Jim Bridger Power Plant

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1 2015 Coal Combustion Residuals Annual Inspection Jim Bridger Power Plant Industrial Landfill Prepared for PacifiCorp Energy North Temple Office 1407 West North Temple Salt Lake City, Utah Final December 29, 2015 URS Corporation 756 East Winchester, Suite 400 Salt Lake City, Utah 84107

2 Contents 1 Findings Description and History of Industrial Landfill General Overview Location Jim Bridger Industrial Landfill Description Performance History Construction History Review of Operating Record Files Design and Construction Information Previous Periodic Structural Analyses Results of Inspection by a Qualified Person Results of Previous Annual Inspections Field Inspection of Jim Bridger Landfill General Jim Bridger Industrial Landfill Geometry Observed or Potential Structural Weaknesses Observed Changes Limitations and Consultant Qualifications Limitations Professional Engineer Qualifications References... 7 Appendices Appendix A Appendix B Appendix C Photograph Log Annual Inspection Report Form Example PacifiCorp Inspection Form 2015 Jim Bridger Industrial Landfill Inspection i

3 1 Findings This annual inspection and report are being completed for the purpose of providing due diligence by PacifiCorp to ensure the safety of its coal combustion residual facilities. The inspection was performed according to the requirements for annual inspection (for CCR landfills) of 40 CFR Parts 257 and 261, Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals from Electric Utilities, Final Rule, dated April 17, 2015 [4]. URS found no observations that would indicate imminent failure of the embankment for the Jim Bridger Power Plant Industrial Landfill. There is no indication of movement of the embankment. Figure 1 1 on the following page is an aerial photograph of the landfill showing its location in relation to the plant. Observations from the 2015 inspection include: 1. Former erosion area that had been treated. Refer to Photo 9, Appendix A. 2. Recent erosion near the north retention basin. Not repaired on day of inspection. Refer to Photo 2, Appendix A. The erosion was a result of two separate rain storms. Repairs to the north retention basin liner were completed on November 11, Positive observations include: 1. Vegetation is established on final cover. Refer to Photo 10, Appendix A. 2. No observed slope instabilities. The photograph log in Appendix A also provides a baseline of landfill conditions to compare with when performing future inspections Jim Bridger Industrial Landfill Inspection 1

4 Figure 1 1. Jim Bridger Power Plant Industrial Landfill 2015 Jim Bridger Industrial Landfill Inspection 2

5 The coal combustion residual (CCR) rules requirement for signage is not applicable to CCR landfills. They are only required for surface water impoundments. The following Figure 1 2 shows a sign located at the entrance for the Jim Bridger Industrial Landfill. The industrial portion of the landfill is adjacent to the CCR portion of the landfill and neither accepts hazardous wastes. Figure Description and History of Industrial Landfill 2.1 General Overview The Jim Bridger Power Plant is owned and operated by PacifiCorp. Fly ash and bottom ash produced by the plant are disposed of in the Industrial Landfill. These waste materials are delivered to the landfill by haul truck. 2.2 Location The Industrial Landfill is located approximately 1.8 miles north of the Jim Bridger Power Plant. The plant is located seven miles north of Point of Rocks, Wyoming [3]. The landfill is accessed by a haul road along its southern boundary that is accessed from 9 Mile Road. 2.3 Jim Bridger Industrial Landfill Description The Jim Bridger Power Plant consists of the power generating facility, numerous ponds, and the Industrial Landfill. This study specifically addresses the CCR waste landfill identified as the Jim Bridger Power Plant Industrial Landfill. An aerial map the landfill is shown in Figure Jim Bridger Industrial Landfill Inspection 3

