RESPONSE TO COMMENTS
Permit Modification of the APS Four Corners Power Plant Permit
NPDES Permit No. NN0000019
December 2023
EPA solicited comments on the draft permit modification and factsheet on September 27, 2023
and this comment period ended on October 30, 2023. EPA received comments from Law Office
of John Barth on behalf of Dine CARE, San Juan Citizens' Alliance, Center for Biological
Diversity, Amigos Bravos, and Sierra Club on October 30, 2023. EPA has summarized the
comments and responded to comments below.
COMMENT 1: The currently effective effluent guideline for the discharge of pollutants in
bottom ash states, "there shall be no discharge of pollutants in bottom ash transport water." 40
C.F.R. §423.13(k)(l)(i). EPA's draft permit modification would allow APS to avoid this "no
discharge" requirement by allowing a discharge of up to 2.5% of a 30-day rolling average of the
primary active wetted bottom ash system volume at Outfall 01E. These bottom ash pollutants
would flow into the receiving canal and then flow into Morgan Lake. Morgan Lake is a public
recreation lake allowing for primary contact with the water and sustenance fishing. APS' permit
modification request poses risks to public health and the environment because of the
discharge of toxic pollutants into waters of the Navajo Nation.
RESPONSE 1: Commenter is citing the general no discharge rule. However, the full text of 40
C.F.R. Section 423.13(k)( 1 )(i) is as follows:
" (i) Bottom ash transport water. Except for those discharges to which paragraph (k)(2) of
this section applies, or when the bottom ash transport water is used in the FGD scrubber,
there shall be no discharge of pollutants in bottom ash transport water. Dischargers must
meet the discharge limitation in this paragraph by a date determined by the permitting
authority that is as soon as possible beginning October 13, 2021, but no later than December
31, 2025. This limitation applies to the discharge of bottom ash transport water generated on
and after the date determined by the permitting authority for meeting the discharge limitation,
as specified in this paragraph. Except for those discharges to which paragraph (k)(2) of this
section applies, whenever bottom ash transport water is used in any other plant process or is
sent to a treatment system at the plant (except when it is used in the FGD scrubber), the
resulting effluent must comply with the discharge limitation in this paragraph. When
the bottom ash transport water is used in the FGD scrubber, it ceases to be bottom
ash transport water, and instead is FGD wastewater, which must meet the
requirements in paragraph (g) of this section."
This complete excerpt from the applicable regulation indicates that although full prohibition of
the discharge of bottom ash transport water is the general rule, there is also a well-developed
provision for identifying exceptions to that full prohibition.
In the case of this permit modification, and as discussed in more detail in the Notice of Proposed
Modification and below, EPA has found that the discharger has met the requirements of Section
1
-------
423.3(k)(2), including the allowance for and limits on discharge of bottom ash transport water at
Section 423(k)(2)(i), such that the proposed modification is appropriate. Section 423(k)(2)(i)(A)
states that:
"The discharge ofpollutants in bottom ash transport water from a properly installed,
operated, and maintained bottom ash system is authorized under the following conditions:
(1) To maintain system water balance when precipitation-related inflows are generated from
storm events exceeding a 10-year storm event of 24-hour or longer duration ( e.g., 30-day
storm event) and cannot be managed by installed spares, redundancies, maintenance tanks,
and other secondary bottom ash system equipment; or ( 2) To maintain system water balance
when regular inflows from waste streams other than bottom ash transport water exceed the
ability of the bottom ash system to accept recycled water and segregating these other waste
streams is not feasible; or ( 3) To maintain system water chemistry where installed equipment
at the facility is unable to manage pH, corrosive substances, substances or conditions causing
scaling, or fine particulates to below levels which impact system operation or maintenance;
or ( 4) To conduct maintenance not otherwise included in paragraphs (k)(2)(i)(A) (1),(2), or
(3) of this section and not exempted from the definition of transport water in § 423.1 l(p), and
when water volumes cannot be managed by installed spares, redundancies, maintenance
tanks, and other secondary bottom ash system equipment."
The permit modification allows for discharge of bottom ash transport water only in the above
authorized situations.
As an artificial cooling pond designed and constructed to be used as treatment for the FCPP's
waste heat, Morgan Lake is a waste treatment system and is excluded from the definition of
"waters of the United States." 40 C.F.R. § 122.2. EPA regulates discharges from the FCPP into
Morgan Lake as an "internal outfall" pursuant to 40 CFR 122.45(h), and the proposed permit
modification affects only the discharge into Morgan Lake labeled Internal Outfall No. 01E.
COMMENT la: The permit modification request should be denied because APS has not
proven that the water balance in its system "cannot be managed by installed spares,
redundancies, maintenance tasks, and other secondary bottom ash system equipment" or other
measures. 40 C.F.R. §423.13(k)(2)(i)(l)-(4). APS should be required to install and operate
additional and/or redundant equipment, such as additional bottom ash sluice water recycle tanks,
in order to comply with the "no discharge" effluent requirement. Alternatively, APS should be
required to abandon its wet sluicing of bottom ash and fly ash at the plant and switch to a dry
system.
