ML25024A131

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Terrapower CP Env Docs - NPDES Permit Application Requirements, 40 CFR 122.21(r)(2) – (8), Naughton Power Plant, Wyoming, Prepared for, Pacificorp, Inc., Jan 2018, CH2MHill
ML25024A131
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NPDES Permit Application Requirements, 40 CFR 122.21(r)(2) - (8),

Naughton Power Plant, Wyoming, Prepared for, PacifiCorp, Inc., Jan 2018, CH2MHill Attachments:

HYD-05_PacifiCorp 2018.pdf William K. Burris, P.G.

Environmental Project Manager Environmental Center of Expertise Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Rockville, MD william.burris@nrc.gov 301-415-1621

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F I N A L NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8)

Naughton Power Plant, Wyoming Prepared for PacifiCorp, Inc.

January 2018 CH2M HILL Engineers, Inc.

4246 S. Riverboat Road Suite 210 Taylorsville, UT 84123 TP-LIC-LET-0362

Contents Section Page Acronyms and Abbreviations.............................................................................................................. v 1

(r)(2) Source Water Body Physical Data................................................................................ 1-1 1.1 Introduction..................................................................................................................... 1-1 1.2 Description of Source Water Body.................................................................................. 1-1 1.3 Location Map................................................................................................................... 1-2 1.4 Source Water Body Physical Characteristics.................................................................... 1-2 1.4.1 Hydrological Characteristics............................................................................... 1-2 1.4.2 Geomorphological Characteristics...................................................................... 1-4 1.4.3 Intake Hydraulic Zone of Influence..................................................................... 1-4 2

(r)(3) Cooling Water Intake Structure Data........................................................................... 2-1 2.1 Facility Description........................................................................................................... 2-1 2.2 Cooling Water Intake Structure Configuration................................................................ 2-1 2.2.1 Naughton CWIS: Units 1 and 2 Intake Bay.......................................................... 2-2 2.2.2 Naughton CWIS: Unit 3 Intake Bay..................................................................... 2-2 2.2.3 Location of Cooling Water Intake Structure..................................................... 2-12 2.3 Cooling Water Intake Structure Operation.................................................................... 2-12 2.3.1 Design Intake Flows.......................................................................................... 2-12 2.3.2 Actual Intake Flows........................................................................................... 2-12 2.3.3 CWIS Velocities................................................................................................. 2-13 2.3.4 Hourly, Daily, and Seasonal Operation............................................................. 2-13 2.3.5 Cooling Water Intake Pumps............................................................................ 2-14 3

(r)(4) Source Water Baseline Biological Characterization Data.............................................. 3-1 3.1 Introduction..................................................................................................................... 3-1 3.2 Fish and Shellfish Species and Habitats in the Vicinity of the CWIS................................ 3-1 3.2.1 Site Conditions and Habitats............................................................................... 3-1 3.2.2 Fish Species......................................................................................................... 3-2 3.2.3 Shellfish Species.................................................................................................. 3-3 3.2.4 Reproduction and Larval Recruitment................................................................ 3-3 3.2.5 Seasonal and Daily Activities.............................................................................. 3-3 3.2.6 Characterization of Species in the Vicinity of the CWIS..................................... 3-4 3.3 Species of Concern and Rare, Threatened, and Endangered Species............................. 3-6 3.3.1 Federal Agency Consultation.............................................................................. 3-6 3.3.2 State Agency Consultation.................................................................................. 3-6 4

(r)(5) Cooling Water System Data........................................................................................ 4-1 4.1 Introduction..................................................................................................................... 4-1 4.2 Cooling Water System Operations................................................................................... 4-1 4.3 Flow Distribution.............................................................................................................. 4-2 4.4 Distribution of Water Reuse............................................................................................ 4-3 4.5 Water Withdrawals.......................................................................................................... 4-3 4.5.1 Reductions to Total Withdrawal......................................................................... 4-3 4.5.2 Proportion of Source Water Body Withdrawn................................................... 4-4 4.6 Daily and Seasonal Cooling Water Uses.......................................................................... 4-4 4.7 Cooling Water System Technologies and Operational Measures................................... 4-5 TP-LIC-LET-0362

4.7.1 Impingement Technologies or Operational Measures....................................... 4-5 4.7.2 Entrainment Technologies or Operational Measures........................................ 4-5 5

(r)(6) Chosen Method of Compliance for CWIS..................................................................... 5-1 6

(r)(7) Entrainment Studies................................................................................................... 6-1 7

(r)(8) Operational Status..................................................................................................... 7-1 7.1 Introduction..................................................................................................................... 7-1 7.2 Operation Status of Each Unit......................................................................................... 7-1 7.2.1 Age of Units......................................................................................................... 7-1 7.2.2 Capacity Utilization Rates................................................................................... 7-1 7.2.3 Unit Upgrades..................................................................................................... 7-2 7.2.4 New Unit Planning.............................................................................................. 7-2 8

References.......................................................................................................................... 8-1 Appendixes A

Naughton HZI Calculations B

Naughton CWIS Velocity Calculations C

Letter to U.S. Fish and Wildlife Service Tables 2-1 Naughton CWIS Design Intake Flows.......................................................................................... 2-12 2-2 Naughton CWIS Actual Intake Flows (June 2016 - June 2017)................................................... 2-12 2-3 Through-Opening/Through-Screen Velocities (fps).................................................................... 2-13 2-4 Summary of Cooling Water Intake Data..................................................................................... 2-14 3-1 Hams Fork River Fish Species........................................................................................................ 3-2 4-1 Cooling Tower Data....................................................................................................................... 4-2 4-2 CWIS Flow Distribution Under Average Actual Intake Flow Condition......................................... 4-3 4-3 Proportion of Source Water Body Withdrawn at Naughton CWIS............................................... 4-4 Figures 1-1 General Location Map................................................................................................................... 1-3 2-1 Water Balance Diagram............................................................................................................... 2-3 2-2 Site Plan and Location Map.......................................................................................................... 2-5 2-3 Unit 1 and Unit 2 Intake Bay Plan................................................................................................. 2-6 2-4 Unit 1 and Unit 2 Intake Bay Section............................................................................................ 2-7 2-5 Unit 3 Intake Bay Plan................................................................................................................... 2-8 2-6 Unit 3 Intake Bay Section.............................................................................................................. 2-9 2-7 Naughton Intake Bays................................................................................................................. 2-10 2-8 CWIS Diversion Structure............................................................................................................ 2-11 4-1 Average Monthly Actual Intake Flow at Naughton CWIS............................................................. 4-5 TP-LIC-LET-0362

Acronyms and Abbreviations

°C degrees Celsius

°F degrees Fahrenheit AIF actual intake flow CFR Code of Federal Regulations cfs cubic feet per second cm centimeter CUR capacity utilization rate CWIS cooling water intake structure DIF design intake flow EPA U.S. Environmental Protection Agency fps foot/feet per second gpm gallons per minute HZI hydraulic zone of influence IM impingement mortality mg/L milligram(s) per liter mgd million gallons per day MW megawatt Naughton Naughton Power Plant NPDES National Pollutant Discharge Elimination System PAR permit application requirement SWAP (Wyoming) State Wildlife Action Plan U.S.

United States USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey WGFD Wyoming Game and Fish Department WYDEQ Wyoming Department of Environmental Quality TP-LIC-LET-0362

(r)(2) Source Water Body Physical Data 1.1 Introduction The purpose of this permit application requirement (PAR) is to provide information on the physical attributes of the Hams Fork River in the vicinity of the cooling water intake structure (CWIS) in support of the Wyoming Pollutant Discharge Elimination System permit application for Naughton Power Plant (Naughton). The information provided here is consistent with the U.S. Environmental Protection Agencys (EPA) Final Regulations to Establish Requirements for CWIS at Existing Facilities and Amend Requirements at Phase I Facilities (40 Code of Federal Regulations [CFR] Part 122).

This section provides the applicable information required under §122.21(r)(2) - Source Water Physical Data. This PAR calls for the following information:

Narrative description and scaled drawings showing the physical configuration of all source water bodies used by the facility including areal dimensions, depths, salinity and temperature regimes, and other documentation that supports the determination of water body type where each CWIS is located Identification and characterization of the source water bodys hydrological and geomorphologic features, as well as the methods used to conduct any physical studies to determine the intakes area of influence within the water body and the results of such studies Location map 1.2 Description of Source Water Body Source water body descriptions for Naughton were compiled from a variety of sources, including the Wyoming Water Development Commission Basin Planning Program report titled 2010 Green River Basin Water Plan Final Report (WWC Engineering et al., 2010), the Green River Basin Plan - 2010 Technical Memorandum (Wyoming Water Development Office, 2010), the Blacks Fork River Watershed Study, Level 1, Phase 1: Hams Fork (Anderson Consulting Engineers, 2015), annual monitoring data from the U.S. Geological Survey (USGS) Hams Fork River stream gauging stations, and confidential PacifiCorp technical information. Naughton was commissioned in 1963 on a 1,120-acre site near Kemmerer, Wyoming. Two additional units were commissioned between 1963 and 1971, bringing the total gross generating capacity of Naughton to 725 megawatts (MW). Cooling water for Naughton is drawn from the Hams Fork River at a diversion structure and is conveyed via a buried pipeline approximately 7 miles to Naughton.

The Hams Fork River headwaters are found in the upper reaches of the southern Wyoming Mountain Range near 10,000 feet in elevation. Many smaller tributaries join to form the upper portion of the Hams Fork River before it reaches Lake Viva Naughton. The smaller Kemmerer Reservoir is just below Lake Viva Naughton and both are used to regulate the water supply for irrigation, municipal, private, and ecological uses. The tailwaters area of the Hams Fork River below the two reservoirs is a popular sport fishery that can be floated in high water during the spring and early summer, and waded during other times. The river in the vicinity of the CWIS ranges from 30 to 60 feet wide and up to 15 feet deep in pools.

TP-LIC-LET-0362

1.3 Location Map Figure 1-1 shows the source water body available for Naughton cooling water along with the general location of Naughton and the CWIS on the Hams Fork River, respectively.

1.4 Source Water Body Physical Characteristics 1.4.1 Hydrological Characteristics Surface water quantity is recorded by a USGS stream gaging station below Lake Viva Naughton and above Kemmerer Reservoir. Streamflow varies from season to season and year to year as a function of the variability of precipitation and the consumptive uses in the region. The average yearly mean flow of the Hams Fork River, approximately 10 miles upstream of the CWIS, is 112 cubic feet per second (cfs) since data collection began at the site on August 2, 2007. Notably, the highest annual mean was 246 cfs in 2011 and the lowest annual mean was 44.9 cfs in 2016. The highest daily mean for water years 2008 to 2016 was 1,130 cfs on June 28, 2011. The lowest daily mean for the same water years was zero cfs on March 20, 2011 (USGS, 2017).

The Hams Fork River below Viva Naughton Reservoir is classified as Class 2AB designation (WYDEQ, 2013a). Class 2AB waters are those waters known to support game fish populations or spawning and nursery areas, at least seasonally, and all their perennial tributaries and adjacent wetlands and where a game fishery and drinking water use is otherwise attainable. Class 2AB waters include all permanent and seasonal game fisheries and can be either cold water or warm water depending on the predominance of cold water or warm water species present. All Class 2AB waters are designated as cold-water game fisheries unless identified as a warm water game fishery by a ww notation in the Wyoming Surface Water Classification List. Class 2AB waters are also protected for nongame fisheries, fish consumption, aquatic life other than fish, recreation, wildlife, industry, agriculture, and scenic value uses (WYDEQ, 2013a).

The Hams Fork River, below Lake Viva Naughton and Kemmerer Reservoir, has water quality characteristics generally within the acceptable ranges set by the Wyoming Department of Environmental Quality (WYDEQ) in Chapter 1 of the state Water Quality Rules (WYDEQ, 2013b). The Hams Fork River contains median dissolved solids concentrations of less than 500 milligrams per liter (mg/L). The Hams Fork River and water bodies in the drainage basin are generally within the acceptable water quality pH range of 6.5 and 9.0, which is set by WYDEQ. However, pH readings below Kemmerer Reservoir range between 8.0 and 9.5 constantly and in general indicate that the water below the reservoir is slightly alkaline. Temperatures in the river and the water bodies within the basin generally vary from 32 degrees Fahrenheit (°F) (0 degrees Celsius [°C]) in the winter months to approximately 70°F (21°C) in the summer months.

The concentrations of total phosphorous in the Hams Fork River Basin rarely exceed levels recommended to protect reservoirs and lakes from nuisance growth of algae and other aquatic plants.

One sample taken below Kemmerer Reservoir exceeded the recommended concentration of total phosphate as phosphorus for streams entering lakes and reservoirs established to prevent and control nuisance algal blooms of 0.05 mg/L (EPA, 2001). Most of the sediment in the Hams Fork River drainage is deposited in Lake Viva Naughton and the Kemmerer Reservoir with little impact on downstream portions of the river. Bacteria concentrations in the Hams Fork River vary, but no samples exceed the WYDEQ surface water standard for fecal coliform bacteria (WYDEQ, 2013a, 2013b; USGS, 1993).

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North 0

6 3

Approximate scale in miles Figure 1-1 General Location Map Naughton Power Plant Aerial photo source: Google ©2017, modified by CH2M HILL.

Kemmerer, WY Kemmerer, WY 189 Naughton Power Plant Naughton Hams Fork CWIS Kemmerer Reservoir Lake Viva Naughton 189 30 30 TP-LIC-LET-0362

1.4.2 Geomorphological Characteristics The watershed of the Upper Hams Fork River is the main drainage of the southern Wyoming Range and a major tributary of the Green River and covers parts of southwestern Wyoming. The Upper Hams Fork River is approximately 80 miles long and originates from snowmelt and precipitation in the Wyoming Mountains before flowing through southwestern Wyoming. The riverbank near the CWIS is characterized by steep gradients and steeply constructed banks that help prevent the erosion of the surrounding infrastructure and developments.

The main stem of the upstream portion of the Hams Fork River above Viva Naughton and Kemmerer reservoirs predominately runs through Bridger-Teton National Forest and is generally unaffected by water withdrawals. Below the reservoirs, water is diverted for domestic water, irrigation, and industrial uses. Naughton is the largest industrial water user in the Upper Hams Fork River Basin, accounting for about 70 percent of the industrial water use. Stream diversions and the use of surface water supplies for agricultural, industrial, or municipal uses affect the quality and availability of water to support fish and the aquatic life ecosystem in the Lower Hams Fork drainage. Reductions in streamflow can affect the quality of water by increasing temperatures and concentrations of constituents deleterious to aquatic life. Lower stream flows can also impact the composition and distribution of wetland and riparian habitats critical to amphibians, birds, waterfowl, and mammals in an arid environment. Likewise, substantial reductions or fluctuations in surface water levels on reservoirs can impact the amount and quality of water to support fish and angling.

Two dams store and regulate Hams Fork River water flows for downstream users and mark the division of the Upper and Lower Hams Fork River drainages: the Kemmerer City Dam and the Viva Naughton Dam, both located a short distance upstream from the Naughton CWIS. The Viva Naughton Dam was commissioned by PacifiCorp to store water for Naughton and the Kemmerer Reservoir provides additional impoundment for public drinking and irrigation water. The Hams Fork River eventually merges with the Blacks Fork River and flows to the Green River.

1.4.3 Intake Hydraulic Zone of Influence Analysis of the hydraulic zone of influence (HZI) that the Naughton CWIS has at the diversion from the Hams Fork River is included in this subsection, while full calculations are found in Appendix A. The HZI is determined by comparing intake velocities of the CWIS to natural velocities in the source water body, the Hams Fork River. If the CWIS intake velocity is less than the river velocity, then the effective HZI does not extend beyond the intake opening. If the CWIS intake velocity is greater than the river velocity, then the limits of the HZI extend radially from the CWIS to a point of constant velocity. The point of constant velocity between the intake and river occurs where the intake velocity has dissipated to be equal to the river velocity.

Intake velocities for this analysis are those calculated at the intake opening for each of the two intake bays under average actual intake flows (AIFs) and a low water surface elevation of 6,969.5 feet, presented in full in later sections of this report and Appendix B. Velocities at the Naughton CWIS ranged from approximately 0.27 foot per second (fps) at the intake opening to the Unit 3 intake bay, up to 0.86 fps at the intake opening to the Units 1 and 2 intake bay. The Units 1 and 2 intake opening is beveled, with a velocity of 0.86 fps calculated for the most constricted cross section, at the entrance to the intake bay. At the face of the CWIS, the intake opening is 1 foot larger in both width and height, resulting in a lower velocity of 0.46 fps at the outer face of the CWIS. This velocity is less than the average river velocity; therefore, the HZI does not extend out into the river beyond the face of the CWIS, and potential impacts associated with the HZI on critical habitat and migratory fish are expected to be minimal.

The river velocities for the Hams Fork River are calculated as the approach velocity to the radial gate diversion under average annual discharge conditions. Average annual discharge for the Hams Fork River TP-LIC-LET-0362

was determined to be approximately 116.9 cfs from publicly available USGS gage station data dated August 2007 through October 2016 (USGS, 2017). The cross-sectional area of the river at the CWIS is determined by the radial gate diversion structure, ultimately resulting in an average river velocity of approximately 0.66 fps.

The through opening velocity for the Units 1 and 2 intake bay of 0.86 fps is greater than the average river velocity. However, the beveled intake opening is larger at the face of the CWIS, resulting in a lower velocity of 0.46 fps. This velocity is less than the average river velocity; therefore, the HZI does not extend out into the river beyond the face of the CWIS, and potential impacts associated with the HZI on critical habitat and migratory fish are expected to be minimal.

TP-LIC-LET-0362

(r)(3) Cooling Water Intake Structure Data This section provides the information required under §122.21(r)(3) - CWIS Data. This PAR calls for the following information:

A narrative description of the configuration of each CWIS and where it is in the water body and in the water column Latitude and longitude in degrees, minutes, and seconds for each CWIS A narrative description of the operation of each CWIS, including design intake flows (DIFs), daily hours of operation, number of days of the year in operation, and seasonal changes, if applicable A flow distribution and water balance diagram including all sources of water to the facility, recirculating flows, and discharges Engineering drawings of the CWIS 2.1 Facility Description Naughton is a coal-fired power generation facility located in western Wyoming approximately 4 miles southwest of the community of Kemmerer in Lincoln County, Wyoming (Figure 1-1). Naughton presently operates three coal-powered units with a total station output of 700 MW. Naughton uses a closed-cycle, recirculating cooling water system. Water for cooling is withdrawn from a single CWIS located on the western shoreline of the Hams Fork River, approximately 7 miles north of Naughton. The intake structure is hereafter referred to as the Naughton CWIS. Flow from the river is controlled by two radial gates spanning across the river. The Naughton CWIS was originally constructed with one intake bay to provide raw water for Units 1 and 2, with a second intake bay later added to the CWIS when Unit 3 was completed and additional raw water supply was required. The two intake bays each discharge to one of two independent underground pipelines running south to Naughton. Both pipelines discharge at the settling basin, where river water flow is combined. Water is then pumped out of the settling basin to the individual units for cooling, as well as to various systems within Naughton for noncooling uses. This settling basin serves as a clarifying pond and provides balancing between Naughton water use demands and the river water intake flow. A water balance diagram is provided as Figure 2-1.

