316(b) Supporting Documentation for NPDES Nutrien Ltd. Permit Renewal Kennewick Fertilizer Operations NPDES Permit WA0003671 – Kennewick Facility and NPDES Permit WA0003727 – Finely Facility 30 June 2020 Project No.: 0549532 The business of sustainability Signature Page 30 June 2020 316(b) Supporting Documentation for NPDES Permit Renewal Kennewick Fertilizer Operations NPDES Permit WA0003671 – Kennewick Facility and NPDES Permit WA0003727 – Finely Facility Kennewick, Washington David P. Edwards, L.G. Mich ael F. Mendes, L. G. Partner Project Manager Kurtis Schlicht Suzanne Dolberg, P.E. Technical Lead Deputy Project Manager Environmental Resources Management 1218 3rd Avenue, Suite 1412 Seattle, Washington 98101 T: +1 425 462 8591 F: +1 425 455 3573 © Copyright 2020 by ERM Worldwide Group Ltd and / or its affiliates (“ERM”). All rights reserved. No part of this work may be reproduced or transmitted in any form, or by any means, without the prior written permission of ERM. www.erm.com Version: 1.0 Project No.: 0549532 Client: Nutrien Ltd. 30 June 2020 Page iii Seattle\Projects\0549532\DM\28730H(316b).docx 316(B) SUPPORTING DOCUMENTATION FOR NPDES PERMIT CONTENTS RENEWAL CONTENTS 1. INTRODUCTION ................................................................................................................................ 1 2. §122.21(R)(2) SOURCE WATER PHYSICAL DATA ........................................................................ 3 3. §122.21(R)(3) COOLING WATER INTAKE STRUCTURE DATA .................................................. 15 4. §122.21(R)(4) SOURCE WATER BASELINE BIOLOGICAL CHARACTERIZATION DATA ........ 18 5. §122.21(R)(5) COOLING WATER SYSTEM DATA ........................................................................ 37 6. §122.21(R)(6) CHOSEN METHOD OF COMPLIANCE WITH IMPINGEMENT MORTALITY STANDARD ...................................................................................................................................... 40 7. §122.21(R)(7) ENTRAINMENT PERFORMANCE STUDIES .......................................................... 41 8. §122.21(R)(8) OPERATIONAL STATUS ......................................................................................... 42 9. REFERENCES ................................................................................................................................. 44 ATTACHMENT 1 FLOW DIAGRAM AND WATER BALANCE ATTACHMENT 2 ENGINEERING DRAWINGS ATTACHMENT 3 SITE PHOTOS ATTACHMENT 4 SPECIES LIFE HISTORIES List of Tables Table 1: List of Fish Species Occurring in the Columbia River Table 2: Abundant and Common Fish Species Occurring Near the Kennewick and Finley CWIS Table 3: Summary of Impingement Studies on the Middle Columbia River Table 4: Summary of Species Impinged in the Columbia River Table 5: Mean Length of Fish Impinged on Large and Small Rivers Table 6: Fish and Shellfish Species Susceptible to Impingement at the Kennewick and Finley CWIS Table 7: Fish and Shellfish Species Susceptible to Entrainment at Kennewick and Finley Table 8: Summary of the Risks to Chinook Salmon Related to Intake Structures By Entrainment (Energy Northwest 2019) Table 9: Typical Spawning Periods of Species Susceptible to Impingement at the Kennewick and Finley CWIS Table 10: Species Life Stages and Periods of Occurrence Most Susceptible to Entrainment at the Kennewick and Finley CWIS Table 11: USFWS and NOAA Threatened, Endangered and Protected Aquatic Species Table 12: Major Upgrades within the last 15 years at the Finley Facility List of Figures Figure 1: General Location of the Kennewick and Finley CWIS on the Columbia River Figure 2: Location of the Kennewick CWIS on the Columbia River Figure 3: River Cross Section at the Kennewick CWIS Figure 4: Location of the Finley CWIS on the Columbia River Figure 5: River Cross Section at the Finley CWIS Figure 6: Bathymetry at the Kennewick and Finley CWIS (National Oceanic and Atmospheric Administration) www.erm.com Version: 1.0 Project No.: 0549532 Client: Nutrien Ltd. 30 June 2020 Page 1 Seattle\Projects\0549532\DM\28730H(316b).docx 316(B) SUPPORTING DOCUMENTATION FOR NPDES PERMIT CONTENTS RENEWAL Figure 7: Average monthly stream temperature at USGS Gage 14105700 Columbia River near Dalles, Oregon 2006 through 2020 Figure 8: Average daily river temperature at USGS Gage 14105700 Columbia River near Dalles, Oregon 2006 through 2020 Figure 9: Specific conductance at Washington Department of Ecology Location ID 31A070 1990 through 2020 Figure 10: Dissolved Oxygen at Washington Department of Ecology Location ID 31A070 1990 through 2020 Figure 11: Columbia River Basin Map (U.S. Department of Interior Bureau of Reclamation) Figure 12: Discharge (cfs) at USGS 12472800 Columbia River below Priest