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HomeMy WebLinkAboutNC0003417_20180322_ Amendment to Existing Renewal Application 4' DUKE H.F. Lee Energy Complex ENERGY® Duke Energy Progress 1199 Black Jack Church Road Goldsboro, NC 27530 March 22, 2018 RECEWVEDIDENRIDWA Mr. Jeffrey Poupart, Section Chief APR o 3 201 NC Division of Water Resources 1617 Mail Service Center Water Resources ;,el.mlttlnq Section Raleigh, NC 27699-1617 Subject. HF Lee Energy Complex Amendment to existing NPDES permit renewal application NC0003417 Wayne County Dear Mr. Poupart, Duke Energy Progress, LLC (Duke Energy) submits this letter to amend the pending NPDES permit application under consideration by the Division. The amendment is to follow up on several items of discussion between Duke Energy and the Division of Water Resources in a meeting on February 20, 2018. Below is a list of the items in question. The items in question are bolded and Duke Energy's response is italicized. 1) Please provide clarity on the ash beneficiation plant to be located at the HF Lee Energy Complex. Duke Energy is planning an ash beneficiation plant at the HF Lee Energy Complex. The project is still under design, however, Duke Energy has provided an updated narrative and flow diagram that includes a description of the plant and data from a similar, out of state, beneficiation plant. Duke Energy requests this information be used to develop an RPA for a new outfall to the Neuse River from the beneficiation plant. The new outfall will be located at approximately latitude 35°22' 18.84" N and longitude 78°06' 09.41W. 2) Please provide clarity on whether or not Duke Energy plans to construct an ash landfill at the HF Lee Energy Complex. Duke Energy has no plans to construct an ash landfill at the HF Lee Energy Complex. An updated narrative and flow diagram is included with this submittal to reflect the change and remove landfill leachate from the application. Also included with this amendment is an updated otherwise chemical used for two chemical coagulants. An updated narrative, flow diagram, and data from an ash beneficiation plant discharge are attached. If you have any questions regarding this letter, please contact Mr. Steve Cahoon at (919) 546-7457 or steve.cahoon@duke-energy.com. Mr. Jeff Poupart HF Lee Energy Complex NPDES Permit Application Update March, 2018 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 gather and evaluate 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 fines and imprisonment for knowing violations Respectfully Submitted, /,'°71 /f4-z l Jeff Hines General Manager, Lee Energy Complex Cc David May-DWR Washington Regional Office Steve Cahoon—NC 15 Mike Graham—HF Lee Shannon Langley—NCRH 15th floor H.F.Lee Energy Complex Duke Energy Progress,Inc. NC0003417 Attachment 3. Water Flow Line Drawing II.F Lee Energy Complex Collection Tanks 0 Wayne Co.CT Site and Drain Tanks Plant Processes anew Collection Sump F— EResiduaIs AOil Water from W R.Q.Reject Se forRetention ! Basins Wayne Co.CT Site (Sludge) ----> H. RO System ee LCC K Plant Other Law Volume > Processes P Wastes Beneticlation K Plant CT Site secondary containment and fuel 1-1 V I F forwarding area SW Zi HRSC blowdown to nulling Pnnd V V Oil Water Neuse River Outfall 003 or cooling pond¢X New Collection Sump t R Separator Outfall 002 Sump 7 (Sludge) A s mwwnu,� rrma�� Sludge Filter Cake AA t�,ra,� ,, —�offsite disposal Y OW extraction mid.ii,hai.gi.mail.6itaa ice well system «d�,tio �MergesFilter Press satical OC&im6Diii1'+i a Z,AA,BE nemearr Domestic Waste& Lee Do tie BB CC P AA iPotable Water Drains Sewage ���/// d v Residuals sent off site< Te0iNeuse River via System Ash pond outfall 001 Alternate Alum Sludge Path(rare) J Evaporation and (sludge seepage Water Treatment Evaporation Neuse River K Plant &Seepage Outfall 002 I yiIIA Y u Neuse River A HRSC blowdown Cooling Pond B River Make-up Intake R.O. Cleaning E } 0 V Cooling water intake N ) Condensers March 2018 Page A3-1 Duke Energy Progress,Inc. H.F.Lee Energy Complex Attachment 3 Estimated Average Flow (New Lee Combined Stream cycle site Comments A 12.7 MGD' Make-up water from Neuse River B 12.7 MOD Make-up water to cooling pond D 453 MGD Circulating Water withdrawal from cooling pond E 453 MGD Condenser cooling water return F - Lee Combined Cycle Plant Site wastewaters from oil/water separator (existing) I 11.3 MOD' Cooling pond evaporation&seepage(estimated) J 0.004 MOD Existing Lee site Sewage treatment system K 0.43 MGD Treated water to reverse osmosis system and plant processes M Rare Occurrence Cooling pond discharge to Neuse River(Outfall 002) N 