2.2 Cooling Water Intake Structure Configuration This section describes and illustrates the following:

Existing layout of the CWIS and the location of the structures in the water body and in the water column Existing components including, but not limited to, intake pumps, traveling screens, and references to relevant reports for detailed descriptions Naughton uses a closed-cycle recirculating cooling water system with makeup water drawn from the Hams Fork River. Hereafter, the original intake bay is designated as the Units 1 and 2 Intake Bay, while the second intake bay is designated as the Unit 3 Intake Bay. The two intake bays each have an independent underground pipeline running south to Naughton, though all river water flow combines at the settling basin where both pipelines discharge. Each intake bay is evaluated independently due to differences in flow rate and dimensions. Figure 2-2 shows the location of the CWIS relative to Naughton and the route of the underground pipelines.

TP-LIC-LET-0362

2.2.1 Naughton CWIS: Units 1 and 2 Intake Bay The Naughton CWIS is a reinforced concrete intake structure with a single intake bay devoted to Units 1 and 2. This portion of the CWIS for Units 1 and 2 has three raw water pumps. The intake includes a small opening at the face of the structure, and screening provided before the pumps by an angled trashrack and a vertical traveling screen. This section provides a detailed description of the CWIS. A summary of pertinent CWIS data is provided at the end of Section 2, and engineering drawings of the Units 1 and 2 intake bay are located on Figures 2-3 and 2-4 (plan and section view, respectively).

At the east face of the intake along the river, the CWIS is 18 feet-6 inches wide and 13 feet high from the CWIS invert up to the top deck. The intake opening on the CWIS face is rectangular with dimensions of 4 feet 2 inches wide and 2 feet high. Water flows through the intake bay with slots for stop logs positioned immediately behind the entrance. The trashrack is angled at 2.5 feet horizontally and 12 feet vertically and has 3/8-inch thick vertical bars spaced at 3-inch on center. Five horizontal supports for the trashrack are 2 inches wide each and spaced at 2 feet 2 inches on center. A single, vertical traveling screen is located downstream from the trashrack with square 3/8-inch mesh openings, and 0.105-inch diameter #12 Washburn & Moen (W&M) steel wire. The bay width at the traveling screens is 4 feet 2 inches, though the screening baskets have an effective tray width of 3 feet. After the vertical traveling screen, flow opens to the full internal width of the CWIS of 16 feet 6 inches and is withdrawn by the three raw water pumps. Each pump is separated by a concrete wall at the rear of the structure.

Spraywash for the vertical traveling screen is drawn from the discharge header of the raw water pumps and does not withdraw additional flow directly from the CWIS.

Water is conveyed from the CWIS to the settling basin by an underground, 20-inch-diameter steel pipeline. A separate, underground, 20-inch-diameter steel pipeline runs parallel to convey water withdrawn by the intake bay designated for Unit 3. Figure 2-2 shows the route of both pipelines. The Units 1 and 2 pipeline is designated as Existing Pipeline and the Unit 3 pipeline is designated as New Pipeline. The pipelines parallel each other along the same route from the CWIS to Naughton.

2.2.2 Naughton CWIS: Unit 3 Intake Bay The Naughton CWIS was expanded since its original construction to provide a separate intake bay to provide additional water supply needed for Unit 3. This intake bay is similar in setup to the original intake bay devoted to Units 1 and 2, with a single intake bay, a small opening at the face of the structure, and screening provided before the pumps by an angled trashrack and a vertical traveling screen. This portion of the CWIS for Unit 3 has two raw water pumps. The intake bay for Unit 3 is set farther off the shoreline than the Units 1 and 2 intake bay, with a 7-foot-high intake tunnel conveying water from the shoreline to the intake entrance. This section provides a detailed description of the CWIS. A summary of pertinent CWIS data is provided at the end of Section 2, engineering drawings of the Unit 3 intake bay are located on Figures 2-5 and 2-6 (plan and section view, respectively), and photos of the CWIS are provided on Figures 2-7 and 2-8.

The CWIS is 13 feet high from the CWIS invert up to the top deck at the entrance side (east end) of the structure. The intake opening on the CWIS face is rectangular with dimensions of 4 feet 2 inches wide and 7 feet high. Water flows past the opening through a single 4-foot 2-inch-wide bay with slots for stop logs positioned immediately behind the entrance. The trashrack is angled at 2.5 feet horizontally and 12 feet vertically and has 3/8-inch-thick vertical bars spaced at 3-inch on center. Five horizontal supports for the trashrack are 2-inch wide each and spaced at 2 feet 2 inches on center. A single vertical traveling screen is located downstream from the trashrack with square 3/8-inch mesh openings, and 0.105-inch diameter #12 W&M steel wire. The bay width at the traveling screens is 4 feet 2 inches, though the screening baskets have an effective tray width of 3 feet. After the vertical traveling screen, flow opens to the full internal width of the CWIS of approximately 13 feet 11 inches and is withdrawn by the two raw water pumps. Each pump is separated by a concrete wall at the rear of the structure. Spraywash for the vertical traveling screen is drawn from the discharge header of the raw water pumps and does not withdraw additional flow directly from the CWIS.

TP-LIC-LET-0362

Figure 2-1 Water Balance Diagram Naughton Power Plant TP-LIC-LET-0362

Figure 2-2 Site Plan and Location Map Naughton Power Plant TP-LIC-LET-0362

Figure 2-3 Unit 1 and Unit 2 Intake Bay Plan Naughton Power Plant TP-LIC-LET-0362

Figure 2-4 Unit 1 and Unit 2 Intake Bay Section Naughton Power Plant TP-LIC-LET-0362

Figure 2-5 Unit 3 Intake Bay Plan Naughton Power Plant TP-LIC-LET-0362 SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2024 TerraPower, LLC. All Rights Reserved

Figure 2-6 Unit 3 Intake Bay Section Naughton Power Plant TP-LIC-LET-0362

Figure 2-7 Naughton Intake Bays Naughton Power Plant TP-LIC-LET-0362

Figure 2-8 CWIS Diversion Structure Naughton Power Plant TP-LIC-LET-0362

Water is conveyed from the CWIS to the settling basin by an underground, 20-inch-diameter steel pipeline. A separate, underground, 20-inch-diameter steel pipeline runs parallel from the CWIS to Naughton to convey water withdrawn by the intake bay designated for Units 1 and 2. Figure 2-2 shows the route of both pipelines. The Units 1 and 2 pipeline is designated as Existing Pipeline and the Unit 3 pipeline is designated as New Pipeline.

2.2.3 Location of Cooling Water Intake Structure The Naughton CWIS is located perpendicular to the western shore of the Hams Fork River, in Kemmerer, Wyoming, as shown on Figure 1-1. Coordinates of the Naughton CWIS are 41°51'28.54"N, 110°33'52.00"W.

2.3 Cooling Water Intake Structure Operation 2.3.1 Design Intake Flows The DIF of the Naughton CWIS is based on the total design pumping capacity of all pumps in combination (Table 2-1).

Table 2-1. Naughton CWIS Design Intake Flows NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8), Naughton Power Plant, Wyoming Intake Bay Number of Pumps Design Capacity per Pump (gpm)

Total Design Intake Flow (gpm)

Units 1 and 2 3

2,500 7,500 Unit 3 2

6,000 12,000 TOTAL:

5 19,500 Note:

gpm = gallons per minute The Naughton CWIS has a total DIF of 19,500 gpm (28.1 million gallons per day [mgd]) including the flow from both intake bays. Units 1 and 2 utilize three intake pumps with a rated design capacity of 2,500 gpm each, resulting in a total DIF of 7,500 gpm (10.8 mgd) for the Units 1 and 2 intake bay. Unit 3 utilizes two intake pumps with a rated design capacity of 6,000 gpm each, resulting in a total DIF of 12,000 gpm (17.3 mgd) for the Unit 3 intake bay.

2.3.2 Actual Intake Flows The average AIF for each intake bay was assessed based on the most recent flowmeter data available from the discharge of the Naughton CWIS, as summarized in Table 2-2.

Table 2-2. Naughton CWIS Actual Intake Flows (June 2016 - June 2017)

NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8), Naughton Power Plant, Wyoming Intake Bay Average Actual Intake Flow (gpm)

Units 1 and 2 3,230 Unit 3 3,594 TOTAL:

6,824 TP-LIC-LET-0362

From June 2016 to June 2017, the total AIF for the Naughton CWIS averaged 6,824 gpm (9.8 mgd). Flow from the Units 1 and 2 intake bay averaged 3,230 gpm (4.7 mgd), while flow from the Unit 3 intake bay averaged 3,594 gpm (5.2 mgd). Only 1 years dataset is available, from June 2016 through June 2017, due to flowmeter malfunctions prior to 2016. PacifiCorp installed new instruments in 2016 and is continuing to record the actual flow data.

Figure 2-1 shows the Naughton water balance diagram. The water balance displays facility water sources, recirculating flows, and discharges.

2.3.3 CWIS Velocities Table 2-3 provides a summary of CWIS velocities for each intake bay.

Table 2-3. Through-Opening/Through-Screen Velocities (fps)

NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8), Naughton Power Plant, Wyoming Location and Flow Scenario Units 1 and 2 Intake Bay Unit 3 Intake Bay Intake Opening Average AIF 0.86 0.27 DIF 2.01 0.92 Trashrack Average AIF 0.34 0.38 DIF 0.79 1.26 Traveling Screen Average AIF 1.00 1.12 DIF 2.33 3.73 Intake velocities were determined at average AIF, and at the DIF for each intake bay. AIF rates are based on flowmeter data from June 2016 to June 2017, discussed in Section 2.3.2, while DIF rates are based on the pump capacities discussed in Section 2.3.1. All velocities were calculated assuming the design low water surface elevation of 6,969.5 feet. For full calculations, refer to Appendix B.

2.3.4 Hourly, Daily, and Seasonal Operation This section describes the daily hours of operation, number of days of the year in operation, and seasonal operational changes, if applicable, of the traveling water screens and cooling water intake pumps. Table 2-4 presents information related to the cooling water system operation at Naughton.

2.3.4.1 Traveling Water Screens The traveling water screen at each intake bay is operated automatically based on differential head across the screen as measured with a bubbler-type control system. Each screen has a 1-horsepower drive motor and four-speed transmission, allowing the screen to rotate at 2.96, 4, 7, or 12 feet per minute. The variable speeds allow each screen to rotate at the optimal rate to clear debris and maintain slower rotation when possible to minimize wear to the screen unit. Each screen is cleaned by a spraywash system requiring approximately 90 gpm at 50 pounds per square inch. Spraywash water is drawn from the main discharge header at each intake bay after being withdrawn by the cooling water intake pumps and therefore does not cause for additional withdrawal from the CWIS.

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2.3.5 Cooling Water Intake Pumps The cooling water intake pumps are vertical turbine, submerged suction-type pumps. Pumps are typically operated manually to match demand with each pump operating on an on/off basis, with no additional means of flow control in place such as a throttling valve or variable frequency drives. The water demand of Naughton varies throughout the year, but flow requirements are typically greatest in the warmer summer months, from June through September.

The cooling water intake pumps primarily supply raw water to the cooling towers, though a small portion of the total intake flow is also supplied to the boiler as feedwater, to the flue-gas desulfurization system and to various other noncooling process uses.

Table 2-4. Summary of Cooling Water Intake Data NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8), Naughton Power Plant, Wyoming Cooling Water Intake Structure Data Units 1 and 2 Intake Bay Unit 3 Intake Bay CWIS location Perpendicular to western shoreline of the Hams Fork River, approximately 7 miles north of Naughton in Kemmerer, Wyoming Directly adjacent to Units 1 and 2 intake bay CWIS coordinates (latitude, longitude) 41°51'28.54"N, 110°33'52.00"W 41°51'28.54"N, 110°33'52.00"W Number of inlets One intake bay One intake bay Type of intake structure Reinforced concrete intake structure with a single intake bay devoted to Units 1 and

2. This intake bay has three raw water pumps. The intake includes a constricting opening at the face of the structure (opening of 4-2 x 20 at constriction),

and screening provided before the pumps by a single angled trashrack and a single vertical traveling screen.

Flow from the river is controlled by two radial gates spanning across the river.

Two separate intake bays for Units 1, 2, and Unit 3 each have independent underground pipelines running south to discharge to the settling basin at Naughton.

Reinforced concrete intake structure with a single intake bay devoted to Unit 3. It has two raw water pumps and an intake opening on the face of the structure (4-2 x 7-0). Screening is provided before the pumps by a single angled trashrack and a single vertical traveling screen identical to the screens in place for Units 1 and 2.

Flow from the river is controlled by two radial gates spanning across the river. The two pumps devoted to Unit 3 discharge to an independent underground pipeline running south to the settling basin at Naughton.

Intake opening dimensions Height = 2-0 (minimum)

Width = 4-2 (minimum)

Height = 7-0 Width = 4-2 Coarse screen type Trashrack (1 total)

Trashrack (1 total)

Coarse screen dimensions Vertical bars at 3 spacing on center (o.c.)

(3/8 thick each) 5 horizontal supports at 2-2 o.c.

(2 width blocking flow each)

Trashrack angled (2.5:12, H:V)

Panel width = 4-3/8 Panel height = 13-4.5 Vertical bars at 3 spacing on center (o.c.)

(3/8 thick each) 5 horizontal supports at 2-2 o.c.

(2 width blocking flow each)

Trashrack angled (2.5:12, H:V)

Panel width = 4-3/8 Panel height = 13-4.5 Number of traveling water screens One traveling screen One traveling screen TP-LIC-LET-0362

Table 2-4. Summary of Cooling Water Intake Data NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8), Naughton Power Plant, Wyoming Cooling Water Intake Structure Data Units 1 and 2 Intake Bay Unit 3 Intake Bay Traveling water screen type Link-Belt Model #45A: thru-flow coarse mesh traveling screen with front debris trough Link-Belt Model #45A: thru-flow coarse mesh traveling screen with front debris trough Traveling water screen dimensions Tray Width = 3-0 Tray Height = 2-0 Screen Height (centerline head shaft to centerline foot shaft = 13-0)

Well Width at Screen = 4-2 1-horsepower drive motor and 4-speed transmission allowing rotation at 2.96, 4, 7, or 12 feet per minute Spraywash requirement of 90 gpm at 50 pounds per square inch. Spraywash water is drawn from the main discharge header of raw water pumps and does not withdraw additional flow.

Tray Width = 3-0 Tray Height = 2-0 Screen Height (centerline head shaft to centerline foot shaft = 13-0)

Well Width at Screen = 4-2 1-horsepower drive motor and 4-speed transmission allowing rotation at 2.96, 4, 7, or 12 feet per minute Spraywash requirement of 90 gpm at 50 pounds per square inch. Spraywash water is drawn from the main discharge header of raw water pumps and does not withdraw additional flow.

Traveling water screen mesh opening 3/8-inch square mesh openings, 0.105-inch diameter #12 W&M steel wire 3/8-inch square mesh openings, 0.105-inch diameter #12 W&M steel wire Traveling water screen operational period (number of days per year and seasonal changes)

As needed, operated based on differential head across the screen As needed, operated based on differential head across the screen Number of pumps 3 pumps 2 pumps Flow per pump 2,500 gpm each 6,000 gpm each Design intake flows 3 pumps x 2,500 gpm = 7,500 gpm (10.8 mgd) 2 pumps x 6,000 gpm = 12,000 gpm (17.3 mgd)

Average actual intake flows, June 2016 - June 2017 3,230 gpm (4.7 mgd) 3,594 gpm (5.2 mgd)

Operational period (number of days per year and seasonal changes) 365 days per year with the exception of maintenance and emergency repair outages.

Peak withdrawals from June through October.

365 days per year with the exception of maintenance and emergency repair outages.

Withdrawal is relatively constant throughout the year with little seasonal variation.

Location of outfall discharge Outfall 003: Cooling tower blowdown from Units 1, 2, and 3 is discharged via Outfall 003, comprising the majority of flow discharged from the site. Additional flow streams discharged via Outfall 003 include boiler blowdown, water treatment effluent, station washdown flow, and flow collected at area floor and roof drains.

Receiving waters: North Fork Little Muddy Creek via an unnamed drainage (Class 3B waters),

Green River Basin.

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(r)(4) Source Water Baseline Biological Characterization Data 3.1 Introduction The purpose of this PAR is to provide information on the source water baseline biological characterization of the Green River in the vicinity of the CWIS and to evaluate the appropriateness and feasibility of technologies for reducing impingement mortality (IM). The Final Rule states the facility owner or operator must submit the following information for this PAR:

A list of species (or relevant taxa) for all life stages and their relative abundance in the vicinity of the CWIS.

Identification of the species and life stages that would be most susceptible to impingement and entrainment. Species evaluated should include the forage base as well as those most important in terms of significance to commercial and recreational fisheries.

Identification and evaluation of the primary period of reproduction, larval recruitment, and period of peak abundance for relevant taxa.

Data representative of the seasonal and daily activities (e.g., feeding and water column migration) of biological organisms in the vicinity of the CWIS.

Identification of all threatened, endangered, and other protected species that might be susceptible to impingement and entrainment at the CWIS.

Documentation of any public participation or consultation with federal or state agencies.

Identification of protective measures and stabilization activities that have been implemented, and a description of how these measures and activities affected the baseline water condition in the vicinity of the CWIS.

The information provided herein is based on a detailed literature review of available fish community data near Naughton and speciesspecific life history information.

3.2 Fish and Shellfish Species and Habitats in the Vicinity of the CWIS The Final Rule requires a facility to characterize the biological community in the vicinity of the CWIS, including a list of species and their relative abundance. The information in this PAR serves as a reference or the basis for other PARs. The purpose of this PAR is to provide information on the fish populations in the Hams Fork River that could be impacted by the operation of the existing CWIS, and estimate the effectiveness of other technologies to reduce IM.

