notably the directions of stormwater flow appeared to be incomplete. The above items require your immediate attention. Please submit a written response to these findings to the Water Division Inspection Branch of this Department. This response should be mailed to the address at the bottom of the first page of the letter or ed to Water-Inspection-Report@adeq.state.ar.us. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentation (i.e. photos) is due by September 4, If I can be of any assistance, please contact me at walker@adeq.state.ar.us or ext.-12. Sincerely, Brent L. Walker District 3 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch NPDES Report Page 2

3 ADEQ Water NPDES Inspection AFIN: Permit #: AR Form Approved OMB No UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report Section A: National Data System Coding Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N A R C 19 S 20 2 Remarks Inspection Work Days Facility Evaluation Rating BI QA Reserved N 72 N Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Plum Point Energy Station 2732 South CR 623 Osceola, AR Mississippi Co. Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Jaret Sullivan/Environmental Specialist/ Name, Address of Responsible Official/Title/Phone and Fax Number Jeff Horn/Plant Manager - NAES/ Plum Point Energy Station P.O. Box 567 Osceola, AR Entry Time/Date /22/ /23/2013 Exit Time/Date /22/ /23/2013 Yes Contacted No Permit Effective Date 5/1/2013 Permit Expiration Date 4/30/2018 Other Facility Data Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) S Permit S Flow Measurement U Operations & Maintenance S Sampling S Records/Reports S Self-Monitoring Program S Sludge Handling/Disposal N Pollution Prevention M Facility Site Review N Compliance Schedules N Pretreatment N Multimedia S Effluent/Receiving Waters S Laboratory M Stormwater N Other: The following violations were noted: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) Since approximately October 1, 2012, and continuing through May 2013, facility personnel estimate that 43.2 million gallons of water was pumped from the coal pile runoff pond to the river intake water clarifiers thus bypassing the coal pile runoff water treatment plant and Outfall 01D. This bypass was not reported to the Department as required by Part III.B.4 and Part III.D.6. of the permit effective at that time. A portion of the coal pile runoff appears to be overflowing the coal pile runoff collection system and thus does not enter the coal pile runoff pond. Instead, this water is entering the general stormwater conveyance ditches and is carried to the south stormwater pond. This was occurring south of the coal pile in the vicinity of the conveyor leading to the plant (Photos 1 & 2). See attached letter, report and photos for additional information. Name(s) and Signature(s) of Inspector(s) Brent L. Walker Agency/Office/Telephone/Fax AR Dept. of Environmental Quality-Jonesboro (870) ext. 12/(870) (Fax) Date 8/15/2013 Signature of Reviewer Jason Bolenbaugh Agency/Office/Phone and Fax Numbers ADEQ/ Date 8/20/2013 NPDES Report Page 3