453 MGD Condenser cooling water supply P Wayne County CT Site wastewaters from sump Iift station Q 2,400 gal/event Collection and drains Tank QOCW 2,400 gal/event New Wayne County CC Site wastewaters from oiUwater separator(for new Combined cycle) R 0.048 MOD Wastewater from filter plant,recirculated back to clarifier U 0.48 MGD Raw water to filter plant(cycle makeup) ✓ 0.168 MGD New WCT CC plant process drains W 0.036 R.O reject stream X 0.3MGD avg. (est.) Outfall 003 to Neuse river Y 0.3MGD avg. (est.) Outfall 003 wastewater flows to cooling pond Z 0.005 MGD Wastewater from beneficiation plant AA 1.8 MOD Est OW extraction well flow to treatment system BB 0.8 MGD Bulkfinterstrial ash pond water to treatment system CC 0.3 MOD Recirculated flow from treatment system to ash pond, 3/20/2018 Duke Energy Progress,Inc. H.F.Lee Energy Complex stormwater Z,AA,BB 1.8 MGD Est. flow from treatment system to Outfall 001 Note:"MGD"=Million Gallons per Day 1. Makeup from the Neuse River to the cooling pond varies throughout the year. Makeup volumes will equate to losses from evaporation and seepage to maintain lake level. 3/20/2018 Duke Energy Progress Inc. H.F.Lee Energy Complex NPDES Permit Number NC0003417 Attachment 4. Description of Operations Contributing to Wastewaters at Outfall 001. Outfall 002 and Outfall 003 The H.F Lee Energy Complex has retired and demolished three coal-fired generating units and four simple cycle combustion turbines. Commercial operation of the site's newly constructed 3 X 1 combined cycle electric generation block began on December 31, 2012. The site now consists of five (5) simple cycle combustion turbines and the combined cycle unit. Total electric generation capacity for the site is over 1800 Megawatts. The site will continue to utilize the existing 545 acre off-stream closed-cycle cooling pond for condenser cooling and process water. Water is withdrawn from the Neuse River, as required, to make up evaporative, seepage, and discharge losses from the cooling pond. Makeup pumping rates are highly variable depending upon natural weather conditions, generation load and plant operations, quantity of water available in the river, and pond water levels. The maximum normal operating level of the cooling pond is maintained at a safe level below the crest of the spillway gates. Discharges from the cooling pond are rarely made, usually only during an extremely heavy rainfall event or a hurricane. The cooling pond last discharged in 1998. Chemical constituents contained in the cooling pond discharge are, for the most part, representative of the naturally-occurring chemical quality and quantity of the intake water. Upon retirement of the coal fired units, waste streams from processes which historically went to the ash pond or the cooling pond will either no longer be generated or will be redirected to new outfall 003 to the Neuse River. More detail on these specific wastestreams is provided below. In addition to the permitted outfalls, backwash from intake screening devices may be discharged into the Neuse River bypass canal associated with the Neuse River pursuant to NCAC 15A 2H .0106 (f) (2). The combined cycle plant utilizes water from the 545 acre off-stream cooling pond as its source for fire water. Infrequently, flushing and testing of the fire system may result in releases of the fire water. The following is a description of wastewater streams that will be reflective of the new H.F Lee Energy Complex: Contributing Flows into the Ash Pond (NPDES outfall 001) The coal plant has been retired and no routine flows associated with coal fired generation are sent to the ash pond. Wastestreams from closure activities associated with the coal fired unit may still be sent to the ash pond until closure is complete. Duke Energy Progress, Inc.wishes to maintain outfall 001 as an active outfall to ensure permitted coverage of any incidental discharges which may occur associated with heavy rainfall events and to facilitate any needed groundwater remediation and dewatering for future closure of the wastewater treatment. Wastestreams that have been historically sent to the ash pond include: Ash Transport System Wastewater Fly ash and bottom ash from all three coal fired units were hydraulically conveyed by ash sluice pipelines to the Lee Plant ash pond. (Ceased) A4-1 March 2018 Duke Energy Progress Inc. H.F.Lee Energy Complex NPDES Permit Number NC0003417 Precipitator and Air Pre-heater Wash Water Water from washing the interior of the precipitators and air heaters is typically routed to the ash pond via the ash transport system but could be routed directly or