3.2.1 Site Conditions and Habitats Site conditions and aquatic habitat zones near the CWIS were evaluated to characterize the potential occurrence and use by fish and shellfish species. The Hams Fork River below Kemmerer Reservoir is recognized as a Class 2AB stream (WYDEQ], 2013a). All waters shown as having any species of game fish present are classified as 2AB (WYDEQ, 2013a).

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3.2.2 Fish Species Table 3-1 represents the fish species identified to inhabit the Hams Fork River Basin, Wyoming, site area as per communication with the Wyoming Game and Fish Department (WGFD) (Keith, 2017, pers.

comm.). The life histories of the dominant species are described in Section 3.2.6.1.

Table 3-1. Hams Fork River Fish Species NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8), Naughton Power Plant, Wyoming Species Name Common Name Cottidae (sculpins)

Cottus bairdii Mottled sculpin Catostomidae (suckers)

Catostomus platyrhynchus Mountain sucker Catostomidae discobolus jarrovii Bluehead sucker Catostomus latipinnis Flannelmouth sucker Catostomus commersonii White sucker Cyprinidae (Cyprinids)

Rhinichthys osculus Speckled dace Pimephales promelas Fathead minnow Catostomus commersonii White sucker Gila atraria Utah chub Couesius plumbeus Lake chub Cyprinus carpio Common carp Richardsonius balteatus Redside shiner Gila robusta Roundtail chub Rhinichthys cataractae Longnose dace Salmonidae (salmonids)

Prosopium williamsoni Mountain whitefish Salmo trutta x Salvelinus fontinalis Tiger trout Oncorhynchus clarkii sp.

Bear River cutthroat trout Salvelinus fontinalis x Salvelinus namaycush Splake Salmo trutta Brown trout Salvelinus namaycush Lake trout Thymallus arcticus Arctic grayling Oncorhynchus mykiss Rainbow trout Source: Communication with Robert Keith of WGFD on August 25, 2017 (Keith, 2017, pers. comm.).

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3.2.3 Shellfish Species No data on shellfish species specific to the reach of the Hams Fork River near Naughton were found through inquiries with WGFD. On August 25, 2017, Robert Keith of the WGFD provided a list of fish species managed and observed within the section of the Hams Fork River upstream of the CWIS (Keith, 2017, pers. comm.). The Wyoming State Wildlife Action Plan (SWAP) (WGFD, 2017) observes no native known mussels from the Hams Fork River Basin and Green River Basin. According to the SWAP, Wyoming is still in the discovery phase in terms of its freshwater mussels and gastropods, with few published accounts existing. Although no shellfish data were found, WGFD heavily monitors for and regulates the presence of the invasive Zebra and Quagga mussels.

Native freshwater mussels rely on fish hosts to complete their life cycle. The larval stage of freshwater mussels and clams (i.e., glochidia) hatch from eggs within female mussels, are released into the water column, and must attach to a suitable fish host to survive. Once the glochidia transform into juveniles, they drop off the host after a 6-to 160-day period, depending on the mussel species (WGFD, 2017).

Therefore, although adult mussels are sessile, and not likely to be impinged directly, their larval and juvenile forms could be impinged via the impingement of their fish host.

3.2.4 Reproduction and Larval Recruitment The Hams Fork River provides habitat for the spawning and early life stage growth and development of numerous fishes. Limited information is available on ichthyoplankton near the Naughton CWIS; however, it can be assumed that based on literature review of the potential species within the Colorado River drainage, the ichthyoplankton community would reflect similar composition. In the Hams Fork River, ichthyoplankton abundance in riverine systems is expected to be greatest in late spring through early fall (WGFD, 2017).

3.2.5 Seasonal and Daily Activities 3.2.5.1 Seasonal Variation There is a distinct pattern in the abundance and distribution of fish within the Hams Fork River habitats, which primarily can be attributed to seasonal patterns of reproduction (WGFD, 2017). Peak abundance for fish in the Hams Fork River generally occur during the spring and summer. Egg recruitment (the process of getting from an egg to fry) peaks in the early spring for most species. The hatching of fry occurs between the late spring and early summer. Peak abundance is expected to occur during this period of late spring and early summer, when the greatest numbers of early and adult life stages are present. Spring through summer months are when most migratory fish (e.g., brown trout, cutthroat trout, and lake trout) enter the river system, further increasing abundance within the River (WGFD, 2017).

Hams Fork River flow volume also affects seasonal fish distribution. The highest flow volumes within this portion of the Hams Fork River typically occur in the late spring and early summer (USGS, 2016). These higher flow volumes provide a larger area of suitable habitat over which fish species can disperse because of the inundation of backwaters and lower-gradient channel border areas. When the waters recede to some of their lowest water levels, fish species that are present in high abundance during the late summer and fall (e.g., white sucker) migrate from the protected backwater to channel habitats.

3.2.5.2 Diel Movements Diel (i.e., daily 24-hour cycle) movements for most fish species are closely tied to daily patterns of foraging and rest. Although these subtle patterns of movement are difficult to document within large fast-flowing river systems, diel movement patterns have been observed in the Hams Fork River (USGS, 2016). Most fish species actively forage during the early morning and before dusk, thus having TP-LIC-LET-0362

increased mobility and exposure during this period. Fish are more dispersed throughout their habitats during these periods of increased activity.

3.2.6 Characterization of Species in the Vicinity of the CWIS The fish species described in this section are considered most likely to be found near the Naughton CWIS based on available fisheries data for the Hams Fork River Basin and Green River Basin, aquatic habitat near the CWIS, and potential susceptibility to impingement. The aquatic types listed are those known to be commonly present upstream of the CWIS, specifically sculpins, suckers, cyprinids, and salmonids (WGFD, 2017).

3.2.6.1 Overview of Life Species Discussion The following subsections describe the life history characteristics for each of five commonly found species and subspecies, including habitat preferences, patterns of abundance and distribution, and temporal activities. Although these species are likely present (seasonally for some) and potentially susceptible to impingement, little to no impingement impacts are expected for adults and juveniles because of the low intake flows and through-pipe velocities (well below 0.5 fps). While impingement impacts to juveniles and adults are not expected, egg and larval life stages may be susceptible to entrainment impacts. No entrainment studies were available for the CWIS or other facilities on the Hams Fork River; therefore, the species susceptible to entrainment impacts are likely the same as those discussed in the following subsection. However, considering the small intake area of influence or HZI described in Section 1.4.3, entrainment impacts are anticipated to be limited.

3.2.6.2 Fish Species Brown Trout. Brown trout are found in streams, ponds, rivers, and lakes (Scott and Scott, 1988).

Individuals spend 1 to 5 years in fresh water and 6 months to 5 years in salt water. Juveniles mature in 3 to 4 years (Hart, 1973). Lacustrine populations undertake migration to tributaries and lake outlets to spawn, rarely spawning on stone, wave-washed lake shores. Spawns in rivers and streams with swift current, usually characterized by downward movement of water intro gravel (Kottelat and Freyhof, 2007). Spawning takes place normally more than one time. They prefer cold, well-oxygenated upland waters, although their tolerance limits are lower than those of rainbow trout, and favor large streams in mountainous areas with adequate cover in the form of submerged rocks, undercut banks, and overhanging vegetation (de Moor and Bruton, 1988). Each female produces about 10,000 eggs (Muus and Nielsen, 1999). Juveniles feed mainly on aquatic and terrestrial insects; adults on mollusks, crustaceans, and small fish (Cadwallader and Backhouse, 1983).

Flannelmouth Sucker. Adults inhabit a wide range of habitats, from rocky pools and riffles of headwaters to large lakes. They are usually found in small, clear, cool creeks and small to medium rivers. They may be found at depths greater than approximately 148 feet (45 meters) (Scott and Crossman, 1973). These fish move to shallower water near sunrise and sunset to feed on plankton and other small invertebrates; bottom feeding commences upon reaching a depth of 0.6 to 0.7 inch (1.6 to 1.8 centimeters [cm]).

Flannelmouth white suckers are preyed upon by birds, fishes, lamprey, and mammals (Scott and Crossman, 1973). Adults are found in certain gravelly spawning streams, where up to four males crowd around a female and press against her with their fins. Eggs are scattered and adhere to the gravel or are carried downstream and adhere to the substrate when the water is calmer. The spawning act lasts 3 to 4 seconds and may occur 6 to 40 times an hour (Scott and Crossman, 1973). Spent adults return to the lake 10 to 14 days after spawning began. Most females return to the lake during the first half of the downstream migration followed by most males in the latter half. Downstream fry migration occurs between dusk and dawn (Geen, 1966).

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Mountain Whitefish. Mountain whitefish are found in lakes and fast, clear, or silty streams. They feed mainly on benthic organisms such as aquatic insect larvae, mollusks, fishes, and fish eggs (including their own) but may feed on plankton and surface insects when the need arises (Scott and Crossman, 1973).

Their main feeding time is in the evening, but they will also feed on drifting prey during the day. The mountain whitefish frequently feeds in the lower strata of streams, but populations may rise to the surface to prey on hatching insects, including mayflies.

The spawning season is from October to early December, when water temperatures are approximately 35°F to 43°F (2 to 6°C). The fish seek out areas of coarse gravels or cobbles, at depths of at least approximately 30 inches (75 cm), and scatter the nonadhesive eggs that will sink into the interstices. The eggs then develop slowly through the winter (6 to 10 weeks), hatching in the early spring (Scott and Crossman, 1973).

This species occurs throughout the western half of North America, as far north as the Mackenzie River (Canada) and the drainages of the Hudson Bay, in the Columbia River, upper Missouri River, upper Colorado River, and so forth (Scott and Crossman, 1973).

Cutthroat Trout. Cutthroat trout prefers relatively small streams, with gravel bottoms and gentle gradients. Spawning adults migrate from the sea into streams to spawn (Morrow, 1980). The young fish usually stay in the stream for a year or two before entering the sea, but some populations never got to sea at all. In rare cases, some individuals of sea-going populations, may remain in fresh water for as long as eight years (Morrow, 1980). Feeds on small fishes, crustaceans, and insects (Clemens, 1961). This species does not compete well with other fish, tends to hybridize, and is unable to withstand fishing pressure which can lead to depletion of stocks.

Spawning occurs both daytime and nighttime. The female selects a site and builds a redd (i.e., spawning nest) while the male courts her and drives away other males. Upon completion of the redd, the female settles into the pit, immediately followed by the male. The pair releases eggs and sperm simultaneously and the eggs fall into the spaces between the gravel. The female then moves to the upstream edge of the redd and resumes digging, thereby covering the eggs. When completely covered, the female may use the new redd to spawn once more or she may look for another spot and repeat the entire process.

Both males and females spawn with one or more members of the opposite sex (Morrow, 1980). The reproductive strategy of this species is characterized by synchronous ovarian organization and determinate fecundity (Murua and Saborido-Rey, 2003).

White Sucker. White sucker fish inhabit a wide range of habitats from rocky pools and riffles of headwaters to large lakes, but are usually found in small, clear, cool creeks and small to medium rivers.

They may be found at a depth greater than 148 feet (45 meters) (Scott and Crossman, 1973). These fish move to shallower water near sunrise and sunset to feed. Fry that are approximately 0.47 inch (1.2 cm) in length feed on plankton and other small invertebrates; bottom feeding commences upon reaching a length of 0.6 to 0.7 inch (1.6 to 1.8 cm).

Adults home to certain gravelly spawning streams. Two to four males crowd around a female and press against her with their fins. Eggs are scattered and adhere to the gravel or are carried downstream and adhere to the substrate when the water is calmer. The spawning act lasts for 3 to 4 seconds and may occur 6 to 40 times an hour (Scott and Crossman, 1973). Spent adults return to the lake 10 to 14 days after spawning began. Most females return to the lake during the first half of the downstream migration, followed by most males in the latter half. Downstream fry migration occurs between dusk and dawn (Geen, 1996).

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3.3 Species of Concern and Rare, Threatened, and Endangered Species A search for federally listed species was conducted on June 14, 2017, using the U.S. Fish and Wildlife Service (USFWS) Information Planning and Conservation website for Lincoln County, Wyoming (USFWS, 2017). This search yielded eight listed species possibly occurring in the area: four fish species listed as endangered (Bonytail chub [Gila elegans], Colorado pikeminnow [Ptychocheilus Lucius], Humpback chub

[Gila cypha], and Razorback sucker [Xyrauchen texanus]); a threatened bird (yellow-billed cuckoo

[Coccyzus americanus]); two mammals listed as experimental populations, nonessential (black-footed ferret [Mustela nigripes] and gray wolf [Canis Lupus]); and a threatened flowering plant (Ute ladies-tresses [Spiraanthes diluvialis]).

3.3.1 Federal Agency Consultation In December of 2017, PacifiCorp sent a letter to the USFWS explaining why threatened and endangered species will not be impacted further by the Naughton CWIS. This letter and the official species list are provided in Appendix C. The Naughton CWIS is located within the Green River Subbasin area of influence of the Colorado River Endangered Fish Recovery Program in Wyoming, but it is not within any critical habitat for the identified species presented in Section 3.3. In addition to the fact that there is little probability of any of the above species being present at the CWIS, this project does not propose any changes to existing operations at the CWIS. Therefore, no changes are proposed to baseline conditions.

3.3.2 State Agency Consultation The WGFD, Hams Fork River office was contacted on August 25, 2017, to determine whether a current list of potential fish and shellfish species inhabiting the Hams Fork River existed. The WGFD provided a list (Keith, 2017, pers. comm.), which is represented in Table 3-1.

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(r)(5) Cooling Water System Data 4.1 Introduction This section provides information needed to satisfy the requirements under §122.21(r)(5) - Cooling Water System Data. This PAR calls for information on the cooling water system operation and the associated CWIS. The following cooling water system information is included in this report:

A narrative description of the operation of the cooling water system and its relationship to the CWIS.

The proportion of the DIF used in the system, encompassing contact cooling, noncontact cooling, and process uses.

A distribution of water reuse to include cooling water reused as process water, process water reused for cooling, and the use of gray water for cooling.

A description of reductions in total water withdrawals, including cooling water intake flow reductions already achieved through minimized process water withdrawals.

The proportion of the source water body withdrawn on a monthly basis.

The number of days of the year the cooling water system is in operation and seasonal changes in the operation of the system, if applicable.

A description of existing impingement and entrainment technologies or operational measures and a summary of their performance.

4.2 Cooling Water System Operations Naughton utilizes one recirculating cooling tower for each of the three units. Pertinent data for all three cooling towers are provided in Table 4-1. Unit 1 and Unit 2 are mechanically induced counterflow design draft technologies and Unit 3 is a mechanically induced crossflow draft technology.

Each cooling tower consists of the following:

Framing and louvers constructed of treated select California redwood A system of distribution piping, valves, and nozzles supported by the framework A heat exchange medium (the fill) made up of a high-impact polypropylene material A basin to collect the cooled water and direct it back to the circulating pumps Fans to move the air necessary for proper heat exchange Drift eliminator medium to prevent water droplets from escaping from the tower in the airflow Operation of the tower centers on exposing warm water to moving air, to affect an evaporative, or latent, heat transfer. This heat is dissipated into the atmosphere.

Level in the tower basin is maintained by the introduction of raw water makeup into one of the condenser inlet pipes. Makeup flow is controlled by a control valve in the makeup line which operates based on a level transmitter at the basin. From there it branches into a distribution valve, distribution box, and onto the hot water basin where nozzles spray the water downward in a predetermined pattern over the heat exchange medium, or fill. Air movement through the tower is achieved using an induced draft air moving system. A motor-driven fan pulls air into the tower through the fill where latent heat transfer takes place.

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Before the airflow is permitted to exit through the top of the tower, it must pass through the drift eliminators. These are simply blocks of material shaped to cause the air to change directions and thus provide impact surfaces, which prevent water droplets from being carried out of the tower with the airflow.

The falling water is caught by the cold-water basin, which is then drawn back to the circulation pumps.

Cooling tower blowdown is taken from a connection to another condenser inlet pipe through a diaphragm valve which discharges to the ash water system. Blowdown rates are controlled automatically in accordance with water quality measurements of the circulating water. All three units at Naughton are operated to maintain selenium levels below 5 parts per million.

Table 4-1 provides specifications for each cooling tower at Naughton.

Table 4-1. Cooling Tower Data NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8), Naughton Power Plant, Wyoming Parameter Unit 1 Unit 2 Unit 3 Manufacturer The Fluor Corporation The Fluor Corporation The Fluor Corporation Model 9F60D-204V-3042CP 12F60D-240V-30X48CP Cells Per Tower 6

12 10+3 Fans Per Cell 1

1 1

Circulating Water Flow Rate (gpm) 56,500 76,100 95,500 Drift Loss Cells 1-9: 0.0005%

Cells 10, 11: 0.001%

0.2%

0.2%

Evaporation Loss 2.83%

2.5%

2.5%

Blowdown Ratea (gpm) 286 398 500 Makeup Rateb (gpm) 1,714 2,387 2,994 Cycles of Concentration 6

6 6

a Typical blowdown rate as shown on Figure 2-1 (Water Balance Diagram). Actual blowdown rate will vary.

b Typical makeup rate as shown on Figure 2-1. Actual makeup rate will vary.

Blowdown and makeup rates shown in Table 4-1 represent typical flows during unit operation as depicted on the water balance diagram (Figure 2-1). An average flow recorded from historical flow metering data would yield a lesser flow rate since the data would include times of partial or no power generation.

Recent cooling water system changes, completing construction in March 2018, result in cooling tower blowdown from all three units to be treated and discharged via Outfall 003.

4.3 Flow Distribution Flow distribution at Naughton was assessed based on relative percentages as depicted on the water balance diagram (Figure 2-1). Flow rates were then calculated with these percentages applied to the average AIF of 6,824 gpm from the Naughton CWIS (July 2016 - July 2017). Table 4-2 provides a breakdown of flow distribution under average AIF conditions.

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Table 4-2. CWIS Flow Distribution Under Average Actual Intake Flow Condition NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8), Naughton Power Plant, Wyoming Use Flow (gpm)

Percentage of Naughton CWIS AIF Primary Use Cooling Tower Makeup Watera,b,c 5,363 78.6%

Noncontact Cooling Flue-Gas Desulfurization System (via Lime Soda Softener) 340 5.0%

Process Boiler Feedwater (via Water Treatment System) 132 1.9%

Process Various Additional Process Usesd 989 14.5%

Process Total AIF (Naughton CWIS) 6,824 100%

a Unit 1 Makeup Water = 1,296 gpm (19.0% of Naughton CWIS AIF).

b Unit 2 Makeup Water = 1,804 gpm (26.4% of Naughton CWIS AIF).

c Unit 3 Makeup Water = 2,263 gpm (33.2% of Naughton CWIS AIF).

d Various additional process uses including mine dust suppression, bottom ash seal water, blowdown tank cooling, seal water, firewater system supply, and supply to the swamp cooler.