4 ADEQ Water NPDES Inspection AFIN: Permit #: AR SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS DETAILS: S M U NA NE 1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: Y N NA NE 2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Y N NA NE 3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: Y N NA NE 4. ALL DISCHARGES ARE PERMITTED: Y N NA NE SECTION B: RECORDKEEPING AND REPORTING EVALUATION RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT DETAILS: S M U NA NE 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS: Y N NA NE 2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE: S M U NA NE a. DATES AND TIME(S) OF SAMPLING: Y N NA NE b. EXACT LOCATION(S) OF SAMPLING: Y N NA NE c. NAME OF INDIVIDUAL PERFORMING SAMPLING: Y N NA NE d. ANALYTICAL METHODS AND TECHNIQUES: Y N NA NE e. RESULTS OF CALIBRATIONS: Y N NA NE f. RESULTS OF ANALYSES: Y N NA NE g. DATES AND TIMES OF ANALYSES: Y N NA NE h. NAME OF PERSON(S) PERFORMING ANALYSES: Y N NA NE 3. LABORATORY EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS ADEQUATE: S M U NA NE 4. PLANT RECORDS INCLUDE SCHEDULES, DATES OF EQUIPMENT MAINTENANCE AND REPAIR: S M U NA NE 5. EFFLUENT LOADINGS CALCULATED USING DAILY EFFLUENT FLOW AND DAILY ANALYTICAL DATA: Y N NA NE SECTION C: OPERATIONS AND MAINTENANCE TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED S M U NA NE DETAILS: Not all coal pile runoff appears to be directed to the coal pile runoff pond main area of concern is under conveyor south of coal pile; unreported bypass of 01D October 2012 May TREATMENT UNITS PROPERLY OPERATED: S M U NA NE 2. TREATMENT UNITS PROPERLY MAINTAINED: Large amount of coal solids appear to be entering coal pile runoff pond S M U NA NE 3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: S M U NA NE 4. ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE: S M U NA NE 5. ALL NEEDED TREATMENT UNITS IN SERVICE: S M U NA NE 6. ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED: S M U NA NE 7. SPARE PARTS AND SUPPLIES INVENTORY MAINTAINED: S M U NA NE 8. OPERATION AND MAINTENANCE MANUAL AVAILABLE: Y N NA NE 9. STANDARD OPERATING PROCEDURES AND SCHEDULES ESTABLISHED: Y N NA NE 10. PROCEDURES FOR EMERGENCY TREATMENT CONTROL ESTABLISHED: Y N NA NE 11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT OR IN THE COLLECTION SYSTEM IN THE LAST YEAR: 01D ~43.2 MGD Y N NA NE 12. IF SO, HAS THE REGULATORY AGENCY BEEN NOTIFIED: Not reported Y N NA NE 13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS: Y N NA NE 14. HAVE ANY HYDRAULIC OVERLOADS OCCURRED AT THE TREATMENT PLANT: Y N NA NE 15. IF SO, DID PERMIT VIOLATIONS OCCUR AS A RESULT: Y N NA NE NPDES Report Page 4

5 ADEQ Water NPDES Inspection AFIN: Permit #: AR SECTION D: SAMPLING PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS DETAILS: S M U NA NE 1. SAMPLES TAKEN AT SITE(S) SPECIFIED IN PERMIT: Y N NA NE 2. LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES: Y N NA NE 3. FLOW PROPORTIONED SAMPLES OBTAINED WHEN REQUIRED BY PERMIT: Y N NA NE 4. SAMPLING AND ANALYSES COMPLETED ON PARAMETERS SPECIFIED IN PERMIT: Y N NA NE 5. SAMPLING AND ANALYSES PERFORMED AT FREQUENCY SPECIFIED IN PERMIT: Missed 2 TSS for 01B April 2013 NCR to be submitted Y N NA NE 6. SAMPLE COLLECTION PROCEDURES ADEQUATE: Y N NA NE a. SAMPLES REFRIGERATED DURING COMPOSITING: Y N NA NE b. PROPER PRESERVATION TECHNIQUES USED: Y N NA NE c. CONTAINERS AND SAMPLE HOLDING TIMES CONFORM TO 40 CFR 136: Y N NA NE 7. IF MONITORING IS PERFORMED MORE OFTEN THAN REQUIRED ARE RESULTS REPORTED ON THE DMR: Y N NA NE SECTION E: FLOW MEASUREMENT PERMITTEE FLOW MEASUREMENT MEETS PERMIT REQUIREMENTS DETAILS: S M U NA NE 1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: TYPE OF DEVICE: Multiple outfalls Y N NA NE 2. FLOW MEASURED AT EACH OUTFALL AS REQUIRED: Y N NA NE 3. SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY OPERATED AND MAINTAINED: Y N NA NE 4. CALIBRATION FREQUENCY ADEQUATE: Y N NA NE 5. RECORDS MAINTAINED OF CALIBRATION PROCEDURES: Y N NA NE 6. CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE: Y N NA NE 7. FLOW ENTERING DEVICE WELL DISTRIBUTED ACROSS THE CHANNEL AND FREE OF TURBULENCE: Y N NA NE 8. FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGE OF FLOW RATES: Y N NA NE 9. HEAD MEASURED AT PROPER LOCATION: Y N NA NE SECTION F: LABORATORY PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS DETAILS: S M U NA NE 1. EPA APPROVED ANALYTICAL PROCEDURES USED (40 CFR FOR LIQUIDS, 503.8(B) FOR SLUDGES) : Y N NA NE 2. IF ALTERNATIVE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN OBTAINED: Y N NA NE 3. SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT: Y N NA NE 4. QUALITY CONTROL PROCEDURES ADEQUATE: Y N NA NE 5. DUPLICATE SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 6. SPIKED SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 7. COMMERCIAL LABORATORY USED: Y N NA NE a. LAB NAME: ETC b. LAB ADDRESS: Memphis, TN c. PARAMETERS PERFORMED: O&G, Acute Toxicity 8. BIOMONITORING PROCEDURES ADEQUATE: Y N NA NE a. PROPER ORGANISMS USED: Y N NA NE b. PROPER DILUTION SERIES FOLLOWED: Y N NA NE c. PROPER TEST METHODS AND DURATION: Y N NA NE d. RETESTS AND/OR TRE PERFORMED AS REQUIRED: Y N NA NE NPDES Report Page 5