6 The Industrial Landfill includes an area of approximately 200 acres 1 It includes CCR deposited material and an area for industrial waste of approximately 9 acres. There are two retention ponds that collect runoff from the landfill. One is located on the north and the other on the east side of the landfill. 2.4 Performance History There are no reported incidences of slope failure or movement of the landfill embankment in the record files. In the summer of 2015, there were two significant flooding events that caused erosion of portions of the northeast face. The eroded material was all contained in the retention basin on the north side of the landfill. Refer to Photo 2, Appendix A. 2.5 Construction History The plant has disposed of CCR at the Industrial Landfill since 1986 [3]. 2.6 Review of Operating Record Files The list of operating records to be reviewed during the annual inspection as contained in 40 CFR 257, Disposal of Coal Combustion Residuals for Electric Utilities is CCR unit design and construction information required by (c)(1) and (c)(1), previous periodic structural stability assessments required under (d) and (d), the results of inspections by a qualified person, and results of previous annual inspections [4]. The following subsection describes the review of operating record files Design and Construction Information Design and construction information for the Jim Bridger Industrial Landfill is found in the Industrial Landfill Permit [5] Previous Periodic Structural Analyses There are no previous structural analyses of the Jim Bridger Industrial Landfill Results of Inspection by a Qualified Person Jim Bridger Industrial Landfill is subject to periodic inspections by the Jim Bridger Power Plant staff. URS reviewed the inspection reports; however, this is the beginning of the first cycle of inspections under CCR regulations and the record is limited to a few weeks of inspections. These inspections are documented and retained by PacifiCorp. A sample of PacifiCorp s Inspection form can be found in Appendix C. In the opinion of this report author, the interim inspections by the plant staff are adequate and appropriate for this CCR unit Results of Previous Annual Inspections This is the initial and only annual inspection conducted under CCR rules [4] for the Jim Bridger Industrial Landfill. However, Wyoming Department of Environmental Quality conducted inspections[8] of the landfill in 2011, 2008, 2003, and 1993 for compliance with the Wyoming Solid and Hazardous Waste Rules and Regulations. 1 URS calculated area from aerial photography, Google Earth, April 30, Jim Bridger Industrial Landfill Inspection 4

7 This report and other pertinent reports and data are accessible at the following website: Section 5 of this report is a list of references reviewed for this report for the Jim Bridger Industrial Landfill. 3 Field Inspection of Jim Bridger Landfill A field inspection was conducted on August 25, 2015 by URS staff, Rick J. Cox, P.E.. Personnel from the Jim Bridger Power Plant accompanied the URS team during the 2015 field inspection. A photograph log documenting features and their condition at the time of the inspection is presented in Appendix A. These photos are referenced in the report. The Annual Inspection Report Form is presented in Appendix B. This checklist should be considered an integral part of the report and remain attached whenever the report is forwarded or otherwise reproduced. 3.1 General The field inspection was performed by the URS inspection team by driving the perimeter road and the crest, stopping at approximately ¼ mile intervals or when observations warranted stopping. Intermittently, photos were taken of the outer face of the embankment to provide a baseline for future inspections. Features and conditions were documented on the Annual Inspection Report Form (Appendix B) and were photographed. The approximate locations of the photos are detailed in the inspection photograph log overview map located at the beginning of the Photograph Log, Appendix A. In addition to documenting current features, the photo log of existing conditions is intended on aiding future inspections. 3.2 Jim Bridger Industrial Landfill Geometry There are no cross sections of the Industrial Landfill in the record file. However, based on the site inspection the finished slopes are between 3 horizontal to 1 vertical (3:1) and 4: Observed or Potential Structural Weaknesses There were no appearances of actual or potential structural weakness or existing conditions that are disrupting, or have the potential to disrupt the operation and safety of the CCR unit. 3.4 Observed Changes This is the initial landfill inspection under the CCR rules [4]. Consequently, there are no previous annual inspections to compare changes Jim Bridger Industrial Landfill Inspection 5

8 4 Limitations and Consultant Qualifications 4.1 Limitations This report presents observations, and conclusions drawn from a review of pertinent documents referenced in Section 5, and a field inspection of the Jim Bridger Industrial Landfill. The purpose of the review and inspection has been to assess the safety or adequacy of the facilities against catastrophic failure of the major constructed elements during normal operations or unusual or extreme events based on visual inspection and available information. A secondary purpose is to identify any potential deficiencies related to the CCR rules [4]. The conclusions and professional opinions presented herein were developed by the independent consultant and are in accordance with generally accepted engineering principles and practices at the time and location the services were provided. URS makes no other warranty, either expressed or implied. 4.2 Professional Engineer Qualifications The professional engineer for this inspection is Rick J. Cox. He is licensed in the State of Wyoming (13825) as a civil engineer. He has over 32 years experience in civil/structural engineering and has performed inspections and safety evaluations on dams, canals and numerous other water containing structures Jim Bridger Industrial Landfill Inspection 6