indirectly to the cooling pond. The wastewater from the Rotamix treatment system added to Unit 3 for NOx removal is also routed to the ash pond. (Ceased) Filter Plant Wastewater Blowdown and filter backwash wastewater generated in the filter plant is discharged into the ash sluice transport system which flows to the ash pond. (To be redirected to outfall 003, recirculated or directed to Outfall 002) Wayne County Combustion Turbine Site Wastewaters The containments around the accessory module, liquid fuel, and atomizing air modules and the wash water drain empty into collection tanks. Once there is a quantity of liquid collected in the tanks, the wastewater is removed by pumper truck and transported offsite. The wash water drain tanks collect the water and detergent used to clean the CT compressors. (To be redirected to outfall 003, Outfall 002 or disposed of offsite after ash pond closure) Miscellaneous Wastes Cooling tower basin sludge, circulating water tunnel sediment, and boiler vacuuming sediments are sent to the ash pond. Other residuals from the low volume wastes retention basin and the coal pile runoff retention basin and other miscellaneous low volume wastes from plant processes are also transported to the ash pond. Storm water from the ash line trench flows into the ash pond. There may be seepage in the vicinity of the ash pond. Some seeps may be seasonal. Bulk water decanting/Interstitial Dewatering Bulk and interstitial ash basin water will be decanted/dewatered from the 1982 ash pond through Outfall 001. Additional wastewater equipment will be brought onsite to assist in the bulk and interstitial decanting/dewatering. The additional wastewater treatment consists of: • Ballasted flocculation; • Catalytic oxidation media filters; • Coagulant,polymer, and additive feed systems; • Ion exchange resin; • Reverse osmosis system; • Filter press trailers and sludge holding tanks Low volume wastes from the wastewater treatment system(WTS)as well as stormwater from the WTS pad area are recycled back to the ash pond. Sludge is removed from the system.The WTS will only discharge through Outfall 001. Groundwater Extraction Well System Duke Energy is currently designing an extraction well system to provide accelerated groundwater remediation. The groundwater will be treated prior to discharge through outfall 001. Treatment of the discharge may be provided by introducing the groundwater as a waste stream to the ash ponds(for A4-2 March 2018 Duke Energy Progress Inc. H.F.Lee Energy Complex NPDES Permit Number NC0003417 treatment through the WTS),direct treatment through the WTS,or direct treatment through a dedicated groundwater treatment system. Contributing Flows into the Cooling Pond (Closed Cycle) (NPDES outfall 002) Re-circulated Condenser Cooling Water This flow will provide condenser cooling water for the 3x 1 combined cycle generation units.The total flow is re-circulated into the 545 acre pond from the condensers, routed through the pond by baffle dikes to achieve maximum surface cooling efficiency before reaching the condenser cooling water intake to be again introduced to the condensers for cooling. Cooling of the recirculated water in the pond is achieved primarily by evaporation from the pond surface, which is estimated to consume approximately 3-5 MGD above natural evaporation rates during times the units are in full operation. Some flows from stormwater drains on the Lee plant site will still be directed to the cooling pond. Sewage Treatment System(limited use) Domestic waste is treated in a septic tank and sand filter bed system. Flow from the system is dependent upon fluctuating demand due to variations in the number of personnel on site. Residuals are disposed of off-site by a licensed contract disposal firm.The sand in the system is periodically changed to ensure system effectiveness is maintained. The spent sand is disinfected and disposed of in a landfill. Coal Pile Runoff Until the coal pile is completely removed, runoff will still be directed to the cooling pond. The coal pile area is surrounded by a drainage ditch that is routed to a clay-bottomed,asphalt and concrete-sided settling basin. The settling basin is sized so as to adequately store runoff and allow suspended solids to settle before the supernatant is discharged by overflow to the cooling pond. During routine maintenance of the basin,any solids removed will be disposed of in the active ash pond. (Ceased) Other During routine maintenance, the water treatment plant clarifier may be drained to the cooling pond to allow for inspection of the clarifier. This activity typically occurs