6 ADEQ Water NPDES Inspection AFIN: Permit #: AR SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS BASED ON VISUAL OBSERVATIONS ONLY S M U NA NE DETAILS: Observation made a sampling location OUTFALL #: OIL SHEEN GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER 001 None None Low None None Clear -- SECTION H: SLUDGE DISPOSAL SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: S M U NA NE 2. SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: S M U NA NE 3. FOR LAND APPLIED SLUDGE, TYPE OF LAND APPLIED TO: (E.G., FOREST, AGRICULTURAL, PUBLIC CONTACT SITE): SECTION I: SAMPLING INSPECTION PROCEDURES SAMPLE RESULTS WITHIN PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SAMPLES OBTAINED THIS INSPECTION: Y N NA NE 2. TYPE OF SAMPLE: GRAB: COMPOSITE: METHOD: FREQUENCY: 3. SAMPLES PRESERVED: Y N NA NE 4. FLOW PROPORTIONED SAMPLES OBTAINED: Y N NA NE 5. SAMPLE OBTAINED FROM FACILITY'S SAMPLING DEVICE: Y N NA NE 6. SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE: Y N NA NE 7. SAMPLE SPLIT WITH PERMITTEE: Y N NA NE 8. CHAIN-OF-CUSTODY PROCEDURES EMPLOYED: Y N NA NE 9. SAMPLES COLLECTED IN ACCORDANCE WITH PERMIT: Y N NA NE SECTION J: STORM WATER POLLUTION PREVENTION PLAN STORM WATER MANAGEMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Stormwater is covered under a separate permit: ARR SWPPP UPDATED AS NEEDED: DATE OF LAST UPDATE: Y N NA NE 2. SITE MAP INCLUDING ALL DISCHARGES AND SURFACE WATERS: Y N NA NE 3. POLLUTION PREVENTION TEAM IDENTIFIED: Y N NA NE 4. POLLUTION PREVENTION TEAM PROPERLY TRAINED: Y N NA NE 5. LIST OF POTENTIAL POLLUTANT SOURCES: Y N NA NE 6. LIST OF POTENTIAL SOURCES AND PAST SPILLS AND LEAKS: Y N NA NE 7. ALL NON-STORM WATER DISCHARGES ARE AUTHORIZED: Y N NA NE 8. LIST OF STRUCTURAL BMPS: Y N NA NE 9. LIST OF NON-STRUCTURAL BMPS: Y N NA NE 10. BMPS PROPERLY OPERATED AND MAINTAINED: Y N NA NE 11. INSPECTIONS CONDUCTED AS REQUIRED: Y N NA NE NPDES Report Page 6