The largest use of raw water withdrawn at the Naughton CWIS is for cooling tower makeup. Per 40 CFR 125.92(d):

Contact cooling water means water used for cooling which comes into direct contact with any raw material, product, or byproduct. Examples of contact cooling water may include but are not limited to quench water at facilities, cooling water in a cracking unit, and cooling water directly added to food and agricultural products processing.

Cooling water at Naughton does not come into direct contact with any raw material, product, or byproduct and is therefore considered noncontact cooling water. Cooling tower makeup water represents the majority of all flow, using 78.6 percent of the flow withdrawn at the Naughton CWIS as noncontact cooling water. Noncooling process uses comprise the remaining 21.4 percent of raw water use.

Actual makeup rates when the units are running will be higher because these averages also include times when the units are not running and will have reduced or no flow. Figure 2-1 shows the Naughton water balance diagram.

4.4 Distribution of Water Reuse There is no reuse of cooling water for other processes within Naughton, and no process water or gray water is reused as cooling water.

4.5 Water Withdrawals 4.5.1 Reductions to Total Withdrawal The primary reduction to total withdrawal results from operation of the closed-cycle cooling system compared to an equivalent once-through cooling system. As documented in the Final Rule, EPA estimates facilities using freshwater cooling towers achieve flow reductions of approximately 98 percent compared to an equivalent once-through cooling system. It is estimated that an equivalent once-through cooling system would require an annual average AIF of just over 340,000 gpm.

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4.5.2 Proportion of Source Water Body Withdrawn The source water body for the Naughton CWIS is the Hams Fork River, which has a mean annual flow of approximately 116.9 cfs. The proportion of the source water body withdrawn on a monthly basis is determined by comparing the average monthly water withdrawal at the Naughton CWIS to the average monthly discharge of the Hams Fork River. Average monthly AIF at the Naughton CWIS was calculated using available intake flow data from June 2016 to June 2017. Average monthly discharge of the Hams Fork River was determined from the full record of available USGS gage station data (2007 - 2016) for Station 09223385, Hams Fork below Lake Viva Naughton, Wyoming (USGS, 2017). Table 4-3 lists the proportions withdrawn on a monthly basis.

Table 4-3. Proportion of Source Water Body Withdrawn at Naughton CWIS NPDES Permit Application Requirements 40 CFR 122.21(r)(2) - (8), Naughton Power Plant, Wyoming Month Average Monthly AIF at Naughton CWISa (cfs)

Average Monthly River Discharge (cfs)

Proportion of Source Water Body Used

(%)

January 13.3 35.7 37.2 February 12.6 30.9 40.9 March 13.1 29.8 43.9 April 12.2 89.4 13.6 May 11.7 358.3 3.3 June 17.6 407.5 4.3 July 20.8 152.4 13.7 August 19.2 81.6 23.6 September 18.7 97.9 19.1 October 15.9 51.8 30.7 November 13.9 38.7 35.9 December 13.3 36.7 36.2 a AIF including total withdrawals for both the Units 1 and 2 intake bay and the Unit 3 intake bay.

The proportion of the source water body withdrawn on a monthly basis is variable at the Naughton CWIS, primarily due to the wide range in average monthly discharge for the Hams Fork River. Monthly average values for the proportion of the source water body used ranged from 3.3 percent of the source water body in May up to 43.9 percent in March.

4.6 Daily and Seasonal Cooling Water Uses The cooling water system operates 365 days per year, with the exception of brief outages for maintenance or emergency repairs at the CWIS. No outages were observed within the period of available intake flow data from June 2016 to June 2017. Seasonal changes in demand from the CWIS are seen on Figure 4-1, presenting the average monthly AIF at the Naughton CWIS from June 2016 to June 2017.

TP-LIC-LET-0362

Figure 4-1. Average Monthly Actual Intake Flow at Naughton CWIS Flow at the Naughton CWIS peaks during warmer months in the summer from June through October.

The greatest monthly average is seen in July at 20.8 cfs (9,350 gpm). This seasonal fluctuation coincides with the warmer average air temperatures experienced in those months, which requires increased cooling water demand. The lowest monthly average AIF is seen in May at 11.7 cfs (5,236 gpm) when air temperatures are still relatively low and the higher energy demands often seen in the coldest winter months have subsided.

4.7 Cooling Water System Technologies and Operational Measures 4.7.1 Impingement Technologies or Operational Measures Naughton utilizes a closed-cycle cooling system to reduce impingement. The closed-cycle cooling system, already in place at Naughton, significantly reduces cooling water demand compared to an equivalent once-through cooling system. The resulting reduction to impingement is assumed to be directly proportional to this reduction in flow. As documented in the 2014 Phase II Rule, EPA estimates facilities utilizing freshwater cooling towers achieve flow reductions, and therefore associated entrainment and IM reductions, of 98 percent.

4.7.2 Entrainment Technologies or Operational Measures Naughton currently utilizes a closed-cycle cooling system to reduce entrainment. Similar to the estimated impingement reduction resulting from use of a closed-cycle cooling system, the reduction to entrainment is assumed to be directly proportional to the flow reduction. Therefore, entrainment of organisms at the Naughton CWIS is assumed to be reduced by approximately 98 percent compared to an equivalent once-through cooling system.

0.0 5.0 10.0 15.0 20.0 25.0 Average Monthly Intake Flow (cfs)

Month TP-LIC-LET-0362

(r)(6) Chosen Method of Compliance for CWIS The purpose of this PAR is to provide information required for the chosen method of compliance with the IM standard PAR (§122.21(r)(6)):

The owner or operator of the facility must identify the chosen compliance method for the entire facility; alternatively, the applicant must identify the chosen compliance method for each CWIS at its facility.

The applicant must identify any intake structure for which a best technology available determination for IM under the de minimis provisions [40 CFR 125.94 (c)(11)] or low-capacity utilization [40 CFR 125.94(c)(12)] is requested.

In addition, the owner or operator that chooses to comply with IM Compliance Option 5 by using modified traveling screens [40 CFR 125.94 (c)(5)] or IM Compliance Option 6 [40 CFR 125.94 (c)(6)]

must also submit an impingement technology performance optimization study as described in the rule.

IM Compliance Option 1, listed in the Final Rule, is a closed-cycle recirculating system with daily monitoring of intake flows. This option is a preapproved best technology available for IM that requires no biological studies or additional flow monitoring.

TP-LIC-LET-0362

(r)(7) Entrainment Studies No entrainment studies have been conducted for Naughton, and no entrainment studies for other facilities on the Green River or raw water surge pond were available to include in this permit application.

TP-LIC-LET-0362

(r)(8) Operational Status 7.1 Introduction This section provides information needed to satisfy requirements under §122.21(r)(8) - Operational Status. This PAR calls for an explanation of the operational status of each generating, production, or process unit that uses cooling water. Requirements relevant to Naughton are as follows:

For power production or steam generation, descriptions of individual unit operating status including:

Age of each unit Capacity utilization rate (CUR) (or equivalent) for the previous 5 years including any unusual or extended outages that significantly affect the facilitys reporting of flow, impingement, or other factors Identification of any operating unit with a CUR of less than 8 percent averaged over a 24-month block contiguous period Any major upgrades completed within the last 15 years including, but not limited to, boiler replacement, condenser replacement, turbine replacement, or changes to fuel type Descriptions of plans or schedules for any new units planned within the next 5 years 7.2 Operation Status of Each Unit Naughton consists of three coal-fired steam electric generating units with a total gross plant output of approximately 725 MW. Each unit uses a recirculating cooling tower. Unit 1 and Unit 2 are mechanically induced counterflow design draft technologies and Unit 3 is a mechanically induced crossflow draft technology. As stated in Section 2.1 (Facility Description), Naughton is located in western Wyoming approximately 4 miles southwest of the community of Kemmerer in Lincoln County, Wyoming.

7.2.1 Age of Units Naughton was commissioned in 1963 on a 1,120-acre site near Kemmerer, Wyoming. Two additional units were commissioned between 1963 and 1971, bringing the total generating capacity of Naughton to 725 MW. Unit 1 began operation in November 1963 and is approximately 54 years old. Units 2 and 3 began operation between 1963 and 1971 and are between approximately 46 and 54 years old, respectively.

7.2.2 Capacity Utilization Rates Naughton has three combustion turbine generators (Units 1, 2, and 3) with a total nominal rating of 725 MW. From 2011 to 2015, Unit 1 CUR was 87 percent, Unit 2 CUR was 87 percent, and Unit 3 CUR was 84 percent. Naughton units operate 365 days per year except for maintenance period shutdowns.

From 2011 to 2015, there were no extended or unusual outages that significantly affected flow and impingement. Over the past 5 years, no unit at Naughton has operated with a CUR of less than 8 percent averaged over any contiguous 24-month block.

TP-LIC-LET-0362

7.2.3 Unit Upgrades There have been no substantial upgrades to the existing units associated with cooling water supply and operations at Naughton in the past 15 years.

7.2.4 New Unit Planning There are no plans or schedules for new units to be added to Naughton in the next 5 years. PacifiCorp is evaluating a potential project to convert Unit 3 to natural gas firing in the future. However, this conversion is currently not in the Naughton budget.

TP-LIC-LET-0362

References Anderson Consulting Engineers. 2015. Blacks Fork River Watershed Study, Level 1, Phase 1: Hams Fork.

Cadwallader, P. L. and G. N. Backhouse. 1983. A Guide to the Freshwater Fish of Victoria. Government Printers. Melbourne. p. 249.

Clemens, W. A. and G. V. Wilby. 1961. Fishes of the Pacific Coast of Canada. 2nd ed. Journal of the Fisheries Research Board of Canada. Bulletin No. 68. 443 p.

de Moor, I. J. and M. N. Bruton. 1988. Atlas of Alien and Translocated Indigenous Aquatic Animals in Southern Africa. A Report of the Committee for Nature Conservation Research National Programme for Ecosystem Research. South African Scientific Programmes. Report No. 144. p. 310. Port Elizabeth, South Africa.

Geen, G. H., T. G. Northcote, G. F. Hartman, and C. C. Lindsey. 1966. Life histories of two species of catostomid fishes in Sixteenmile Lake, British Columbia, with particular reference to inlet stream spawning. Journal of the Fisheries Research Board of Canada. Vol. 23. No. 11. pp. 1762-1787.

Hart, J. L. 1973. Pacific Fishes of Canada. Journal of the Fisheries Research Board of Canada. No. 180.

740 p.

Keith, Robert, Wyoming Game and Fish Department. 2017. Personal communication (email) with CH2M.

August 25.

Kottelat, M. and J. Freyhof. 2007. Handbook of European Freshwater Fishes. Publications Kottelat, Cornol and Freyhof, Berlin. 646 pp.

Morrow, J. E. 1980. The Freshwater Fishes of Alaska. University of. B.C. Animal Resources Ecology Library. 248 p.

Murua, H. and F. Saborido-Rey. 2003. Female Reproductive Strategies of Marine Fish Species of the North Atlantic. Journal of Northwest Atlantic Fishery Science. Vol. 33. pp. 23-31.

Muus, B. J. and J. G. Nielsen. 1999. Sea Fish. Scandinavian Fishing Year Book, Hedehusene, Denmark.

p. 340.

Scott, W. B. and E. J. Crossman. 1973. Freshwater Fishes of Canada. Journal of the Fisheries Research Board of Canada. 184:1-966.

Scott, W. B. and M. G. Scott. 1988. Atlantic Fishes of Canada. Canadian Bulletin of Fisheries and Aquatic Sciences. No. 219. 731 p.

U.S. Environmental Protection Agency (EPA). 2001. Ambient Water Quality Criteria Recommendations Information Supporting the Development of State and Tribal Nutrients Criteria for Rivers and Streams in Nutrient Ecoregion IV, Great Plains Grass and Shrublands including all or parts of: North Dakota, South Dakota, Montana, Wyoming, Nebraska, Colorado, Kansas, Oklahoma, New Mexico, and Texas, and the authorized Tribes within the Ecoregion. U.S. Environmental Protection Agency, Office of Water, Office of Science and Technology, Health and Ecological Criteria Division, Washington D.C. EPA 822-B-01-013.

December.

U.S. Fish and Wildlife Service (USFWS). 2017. Environmental Conservation Online System (ECOS) -

Information Planning and Conservation (IPaC). Species by County Report for Lincoln County, Wyoming.

U.S. Geological Survey (USGS). 1993. National Water Summary 1990-91: Hydrologic Events and Stream Water Quality. United States Geological Survey Water - Supply Paper 2400. Richard W. Paulson, Edith B.

TP-LIC-LET-0362

Chase, John S. Williams, and David W. Moody, Compilers. U.S. Department of the Interior, Bruce Babbitt, Secretary. U.S. Geological Survey, Dallas L. Peck, Director. United States Government Printing Office.

U.S. Geological Survey (USGS). 2016. USGS Water-Year Summary for Site USGS 09217000 - Green River near Green River, Wyoming. USGS Water-Year Summary 2015. Accessed November 1, 2016.

http://waterdata.usgs.gov/nwis/wys_rpt?dv_ts_ids=161782&wys_water_yr=2015&site_no=09217000&

agency_cd=USGS&adr_water_years=2006%2C2007%2C2008%2C2009%2C2010%2C2011%2C2012%2C2 013%2C2014%2C2015&referred_module.

U.S. Geological Survey (USGS). 2017. USGS Water-Year Summary for Site USGS 09223385 - Hams Fork below Viva Naughton Reservoir, Wyoming: USGS Water-Year Summary. July 24.

https://waterdata.usgs.gov/nwis/dv?referred_module=sw&site_no=09223385.

WWC Engineering, AECOM, and ERO Resources Corporation. 2010. Green River Basin Water Plan Final Report. Prepared for: Wyoming Water Development Commission Basin Planning Program. December.

Wyoming Water Development Office. 2010. Green River Basin Water Plan - 2010 Technical Memoranda.

http://waterplan.state.wy.us/plan/green/2010/techmemos/techmemos.html.

Wyoming Department of Environmental Quality (WYDEQ). 2013a. Wyoming Surface Water Classification List. Water Quality Division Surface Water Standards. Wyoming Department of Environmental Quality.

Updated July 26.

http://deq.wyoming.gov/media/attachments/Water%20Quality/Surface%20Water%20Quality%20Stand ards/Guidance%20Documents/2013-0726_wqd-wpp-surface-water-standards_Wyoming-Surface-Water-Classification-List.pdf.

Wyoming Department of Environmental Quality (WYDEQ). 2013b. Chapter 1: Wyoming Surface Water Quality Standards. Wyoming Administrative Rules. Water Quality. Effective Date: 09/24/2013 to Current. Rule Type: Current Rules & Regulations. Reference Number: 020.0011.1.09242013. Accessed November 1, 2017. https://rules.wyo.gov/Search.aspx.

Wyoming Game and Fish Department (WGFD). 2017. Wyoming State Wildlife Action Plan.

TP-LIC-LET-0362

Appendix A Naughton HZI Calculations TP-LIC-LET-0362

SUBJECT:

PacifiCorp - Naughton 316(b) Evaluation BY: A. George CHECKED BY: Esther Chang Naughton CWIS: Hydraulic Zone of Influence DATE: 5 July 2017 19 July 2017 PROJECT NO.: 680779.01.06.01 OBJECTIVE AND METHODOLOGY:

CALCULATIONS:

Intake Opening Velocities (see Appendix A for full calculations):

Unit 1 and 2 Intake Bay, Through-opening velocity =

0.86 fps (Assumes Average AIF flow rate of 7.2 cfs for U1/U2 intake bay)

Unit 3 Intake Bay, Through-opening velocity =

0.27 fps (Assumes Average AIF flow rate of 8.0 cfs for U3 intake bay)

Average AIF =

7.20 cfs Intake Opening Width at face of CWIS =

3.00 ft Intake Opening Height at face of CWIS =

5.17 ft Intake opening area at face of CWIS =

15.50 sf Unit 1/2 Intake Opening Velocity at face of CWIS =

0.46 fps (Assumes Average AIF flow rate of 7.2 cfs for U1/U2 intake bay)

Ham's Fork River Velocities:

Average Annual Discharge of Ham's Fork River:

Source: USGS gage station data, August 2007 through October 2016 (USGS 09223385 Hams Fork below Viva Naughton Reservoir, WY)

Average Annual Discharge =

116.9 cfs Cross Sectional Approach Area:

Source: River diversion dimensions per Bechtel Corporation Dwg. No. 37048, Job No. 3420: "River Pumping Station Gate Structure & Details" Approach width of radial gate diversion structure =

50.5 ft Diversion structure invert elevation =

6,966.0 ft Low WSEL =

6,969.5 ft Water Depth at Low WSEL =

3.5 ft Cross Sectional Area of diversion structure approach at Low WSEL =

176.75 sf Average River Velocity:

Average River Velocity =

0.66 fps RESULTS:

Determine the hydraulic zone of influence (HZI) that the Naughton CWIS has at the diversion from the Ham's Fork River.

Analysis is completed by comparing intake velocities of the CWIS to natural velocities in the source waterbody, the Ham's Fork River. If the CWIS intake velocity is less than the river velocity then the effective HZI does not extend beyond the intake opening. If the CWIS intake velocity is greater than the river velocity, then the limits of the HZI extend radially from the CWIS to a plane of constant velocity (intake velocity has dissipated to the point where it is equal to the river velocity).

Intake velocities for this analysis are those calculated at the intake opening for each of the two intake bays under Average AIF and an assumed Low WSEL of 6,969.5', as calculated in Appendix A. The river velocities for the Ham's Fork River are calculated as the approach velocity to the radial gate diversion under average annual discharge conditions. Average annual discharge for the Ham's Fork River was determined from publicly available USGS gage station data, August 2007 through October 2016 (USGS 09223385 Hams Fork below Viva Naughton Reservoir, WY).

The Unit 1 and 2 intake opening is beveled, with a velocity of 0.86 fps being calculated for the most constricted cross section, at the entrance to the intake bay. At the face of the CWIS the intake opening is one foot greater in both width and height with dimensions and an intake opening velocity as follows:

The through opening velocity for the Unit 1 and Unit 2 intake bay is greater than the average river velocity. However, the beveled intake opening is larger at the face of the CWIS resulting in a velocity of 0.46 fps.