9 5 References [1] URS, 2014 Coal Combustion Residuals Impoundment Inspection and Assessment Hunter Power Plant Ash Landfill, January 6, [2] Wyoming Department of Environmental Quality, Operating Permit, Jim Bridger Power Plant Industrial Landfill, April 26, [3] Water & Environmental Technologies, 2014 Annual Report, Ash Landfill Ground Water Monitoring Program, May 11, [4] 40 CFS 257 Disposal of Coal Combustion Residuals from Electric Utilities, April 17, [5] State of Wyoming, Industrial Siting Permit, Jim Bridger Unit 4, February 6, [6] GEI, "Final Coal Ash Impoundment Specific Site Asssessment Report, PacifiCorp Energy, Jim Bridger Power Station, September, [7] PacifiCorp Energy, Plant Brochure: Jim Bridger Plant, Point of Rocks, Wyoming, [8] Wyoming Department of Environmental Quality, Compliance Evaluation Inspection Jim Bridger Power Plant and Industrial Landfill. 2011, 2008,2003, Jim Bridger Industrial Landfill Inspection 7

10 Appendix A Photograph Log 2015 Jim Bridger Industrial Landfill Inspection

11 Inspection Photographs PacifiCorp Energy Industrial Landfill - Jim Bridger Power Plant August 25, 2015 Page No. A-1

12 Photograph No. 1 Excavation of a CCR disposal trench. Photograph No. 2 Erosion along the south western bank of the Industrial Landfill s northern retention pond. Inspection Photographs PacifiCorp Energy Industrial Landfill - Jim Bridger Power Plant August 25, 2015 Page No. A-2

13 Photograph No. 3 View to the south east of the Industrial Landfill. Photograph No. 4 View of the active Industrial Waste site of the Industrial Landfill. Inspection Photographs PacifiCorp Energy Industrial Landfill - Jim Bridger Power Plant August 25, 2015 Page No. A-3

14 Photograph No. 5 Elevated view to the south east of the Industrial Landfill. Photograph No. 6 View of the petroleum contaminated soil treatment area. Inspection Photographs PacifiCorp Energy Industrial Landfill - Jim Bridger Power Plant August 25, 2015 Page No. A-4

15 Photograph No. 7 View from the top of the landfill to the north east. Northern retention pond visible. Photograph No. 8 South west view of a filled coal residual solids disposal trench filled. Inspection Photographs PacifiCorp Energy Industrial Landfill - Jim Bridger Power Plant August 25, 2015 Page No. A-5

16 Photograph No. 9 Erosion prevention measures along the south western aspect of the Industrial Landfill. Photograph No. 10 Erosion prevention measures along the south western slope of the Industrial Landfill. Note vegetation established on finish cover. Inspection Photographs PacifiCorp Energy Industrial Landfill - Jim Bridger Power Plant August 25, 2015 Page No. A-6

17 Photograph No. 11 Sign at entry point to the Industrial Landfill. Photograph No. 12 Eastward view of the southern retention basin of the Industrial Landfill. Inspection Photographs PacifiCorp Energy Industrial Landfill - Jim Bridger Power Plant August 25, 2015 Page No. A-7

18 Appendix B Annual Inspection Report Form 2015 Jim Bridger Industrial Landfill Inspection

19 Feature Name: Jim Bridger Industrial Landfill Annual Landfill Inspection Report Feature ID: Issue Date: Form XXXXX Revision A Page 1 of 2 Date: August 25,2015 Station/Owner PacifiCorp Inspected By Rick J. Cox, P.E. and Matt Zion County, Sweetwater Date State Wyoming Phone No Type of Inspection Initial Periodic Follow up Other Weather Wet Dry Snow Cover Other Remarks Inspector accompanied by Jason Maes, Environmental Analyst, Jim Bridger Power Plant. This was the initial inspection under CCR regulations. Total Precipitation last 24 hrs None COVER 1. None 2. Animal burrows 3. Animal damage 4. Weeds & Brush 5. Vegetation >2 dia. 6. Vegetation islands 7. Poor grass cover 8. Slope Stability PROBLEMS 9. Settlement 10. Cracks 11. Erosion 12. Rills Comments /Action Items: Item 11, Erosion had been repaired. Photos 9 and 10 of photo log. 13. Seepage 14. Ponding 15. Other COVER Vegetation Gravel Soil Other Temp bottom ash SLOPES & PERIMETER BERMS Actions None Maintenance Monitoring Minor Repair Engineering PROBLEMS COVER: 1. None 5. Vegetation >2 dia. 9. Settlement 13. Seepage Vegetation 2. Animal burrows 6. Bare spots >25ft Cracks 14. Ponding Gravel 3. Animal damage 7. Poor grass cover 11. Erosion 15. Other Soil 4. Weeds & Brush 8. Slope Stability 12. Rills Asphalt Other temp. bottom ash, north slope OBSERVATIONS 16. Do slopes and berms provide positive drainage? Yes No NA 17. Is there exposed waste on exterior slopes? Just on north face, discharges to sediment basin. Yes No NA Comments /Action Items: Erosion of north slope into detention basin. Photos 2 and 7 of photo log. Repair work planned for erosion and sediment in sedimentation basin. Actions None Maintenance Monitoring Minor Repair Engineering