annually but may occur more frequently. Additionally, should the filter press not be operational, clarifier solids may temporarily be directed to the wastewater cooling pond for a short duration until the filter press can be repaired. This is expected to be infrequent and will not be a routine operating mode. Wastewater associated with the cleaning the plant process reverse osmosis process unit will be taken offsite or directed to the cooling pond. If directed to the cooling pond an antifoam chemical may be added to the wastewater. A blowdown stream from the combined cycle Heat Recovery Steam Generator is directed to the cooling pond. In the near future the Lee Plant plans to construct piping to allow for all of the flows listed below which contribute to Outfall 003 to be discharged into the cooling pond. Including filter plant wastewater and existing Wayne County Combustion Turbine Site Wastewaters,which are described below. A4-3 March 2018 Duke Energy Progress Inc. H.F.Lee Energy Complex NPDES Permit Number NC0003417 Filter Plant Wastewater Existing water treatment plant clarifier blow down and filter backwash wastewater generated in the filter plant was previously discharged into the ash sluice transport system and to the ash pond. Filter backwash and clarifier alum solids will be treated via a gravity thickener and filter press. Filtrate from the filter press was previously commingled with other waste streams and directed to outfall 003. This flow has been rerouted and is now back to the water treatment plant clarifier. Solids from the filter press will be disposed of at an offsite location,or on rare occasion in the cooling pond. Existing Wayne County Combustion Turbine Site Wastewaters Water from the cooling pond passes through a clarifier,dual media sand filters and then through a five- micron cartridge pre-filter before entering either of two reverse osmosis (RO) units. The two RO units may be operated in parallel or series depending on operational needs. The treated water is stored in a tank until needed. Reject wastewater from the reverse osmosis process is sent to a sump where it will be routed to either the cooling pond(outfall 002)or outfall 003. In addition to the RO reject wastewater,excess evaporative cooling water, process drains, and waters from the oil water separator will be routed to the cooling pond(outfall 002) or routed to outfall 003. Historically, the containments around the accessory module, liquid fuel, and atomizing air modules empty into collection tanks. Once there is a quantity of liquid collected in the tanks, the wastewater is removed by pumper truck and transported and released into the Lee Plant ash pond. There is also a drain tank that collects the water and detergent used to clean the CT compressors. All of these wastewaters will be either pumped and hauled offsite or redirected to the cooling pond (outfall 002) or outfall 003 after the ash pond is no longer used. An oil water separator treats storm water from the containment areas around the facility's fuel oil storage tanks, the fuel forwarding pumps, and the fuel oil unloading area. Water from the oil water separator will be conveyed to the new collection sump and routed to outfall 003, or the cooling pond (outfall 002). Storm water collection containment areas around transformers and substations are examined for the presence of any oily substance; if oily substances are not present in the water, the water is drained to the ground. If oily substances are present nothing will be drained from the containments until that substance is properly removed. Outfall 003 will also contain a blowdown stream from the wet surface air cooler (WSAC). Wastewaters from routine cleaning, fuel oil/water condensate, false start materials, equipment drains containing potential oil, and compressor wash water may be routed to outfall 003. Any of these waters with a potential for containing oil are routed through the oil water separator before being sent to outfall 003. Incidental leaks associated with the routine operation of the combustion turbine heat recovery steam generator may occur and get to the ground surface. Other infrequent draining and cleaning of various process units during operation and maintenance activities may generate wastewater that will be routed to outfall 003. These wastewaters may also be routed to the cooling pond(outfall 002). Contributing flows to Outfall 003 Filter PIant Wastewater Existing water treatment plant clarifier blow down and filter backwash wastewater generated in the filter plant was previously discharged into the ash sluice transport system and to the ash