This velocity is less than the average river velocity, therefore the HZI does not extend out into the river beyond the face of the CWIS.

Page 1 of 1 TP-LIC-LET-0362

Appendix B Naughton CWIS Velocity Calculations TP-LIC-LET-0362

SUBJECT:

PacifiCorp - Naughton 316(b) Evaluation BY: A. George CHECKED BY: E. Chang Naughton CWIS: Unit 1 and 2 Intake Bay Velocity Calculations DATE: 5 July 2017 19 July 2017 PROJECT NO.: 680779.01.06.01 Pump Data Naughton CWIS: Unit 1 and 2 (gpm)

(MGD)

(cfs)

Pump No. 1-1 2,500 3.6 5.57 0.00 Pump No. 1-2 2,500 3.6 5.57 0.00 Pump No. 1-3 2,500 3.6 5.57 0.00 Total DIF:

7,500 10.8 16.71 0.00 Average AIF =

3,230 4.7 7.20 Daily Data, 6/7/2016 - 6/6/2017 Assumptions

  • The velocity calculations are based on pump design capacities and do not consider the impact of variable head conditions (river stage) on pumping rates.
  • Sediment accumulation is assumed to be minimal.
  • No service water pumps pumps contribute to the total intake flow through the trashracks.
  • The Settling Basin Raw Water Pumphouse does not withdraw from a natural waterbody and is therefore not subject to the 316(b) Final Rule.

Water Surface Elevations CWIS Deck:

6976.0 ft Bechtel Corporation Dwg. No. 37047, Job No. 3420: "Water Supply System, River Pumping Station, Pump & Screen Well" High WSEL:

6972.0 ft L-21995 P3-6, "Naughton Plant Units #1, #2, #3 P. & I.D. River Water System" Low WSEL:

6969.5 ft L-21995 P3-6, "Naughton Plant Units #1, #2, #3 P. & I.D. River Water System" Top of Intake Opening:

6969.0 ft Bechtel Corporation Dwg. No. 37047, Job No. 3420: "Water Supply System, River Pumping Station, Pump & Screen Well" Bottom of Intake Opening:

6967.0 ft Bechtel Corporation Dwg. No. 37047, Job No. 3420: "Water Supply System, River Pumping Station, Pump & Screen Well" River Bottom at CWIS:

6966.0 ft Bechtel Corporation Dwg. No. 37047, Job No. 3420: "Water Supply System, River Pumping Station, Pump & Screen Well" CWIS Invert at Traveling Screen:

6964.0 ft Bechtel Corporation Dwg. No. 37047, Job No. 3420: "Water Supply System, River Pumping Station, Pump & Screen Well" CWIS Invert:

6963.0 ft Bechtel Corporation Dwg. No. 37047, Job No. 3420: "Water Supply System, River Pumping Station, Pump & Screen Well" CWIS Description Intake Tunnel Opening

  • Beveled, rectangular intake opening at east face of CWIS
  • Opening Dimensions at face of CWIS: Width = 5'-2", Height = 3'-0"
  • Opening Dimensions at entrance to Intake Bay: Width = 4'-2", Height = 2'-0" Trashrack
  • 1 angled trashrack panel
  • Trashrack angled 78.2 degrees from horizontal (2.5:12, H:V)
  • Intake Bay width at trashrack = 4'-2"
  • Panel height = 13-4.5"
  • 17 vertical bars at 3" o.c., (3" depth x 0.375" thick)
  • 5 horizontal structural supports (2" blocking flow each; only two are below Low WSEL)
  • Horizontal End Supports (top and bottom of panel; 3" blocking flow each; only bottom is below Low WSEL)
  • Frame top and bottom bar 0.75" thickness each (only bottom is below Low WSEL)
  • Invert at trashrack = 6963.0'
  • Top of trashrack = CWIS Deck = 6976.0' Vertical Traveling Screen
  • Single vertical traveling screen for Unit 1 and Unit 2 Intake Bay
  • Intake Bay width at trashrack = 4'-2"
  • Height (headshaft to footshaft centerlines) = 13'-0"
  • Basket Width = 3'-0"; Basket Height = 2'-0"
  • Screen Mesh = 3/8" square opening; #12 W&M gauge steel wire cloth (0.105" diameter)
  • Bottom Boot Height blocking flow = 9" (assumed)
  • Invert at vertical traveling screen = 6964.0' (raised one foot from rest of CWIS)

Design Capacity Total Dynamic Head (ft)

Spray Wash Pump (cfs)

Notes Single vertical traveling screen draws spraywash from the discharge header of the raw water pumps. No additional withdrawal from CWIS.

1 of 6 TP-LIC-LET-0362

SUBJECT:

PacifiCorp - Naughton 316(b) Evaluation BY: A. George CHECKED BY: E. Chang Naughton CWIS: Unit 1 and 2 Intake Bay Velocity Calculations DATE: 5 July 2017 19 July 2017 PROJECT NO.: 680779.01.06.01 Velocity Calculations Summary Intake Tunnel Opening Through-Opening Velocity (fps)

Approach Velocity (fps)

Through-Slot Velocity (fps)

Approach Velocity (fps)

Through-Slot Velocity (fps)

Design Intake Flow (DIF) 2.01 0.62 0.79 0.73 2.33 Average Actual Intake Flow (Avg. AIF) 0.86 0.27 0.34 0.31 1.00 Pump Data This CWIS contains 3

circulating water pumps This CWIS contains 1

trashracks Cooling water DIF per bay:

16.71 cfs Spray water per bay:

0.00 cfs Service water per bay:

0.00 cfs Fire water per bay:

0.00 cfs Total per bay:

16.71 cfs Average AIF =

7.20 cfs Intake Opening Opening Width =

4.17 ft Opening Height =

2.00 ft Gross area =

8.33 sf Through-opening velocity (DIF) =

2.01 fps Through-opening velocity (Avg AIF) =

0.86 fps Trashrack Approach Intake Bay width at trashrack =

4.17 ft Approach water depth at Low WSEL =

6.50 ft Gross area =

27.08 sf Approach velocity (DIF) =

0.62 fps Approach velocity (Avg AIF) =

0.27 fps Trashrack Through-Slot Number of trashrack panels =

1.00 ea Clear Opening Through Trashrack Guide =

4.17 ft Panel height below Low WSEL=

6.50 ft Number of vertical bars per panel =

17.00 ea Vertical bar width =

0.03 ft Number of Horizontal structural supports below Low WSEL =

2.00 ea (lower two 2" horizontal supports + one 3" end support only are submerged at Low WSEL)

Horizontal structural support height =

0.17 ft Number of End Horizontal structural supports below Low WSEL =

1.00 ea (top and bottom horizontal end support is different height than all others)

Top Horizontal structural support height =

0.25 ft Trashrack Frame Top and Bottom Bar Thickness =

0.06 ft Effective open width per panel =

3.64 ft Effective open height per panel =

5.85 ft Net open area per bay =

21.28 sf Through-slot velocity (DIF) =

0.79 fps Through-slot velocity (Avg AIF) =

0.34 fps All velocities calculated at Low WSEL = 6969.5'. Through-opening velocity for Intake Tunnel Opening assumes most constricted cross section of opening.

Notes Trashrack Vertical Traveling Screen 2 of 6 TP-LIC-LET-0362

SUBJECT:

PacifiCorp - Naughton 316(b) Evaluation BY: A. George CHECKED BY: E. Chang Naughton CWIS: Unit 1 and 2 Intake Bay Velocity Calculations DATE: 5 July 2017 19 July 2017 PROJECT NO.: 680779.01.06.01 Traveling Screens Screen Approach Intake Bay width at traveling screen =

4.17 ft Approach water depth at Low WSEL =

5.5 ft Area =

22.9 sf Approach velocity (DIF) =

0.73 fps Approach velocity (Avg AIF) =

0.31 fps Screen Through-Slot Mesh opening size =

0.375 inch square Wire size =

0.105 inch Effective open area =

0.14 square inch Total area =

0.23 square inch Porosity =

0.61 Effective tray width =

3.00 ft Water depth =

5.50 ft Boot height =

0.75 ft assumed Screen panel height =

2.00 ft Screen panel opening =

1.77 ft Effective screen height =

3.92 ft Effective area =

7.17 sf Through-slot velocity (DIF) =

2.33 fps Through-slot velocity (Avg AIF) =

1.00 fps 3 of 6 TP-LIC-LET-0362

SUBJECT:

PacifiCorp - Naughton 316(b) Evaluation BY: A. George CHECKED BY: E. Chang Naughton CWIS: Unit 3 Intake Bay Velocity Calculations DATE: 5 July 2017 19 July 2017 PROJECT NO.: 680779.01.06.01 Pump Data Naughton CWIS: Unit 3 (gpm)

(MGD)

(cfs)

Pump No. 3-1 6,000 8.6 13.37 0.00 Pump No. 3-2 6,000 8.6 13.37 0.00 Total DIF:

12,000 17.3 26.74 0.00 Average AIF =

3,594 5.2 8.01 Daily Data, 6/7/2016 - 6/6/2017 Assumptions

  • The velocity calculations are based on pump design capacities and do not consider the impact of variable head conditions (river stage) on pumping rates.
  • Sediment accumulation is assumed to be minimal.
  • No service water pumps pumps contribute to the total intake flow through the trashracks.
  • The Settling Basin Raw Water Pumphouse does not withdraw from a natural waterbody and is therefore not subject to the 316(b) Final Rule.

Water Surface Elevations CWIS Deck:

6976.0 ft Stearns Roger Corporation Dwg. No. L-21995, Sheet No. P4-25: "Piping River Pump House, Plans and Section" High WSEL:

6972.0 ft L-21995 P3-6, "Naughton Plant Units #1, #2, #3 P. & I.D. River Water System" Top of Intake Opening:

6970.0 ft Stearns Roger Corporation Dwg. No. L-21995, Sheet No. P4-25: "Piping River Pump House, Plans and Section" Low WSEL:

6969.5 ft L-21995 P3-6, "Naughton Plant Units #1, #2, #3 P. & I.D. River Water System" River Bottom at CWIS:

6966.0 ft Bechtel Corporation Dwg. No. 37047, Job No. 3420: "Water Supply System, River Pumping Station, Pump & Screen Well" CWIS Invert at Traveling Screen:

6964.0 ft Stearns Roger Corporation Dwg. No. L-21995, Sheet No. P4-25: "Piping River Pump House, Plans and Section" CWIS Invert/Bottom of Intake Opening:

6963.0 ft Stearns Roger Corporation Dwg. No. L-21995, Sheet No. P4-25: "Piping River Pump House, Plans and Section" CWIS Description Intake Tunnel Opening

  • Opening width = 4'-2"
  • Opening height = 7'-0" Trashrack
  • 1 angled trashrack panel
  • Trashrack angled 78.2 degrees from horizontal (2.5:12, H:V)
  • Intake Bay width at trashrack = 4'-2"
  • Panel height = 13-4.5"
  • 17 vertical bars at 3" o.c., (3" depth x 0.375" thick)
  • 5 horizontal structural supports (2" blocking flow each; only two are below Low WSEL)
  • Horizontal End Supports (top and bottom of panel; 3" blocking flow each; only bottom is below Low WSEL)
  • Frame top and bottom bar 0.75" thickness each (only bottom is below Low WSEL)
  • Invert at trashrack = 6963.0'
  • Top of trashrack = CWIS Deck = 6976.0' Vertical Traveling Screen
  • Single vertical traveling screen for Unit 3 Intake Bay
  • Intake Bay width at trashrack = 4'-2"
  • Height (headshaft to footshaft centerlines) = 13'-0"
  • Basket Width = 3'-0"; Basket Height = 2'-0"
  • Screen Mesh = 3/8" square opening; #12 W&M gauge steel wire cloth (0.105" diameter)
  • Bottom Boot Height blocking flow = 9" (assumed)
  • Invert at vertical traveling screen = 6964.0' (raised one foot from rest of CWIS)

Design Capacity Total Dynamic Head (ft)

Spray Wash Pump (cfs)

Notes Single vertical traveling screen draws spraywash from the discharge header of the raw water pumps. No additional withdrawal from CWIS.

4 of 6 TP-LIC-LET-0362

SUBJECT:

PacifiCorp - Naughton 316(b) Evaluation BY: A. George CHECKED BY: E. Chang Naughton CWIS: Unit 3 Intake Bay Velocity Calculations DATE: 5 July 2017 19 July 2017 PROJECT NO.: 680779.01.06.01 Velocity Calculations Summary Intake Tunnel Opening Through-Opening Velocity (fps)

Approach Velocity (fps)

Through-Slot Velocity (fps)

Approach Velocity (fps)

Through-Slot Velocity (fps)

Design Intake Flow (DIF) 0.92 0.99 1.26 1.17 3.73 Average Actual Intake Flow (Avg. AIF) 0.27 0.30 0.38 0.35 1.12 Pump Data This CWIS contains 3

circulating water pumps This CWIS contains 1

trashracks Cooling water DIF per bay:

26.74 cfs Spray water per bay:

0.00 cfs Service water per bay:

0.00 cfs Fire water per bay:

0.00 cfs Total per bay:

26.74 cfs Average AIF =

8.01 cfs Intake Opening Opening Width =

4.17 ft Opening Height =

7.00 ft Gross area =

29.17 sf Through-opening velocity (DIF) =

0.92 fps Through-opening velocity (Avg AIF) =

0.27 fps Trashrack Approach Intake Bay width at trashrack =

4.17 ft Approach water depth at Low WSEL =

6.50 ft Gross area =

27.08 sf Approach velocity (DIF) =

0.99 fps Approach velocity (Avg AIF) =

0.30 fps Trashrack Through-Slot Number of trashrack panels =

1.00 ea Clear Opening Through Trashrack Guide =

4.17 ft Panel height below Low WSEL=

6.50 ft Number of vertical bars per panel =

17.00 ea Vertical bar width =

0.03 ft Number of Horizontal structural supports below Low WSEL =

2.00 ea (lower two 2" horizontal supports + one 3" end support only are submerged at Low WSEL)

Horizontal structural support height =

0.17 ft Number of End Horizontal structural supports below Low WSEL =

1.00 ea (top and bottom horizontal end support is different height than all others)

Top Horizontal structural support height =

0.25 ft Trashrack Frame Top and Bottom Bar Thickness =

0.06 ft Effective open width per panel =

3.64 ft Effective open height per panel =

5.85 ft Net open area per bay =

21.28 sf Through-slot velocity (DIF) =

1.26 fps Through-slot velocity (Avg AIF) =

0.38 fps Trashrack Vertical Traveling Screen Notes All velocities calculated at Low WSEL = 6969.5'.

5 of 6 TP-LIC-LET-0362

SUBJECT:

PacifiCorp - Naughton 316(b) Evaluation BY: A. George CHECKED BY: E. Chang Naughton CWIS: Unit 3 Intake Bay Velocity Calculations DATE: 5 July 2017 19 July 2017 PROJECT NO.: 680779.01.06.01 Traveling Screens Screen Approach Intake Bay width at traveling screen =

4.17 ft Approach water depth at Low WSEL =

5.5 ft Area =

22.9 sf Approach velocity (DIF) =

1.17 fps Approach velocity (Avg AIF) =

0.35 fps Screen Through-Slot Mesh opening size =

0.375 inch square Wire size =

0.105 inch Effective open area =

0.14 square inch Total area =

0.23 square inch Porosity =

0.61 Effective tray width =

3.00 ft Water depth =

5.50 ft Boot height =

0.75 ft assumed Screen panel height =

2.00 ft Screen panel opening =

1.77 ft Effective screen height =

3.92 ft Effective area =

7.17 sf Through-slot velocity (DIF) =

3.73 fps Through-slot velocity (Avg AIF) =

1.12 fps 6 of 6 TP-LIC-LET-0362

Appendix C Letter to U.S. Fish and Wildlife Service TP-LIC-LET-0362

TP-LIC-LET-0362

TP-LIC-LET-0362

Attachment U.S. Fish and Wildlife Service Official Species List for Lincoln County, Wyoming TP-LIC-LET-0362

June 14, 2017 United States Department of the Interior FISH AND WILDLIFE SERVICE Wyoming Ecological Services Field Office 5353 Yellowstone Road, Suite 308a Cheyenne, WY 82009-4178 Phone: (307) 772-2374 Fax: (307) 772-2358 http://www.fws.gov/wyominges/

In Reply Refer To:

Consultation Code: 06E13000-2017-SLI-0332 Event Code: 06E13000-2017-E-01227 Project Name: PacifiCorp Naughton 316b

Subject:

List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by your proposed project To Whom It May Concern:

The enclosed species list identifies threatened, endangered, proposed and candidate species, as well as proposed and final designated critical habitat, that may occur within the boundary of your proposed project and/or may be affected by your proposed project. The species list fulfills the requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of the Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 et seq.).

New information based on updated surveys, changes in the abundance and distribution of species, changed habitat conditions, or other factors could change this list. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the Act, the accuracy of this species list should be verified after 90 days. This verification can be completed formally or informally as desired. The Service recommends that verification be completed by visiting the Environmental Conservation Online System-Information, Planning, and Conservation System (ECOS-IPaC) website at regular intervals during project planning and implementation for updates to species lists and information. An updated list may be requested through the ECOS-IPaC system by completing the same process used to receive the enclosed list.

Please feel free to contact us if you need more information or assistance regarding the potential impacts to federally proposed, listed, and candidate species and federally designated and proposed critical habitat. We also encourage you to visit the Wyoming Ecological Services website at for more http://www.fws.gov/wyominges/Pages/Species/Species_Endangered.html information about species occurrence and designated critical habitat.

The purpose of the Act is to provide a means whereby threatened and endangered species and the ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2) of the Act and its implementing regulations (50 CFR 402 et seq.), Federal agencies are required to use their authorities to carry out programs for the conservation of threatened and endangered species TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 2

and to determine whether projects may affect threatened and endangered species and/or designated critical habitat.

A biological assessment is required for construction projects (or other undertakings having similar physical impacts) that are major Federal actions significantly affecting the quality of the human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2)

(c)). For projects other than major construction activities, the Service suggests that a biological evaluation similar to a biological assessment be prepared to determine whether the project may affect listed or proposed species and/or designated or proposed critical habitat. Recommended contents of a biological assessment are described at 50 CFR 402.12.