20 Feature Name: Jim Bridger Industrial Landfill Annual Landfill Inspection Report Feature ID: PROBLEMS Issue Date: Form XXXXX Revision A Page 2 of 2 Date: August 25,2015 LECHATE SYSTEM 1. None 2. Sump 3. Piping leaking 4. Containment Leaking 5. Tank leaking 6. Other OBSERVATIONS 7. Is the Leachate transmission system functioning properly? Yes No NA 8. Is the leak detections system functioning properly? Yes No NA Comments /Action Items: EROSION SEDIMENT CONTROLS Other Actions None Maintenance Monitoring Minor Repair Engineering PROBLEMS 1. None 3. Ditch Failure. 5. Debris 7. Silt Fences 9. Rip Rap Aprons 2. Channel 4. Ditch Washouts 6. Sediment 8. Filter Socks 10. Other OBSERVATIONS 11. No erosion or sediment controls Yes No 12. Are drop structures in good repair? Yes No N/A 13. Are perimeter run on diversion ditches present and in good repair? Yes No N/A 14. Are perimeter run off diversion ditches present and in good repair? Yes No N/A Comments /Action Items: See above issue of erosion of north face of landfill and sedimentation in sedimentation basin. Actions None Maintenance Monitoring Minor Repair Engineering Observations 1. Are temporary covers functioning as intended? Yes No N/A 2. Are Stormwater systems functioning as intended? Yes No N/A 3. Fences and Gates in good condition? Yes No N/A 4. Security devices in good condition? Yes No N/A 5. Signs in good condition? Yes No N/A 6. Reference monuments/survey Monuments in good condition? Not observed. Yes No N/A Comments /Action Items Actions None Maintenance Monitoring Minor Repair Engineering Inspector Signature Date

21 Appendix C Example PacifiCorp Inspection Form 2015 Jim Bridger Industrial Landfill Inspection

22 1 Jim Bridger Landfill Inspection Report CCR Landfill Name: Jim Bridger Industrial Landfill Date: Inspected By: Inspection Frequency: Routine Weather/Seismic Event Other: Type of Landfill: Active Inactive Weather Conditions: Wet Dry Snow Cover Windy Other Operations Checks & Observations 1. Placement procedures are being followed. Yes No 2. Dust control is effective. Yes No 3. Dust control logs are complete and available. Yes No 4. Haul road maintained and dust controlled. Yes No Observations: Actions: None Maintenance Monitoring Engineering Notification/Work Order#: Cover (if applicable) None Animal burrows Animal damage Slope stability Settlement Cracks Problems Erosion Rills Seepage Ponding Other Cover Vegetation Gravel Soil Other 5. Exterior slopes in good condition, with no exposed CCR waste (non-beneficial). Yes No Observations: Actions: None Maintenance Monitoring Engineering Notification/Work Order#: Slopes & Perimeter Berms None Animal burrows Animal damage Slope stability Settlement Cracks Problems Erosion Rills Seepage Ponding Other Cover Vegetation Gravel Soil Other Observations 6. Slopes and berms provide positive drainage. Yes No Observations: Actions: None Maintenance Monitoring Engineering Issue Date: Rev. 2 Notification/Work Order#:

23 2 Erosion Sediment Controls Problems None Ditch Failure Debris Berms Ditch Washouts Sediment Bales/Waddles Other Observations 7. Erosion or sediment controls in good condition. Yes No 8. Drop inlet or other storm water controls structures are in good repair. Yes No 9. Perimeter run-on and run-off diversion ditches present and in good repair. Yes No Observations: Actions: None Maintenance Monitoring Engineering Notification/Work Order#: Other Observations 10. Temporary covers functioning as intended. Yes No 11. Storm water systems functioning as intended. Yes No 12. Any appearance of actual or potential structural weakness and other conditions which are disrupting or have the potential to disrupt the operation or safety of the CCR landfill? Yes No 13. Other non-structural or non-emergency safety issues. Yes No Observations: Actions: None Maintenance Monitoring Engineering Notification/Work Order#: Inspector Signature: Date: Issue Date: Rev. 2