pond. Filter A4-4 March 2018 Duke Energy Progress Inc. H.F.Lee Energy Complex NPDES Permit Number NC0003417 backwash and clarifier alum solids will be treated via a gravity thickener and filter press. Filtrate from the filter press was previously commingled with other waste streams and directed to outfall 003. This flow has been rerouted and is now back to the water treatment plant clarifier. Solids from the filter press will be disposed of at an offsite location,or on rare occasion in the cooling pond. Existing Wayne County Combustion Turbine Site Wastewaters Water from the cooling pond passes through a clarifier,dual media sand filters and then through a five- micron cartridge pre-filter before entering either of two reverse osmosis (RO)units.The two RO units may be operated in parallel or series depending on operational needs. The treated water is stored in a tank until needed. Reject wastewater from the reverse osmosis process is sent to a sump where it will be routed to either the cooling pond(outfall 002)or outfall 003. In addition to the RO reject wastewater, excess evaporative cooling water, process drains, and waters from the oil water separator will be routed to the cooling pond(outfall 002)or routed to outfall 003. Historically, the containments around the accessory module, liquid fuel, and atomizing air modules empty into collection tanks. Once there is a quantity of liquid collected in the tanks, the wastewater is removed by pumper truck and transported and released into the Lee Plant ash pond. There is also a . drain tank that collects the water and detergent used to clean the CT compressors. All of these wastewaters will be either pumped and hauled offsite or redirected to the cooling pond (outfall 002)or outfall 003 after the ash pond is no longer used. An oil water separator treats storm water from the containment areas around the facility's fuel oil storage tanks, the fuel forwarding pumps, and the fuel oil unloading area. Water from the oil water separator will be conveyed to the new collection sump and routed to outfall 003, or the cooling pond (outfall 002). Storm water collection containment areas around transformers and substations are examined for the presence of any oily substance; if oily substances are not present in the water, the water is drained to the ground. If oily substances are present nothing will be drained from the containments until that substance is properly removed. Outfall 003 will also contain a blowdown stream from the wet surface air cooler (WSAC). Wastewaters from routine cleaning, fuel oil/water condensate, false start materials, equipment drains containing potential oil,and compressor wash water may be routed to outfall 003. Any of these waters with a potential for containing oil are routed through the oil water separator before being sent to outfall 003. Incidental leaks associated with the routine operation of the combustion turbine heat recovery steam generator may occur and get to the ground surface. Other infrequent draining and cleaning of various process units during operation and maintenance activities may generate wastewater that will be routed to outfall 003. These wastewaters may also be routed to the cooling pond(outfall 002). Beneficiation Plant(new outfall) A planned coal ash beneficiation system is being designed for the site. Coal ash beneficiation is a process where ash is excavated from a basin and in essence re-burned to remove carbon to make the material suitable for reuse as a product in cement. The HF Lee Energy Complex is one of the three sites chosen by Duke Energy to comply with the mandate for beneficiation in the 2016 amendments to the Coal Ash Management Act. Ponded ash will be taken out of the basins and placed in an enclosed load-out area for use in the beneficiation unit. Small amounts of truck wash water and waste water for dust suppression will be A4-5 March 2018 Duke Energy Progress Inc. H.F.Lee Energy Complex NPDES Permit Number NC0003417 potential streams originating from the beneficiation facility. Any stormwater contacting ash would be collected in a sump,leading to a basin with a capacity to hold potential 25-year storm event.This basin discharges to an oil-water separator,then routed to one of the two proposed flow paths described below.These flows will typically be less than 0.005 MGD. Untreated wastewater analytical results are provided in Table 1. from an existing beneficiation facility in another State. This site is not owned by Duke Energy but is operated by the same company that will be operating the Buck and Cape Fear beneficiation system. Flows from the existing site where this data was obtained flow to the sites ash basin for treatment. Designs for the HF Lee beneficiation facility are in progress,however the flow path for any waste water generated by the facility would be a new outfall to the Neuse River. Duke Energy requests that Iimits and authorizations associated with a new outfall for the beneficiation plant be included in the renewed permit to avoid having to re-open the permit in the near future. A4-6 March 2018 Table 1.