If a Federal agency determines, based on the biological assessment or biological evaluation, that listed species and/or designated critical habitat may be affected by the proposed project, the agency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Service recommends that candidate species, proposed species, and proposed critical habitat be addressed within the consultation. More information on the regulations and procedures for section 7 consultation, including the role of permit or license applicants, can be found in the "Endangered Species Consultation Handbook" at:

http://www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF We also recommend that you consider the following information when assessing impacts to federally listed species, as well as migratory birds, and other trust resources:

Consultation under section 7 of the Act is required Colorado River and Platte River Systems for projects in Wyoming that may lead to water depletions or have the potential to impact water quality in the Colorado River system or the Platte River system, because these actions may affect threatened and endangered species inhabiting the downstream reaches of these river systems. In general, depletions include evaporative losses and/or consumptive use of surface or groundwater within the affected basin, often characterized as diversions minus return flows. Project elements that could be associated with depletions include, but are not limited to: ponds, lakes, and reservoirs (e.g., for detention, recreation, irrigation, storage, stock watering, municipal storage, and power generation); hydrostatic testing of pipelines; wells; dust abatement; diversion structures; and water treatment facilities.

Species that may be affected in the Colorado River system include the endangered bonytail (Gila

), Colorado pikeminnow (

), humpback chub (

), and elegans Ptychocheilus lucius Gila cypha razorback sucker (

) and their designated critical habitats. Projects in the Platte Xyrauchen texanus River system may impact the endangered interior population of the least tern (

),

Sterna antillarum the endangered pallid sturgeon (

), the threatened piping plover (

Scaphirhynchus albus Charadrius

), the threatened western prairie fringed orchid (

), as well as the melodus Platanthera praeclara endangered whooping crane (

) and its designated critical habitat. For more Grus americana information on consultation requirements for the Platte River species, please visit http://www.fws.gov/platteriver.

The Migratory Bird Treaty Act (16 U.S.C. 703-712), prohibits the taking of Migratory Birds any migratory birds, their parts, nests, or eggs except as permitted by regulations, and does not TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 3

require intent to be proven. Except for introduced species and some upland game birds, almost all birds occurring in the wild in the United States are protected (50 CFR 10.13). Guidance for minimizing impacts to migratory birds for projects that include communications towers (e.g.,

cellular, digital television, radio, and emergency broadcast) can be found at http://www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/towers.htm.

The Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d) prohibits knowingly taking, or taking with wanton disregard for the consequences of an activity, any bald or golden eagles or their body parts, nests, or eggs, which includes collection, molestation, disturbance, or killing.

Eagle nests are protected whether they are active or inactive. Removal or destruction of nests, or causing abandonment of a nest could constitute a violation of one or both of the above statutes.

Projects affecting eagles may require development of an eagle conservation plan (http://www.fws.gov/windenergy/eagle_guidance.html). Additionally, wind energy projects should follow the wind energy guidelines (http://www.fws.gov/windenergy/) for minimizing impacts to migratory birds and bats.

If nesting migratory birds are present on or near the project area, timing of activities is an important consideration and should be addressed in project planning. Activities that could lead to the take of migratory birds or eagles, their young, eggs, or nests, should be coordinated with our office prior to project implementation. If nest manipulation (including removal) is proposed for the project, the project proponent should contact the Migratory Bird Office in Denver at 303-236-8171 to see if a permit can be issued for the project. If a permit cannot be issued, the project may need to be modified to protect migratory birds, eagles, their young, eggs, and nests.

We appreciate your concern for threatened and endangered species. The Service encourages Federal agencies to include conservation of threatened and endangered species into their project planning to further the purposes of the Act. Please include the Consultation Tracking Number in the header of this letter with any request for consultation or correspondence about your project that you submit to our office.

Attachment(s):

Official Species List USFWS National Wildlife Refuges and Fish Hatcheries Migratory Birds Wetlands TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 1

Official Species List This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the requirement for Federal agencies to "request of the Secretary of the Interior information whether any species which is listed or proposed to be listed may be present in the area of a proposed action".

This species list is provided by:

Wyoming Ecological Services Field Office 5353 Yellowstone Road, Suite 308a Cheyenne, WY 82009-4178 (307) 772-2374 TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 2

Project Summary Consultation Code:

06E13000-2017-SLI-0332 Event Code:

06E13000-2017-E-01227 Project Name:

PacifiCorp Naughton 316b Project Type:

Water Withdrawal / Depletion Project

Description:

This IPaC evaluates potential threatened and endangered species that may occur within Naughton's CWIS cooling water withdrawal.

Project Location:

Approximate location of the project can be viewed in Google Maps:

https://www.google.com/maps/place/41.85872238272951N110.56565291070838W Counties:

Lincoln, WY Endangered Species Act Species There is a total of 5 threatened, endangered, or candidate species on your species list. Species on this list should be considered in an effects analysis for your project and could include species that exist in another geographic area. For example, certain fish may appear on the species list because a project could affect downstream species. See the "Critical habitats" section below for those critical habitats that lie wholly or partially within your project area. Please contact the designated FWS office if you have questions.

TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 3

Birds NAME STATUS Yellow-billed Cuckoo (Coccyzus americanus)

Population: Western U.S. DPS There is a for this species. Your location is outside the proposed critical proposed critical habitat habitat.

Species profile: https://ecos.fws.gov/ecp/species/3911 Threatened Fishes NAME STATUS Bonytail Chub (Gila elegans)

There is a designated for this species. Your location is outside the designated final critical habitat critical habitat.

Species profile: https://ecos.fws.gov/ecp/species/1377 Endangered Colorado Pikeminnow (=squawfish) (Ptychocheilus lucius)

Population: Wherever found, except where listed as an experimental population There is a designated for this species. Your location is outside the designated final critical habitat critical habitat.

Species profile: https://ecos.fws.gov/ecp/species/3531 Endangered Humpback Chub (Gila cypha)

There is a designated for this species. Your location is outside the designated final critical habitat critical habitat.

Species profile: https://ecos.fws.gov/ecp/species/3930 Endangered Razorback Sucker (Xyrauchen texanus)

There is a designated for this species. Your location is outside the designated final critical habitat critical habitat.

Species profile: https://ecos.fws.gov/ecp/species/530 Endangered Critical habitats There are no critical habitats within your project area.

TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 1

USFWS National Wildlife Refuges And Fish Hatcheries Any activity proposed on lands must undergo a 'Compatibility National Wildlife Refuge Determination' conducted by the Refuge. Please contact the individual Refuges to discuss any questions or concerns.

There are no refuges or fish hatcheries within your project area.

TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 1

1.
2.
3.

Migratory Birds Certain birds are protected under the Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act.

Any activity that results in the of migratory birds or eagles is prohibited unless authorized take by the U.S. Fish and Wildlife Service. There are no provisions for allowing the take of migratory birds that are unintentionally killed or injured.

Any person or organization who plans or conducts activities that may result in the take of migratory birds is responsible for complying with the appropriate regulations and implementing appropriate conservation measures.

The of 1918.

Migratory Birds Treaty Act The of 1940.

Bald and Golden Eagle Protection Act 50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)

The migratory birds species listed below are species of particular conservation concern (e.g.

) that may be potentially affected by activities in this location. It Birds of Conservation Concern is not a list of every bird species you may find in this location, nor a guarantee that all of the bird species on this list will be found on or near this location. Although it is important to try to avoid and minimize impacts to all birds, special attention should be made to avoid and minimize impacts to birds of priority concern. To view available data on other bird species that may occur in your project area, please visit the and

. To AKN Histogram Tools Other Bird Data Resources fully determine any potential effects to species, additional site-specific and project-specific information is often required.

NAME SEASON(S)

American Bittern (Botaurus lentiginosus) https://ecos.fws.gov/ecp/species/6582 On Land: Breeding Fox Sparrow (Passerella iliaca)

On Land: Breeding Williamson's Sapsucker (Sphyrapicus thyroideus) https://ecos.fws.gov/ecp/species/8832 On Land: Breeding Golden Eagle (Aquila chrysaetos) https://ecos.fws.gov/ecp/species/1680 On Land: Year-round Bald Eagle (Haliaeetus leucocephalus) https://ecos.fws.gov/ecp/species/1626 On Land: Year-round Black Rosy-finch (Leucosticte atrata) https://ecos.fws.gov/ecp/species/9460 On Land: Year-round 1

2 3

TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 2

Brewer's Sparrow (Spizella breweri) https://ecos.fws.gov/ecp/species/9291 On Land: Breeding Burrowing Owl (Athene cunicularia) https://ecos.fws.gov/ecp/species/9737 On Land: Breeding Cassin's Finch (Carpodacus cassinii) https://ecos.fws.gov/ecp/species/9462 On Land: Year-round Ferruginous Hawk (Buteo regalis) https://ecos.fws.gov/ecp/species/6038 On Land: Breeding Greater Sage-grouse (Centrocercus urophasianus) https://ecos.fws.gov/ecp/species/8159 On Land: Year-round Loggerhead Shrike (Lanius ludovicianus) https://ecos.fws.gov/ecp/species/8833 On Land: Breeding Long-billed Curlew (Numenius americanus) https://ecos.fws.gov/ecp/species/5511 On Land: Breeding Mountain Plover (Charadrius montanus) https://ecos.fws.gov/ecp/species/3638 On Land: Breeding Olive-sided Flycatcher (Contopus cooperi) https://ecos.fws.gov/ecp/species/3914 On Land: Breeding Peregrine Falcon (Falco peregrinus) https://ecos.fws.gov/ecp/species/8831 On Land: Breeding Pinyon Jay (Gymnorhinus cyanocephalus) https://ecos.fws.gov/ecp/species/9420 On Land: Year-round Sage Thrasher (Oreoscoptes montanus) https://ecos.fws.gov/ecp/species/9433 On Land: Breeding Short-eared Owl (Asio flammeus) https://ecos.fws.gov/ecp/species/9295 On Land: Year-round Swainson's Hawk (Buteo swainsoni) https://ecos.fws.gov/ecp/species/1098 On Land: Breeding Virginia's Warbler (Vermivora virginiae) https://ecos.fws.gov/ecp/species/9441 On Land: Breeding Western Grebe (aechmophorus occidentalis) https://ecos.fws.gov/ecp/species/6743 On Land: Breeding Willow Flycatcher (Empidonax traillii) https://ecos.fws.gov/ecp/species/3482 On Land: Breeding TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 3

Calliope Hummingbird (Stellula calliope) https://ecos.fws.gov/ecp/species/9526 On Land: Migrating Rufous Hummingbird (selasphorus rufus) https://ecos.fws.gov/ecp/species/8002 On Land: Migrating Additional information can be found using the following links:

Birds of Conservation Concern http://www.fws.gov/birds/management/managed-species/

birds-of-conservation-concern.php Conservation measures for birds http://www.fws.gov/birds/management/project-assessment-tools-and-guidance/

conservation-measures.php Year-round bird occurrence data http://www.birdscanada.org/birdmon/default/datasummaries.jsp TP-LIC-LET-0362

06/14/2017 Event Code: 06E13000-2017-E-01227 1

Wetlands Impacts to and other aquatic habitats may be subject to regulation under Section NWI wetlands 404 of the Clean Water Act, or other State/Federal statutes.

For more information please contact the Regulatory Program of the local U.S. Army Corps of Engineers District FRESHWATER EMERGENT WETLAND PEMC FRESHWATER FORESTED/SHRUB WETLAND PSSC TP-LIC-LET-0362

Kemmerer Unit 1 Environmental Report SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2024 TerraPower, LLC.

All Rights Reserved 3.1-12 Revision 0 Figure 3.1-3 Kemmerer Unit 1 Major Plant Structures X

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LEGEND:

FENCE FACILITY NUMBER TRUE NORTH AND PLANT NORTH 0° RETENTION POND 62 12 51 82 41 43 21 36 72 73 37 11 34 33 45 38 44 52 RETENTION POND 78 75 42 76 35 81B 61 84 TRUE NORTH AND PLANT NORTH 0° 32B 32A HWY 189 HWY 189 HWY 189 71 81A RETENTION POND 85 C REACTOR L

C REACTOR L

FACILITY NUMBER/DESCRIPTION:

11 REACTOR BUILDING 12 REACTOR AUXILIARY BUILDING 21 TURBINE FACILITY BUILDING 32A MEDIUM VOLTAGE HOUSING 32B MEDIUM VOLTAGE HOUSING 33 MAIN AND AUXILIARY TRANSFORMERS 34 RESERVE AUXILIARY TRANSFORMERS 35 SWITCHYARD 36 SWITCHYARD CONTROL BUILDING 37 STANDBY DIESEL GENERATORS 38 NI CONTROL BUILDING 41 ENERGY STORAGE STRUCTURE SALT TANK HOT 42 ENERGY STORAGE STRUCTURE SALT TANK COLD 43 STEAM GENERATOR BUILDING 44 CONDENSATE STORAGE TANK 45 SALT CONTAINMENT BERM 51 FUEL HANDLING BUILDING 52 FUEL AUXILIARY BUILDING 61 TRAINING, ADMINISTRATION BUILDING 62 NI WAREHOUSE 71 WATER TREATMENT BUILDING 72 COOLING TOWER 73 CIRCULATING WATER PUMP AREA INTAKE FACILITY 75 FIRE TANKS AND PUMP BUILDING 76 WASTEWATER TREATMENT 78 EI DEMINERALIZED WATER TANK 81A NI ARGON AND NITROGEN BULK STORAGE 81B HYDROGEN GAS TRAILER 82 NI/EI (SALT) PIPE RACK 84 STEAM GENERATOR BUILDING/TURBINE FACILITY BUILDING (STEAM) RACK 85 AUXILIARY BOILER E. 6858 ft TP-LIC-LET-0362 SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2024 TerraPower, LLC. All Rights Reserved

Kemmerer Unit 1 Environmental Report SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2024 TerraPower, LLC.

All Rights Reserved 3.1-13 Revision 0 Figure 3.1-4 Kemmerer Unit 1 Site Plan TP-LIC-LET-0362 SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2024 TerraPower, LLC. All Rights Reserved

Kemmerer Unit 1 Environmental Report SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2024 TerraPower, LLC.

All Rights Reserved 3.2-8 Revision 0 Figure 3.2-1 Reactor Power Conversion System Diagram Generator Hot Salt Storage Tank(s)

Cold Salt Storage Tank(s)

Primary Sodium Pumps Intermediate Heat Exchangers Sodium-Salt Heat Exchangers Condenser(s)

Cooling Tower(s)

NOTES

1. Only major power cycle components are identified.
2. All equipment quantities and layout are preliminary and used to help conceptualize the power cycle. This diagram should not be used for design input.

Makeup Water Salt Primary Sodium Steam Water Process Legend Power Grid Power Condensate Pumps Feedwater Pumps HP Feedwater Heaters Intermediate Sodium Pumps Intermediate Air Cooling Secondary Sodium Deaerator Reactor Vessel LP Feedwater Heaters Steam Turbine Steam Generators TP-LIC-LET-0362 SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2024 TerraPower, LLC. All Rights Reserved

Kemmerer Unit 1 Environmental Report SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2024 TerraPower, LLC.

All Rights Reserved 3.2-9 Revision 0 Figure 3.2-2 Plant Water Use/Balance NAUGHTON POWER PLANT RAW WATER SETTLING POND FIRE WATER STORAGE TANKS 1

FIRE WATER CARTRIDGE FILTERS 5

1ST PASS REVERSE OSMOSIS 2ND PASS REVERSE OSMOSIS PERMEATE TANK ELECTRODEION-IZATION UNIT DEMIN STORAGE TANK CFW/SGS/STS (POWER CYCLE)

SGS BLOWDOWN TANK WASTE WATER SUMP NORTH FORK LITTLE MUDDY CREEK 19 7

8 FLASH BLOWDOWN 11 15 COOLING TOWER CIRC RATE: 220,000 gpm TEMPERATURE RISE: 22 °F DESIGN DUTY: 2,415.7 MMBTU/hr

[5 CYCLES OF CONCENTRATION, 0.001% DRIFT]

9 SAMPLING AND MISC. LOSSES 12 QUENCHED BLOWDOWN 13 18 POTABLE WATER USERS SANITARY WASTES PACKAGED SEWAGE TREATMENT EXTENDED AERATION SKID 16 SLUDGE TO OFF-SITE DISPOSAL 17 OIL / WATER SEPARATOR 22 SLUDGE TO OFF-SITE DISPOSAL 23 24 POTABLE WATER TREATMENT POTABLE WATER STORAGE TANK COOLING TOWER BLOWDOWN EVAPORATION AND DRIFT 21 20 COOLING TOWER MAKEUP ULTRAFILTRATION SKID 2

3 4

10 QUENCH WATER WATER TREATMENT REJECT ULTRAFILTRATION REJECT POTABLE WATER SUPPLY 14 SERVICE WATER USERS 6

WATER TREATMENT TP-LIC-LET-0362 SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2024 TerraPower, LLC. All Rights Reserved

Statement-of-Basis Page 1 Wyoming Department of Environmental Quality Water Quality Division WYPDES (Wyoming Pollutant Discharge Elimination System) Program STATEMENT OF BASIS RENEWAL APPLICANT NAME:

PacifiCorp MAILING ADDRESS:

PO Box 191 Kemmerer, WY 83101 FACILITY LOCATION:

Naughton Plant, which is located in SWNW Section 33, Township 21N, Range 116W, Lincoln County. The wastewater will discharge to North Fork Little Muddy Creek via an unnamed drainage (3B), Green River Basin.

PERMIT NUMBER:

WY0020311 This permit has been renewed in accordance with current WYPDES permitting requirements. All permit effluent limits and monitoring requirements have been updated in accordance with current WDEQ regulations and policy. Specific changes to the permit include the following:

1.

The facility ceased discharge through outfalls 001 and 002 on December 29, 2017 for compliance with selenium limits. These outfalls are deleted from this permit.

2.

This permit renewal includes one outfall, 003.

Background:

PacifiCorp Naughton Power Plant is a coal-fired steam electric generating plant located south of the Town of Kemmerer, Wyoming. The plant consists of three separate units. Unit #1 is rated at 160 MW and went on line in May 1963; Unit #2 is rated at 220 MW and went on line in October 1968; and Unit #3 is rated at 330 MW and went on line in October 1971.

Wastewater treatment for the plant consists of two settling ponds, now used for evaporation and waste storage. The southernmost pond, former location of outfall 001, accepts all wastewater from Units #1 and

  1. 2. The northernmost pond, former location of outfall 002, accepts all wastewater from Unit #3.