7 ADEQ Water NPDES Inspection AFIN: Permit #: AR DMR Calculation Check Reporting Period: From To Year Month Day Year Month Day Parameter Checked: TSS Loading Concentration Mass Monthly Mo. Avg./Max - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l Reported Value: 123/ Calculated Value: 123/ Permit Value: 525.4/ If calculated value does not equal reported value, explain: Equal NPDES Report Page 7

8 ADEQ Water NPDES Inspection AFIN: Permit #: AR DMR Calculation Check Reporting Period: From To Year Month Day Year Month Day Parameter Checked: ph Loading Concentration Mass Monthly Mo. Avg. - lbs/day Minimum Maximum Reported Value: N/A Calculated Value: N/A Permit Value: N/A If calculated value does not equal reported value, explain: Equal NPDES Report Page 8

9 ADEQ Water NPDES Inspection AFIN: Permit #: AR Water Division Photographic Evidence Sheet Location: Plum Point Energy Station Photographer: Brent Walker Date: 5/22/2013 Time: 1500 Witness: Jaret Sullivan NAES Photo #: 1 Description: Area under coal conveyor to plant (facing west). Photographer: Brent Walker Date: 5/22/2013 Time: 1502 Witness: Jaret Sullivan NAES Photo #: 2 Description: Area under coal conveyor to plant (facing east) portions of this area do not appear to flow back to the coal pile runoff pond. NPDES Report Page 9

10 Form Approved OMB No UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report Section A: National Data System Coding Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N A R G R 19 S 20 2 Remarks Inspection Work Days Facility Evaluation Rating BI QA Reserved N 71 N 72 N Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Plum Point Energy Station - Landfill 2732 South CR 623 Osceola, AR Mississippi Co. Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Jaret Sullivan/Environmental Specialist/ Name, Address of Responsible Official/Title/Phone and Fax Number Jeff Horn/Plant Manager - NAES/ Plum Point Energy Station PO Box 567 Osceola, AR Entry Time/Date /22/ /23/2013 Exit Time/Date /22/ /23/2013 Yes Contacted No Permit Effective Date 4/30/2009 Permit Expiration Date 2/28/2015 Other Facility Data Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) N Permit N Flow Measurement U Operations & Maintenance N Sampling N Records/Reports N Self-Monitoring Program N Sludge Handling/Disposal U Pollution Prevention N Facility Site Review N Compliance Schedules N Pretreatment N Multimedia N Effluent/Receiving Waters N Laboratory U Stormwater N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) This reconnaissance inspection was conducted in conjunction with a CEI of the facility s individual wastewater permit AR There was an overflow of leachate from the collection ditch on east side of landfill. This bypasses the leachate collection system and violates A.C.A (a)(2) Place or cause to be placed any sewage, industrial waste, or other wastes in a location where it is likely to cause pollution of any waters of this State. The above item is addressed in the letter attached to the AR inspection. Additionally, during the course of the inspection the need for minor improvements to the stormwater conveyance ditches were discussed. Due to the large size of the stormwater pond and currently small landfill footprint, the facility has not yet had a stormwater discharge. Name(s) and Signature(s) of Inspector(s) Brent L. Walker Agency/Office/Telephone/Fax AR Dept. of Environmental Quality-Jonesboro (870) ext. 12/(870) (Fax) Date 8/15/2013 Signature of Reviewer Agency/Office/Phone and Fax Numbers ADEQ/ Date 8/20/2013 Jason Bolenbaugh

11 ADEQ Water NPDES Inspection AFIN: Permit #: ARG Water Division Photographic Evidence Sheet Location: Plum Point Energy Station - Landfill Photographer: Brent Walker Date: 5/23/2013 Witness: Jaret Sullivan - NAES Description: Leachate collection ditch along east side of landfill. Photographer: Brent Walker Date: 5/23/2013 Witness: Jaret Sullivan - NAES Description: Closer view of leachate collection ditch above. Time: 1140 Photo #: 1 Time: 1121 Photo #: 2

12 ADEQ Water NPDES Inspection AFIN: Permit #: ARG Water Division Photographic Evidence Sheet Location: Plum Point Energy Station - Landfill Photographer: Brent Walker Date: 5/23/2013 Time: 1126 Witness: Jaret Sullivan - NAES Photo #: 3 Description: View further south of leachate collection ditch in photos 1 & 2. Photographer: Brent Walker Date: 5/23/2013 Time: 1125 Witness: Jaret Sullivan - NAES Photo #: 4 Description: Overflow of leachate from the collection ditch on east side of landfill.