-Untreated Wash Water Data from another site Parameter CAS Analytical Number Method Result PQL MDL Units Alkalinity SM 2320B-20 59 10 2 mg/L Chloride 300 330 10 2 mg/L COD SM 5220D-20 23 10 8 mg/L pH 9040C 7.16 su Specific SM 2510B-20 2610 10 0.717 umhos/cm Conductance TDS SM 2540C-20 2200 10 3.4 mg/L TS SM 25408-20 2400 10 2.2 mg/L TSS SM 2540D-20 40 2 0.5 mg/L Aluminum 7429-90-5 60100 3.2 0.4 0.1 mg/L Antimony 7440-36-0 6010D 0.0079 0.02 0.007 mg/L Arsenic 7440-38-2 60100 0.08 0.015 0.0025 mg/L Barium 7440-39-3 60100 0.17 0.025 0.0031 mg/L Beryllium 7440-41-7 6010D ND 0.005 0.0006 mg/L Cadmium 7440-43-9 6010D 0.0009 0.005 0.0006 mg/L Calcium 7440-70-2 6010D 440 5 0.63 mg/L Chromium 7440-47-3 6010D 0.0064 0.01 0.0013 mg/L Cobalt 7440-48-4 6010D 0.0035 0.025 0.0031 mg/L Copper 7440-50-8 60100 ND 0.01 0.002 mg/L Iron 7439-89-6 6010D 1.5 0.1 0.04 mg/L Lead 7439-92-1 60100 0.0048 0.01 0.0047 mg/L Magnesium 7439-95-4 6010D 60 5 0.63 mg/L Manganese 7439-96-5 6010D 0.047 0.015 0.0019 mg/L Mercury 7439-97-6 7470A 0.000047 0.0001 0.000028 mg/L Nickel 7440-02-0 6010D 0.012 0.04 0.005 mg/L Potassium 7440-09-7 6010D 17 5 0.63 mg/L Selenium 7782-49-2 6010D 0.25 0.02 0.0085 mg/L Silver 7440-22-4 6010D ND 0.01 0.0021 mg/L Sodium 7440-23-5 60100 120 5 0.63 mg/L Thallium 7440-28-0 6010D ND 0.05 0.0063 mg/L Vanadium 7440-62-2 6010D 0.056 0.05 0.0063 mg/L Zinc 7440-66-6 6010D 0.036 0.02 0.0025 mg/L H. F. Lee Energy Complex Duke Energy Progress, Inc. NPDES Permit Number NC0003417 Attachment 5. Potential Discharges Not Covered By Analysis Estimated Quantity (used per Chemical year) Frequency Purpose NALCO Stabrex ST-70 800 gal As required Wet Surface Air Cooler biocide NALCO 3D Trasar 3DT 189 300 gal As required Wet Surface Air Cooler corrosion control NALCO BT 3000 150 lb As needed Boiler corrosion inhibitor Ammonium Hydroxide(19%) 1,200 gal As required Boiler condensate pH control NALCO Y302939.52 Sodium hypochlorite, 10-16% 34,000 gal As required Raw water biocide Winter alum liquid 36,000 gal As required Raw water treatment Caustic,25% tech grade 21,000 gal Continuous Raw water pH control Caustic, 50%tech grade 12,000 gal Continuous Ash pond pH control Soda Ash 4,000 lb As required Ash pond pH control Connect 6000 280 gal As required Wayne County Combustion Turbine Site Turbine compressor cleaning NALCO PC-77 110 gal As required Wayne County Combustion Turbine Site RO System membrane low pH cleaner NALCO PC 98 400 gal As required Wayne County Combustion Turbine Site RO System membrane high pH cleaner NALCO PermaTreat PC-191 220 gal Continuous Wayne County Combustion Turbine Site RO System antiscalant NALCO 7408 (sodium bisulfate) 880 gal As needed Various water stream dechlorination NALCO PC 11 variable As required Biocide for Reverse osmosis system Miscellaneous laboratory solutions 2 gal As required Wayne County Combustion and reagents Turbine Site RO water testing Nalco 7465 < 1 gallon As required Foam Control Nalco 7468 < 1 gallon As required Foam Control A5-1 March,2018 H. F.Lee Energy Complex Duke Energy Progress, Inc. NPDES Permit Number NC0003417 Sulfuric Acid As required pH adjustment of ash basin discharge Acetic Acid As required pH adjustment of ash basin discharge Citric Acid As required pH adjustment of ash basin discharge Hydrochloric acid As required pH adjustment of ash basin discharge Alum As required pH adjustment of ash basin discharge CO, As required pH adjustment of ash basin discharge Ferric chloride 7,500 gal As required Wastewater treatment additive Ferric sulfate 7,500 gal As required Wastewater treatment additive Ash Pond Water Wastewater Treatment System Chlorine Dioxide <500 As needed Biofouling control gallons Sulfuric Acid (98%) <500 As needed Membrane cleaning gallons ChemTreat P860E Polymer <1000 Continuous Polymer allons Ferric Chloride 30,000 Continuous Wastewater treatment additive gallons Sodium Hypochlorite 30,000 Continuous Wastewater treatment additive •allons Sodium Bisulfite 2,000 Continuous Wastewater treatment additive gallons ChemTreat RL9004 <1000 As needed Antiscalant gallons Sodium Hydroxide <10,000 Continuous Wastewater treatment additive gallons A5-2 March,2018