Outfall 003 discharges cooling tower blowdown, boiler water treatment blowdown, and boiler quench water. As of January 1, 2018, the effluent limit for total selenium is 5 µg/L. The selenium limit imposed precludes discharge of water used for ash transport, hence the discontinuation of outfalls 001 and 002.

The plant is separating waste streams, with ash transport wastewater disposed in the ponds, and the waste streams listed above discharging from outfall 003. The ash ponds associated with former outfalls 001 and 002 are used for evaporation and waste storage.

This facility has cooling water intake structures, requiring compliance with Clean Water Act § 316(b).

Existing facilities with a design intake flow greater than 2 MGD but actual intake flow not greater than 125 MGD, which applies to this facility, must submit permit application information as described in 40 CFR 122.21(r)(2) through (r)(8) and comply with one of the seven impingement best available technologies (BATs) listed per 40 CFR 125.94 (c). Permit application requirements as per 40 CFR TP-LIC-LET-0362

Statement-of-Basis Page 2 122.21(r)(2) through (r)(8) include descriptions and drawings showing the configuration of the source water body used by the plant, a characterization of the source, and location maps. The facility satisfactorily included this with the permit application for this renewal. Also, the facility utilizes an acceptable impingement BAT. The impingement BAT this facility is operating is a closed-cycle recirculating system, as defined in 40 CFR 125.92. A closed-cycle recirculating system passes cooling water through the condenser and other components of the cooling system and reuses the water for cooling multiple times. This is an essentially pre-approved technology requiring no demonstration or only a minimal demonstration that the flow reduction and control measures are functioning as envisioned. This facility is in compliance with the 316(b) requirements.

EFFLUENT LIMITS:

In developing effluent limits, all federal and state regulations and standards have been considered and the most stringent requirements incorporated into the permit. Permit limits are based on technology-based standards and water-quality based standards, as described below.

The permit requires immediate compliance with Best Practical Control Technology (BPT) and Best Available Technology (BAT) limits that are defined in the EPA Effluent Guidelines and Standards for Steam Electric Power Generating Point Source Category, 40 CFR Part 423. In addition, aquatic life standards for the constituents of concern are evaluated to ensure that water-quality standards are not violated.

TECHNOLOGY-BASED EFFLUENT LIMITS: All wastewater streams, except cooling tower blowdown, boiler blowdown, boiler cleaning streams, yard area runoff, and sanitary waste are considered to be low volume waste sources However, constituents requiring control in low volume wastewater sources are the same as for ash transport water.

The constituents requiring control are total suspended solids and oil and grease per 40 CFR Part 423. The permit includes an oil and grease limit of 10 mg/L (daily max) based on Chapter 1, Wyoming Water Quality Rules and Regulations, total suspended solids of 30 mg/L (monthly average) 45 mg/L (weekly average) and 90 mg/L, daily maximum, based on the state of Wyomings determination of Best Available Treatment for similar facilities. These limits are more stringent than the BPT and BAT standards of 40 CFR Part 423, however, the facility has been able to meet these more stringent limits.

Boiler blowdown and boiler cleaning streams require control for the parameters total suspended solids, oil and grease, copper and iron. BPT and BAT (technology-based) limits are Total Copper, 1.0 mg/L (daily max and monthly average) and Total Iron 1.0 mg/L (daily max and monthly average).

Various chemicals are added to the boilers and cooling tower for water treatment. Because phosphorus has been identified as the pollutant which is beginning to create eutrophication problems in Flaming Gorge Reservoir, the permit requires monitoring for total phosphorus.

WATER-QUALITY-BASED EFFLUENT LIMITS: This plant discharges to a Class 3B water, and effluent limits for these constituents are set assuming that the dilution provided by the receiving water is zero. Cooling tower blowdown is the largest portion of wastewater discharged at this plant. The constituent requiring control for cooling tower blowdown is chlorine. The effluent limit for total residual chlorine is set at 0.02 mg/L, the chronic instream standard for total residual chlorine per Chapter 1, Wyoming Water Quality Rules and Regulations. Effluent limits for pH are set at 6.5 to 9.0 standard units, per Chapter 1, Wyoming Water Quality Rules and Regulations. The Federal regulations (40 CFR 423) stipulate that Neither free available chlorine nor total residual chlorine may be discharged from any unit for more than two hours in any one day and not more than one unit in any plant may discharge free TP-LIC-LET-0362

Statement-of-Basis Page 3 available or total residual chlorine at any one time unless the utility can demonstrate to the Regional Administrator or State, if the State has NPDES permit issuing authority, that the units in a particular location cannot operate at or below this level of chlorination. The facility has demonstrated that that the cooling towers biocide procedures operate more efficiently when chlorinating at a constant, lower level, rather than shock chlorinating for two hours per day Therefore, they have DEQ permission to chlorinate for more than two hours per day.

Various chemicals are added to the boilers and cooling tower for water treatment. Because phosphorus has been identified as the pollutant that is beginning to create eutrophication problems in Flaming Gorge Reservoir, the permit requires monitoring for total phosphorus.

Effluent Limits:

COLORADO RIVER BASIN SALINITY: The facility discharges to the Colorado River Basin. The State of Wyoming cooperates with the other states of the Colorado River Basin Salinity Control Forum and the government of the United States to maintain salinity levels in the main stem of the Colorado River. According to Chapter 6 of the Wyoming Water Quality Rules and Regulations, all point sources that discharge to the Colorado River must control the salinity concentration discharged to the surface.

The Colorado River Salinity Control Forum policy states that the salt load reaching the main stem of the Colorado River shall be less than one-ton per day or 366 tons per year. Because the facility discharges to the Colorado River Basin, the permit requires effluent monitoring and limits for total dissolved solids (TDS). This permit requires that the permittee monitor the load (quantity) of salt in the discharge in tons per month. This is calculated utilizing flow and concentration information:

[Total Monthly Flow (MG)]*[Concentration (mg/L)]*[8.34(lb/MG)/mg/L)] = Load (tons/month).

2000 lb/ton The permittee also must report the total salt discharged annually. The facility is unable to meet the 366 ton per year limit, but submitted a cost benefit analysis deeming it cost prohibitive to treat the wastewater to meet the limit. Therefore, the facility is waived from the 366 tons/year TDS limit.

WHOLE EFFLUENT TOXICITY:

This facility uses anti-corrosion and biocide chemicals in the cooling water. Because of the unknown synergistic effects of these toxicants, the permit also includes effluent limits for acute whole effluent toxicity (WET). On a quarterly basis, acute toxicity testing must be performed on two species. Acute toxicity occurs when 50 percent or more mortality is observed at any effluent concentration. Because the immediate receiving streams are effluent-dominated Class 3B, the DEQ determines that monitoring for acute toxicity (mortality) is more appropriate than chronic toxicity (growth and reproduction).

The permit establishes effluent limits for the end of pipe, which are protective of the designated uses for class 3B waters as defined in Chapter 1 of Wyoming Water Quality Rules and Regulations. These include aquatic life other than fish, recreation, agriculture, wildlife, industry and scenic value. Water quality based effluent limits for this permit are based on standards which are intended to protect for the above listed designated uses and reflect the application of "tier 1" antidegradation protection. Tier 1 antidegradation protection is the basic level of protection that applies to all waters of the state, as described in the Wyoming Surface Water Quality Standards "Implementation Policies for Antidegradation."

Antidegradation, impairment review: The discharge of wastewater and the effluent limits established in this permit ensure that the levels of water quality maintain and protect the designated uses of the receiving waters. An antidegradation review verifies that the permit conditions, including the effluent limitations established, provide a level of protection to the receiving water consistent with the antidegradation TP-LIC-LET-0362

Statement-of-Basis Page 4 provisions of Wyoming surface water quality standards. In addition, an evaluation of the receiving waters revealed that they are not on the 303(d) list as waterbodies that cannot support designated uses.

Self-monitoring of effluent quality and quantity is required on a regular basis with reporting of results quarterly. The permit is scheduled to expire on July 31, 2023.

Roland Peterson Water Quality Division Department of Environmental Quality Drafted: February 27, 2018 TP-LIC-LET-0362

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 2 PART I A.

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1.

Effective August 1, 2018 and lasting through July 31, 2023 the quality of effluent discharged by the permittee shall, at a minimum, meet the limitations set forth below.

The permittee is authorized to discharge from outfall serial number(s) 003.

Such discharges shall be limited and monitored by the permittee as specified below:

Effluent Characteristic Discharge Limitations Monthly Average Weekly Average Daily Maximum Total Suspended Solids, mg/L 30 45 90 Oil and Grease, mg/L*

N/A N/A 10*

Total Residual Chlorine, mg/L N/A N/A 0.02 Total Copper, mg/L 1.0 N/A 1.0 Total Iron, mg/L 1.0 N/A 1.0 Total Selenium, µg /L N/A N/A 5

  • In the event that an oil sheen or floating oil is observed in the discharge, a grab sample shall be immediately taken, analyzed and reported. The sample shall not exceed 10 mg/L.

The pH shall not be less than 6.5 standard units nor greater than 9.0 standard units in any single grab sample.

There shall be no discharge of floating solids or foam in other than trace amounts. Nor shall the discharge have a visible sheen or cause formation of a visible sheen or visible deposits on the bottom or shoreline of the receiving water.

All waters shall be discharged in a manner to prevent erosion, scouring, or damage to stream banks, stream beds, ditches, or other waters of the state at the point of discharge.

Discharges shall not occur in such a manner that will result in violations of Water Quality Rules and Regulations, Chapter 1, Section 15. In addition, there shall be no deposition of substances in quantities that could result in significant aesthetic degradation, or degradation of habitat for aquatic life, plant life or wildlife; or which could adversely affect public water supplies or those intended for agricultural or industrial use.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 3 Monitoring Requirements, Outfall 003 Effluent Characteristic Measurement Frequency Sample Type Flow - MGD Weekly Continuous Oil and Grease*, mg/L Continuous Visible sheen*

Total Suspended Solids, mg/L Weekly Grab Total Copper, mg/L Monthly Grab Total Iron, mg/L Monthly Grab Total Phosphorus, mg/L Monthly Grab pH Weekly Grab Total Residual Chlorine, mg/L Weekly Grab Selenium, Total, µg /L Monthly Grab Total Dissolved Solids, mg/L Monthly Grab Total Dissolved Solids, tons per month Monthly Calculated Total Dissolved Solids, total tons discharged during the calendar year Annually Calculated Duration of Discharge, Days Monthly Report Number Of Days Discharged

  • Samples shall not be collected unless a visual sheen is detected. The sample must then comply with the limit listed above.

Samples taken in compliance with the monitoring requirements specified above shall be taken at the outfall from the final treatment unit and prior to admixture with diluent water or the receiving stream.

If the permittee only discharges for three (3) days or less during the month, the no discharge code of Less than 3 days of discharge; Avg not applicable may be used for the monthly and weekly averages in place of a numerical value on the Discharge Monitoring Reports (DMRs).

2.

Effluent Limitations (Toxic Pollutants)

Effective immediately there shall be no acute toxicity in the discharge from outfall numbers 003.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 4 3.

Whole Effluent Testing Starting in the third quarter of calendar year 2018, the permittee shall, at least once each calendar quarter, conduct acute static replacement toxicity tests on a grab sample of the discharge. Quarterly samples shall be collected on a two (2) day progression; i.e., if the first quarterly sample is on a Monday, during the next quarter, sampling shall begin on a Wednesday, etc.

The replacement static toxicity tests shall be conducted in accordance with the procedures set out in accordance with the latest procedures set forth in 40 CFR 136.3 and the "Region VIII EPA NPDES Acute Test Conditions - Static Renewal Whole Effluent Toxicity Tests". In the case of conflicts, the 40 CFR 136.3 document will prevail. The permittee shall conduct an acute 48-hour static toxicity test using Ceriodaphnia dubia and an acute 96-hour static toxicity test using Pimephales promelas.

Acute toxicity occurs when 50 percent or more mortality is observed for either species at any effluent concentration. If more than 10 percent control mortality occurs, the test is not valid. The test shall be repeated until satisfactory control survival is achieved.

If acute toxicity occurs, an additional test shall be conducted within two (2) weeks of the date of when the permittee learned of the test failure. If only one species fails, retesting may be limited to this species. Should acute toxicity occur in the second test, testing shall occur once a month until further notified by the permit issuing authority.

Quarterly test results shall be reported along with the Discharge Monitoring Report (DMR) submitted for the end of the reporting calendar quarter (e.g., whole effluent results for the calendar quarter ending March 31, shall be reported with the DMR due April 28, with the remaining reports submitted with DMRs due each July 28, October 28 and January 28). Monthly test results shall be reported along with the DMR submitted for that month. The format for the report shall be consistent with the latest revision of the "Region VIII Guidance for Acute Whole Effluent Reporting", and shall include all chemical and physical data as specified.

If the results for four consecutive quarters of testing indicate no acute toxicity, the permittee may request the permit issuing authority to allow a reduction to quarterly acute toxicity testing on only one species on an alternating basis. The permit issuing authority may approve or deny the request based on the results and other available information without an additional public notice. If the request is approved, the test procedures are to be the same as specified above for the test species.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 5 4.

Toxicity Reduction Evaluation (TRE)

Toxicity Identification Evaluation (TIE)

Should acute toxicity and/or chronic toxicity be detected in the permittee's discharge, a TIE-TRE shall be undertaken by the permittee to establish the cause of the toxicity, locate the source(s) of the toxicity, and develop control of, or treatment for the toxicity.

Failure to initiate, or conduct an adequate TIE-TRE, or delays in the conduct of such tests, shall not be considered a justification for noncompliance with the whole effluent toxicity limits contained in Part I.A.2. of this permit. A TRE plan needs to be submitted to the permitting authority within 45 days after confirmation of the continuance of effluent toxicity.

5.

Chronic Toxicity Limitation-Reopener Provision This permit may be reopened and modified (following proper administrative procedures) to include chronic whole effluent toxicity limitations if any other information or data are developed indicating that chronic whole effluent toxicity limits are needed as required under 40 CFR 122.44 (d).

If acceptable to the permit issuing authority, and if in conformance with current regulations, this permit may be reopened and modified to incorporate TRE conclusions relating to additional numerical limitations, a modified compliance schedule, and or modified whole effluent protocol.

B.

COOLING WATER INTAKE STRUCTURES. This facility has cooling water intake structures, requiring compliance with Clean Water Act 316(b). The impingement best available technology (BAT) this facility is operating is a closed-cycle recirculating system, as defined in 40 CFR 125.92.

C.

MONITORING AND REPORTING 1.

Representative Sampling Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge. All samples shall be taken at the monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream, body of water, or substance. Monitoring points shall not be changed without notification to and approval by, the permit issuing authority.

2.

Reporting Effluent monitoring results obtained during the previous three month(s) shall be summarized and reported on a Discharge Monitoring Report Form. If the permit requires whole effluent toxicity (WET) (biomonitoring) testing, WET test results must be reported on the most recent version of EPA Region 8 Guidance for Whole Effluent Reporting.

Legible copies of these, and all other reports required herein, shall be signed and certified in accordance with the Signatory Requirements (see Part II.A.11.), and submitted to the state water pollution control agency at the following address. The reports must be received by the agency no later than the 28th day of the month following the completed reporting period. The first report is due October 28, 2018.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 6 Wyoming Department of Environmental Quality Water Quality Division 200 West 17th Street Cheyenne, WY 82002 Telephone: (307) 777-7781 If no discharge occurs during the reporting period, "no discharge" shall be reported. If discharge is intermittent during the reporting period, sampling shall be done while the facility is discharging.

3.

Definitions Concentration Values a.

Daily Maximum (mg/L) - The highest single reading from any grab or composite sample collected during the reporting period.

b.

Monthly Average (mg/L) - The arithmetic mean (geometric mean in the case of fecal coliform and E. coli) of all composite and/or grab samples collected during a calendar month.

c.

Weekly Average (mg/L) - The arithmetic mean (geometric mean in the case of fecal coliform and E. coli) of all composite and/or grab samples collected during any week. A week begins at 12:01 a.m. Sunday morning and ends at 12:00 midnight Saturday evening.

Quantity Values d.

Daily Maximum - The highest single daily quantity reading (see Calculations below) recorded during the reporting period.

e.

Monthly Average - The arithmetic mean (geometric mean in the case of fecal coliform and E. coli bacteria) of all the daily quantity readings (see Calculations below) recorded during a calendar month.

f.

Weekly Average - The arithmetic mean (geometric mean in the case of fecal coliform and E. coli bacteria) of all the daily quantity readings (see Calculations below) recorded during a week. A week begins at 12:01 a.m. Sunday morning and ends at 12:00 midnight Saturday evening.

Flow Values g.

Daily Flow - The flow volume recorded on any single day. The daily flow volume may be determined by using an instantaneous reading (if authorized by this permit) or a continuous recorder.

h.

Daily Maximum Flow - The highest single daily flow reading recorded during a reporting period.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 7 i.

Monthly Average Flow - The arithmetic mean of all daily flow values recorded during a calendar month.

j.

Weekly Average Flow - The arithmetic mean of all daily flow values recorded during a week. A week begins at 12:01 am on Sunday morning and ends at 12:00 midnight Saturday evening.

Calculations k.

Daily Quantity (kg/day) - The quantity, in kilograms per day, of pollutant discharged on a single day. The Daily quantity shall be calculated by multiplying the composite or grab sample concentration value for that day in milligrams/liter (mg/L) times the flow volume (in millions of gallons per day - MGD) for that day times 3.78. If a flow volume reading for the day the sample is collected is not available, the average flow volume reading for the entire reporting period shall be used.

l.

Daily Quantity (#/day) - The quantity, in number per day, of bacteria or other pollutants discharged on a single day. The number per day shall be calculated by multiplying the composite or grab sample result for that day, in number per 100 milliliters (#/100 ml), times the flow volume (in millions of gallons per day -

MGD) times 3.78 X 107. If a flow volume reading for the day the sample is collected is not available, the average flow volume reading for the entire reporting period shall be used.

m.

Geometric Mean - Calculated in accordance with the procedure described in the most recent edition of "Standard Methods for the Examination of Water and Wastewater".

Miscellaneous n.

A "composite" sample, for monitoring requirements, is defined as a minimum of four (4) grab samples collected at equally spaced two (2) hour intervals and proportioned according to flow.

o.

An "instantaneous" measurement for monitoring requirements is defined as a single reading, measurement, or observation.

p.

"MGD", for monitoring requirements, is defined as million gallons per day.

q.