13 ADEQ Water NPDES Inspection AFIN: Permit #: ARG Water Division Photographic Evidence Sheet Location: Plum Point Energy Station - Landfill Photographer: Brent Walker Date: 5/23/2013 Time: 1125 Witness: Jaret Sullivan - NAES Photo #: 5 Description: Closer view of leachate overflow. Photographer: Brent Walker Date: 5/23/2013 Time: 1124 Witness: Jaret Sullivan - NAES Photo #: 6 Description: Overview of area with leachate overflow.

14 Form Approved OMB No UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report Section A: National Data System Coding Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N A R R R 19 S 20 2 Remarks Inspection Work Days Facility Evaluation Rating BI QA Reserved N 71 N 72 N Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Plum Point Energy Station 2732 South CR 623 Osceola, AR Mississippi Co. Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Jaret Sullivan/Environmental Specialist/ Name, Address of Responsible Official/Title/Phone and Fax Number Jeff Horn/Plant Manager - NAES/ Plum Point Energy Station P.O. Box 567 Osceola, AR Entry Time/Date /22/ /23/2013 Exit Time/Date /22/ /23/2013 Yes Contacted No Permit Effective Date 6/2/2011 Permit Expiration Date 6/30/2014 Other Facility Data Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) S Permit N Flow Measurement M Operations & Maintenance N Sampling M Records/Reports N Self-Monitoring Program N Sludge Handling/Disposal N Pollution Prevention N Facility Site Review N Compliance Schedules N Pretreatment N Multimedia N Effluent/Receiving Waters N Laboratory M Stormwater N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) This reconnaissance inspection was conducted in conjunction with a CEI of the facility s individual wastewater permit AR Overall industrial stormwater practices appeared satisfactory. The facility s site map was in need of updating to match current conditions at the facility and to ensure all items required by Part 4, Item 6.4 of the permit are included. Most notably, the directions of stormwater flow appeared to be incomplete. The above item is addressed in the letter attached to the AR inspection. Name(s) and Signature(s) of Inspector(s) Brent L. Walker Agency/Office/Telephone/Fax AR Dept. of Environmental Quality-Jonesboro (870) ext. 12/(870) (Fax) Date 8/15//2013 Signature of Reviewer Agency/Office/Phone and Fax Numbers ADEQ/ Date 8/20/2013 Jason Bolenbaugh

15 Bolenbaugh, Jason From: Sent: To: Cc: Subject: Reiber, Loretta Tuesday, August 13, :35 AM Walker, Brent; Fuller, Kim Bolenbaugh, Jason RE: Plum Point Energy Station AR It looks right to me. From: Walker, Brent Sent: Monday, August 12, :33 PM To: Fuller, Kim; Reiber, Loretta Cc: Bolenbaugh, Jason Subject: RE: Plum Point Energy Station AR Kim and Loretta Will you take a look at this letter (specifically the first violation related to the unreported bypass) and let me know if permits has any questions/comments/suggestions before we send it to the permittee. Thanks, Brent Brent L. Walker District 3 Field Inspector Water Division - Jonesboro Field Office Arkansas Department of Environmental Quality ext.-12 walker@adeq.state.ar.us From: Fuller, Kim Sent: Tuesday, June 04, :08 AM To: Reiber, Loretta; Bolenbaugh, Jason; Walker, Brent; Bailey, John Subject: RE: Plum Point Energy Station AR Brent, If it is ok, I would like for Permit Branch to review your inspection report before it is sent to the facility. I would like John and Mo to be aware of the issues before anything is formally submitted to the facility. Thanks! Kimberly A. Fuller, P.E. NPDES Engineer Supervisor ADEQ, Water Division Phone: (501) From: Reiber, Loretta Sent: Tuesday, June 04, :02 AM To: Bolenbaugh, Jason; Walker, Brent Cc: Fuller, Kim Subject: RE: Plum Point Energy Station AR Brent, 1