Rapids Dam 1917 through 2020 Figure 13: Expected Hydraulic Zone of Influence at the Kennewick CWIS High Water Conditions with Two Pumps Figure 14: Expected Hydraulic Zone of Influence at the Kennewick CWIS Low Water Conditions with Two Pumps Figure 15: Expected Hydraulic Zone of Influence at the Finley CWIS High Water Conditions with One Pump Figure 16: Expected Hydraulic Zone of Influence at the Finley CWIS Low Water Conditions with One Pump Acronyms and Abbreviations AIF Actual intake flow BTA Best technology available C Celsius CFR Code of Federal Regulations cfs cubic feet per second CWA Clean Water Act CWIS Cooling water intake structures DIF Design intake flow DOE Department of Energy DVM Diel vertical migration E entrainment Ecology Washington State Department of Ecology EPRI Electric Power Research Institute ERM Environmental Resources Management FERC Federal Energy Regulatory Commission FWEE Foundation for Water and Energy Education gpm gallons per minute HGP Hanford Generating Project HZOI Hydraulic zone of influence IM Impingement mortality KFO Kennewick Fertilizer Operations MGD Million gallons per day NEPA National Environmental Policy Act NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System PNNL Pacific Northwest National Laboratory RM river mile USFWS United States Fish and Wildlife Service USGS United States Geological Survey YOY Young of the year www.erm.com Version: 1.0 Project No.: 0549532 Client: Nutrien Ltd. 30 June 2020 Page 2 Seattle\Projects\0549532\DM\28730H(316b).docx 316(B) SUPPORTING DOCUMENTATION FOR NPDES PERMIT INTRODUCTION RENEWAL NPDES Permit WA0003671 – Kennewick Facility and NPDES Permit WA0003727 – Finely Facility 1. INTRODUCTION ERM-West, Inc. (ERM), on behalf of Nutrien Ltd. (Nutrien), formerly Agrium Inc. (Agrium), completed a detailed compilation and review of available data and other resources related to meeting the requirements of the Clean Water Act (CWA) 316(b) rule issued on 14 October 2014. Nutrien, a manufacturer and wholesaler of nitrogen fertilizers, owns and operates the Kennewick Fertilizer Operations (KFO) facilities. The KFO facilities consist of three non-contiguous facilities located southeast of Kennewick, Washington in rural Benton County. The three facilities are known as the Hedges area, the Kennewick area, and the Finley area. The KFO facilities addressed in this report are the Kennewick and Finley areas (Figure 1). The Hedges facility is not subject to the 316(b) rule requirements and is therefore not addressed in this report. The Kennewick facility is located at 227515 East Bowles Road in Kennewick, Washington. The Kennewick facility is approximately 73 acres and manufactures nitric acid and liquid nitrogen fertilizer solutions. The Kennewick facility includes plant processing units, storage tanks, warehouses, shops, railroad spurs, administrative offices, and parking. The Finley facility is located at 231610 East Game Farm Road in Finley, Washington. The Finley facility receives anhydrous ammonia and stores it in two aboveground spherical pressure tanks and in one atmospheric pressure tank. Pipelines deliver ammonia from the Finley facility to the Kennewick facility, where the ammonia is used to manufacture nitric acid and solution fertilizer. The Finley facility is approximately 27 acres and has storage tanks, warehouses, shops, railroad spurs, administrative offices, and parking. Products are manufactured year-round at both facilities and do not follow seasonal trends. The Kennewick facility has a design intake flow (DIF) of approximately 37 million gallons per day (MGD) based on three circulating pumps, and the Finley facility has a DIF of 64.8 MGD based on five pumps. Both facilities withdraw water from water of the U.S., and use at least 25 percent of the water they withdraw exclusively for cooling purposes. Therefore, the both Kennewick and Finley are subject to requirements under section 316(b) of the CWA for existing regulated facilities that include production processes and product lines. This report was developed pursuant to the CWA 316(b) Rule promulgated on October 14, 2014 and covers those requirements defined and outlined in 40 CFR Section 125.92, 125.94(d), 125.95(a), and 122.21 (r). Focus in this report will be on the application requirements found in 122.21(r)(ii), which covers existing facilities and includes the information listed under (r)(2), (3), (4), (5), (6), (7), and (8). Nutrien believes the information submitted in this document supports the application requirements under 122.21 and demonstrates the Kennewick and Finley Facilities both operate a best technology available (BTA) that meets the standards for impingement mortality (IM) under 40 CFR §125.94(c)(1). Based on the Kennewick and Finley