"Net" value, if noted under Effluent Characteristics, is calculated on the basis of the net increase of the individual parameter over the quantity of that same parameter present in the intake water measured prior to any contamination or use in the process of this facility. Any contaminants contained in any intake water obtained from underground wells shall not be adjusted for as described above and, therefore, shall be considered as process input to the final effluent. Limitations in which "net" is not noted are calculated on the basis of gross measurements of each parameter in the discharge, irrespective of the quantity of those parameters in the intake waters.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 8 r.

A "pollutant" is any substance or substances that, if allowed to enter surface waters of the state, causes or threatens to cause pollution as defined in the Wyoming Environmental Quality Act, Section 35-11-103.

4.

Test Procedures Test procedures for the analysis of pollutants, collection of samples, sample containers, sample preservation, and holding times, shall conform to regulations published pursuant to 40 CFR, Part 136, unless other test procedures have been specified in this permit.

5.

Recording of Results For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information:

a.

The exact place, date and time of sampling; b.

The dates and times the analyses were performed; c.

The person(s) who performed the analyses and collected the samples; d.

The analytical techniques or methods used; and e.

The results of all required analyses including the bench sheets, instrument readouts, computer disks or tapes, etc., used to determine the results.

6.

Additional Monitoring by Permittee If the permittee monitors any pollutant at the location(s) designated herein more frequently than required by this permit, using approved analytical methods as specified above, the results of such monitoring shall be included in the calculation and reporting of the values required in the Discharge Monitoring Report Form. Such increased frequency shall also be indicated.

7.

Records Retention The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, for a period of at least three (3) years from the date of the sample, measurement, report or application. This period may be extended by request of the administrator at any time. Data collected on site, copies of Discharge Monitoring Reports and a copy of this WYPDES permit must be maintained on site during the duration of activity at the permitted location.

8.

Penalties for Tampering The Act provides that any person who falsifies, tampers with or knowingly renders inaccurate, any monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two (2) years per violation, or both.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 9 9.

Compliance Schedules Reports of compliance or noncompliance with, or any progress reports on interim and final requirements contained in any Compliance Schedule of this permit shall be submitted no later than 14 days following each schedule date.

10.

Location of Discharge Points Table 1: WY0020311 Naughton Plant Out-fall Qtr/Qtr SEC-TION TWP (N)

RNG (W)

LATITUDE LONGITUDE Drainage /

Description 003*

SWNE 33 21 116 41.75560

-110.58743 North Fork Little Muddy Creek via an unnamed drainage (3B), Green River Basin

  • Outfall location provided by permittee, 1/30/2018 TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 10 PART II A.

MANAGEMENT REQUIREMENTS 1.

Changes The permittee shall give notice to the administrator of the Water Quality Division as soon as possible of any physical alterations or additions to the permitted facility. Notice is required when:

a.

The alteration or addition to a permitted facility may meet one of the criteria for determining whether a facility is a new source as determined in 40 CFR 122.29 (b); or b.

The alteration or addition could change the nature or increase the quantity of pollutants discharged.

2.

Noncompliance Notification a.

The permittee shall give advance notice of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements.

b.

The permittee shall report any noncompliance which may endanger health or the environment as soon as possible, but no later than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time the permittee first became aware of the circumstances. The report shall be made to the Water Quality Division, Wyoming Department of Environmental Quality at (307) 777-7781.

c.

For any incidence of noncompliance, including noncompliance related to non-toxic pollutants or non-hazardous substances, a written submission shall be provided within five (5) days of the time that the permittee becomes aware of the noncompliance circumstance.

The written submission shall contain:

(1)

A description of the noncompliance and its cause; (2)

The period of noncompliance, including exact dates and times; (3)

The estimated time noncompliance is expected to continue if it has not been corrected; and (4)

Steps taken or planned to reduce, eliminate and prevent reoccurrence of the noncompliance.

d.

The following occurrences of unanticipated noncompliance shall be reported by telephone to the Water Quality Division, Watershed Management Section, WYPDES Program (307) 777-7781 as soon as possible, but no later than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time the permittee first became aware of the circumstances.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 11 (1)

Any unanticipated bypass which exceeds any effluent limitation in the permit; (2)

Any upset which exceeds any effluent limitation in the permit; or (3)

Violation of a maximum daily discharge limitation for any toxic pollutants or hazardous substances, or any pollutants specifically identified as the method to control a toxic pollutant or hazardous substance listed in the permit.

e.

The administrator of the Water Quality Division may waive the written report on a case-by-case basis if the oral report has been received within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by the Water Quality Division, WYPDES Program (307) 777-7781.

f.

Reports shall be submitted to the Wyoming Department of Environmental Quality at the address in Part I under Reporting and to the Planning and Targeting Program, 8ENF-PT, Office of Enforcement, Compliance, and Environmental Justice, U.S. EPA Region 8, 1595 Wynkoop Street, Denver, CO 80202-1129.

g.

The permittee shall report all instances of noncompliance that have not been specifically addressed in any part of this permit at the time the monitoring reports are due.

3.

Facilities Operation The permittee shall, at all times, properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by the permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, as a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance.

4.

Adverse Impact The permittee shall take all reasonable steps to minimize any adverse impact to waters of the state resulting from noncompliance with any effluent limitations specified in this permit, including such accelerated or additional monitoring as necessary to determine the nature and impact of the noncomplying discharge.

5.

Bypass of Treatment Facilities a.

Bypass means the intentional diversion of waste streams from any portion of a treatment facility.

b.

The permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it is for essential maintenance to assure efficient operation. These bypasses are not subject to the provisions of TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 12 paragraphs c. and d. of this section. Return of removed substances to the discharge stream shall not be considered a bypass under the provisions of this paragraph.

c.

Notice:

(1)

Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit prior notice at least 60 days before the date of the bypass.

(2)

Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as required under Part II.A.2.

d.

Prohibition of bypass.

(1)

Bypass is prohibited and the administrator of the Water Quality Division may take enforcement action against a permittee for a bypass, unless:

(a)

The bypass was unavoidable to prevent loss of life, personal injury or severe property damage; (b)

There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes or maintenance during normal periods of equipment downtime.

This condition is not satisfied if adequate back-up equipment should have been installed to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance; and (c)

The permittee submitted notices as required under paragraph c.

of this section.

e.

The administrator of the Water Quality Division may approve an anticipated bypass, after considering its adverse effects, if the administrator determines that it will meet the three conditions listed above in paragraph d. (l) of this section.

6.

Upset Conditions a.

Upset means an exceptional incident in which there is unintentional and temporary noncompliance with technology based permit effluent limitations because of factors beyond the reasonable control of the permittee. An upset does not include noncompliance to the extent caused by operational error, improper designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.

b.

An upset constitutes an affirmative defense to an action brought for noncompliance with technology based permit effluent limitations if the requirements of paragraph c. of this section are met.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 13 c.

A permittee who wishes to establish the affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs or other relevant evidence that:

(1)

An upset occurred and that the permittee can identify the cause(s) of the upset; (2)

The permitted facility was at the time being properly operated; (3)

The permittee submitted notice of the upset as required under Part II.A.2; and (4)

The permittee complied with any remedial measures required under Part II.A.4.

d.

Burden of proof. In any enforcement proceeding, the permittee seeking to establish the occurrence of an upset has the burden of proof.

7.

Removed Substances Solids, sludges, filter backwash or other pollutants removed in the course of treatment or control of wastewaters or intake waters shall be disposed of in a manner such as to prevent any pollutant from such materials from entering waters of the state.

8.

Power Failures In order to maintain compliance with the effluent limitations and prohibitions of this permit, the permittee shall either:

a.

In accordance with a schedule of compliance contained in Part I, provide an alternative power source sufficient to operate the wastewater control facilities; or b.

If such alternative power source as described in paragraph a. above is not in existence and no date for its implementation appears in Part I, take such precautions as are necessary to maintain and operate the facility under its control in a manner that will minimize upsets and insure stable operation until power is restored.

9.

Duty to Comply The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the federal act and the Wyoming Environmental Quality Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The permittee shall give the administrator of the Water Quality Division advance notice of any planned changes at the permitted facility or of any activity which may result in permit noncompliance.

TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 14 10.

Duty to Mitigate The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment.

11.

Signatory Requirements All applications, reports or information submitted to the administrator of the Water Quality Division shall be signed and certified.

a.

All permit applications shall be signed as follows:

(1)

For a corporation: by a responsible corporate officer; (2)

For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; (3)

For a municipality, state, federal or other public agency: by either a principal executive officer or ranking elected official.

b.

All reports required by the permit and other information requested by the administrator of the Water Quality Division shall be signed by a person described above or by a duly authorized representative of that person. A person is a duly authorized representative only if:

(1)

The authorization is made in writing by a person described above and submitted to the administrator of the Water Quality Division; and (2)

The authorization specified either an individual or a position having responsibility for the overall operation of the regulated facility or activity, such as the position of plant manager, operator of a well or a well field, superintendent, position of equivalent responsibility or an individual or position having overall responsibility for environmental matters for the company. A duly authorized representative may thus be either a named individual or any individual occupying a named position.

c.

If an authorization under paragraph II.A.11.b. is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, a new authorization satisfying the requirements of paragraph II.A.11.b must be submitted to the administrator of the Water Quality Division prior to or together with any reports, information or applications to be signed by an authorized representative.

d.

Any person signing a document under this section shall make the following certification:

"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 TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 15 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 fine and imprisonment for knowing violations."

B.

RESPONSIBILITIES 1.

A.

Providing Access The permittee shall allow Department of Environmental Quality personnel and their invitees to enter the premises where the facility is located, or where records are kept under the conditions of this permit, and collect resource data as defined by Wyoming Statute § 6-3-414, inspect and photograph the facility, collect samples for analysis, review records, and perform any other function authorized by law or regulation. The permittee shall secure and maintain such access for the duration of the permit.

If the facility is located on property not owned by the permittee, the permittee shall also secure and maintain from the landowner upon whose property the facility is located permission for Department of Environmental Quality personnel and their invitees to enter the premises where a regulated facility is located, or where records are kept under the conditions of this permit, and collect resource data as defined by Wyoming Statute § 6 414, inspect and photograph the facility, collect samples for analysis, review records, and perform any other function authorized by law. The permittee shall secure and maintain such access for the duration of the permit.

If the facility cannot be directly accessed using public roads, the permittee shall also secure and maintain permission for Department of Environmental Quality personnel and their invitees to enter and cross all properties necessary to access the facility. The permittee shall secure and maintain such access for the duration of the permit.

B.

Access Records The permittee shall maintain in its records documentation that demonstrates that the permittee has secured permission for Department of Environmental Quality personnel and their invitees to access the permitted facility, including (i) permission to access the land where the facility is located, (ii) permission to collect resource data as defined by Wyoming Statute § 6-3-414, and (iii) permission to enter and cross all properties necessary to access the facility if the facility cannot be directly accessed from a public road. The permittee shall also maintain in its records a current map of the access route(s) to the facility and contact information for the owners or agents of all properties that must be crossed to access the facility. The permittee shall ensure that the documentation, map, and contact information are current at all times. The permittee shall provide the documentation, map, and contact information to Department of Environmental Quality personnel upon request. Upon termination of the permit, the permittee shall maintain such records for a period of three (3) years.

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Transfer of Ownership or Control In the event of any change in control or ownership of facilities from which the authorized discharges emanate, the permittee shall notify the succeeding owner or controller of the existence of this permit by letter, a copy of which shall be forwarded to the regional administrator of the Environmental Protection Agency and the administrator of the Water Quality Division. The administrator of the Water Quality Division shall then provide written notification to the new owner or controller of the date in which they assume legal responsibility of the permit. The permit may be modified or revoked and reissued to change the name of the permittee and incorporate such other requirements as described in the federal act.

3.

Availability of Reports Except for data determined to be confidential under Section 308 of the federal act, all reports prepared in accordance with the terms of this permit shall be available for public inspection at the offices of the Wyoming Department of Environmental Quality and the regional administrator of the Environmental Protection Agency. As required by the federal act, effluent data shall not be considered confidential. Knowingly making any false statement on any such report may result in the imposition of criminal penalties as provided for in Section 309 of the federal act.

4.

Toxic Pollutants The permittee shall comply with effluent standards or prohibitions established under Section 307 (a) of the federal act for toxic pollutants within the time provided in the regulations that establish those standards or prohibitions, even if the permit has not yet been modified to incorporate the requirement.

5.

Changes in Discharge of Toxic Substances Notification shall be provided to the administrator of the Water Quality Division as soon as the permittee knows of, or has reason to believe:

a.

That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following "notification levels":

(1)

One hundred micrograms per liter (100 g/l);

(2)

Two hundred micrograms per liter (200 g/l) for acrolein and acrylonitrile; five hundred micrograms per liter (500 g/l) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/1) for antimony; (3)

Five (5) times the maximum concentration value reported for that pollutant in the permit application in accordance with 40 CFR 122.21 (g)

(7); or TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 17 (4)

The level established by the director of the Environmental Protection Agency in accordance with 40 CFR 122.44 (f).

b.

That any activity has occurred or will occur which would result in any discharge, on a non-routine or infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following "notification levels":

(1)

Five hundred micrograms per liter (500 g/l);

(2)

One milligram per liter (1 mg/1) for antimony; (3)

Ten (10) times the maximum concentration value reported for that pollutant in the permit application in accordance with 40 CFR 122.21 (g)

(7); or (4)

The level established by the director of the Environmental Protection Agency in accordance with 40 CFR 122.44 (f).

6.

Civil and Criminal Liability Nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. As long as the conditions related to the provisions of "Bypass of Treatment Facilities" (Part II.A.5), "Upset Conditions" (Part II.A.6), and "Power Failures" (Part II.A.8) are satisfied then they shall not be considered as noncompliance.

7.

Need to Halt or Reduce Activity not a Defense It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

8.

Oil and Hazardous Substance Liability Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities or penalties to which the permittee is or may be subject under Section 311 of the federal act.

9.

State Laws Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities or penalties established pursuant to any applicable state or federal law or regulation. In addition, issuance of this permit does not substitute for any other permits required under the Clean Water Act or any other federal, state, or local law.

10.

Property Rights The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property TP-LIC-LET-0362

WY0020311 RENEWAL-1-30-18 INDI Page 18 or any invasion of personal rights nor any infringement of federal, state or local laws or regulations.

11.

Duty to Reapply If the permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the permittee must apply for and obtain a new permit. The application should be submitted at least 180 days before the expiration date of this permit.

12.

Duty to Provide Information The permittee shall furnish to the administrator of the Water Quality Division, within a reasonable time, any information which the administrator may request to determine whether cause exists for modifying, revoking and reissuing or terminating this permit or to determine compliance with this permit. The permittee shall also furnish to the administrator, upon request, copies of records required by this permit to be kept.

13.

Other Information When the permittee becomes aware that it failed to submit any relevant facts in a permit application or submitted incorrect information in a permit application or any report to the administrator of the Water Quality Division, it shall promptly submit such facts or information.

14.

Permit Action This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncompliance does not stay any permit condition.

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OTHER REQUIREMENTS 1.

Flow Measurement At the request of the administrator of the Water Quality Division, the permittee must be able to show proof of the accuracy of any flow measuring device used in obtaining data submitted in the monitoring report. The flow measuring device must indicate values of within plus or minus ten (10) percent of the actual flow being measured.

2.

208(b) Plans This permit may be modified, suspended or revoked to comply with the provisions of any 208(b) plan certified by the Governor of the State of Wyoming.

3.

Reopener Provision This permit may be reopened and modified (following proper administrative procedures) to include the appropriate effluent limitations (and compliance schedule, if necessary) or other appropriate requirements if one or more of the following events occurs:

a.

The state water quality standards of the receiving water(s) to which the permittee discharges are modified in such a manner as to require different effluent limits than contained in this permit; b.

A total maximum daily load (TMDL) and/or watershed management plan is developed and approved by the state and/or the Environmental Protection Agency which specifies a wasteload allocation for incorporation in this permit; c.

A revision to the current water quality management plan is approved and adopted which calls for different effluent limitations than contained in this permit; d.

Downstream impairment is observed and the permitted facility is contributing to the impairment; e.

The limits established by the permit no longer attain and/or maintain applicable water quality standards; f.

The permit does not control or limit a pollutant that has the potential to cause or contribute to a violation of a state water quality standard.

g.

If new applicable effluent guidelines and/or standards have been promulgated and the standards are more stringent than the effluent limits established by the permit.

h.

In order to protect water quality standards in neighboring states, effluent limits may be incorporated into this permit or existing limits may be modified to ensure that the appropriate criteria, water quality standards and assimilative capacity are attained.

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Permit Modification After notice and opportunity for a hearing, this permit may be modified, suspended or revoked in whole or in part during its term for cause including, but not limited to, the following:

a.

Violation of any terms or conditions of this permit; b.

Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; c.

A change in any condition that requires either a temporary or permanent reduction or elimination of the authorized discharge; or d.

If necessary to comply with any applicable effluent standard or limitation issued or approved under Sections 301(b) (2) (C) and (D), 304 (b) (2) and 307 (a) (2) of the federal act, if the effluent standard or limitation so issued or approved:

(1)

Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or (2)

Controls any pollutant not limited in the permit.

5.

Toxicity Limitation - Reopener Provision This permit may be reopened and modified (following proper administrative procedures) to include a new compliance date, additional or modified numerical limitations, a new or different compliance schedule, a change in the whole effluent protocol or any other conditions related to the control of toxicants if one or more of the following events occur:

a.

Toxicity was detected late in the life of the permit near or past the deadline for compliance; b.

The toxicity reduction evaluation (TRE) results indicate that compliance with the toxic limits will require an implementation schedule past the date for compliance and the permit issuing authority agrees with the conclusion; c.

The TRE results indicate that the toxicant(s) represent pollutant(s) that may be controlled with specific numerical limits and the permit issuing authority agrees that numerical controls are the most appropriate course of action; d.

Following the implementation of numerical controls on toxicants, the permit issuing authority agrees that a modified whole effluent protocol is necessary to compensate for those toxicants that are controlled numerically; e.

The TRE reveals other unique conditions or characteristics which, in the opinion of the permit issuing authority, justify the incorporation of unanticipated special conditions in the permit.

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Severability The provisions of this permit are severable and if any provision of this permit, or the application of any provision of this permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this permit, shall not be affected thereby.

7.

Penalties for Falsification of Reports The federal act provides that any person who knowingly makes any false statement, representation or certification in any record or other document submitted or required to be maintained under this permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per violation or by imprisonment for not more than two years per violation or both.

TP-LIC-LET-0362