16 I looked at SWEPCO s Turk Plant at Kim s suggestion since this issue had arisen with that facility. Turk is allowed to route water from the coal pile runoff/low volume wastewater pond to the makeup water pond. That stream has been designated as Internal Outfall 201 and contains limits for TSS and O & G based on the ELGs and the combined waste stream formula. The makeup water pond then goes through a pretreatment system before being used in the cooling water system. I think we should handle this in the manner that we put it into the Turk NPDES Permit. The permittee should have submitted a request along with the information requested in the Department letter dated 12/15/2011. Since it was not submitted and they said that an engineering study was underway to assess the issues the facility has seen with the coal pile runoff pond, I assumed that they decided not to do it. It is my opinion that they should modify the permit if they want to keep doing this. The last paragraph of the Department s 12/15/2011 letter explains this. Since Plum Point constructed a WWTP to specifically treat the coal pile runoff, I have concerns that they wouldn t be able to meet the ELG based limits without treating the runoff. Loretta From: Reiber, Loretta Sent: Thursday, May 30, :34 PM To: Bolenbaugh, Jason; Bailey, John Cc: Fuller, Kim; Walker, Brent Subject: RE: Plum Point Energy Station AR I e mailed Kim my thoughts on this yesterday afternoon. I don t know if she s had time to review my e mail yet. From: Bolenbaugh, Jason Sent: Thursday, May 30, :35 AM To: Bailey, John Cc: Fuller, Kim; Walker, Brent; Reiber, Loretta Subject: RE: Plum Point Energy Station AR John, Brent is preparing to draft his inspection report for Plum Point Entergy Station but is waiting to hear back from your group whether or not the treatment/recycling of the coal pile runoff waste through alternate outfalls has been approved by Permits. Can someone let him know the current standing regarding this? Thanks, Jason Bolenbaugh Inspection Branch Manager ADEQ Water Division Phone: bolenbaugh@adeq.state.ar.us From: Walker, Brent Sent: Tuesday, May 28, :15 PM To: Reiber, Loretta Cc: Bailey, John; Fuller, Kim; Bolenbaugh, Jason Subject: Plum Point Energy Station AR

17 Loretta As we discussed via telephone earlier this morning, I performed an inspection of the Plum Point Entergy Station (AR ) in Osceola on Wednesday and Thursday of last week and noted the following: The treatment unit for the coal pile runoff pond has been out of service for an extended period of time (several months) and thus they have not discharged from Internal Outfall 01D in They have placed an auxiliary pump in the southwest corner of the coal pile runoff pond and have been routing this water to the west intake water clarifier where it is then treated and used for cooling tower makeup water and demineralized water. Ultimately this water is discharged through Internal Outfall 01A or 01B and then to the river through 001. This appears to be nearly identical to the bypass conditions reported in the attached letter from 12/6/2011, and the Department s response on 12/15/2011. Due to the requirements for both cooling tower makeup water and demineralized water, I am certain this water is being treated to more stringent levels than required by 01D, but this is not being formally demonstrated. It was my understanding that a provision for treating/recycling the coal pile runoff water in this manner was going to be incorporated into the new permit which became effective this month, but I don t see any reference to it. Additionally, the last comments I see in the database regarding this matter are those in the Department s 12/15/2011 response above stating the request to incorporate this change could not be located in the renewal application. To the best of my knowledge, no notification was given to the Department regarding this current situation. Should notification have been given by the permittee? How do you suggestion I handle this matter? Thanks, Brent Brent L. Walker District 3 Field Inspector Water Division - Jonesboro Field Office Arkansas Department of Environmental Quality ext.-12 walker@adeq.state.ar.us 3

