Gage, Hannah From: Casey Vickerson <[email protected]> Sent: Monday, August 08, 2016 8:57 AM To: Gage, Hannah Cc: Lester, Guy; Stephen Cain Subject: 316(b) 122.21(r) Final Reports Attachments: McClellan Final 122.21r Information Document - 6-27-16.pdf; Fitzhugh Final 122.21r Information Document - 6-28-16.pdf; Bailey Final 122.21r Information 6-27-16 (1).pdf Good morning, Hannah, Please see the attached 316(b) 122.21(r) Final Reports to comply with permit requirements for AECC’s Bailey facility (Permit No. AR0000400, Part II.13), Fitzhugh facility (Permit No. AR001759, Part II.14), and McClellan facility (Permit No. AR0000841, Part II.13). Thanks, Casey Vickerson Environmental Engineer II Arkansas Electric Coop. Corp. 501.570.2102 1 John L . McClellan Generating Station 316(b) 122.21(r) Information Final Report, May , 20 1 6 iii ACKNOWLEDGMENTS The Electric Power Research Institute (EPRI) prepared this report with the assistance of t he following individuals and organizations, under contract to t he Electric Power Research Institute (EPRI) : Mr. David Bailey Ron Ulman and Associates 8819 Trafalgar C t. Springfield, VA 22151 Mr. Dan Bigbee EA Engineering, Science, and Technology, Inc. PBC 221 Sun Valley Boulevard, Suite D Lincoln, NE 68521 Mr. Kent Dixon EA Engineering, Science, and Technology, Inc. PBC 221 Sun Valley Boulevard, Suite D Lincoln, NE 68521 Mr. Nate Olken Alden Research Laboratory Inc. 30 Shrewsbury St., Holden, MA 01520 - 1843 iv EXECUTIVE SUMMARY This document is submitted in compliance with U.S. Environmental Protection Agency (“USEPA”) new f inal §316(b) regulations (“Rule”) for existing facilities that bec a me effective on October 14, 2014 for Arkansas Electric Cooperative Corporation ’s ( AECC ) John L. McClellan Generating Station ( McClellan ) . The Rule require s all facilities using a surface water intake flow greater than two million gallons per day ( MGD ) to employ or install best technology available (BTA) to reduce entrainment and impingement mortality. All facilities are required to submit the §122.21(r)(2) and (3) information and applicable provisions of the (r)(4) through (8) information for impingement that includes: (r)(2) – Source Water Physical Data (r)(3) – Cooling Water Intake Structure Data (r)(4) – Source Water Baseline Biological Characterization Data (r)(5) – Cooling Water System Data (r)(6) – Chosen Method of Compliance with the Impingement Mortality Standard (r)(7) – Entrainment Performance Studies (r)(8) – Operational Status All of this information is provided in th is document . The Rule’s entrainment information at §122.21(r)(9) through (12) is not included as this information is only required for facilities with an actual intake flow (AIF) that exceed s 125 MGD. M c C l ellan ’s maximum design intake flow is approximate ly 71 MGD (w e ll below the threshold) , and thus the AIF cannot exceed 125 MGD that requires submittal of the entrainment information. For impingement , McClellan should qualif y for a d e m inimis rate of impingement found at § 125.94(c)(11) of the Rule . This provision states , “ In limited circumstances, rates of impingement may be so low at a facility that additional impingement controls may not be justified. The Director, based on review of site - specific data submitted under 40 CFR 122.21(r), may conclude th at the documented rate of impingement at the cooling water intake is so low that no additional controls are warranted. For threatened or endangered species, all unauthorized take is prohibited by the Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.) . Notice of a determination that no additional impingement controls are warranted must be included in the draft or proposed permit and the Director’s response to all comments on this determination must be included in the record for the final permit.” AECC conducted a one - year impingement study at McClellan for compliance with the now remanded Phase II §316(b) Rule. Impingement samples were co llect ed over a 24 hour period every other week from January 5 th through December 19 th for a total of 25 sampling ev ents. During the course of the study a total of five live finfish were collected and 41 dead on arrival (DOA) fish whose mortality may or may not have been affected by McClellan’s cooling water intake structure ( CWIS ) . The majority of the impinged fish (8 7%) were G izzard S had , a common ubiquitous forage species. For the 25 sampling events ten of the events occurred when v McClellan was not operating , and the only reason the cooling water pumps were placed into operation was for the purpose of conducting the impingement study to estimate annual impingement under baseline (i.e., continuous year - round operation) conditions . All but nine of the fin fish (all DOA s ) impinge d occurred on the sampling da y s when the pumps were op erated solely for the purpose of the impingement study. The result is that under current normal operations the annual estimate of impingement mortality is nine (9) fish per year and th is uses the conservative assumption that the intake contributed to the mortality of these finfish . This equates to 0.75 finfish impinged per month. In addition to finfish, a total of 410 shellfish were collected , 97.6% of which were invasive exotic Asian C lams and Z ebra M ussels. The remaining species were nine crayfish and one native mussel. Based on the sampling , it is estimated 1,475 shellfish are impinged under actual operations. However, as discussed in Chapter 6, the Rule specifically allows zebra mussels, a nuisance species , to be excluded from the impingement numbe r , reducing shellfish impingement to 590 shellfish per year under normal operations. The Rule also allows ADEQ to name additional nuisance species , and AECC requests that ADEQ designate Asian Clams as a nuisance species since they are an exotic invasive s pecies that compete with native freshwater bivalves for food and habitat and have been known to clog condenser tubes and cause outages in power plants. If Asian clams are also excluded , then under normal facility operations zero (0) shellfish were entrain ed at McClellan during the 2006 study . Actual McClellan water flow during the 2006 study was 12,390 million gallons. This is directly comparable to McClellan’s average annual facility flow of 12,281 million gallons over the past fi ve years (see Table 3 - 1 in Chapter 3) , and therefore , the 2006 study is representative of current operations. A complete copy of the 2006 impingement study report is provided as Appendix A of this document. As noted in the §122.21(r)(4)(vi) information in Chapter 4, t he USFWS website and other resources were checked for the presence of f ederally protected threatened and endangered species and their designated critical habitat. No federal ly threatened and endangered finfish or their designated critical hab itat were identified for the Ouachita River. However, five species of federally protected freshwater mussel species were identified as being potentially present in the vicinity of McClellan that included: 1. Ouachita Rock Pocketbook ( Arkansia wheeleri ) – End angered 2. Spectaclecase ( Cumberlandia monodonta) – Endangered 3. Pink Mucket ( Lampsilis abrupta) - En dangered 4. Rabbitsfoot ( Quadrula cylindrical cylindrical ) - Threat ened 5. Winged Mapleleaf ( Streptanthus hyacinthoides ) – Endangered As discussed in Chapter 4, no observation references were found for occurrences for any of these species. A single Spectaclecase was reported five miles upstream of McClellan. Designated critical habitat for the Ouachita River was listed for only the Rabbitsfoot. That designated cri tical habitat extends from the confluence of the Little Missouri River with the Ouachita River at River Mile (RM) 385 downstream to RM 332.4. McClella n’s CWIS is located almost five that vi Insert Appropriate Auto Text License Entry. If license is copyright, please delete there is no reasonable potential to have no more than minor detrimen tal effects 1 to f ederally - listed species and designated critical habitat as a result of the operation of the McClellan CWIS. This is supported by: no impingement of finfish , eliminating risk of any f ederally protected species glochidia attached to the gill s of impinged fish, no impingement of f ederally protected shellfish, the small percentage of water withdrawn from the Ouachita River flowing past the CWIS (i.e., average is 1.8%), and current operations over the past five years have average d approximately a third of the maximum design flow. As a result of providing data and information to support d e m inimis levels of impingement and no more than a minor risk of detrimental effects to f ederally - listed species and their designated critical ha bitat , McClellan’s existing CWIS should qualify as BTA for impingement. 1 See page 48383, 1 st Col., 1 st Full paragraph of Federal Register/Vol. 79, No. 158. As the standard below which the risk is not considered to warrant action in the permit. vii CONTENTS EXECUTIVE SUMMARY ................................ ................................ ................................ ........... V 1 INTRODUCTION ................................ ................................ ................................ ................... 14 General § 316(b) Rule Overview ................................ ................................ ........................... 14 Background ................................ ................................ ................................ .......................... 15