18 Bolenbaugh, Jason From: Sent: To: Cc: Subject: Fuller, Kim Tuesday, August 13, :50 AM Reiber, Loretta; Walker, Brent Bolenbaugh, Jason RE: Plum Point Energy Station AR I agree with Loretta. Kimberly A. Fuller, P.E. NPDES Engineer Supervisor ADEQ, Water Division Phone: (501) From: Reiber, Loretta Sent: Tuesday, August 13, :35 AM To: Walker, Brent; Fuller, Kim Cc: Bolenbaugh, Jason Subject: RE: Plum Point Energy Station AR It looks right to me. From: Walker, Brent Sent: Monday, August 12, :33 PM To: Fuller, Kim; Reiber, Loretta Cc: Bolenbaugh, Jason Subject: RE: Plum Point Energy Station AR Kim and Loretta Will you take a look at this letter (specifically the first violation related to the unreported bypass) and let me know if permits has any questions/comments/suggestions before we send it to the permittee. Thanks, Brent Brent L. Walker District 3 Field Inspector Water Division - Jonesboro Field Office Arkansas Department of Environmental Quality ext.-12 walker@adeq.state.ar.us From: Fuller, Kim Sent: Tuesday, June 04, :08 AM To: Reiber, Loretta; Bolenbaugh, Jason; Walker, Brent; Bailey, John Subject: RE: Plum Point Energy Station AR Brent, If it is ok, I would like for Permit Branch to review your inspection report before it is sent to the facility. I would like John and Mo to be aware of the issues before anything is formally submitted to the facility. Thanks! 1

19 Kimberly A. Fuller, P.E. NPDES Engineer Supervisor ADEQ, Water Division Phone: (501) From: Reiber, Loretta Sent: Tuesday, June 04, :02 AM To: Bolenbaugh, Jason; Walker, Brent Cc: Fuller, Kim Subject: RE: Plum Point Energy Station AR Brent, I looked at SWEPCO s Turk Plant at Kim s suggestion since this issue had arisen with that facility. Turk is allowed to route water from the coal pile runoff/low volume wastewater pond to the makeup water pond. That stream has been designated as Internal Outfall 201 and contains limits for TSS and O & G based on the ELGs and the combined waste stream formula. The makeup water pond then goes through a pretreatment system before being used in the cooling water system. I think we should handle this in the manner that we put it into the Turk NPDES Permit. The permittee should have submitted a request along with the information requested in the Department letter dated 12/15/2011. Since it was not submitted and they said that an engineering study was underway to assess the issues the facility has seen with the coal pile runoff pond, I assumed that they decided not to do it. It is my opinion that they should modify the permit if they want to keep doing this. The last paragraph of the Department s 12/15/2011 letter explains this. Since Plum Point constructed a WWTP to specifically treat the coal pile runoff, I have concerns that they wouldn t be able to meet the ELG based limits without treating the runoff. Loretta From: Reiber, Loretta Sent: Thursday, May 30, :34 PM To: Bolenbaugh, Jason; Bailey, John Cc: Fuller, Kim; Walker, Brent Subject: RE: Plum Point Energy Station AR I e mailed Kim my thoughts on this yesterday afternoon. I don t know if she s had time to review my e mail yet. From: Bolenbaugh, Jason Sent: Thursday, May 30, :35 AM To: Bailey, John Cc: Fuller, Kim; Walker, Brent; Reiber, Loretta Subject: RE: Plum Point Energy Station AR John, Brent is preparing to draft his inspection report for Plum Point Entergy Station but is waiting to hear back from your group whether or not the treatment/recycling of the coal pile runoff waste through alternate outfalls has been approved by Permits. Can someone let him know the current standing regarding this? Thanks, 2

20 Jason Bolenbaugh Inspection Branch Manager ADEQ Water Division Phone: From: Walker, Brent Sent: Tuesday, May 28, :15 PM To: Reiber, Loretta Cc: Bailey, John; Fuller, Kim; Bolenbaugh, Jason Subject: Plum Point Energy Station AR Loretta As we discussed via telephone earlier this morning, I performed an inspection of the Plum Point Entergy Station (AR ) in Osceola on Wednesday and Thursday of last week and noted the following: The treatment unit for the coal pile runoff pond has been out of service for an extended period of time (several months) and thus they have not discharged from Internal Outfall 01D in They have placed an auxiliary pump in the southwest corner of the coal pile runoff pond and have been routing this water to the west intake water clarifier where it is then treated and used for cooling tower makeup water and demineralized water. Ultimately this water is discharged through Internal Outfall 01A or 01B and then to the river through 001. This appears to be nearly identical to the bypass conditions reported in the attached letter from 12/6/2011, and the Department s response on 12/15/2011. Due to the requirements for both cooling tower makeup water and demineralized water, I am certain this water is being treated to more stringent levels than required by 01D, but this is not being formally demonstrated. It was my understanding that a provision for treating/recycling the coal pile runoff water in this manner was going to be incorporated into the new permit which became effective this month, but I don t see any reference to it. Additionally, the last comments I see in the database regarding this matter are those in the Department s 12/15/2011 response above stating the request to incorporate this change could not be located in the renewal application. To the best of my knowledge, no notification was given to the Department regarding this current situation. Should notification have been given by the permittee? How do you suggestion I handle this matter? Thanks, Brent Brent L. Walker District 3 Field Inspector Water Division - Jonesboro Field Office Arkansas Department of Environmental Quality ext.-12 walker@adeq.state.ar.us 3

21 Bolenbaugh, Jason From: Sent: To: Cc: Subject: Attachments: Jaret Sullivan Wednesday, September 04, :16 PM Water-Inspection-Report; Walker, Brent Jeff Horn; Greg Cook; Kellee Fletcher; Hambrook, Lauren; Berner, Pamela AFIN ; Plum Point Inspection Response AFIN Response pdf; PPES SWPPP Updated.pdf Please see the attached response to the May, 2013 inspection of Plum Point Energy Station, AFIN If there are any further comments or questions, please let me know. Thank you, Jaret Jaret Sullivan Environmental Specialist Plum Point Energy Station

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24 NORTH PLANT OUTFALL 001 MISSISSIPPI RIVER Sodium Hypochlorite Tank COAL PILE PERIMETER CONCRETE SWALE WASTEWATER COLLECTION POND AMMONIA STORAGE TANK LIME SILO FLY ASH SILO TO WASTEWATER COLLECTION WATER TREATMENT FUEL OIL TANK FUEL PUMPS HYDROGEN STORAGE STORMWATER POND #2 BENETECH FEED AREA COAL RUNOFF POND (TO WASTEWATER TREATMENT BUILDING) SULFURIC ACID STORAGE TANK FUELING STATION STORMWATER POND SPILLWAY STORMWATER POND #1 LEGEND: OUTFALL SW-2 DRAINAGE AREA FOR SW-1 COAL ROTARY CAR DUMPER OUTFALL SW-1 DRAINAGE AREA FOR SW-2 DRAINAGE ARE FOR WATERS DIRECTED TO WASTE WATER COLLECTION SYSTEM SOLID WASTE LANDFILL EQPT MAINTENANCE BUILDING POTENTIAL POLLUTION SOURCE AREA IMPERVIOUS AREAS OVERLAND FLOW DIRECTION DRAINAGE SWALE TOTAL PROPERTY AREA = 340 ACRES 09/04/2013

25 October 1, 2013 Jeff Horn Plum Point Energy Station P.O. Box 567 Osceola, AR RE: Plum Point Energy Station Inspection Response Permit No.: AR , ARG and ARR000704, AFIN: Dear Mr. Horn: I have reviewed the response pertaining to my inspections of the Plum Point Energy Station. The information provided sufficiently addresses the violations referenced in my inspection reports. At this time the Department has no further comment concerning these particular inspections. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. If we need further information concerning this matter, we will contact you. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at ext.-12 or you may me at walker@adeq.state.ar.us. Sincerely, Brent L. Walker District 3 Field Inspector Water Division