RESPONSE la: Commenter is correct that APS must demonstrate that the water balance in the
system "cannot be managed" by surplus tankage before the facility is entitled to a purge. This
demonstration necessarily differs at a facility with a fully constructed and operating high recycle
rate system and one which, though fully designed, has yet to be commissioned. APS can only be
responsible for providing what is possible and to the extent the facility falls in the latter category
it is not possible for operational data to be applied to such a demonstration. Instead, APS has
provided a good faith estimate of the circumstances in which it estimates that water balance
2
-------
"cannot be managed" and thus, may require a discharge. For example, in the January 8, 2021
permit modification request, APS stated on page 3:
"Every effort will be made to divert stormwater flows from the BATW recirculation
system to a future separate low volume waste system, but given the configuration of
process areas and the open top tanks and equipment that will be part of the BATW
recirculation system, storm events will result in surges in system volume that could
require system purges."
These "efforts" were an intended system design which was followed up on, resulting in a system
design that was later estimated to be able to handle flows not just up to the 10-year events
required by the rule, but up to 100-year events.1 Furthermore, as presented, other potential in-
flows would also be able to be handled by redirection to the FGD scrubber rather than a regular
purge. While there is more uncertainty regarding potential maintenance discharges, here too APS
attempts to estimate the need, stating in the initial certification statement that it may be necessary
to empty a secondary tank as often as once per year.2 In justification of this need, the company
stated that physical space for a third tank was limited, and furthermore that the cost of a third
tank was not warranted for a maintenance event that would happen no more frequently than once
per year. Thus, it is clear that for managing water balance issues, APS is taking actions that
achieve the requirement that "[t]he total volume that may be discharged for the above activities
shall be reduced or eliminated to the extent achievable..." 423.13(k)(2)(i)(B).
With respect to the alternative suggestion that APS should be required to switch to a dry system,
the preamble of the 2020 Rule stated that "[wjhile plants are free to use dry handling
technologies to achieve the limitations in the rule, the final rule limitations are based on high
recycle rate systems..(85 Fed. Reg. 64660) EPA does not have the authority to require which
system APS uses to meet the limitations. While a dry handling system might achieve equal or
greater pollutant removals, APS may select any system so long as it can meet the 2020 Rule
limitations, including the allowable purge.
COMMENT 2: EPA should deny the permit modification request based on environmental
justice considerations. Almost the entire population living near the plant is Native American.
Additionally, the vast majority of the local population is at or below the poverty line. Further, the
Navajo Nation and Four Corners area has been treated as a national "sacrifice zone" for decades,
allowing heavily polluting industries to adversely impact public health. A review of the
administrative record for the proposed permit modification fails to undertake any environmental
justice analysis, contrary to EPA policy and Presidential Executive Orders. See, Attachment 1
and 2 [of the October 30, 2023 comment letter] hereto. EPA must undertake a comprehensive
and cumulative environmental justice analysis before proceeding with this permit modification
and closely consider the findings of that analysis before rendering a decision.
1 See Table 2-2 of Initial Certification Statement Supporting the Discharge of Bottom Ash Transport Water, May,
2022 Draft (see Attachment 3).
2 Id at Table 2-3.
3
-------
RESPONSE 2: As discussed in more detail below, EPA is reconsidering only those permit
conditions being proposed for revision in the public notice. The other provisions of the permit
remain in place for the remainder of the permit term. EPA's consideration of environmental
justice concerns in the permitting decisions have already been subject to public scrutiny when
this permit was issued in 2020 and will again be available for public comment when this entire
permit is proposed for reissuance following reapplication.
As a factual matter, EPA completed a screening-level environmental justice analysis for Four
Corners Power Plant NPDES permit in 2015. In 2015, EPA was considering NPDES permit
renewals for both the FCPP and the adjacent Navajo Mine. In a report dated August 7, 2015,
EPA used the EJSCREEN program to evaluate for EJ concerns an area within 10 miles of the
Navajo Mine, which area includes the entire FCPP facility. The 2015 EJSCREEN report is
included to this Response to Comments document as Attachment 1.
Again, EPA notes that the environmental justice analysis for the FCPP is not being reopened in
this permit modification. EPA notes, however, that the EJSCREEN program is still cited as a
valid EJ screening mechanism. See EPA, E.O. 13985 Equity Action Plan, April 2022, at p. 7 and
footnote 10. EJSCREEN program has been updated since the screening in 2015, so EPA
performed a second EJSCREEN evaluation of the area including the FCPP and the Navajo Mine
on November 21, 2023. The 2023 EJSCREEN report is also included as Attachment 2. The
2023 results largely mirror the initial review from 2015. EPA used EJSCREEN to identify
environmental factors in the vicinity of the APS Four Corners Power Plant (FCPP) that could
pose risk to local residents USEPA also evaluated whether demographic characteristics of the
population living in the vicinity of the facility indicate that the local population might be
particularly susceptible to such environmental risks. The 2023 results largely mirror the initial
review from 2015. The results show that, at the time of this analysis, conducted on November 21,
2023, the area in which the facility is located was above the 97th percentile in New Mexico and
28th percentile nationally for toxics releases to air. No other environmental parameter exceeded
the 80th percentile either for New Mexico, or nationally. The EJSCREEN analysis of
demographic characteristics of the community living near the facility indicates a higher
proportion of minority and low-income population, and population with less than high school
education, compared to the national population.
EPA considers the characteristics of the facility operation and discharges, and whether those
discharges, in combination with discharges from local toxics to air, pose exposure risks that the
NPDES permit needs to further address. The effluent discharge authorized by this permit is
unlikely to contribute to toxics in the air. EPA acknowledges that operations of the facility
outside the scope of this permit may contribute toxics to the air, and air pollution from the
facility is regulated by a separate Air Quality permit. (CAA Operating Permit
NN00000035045NAV02). EPA finds the results of these EJSCREEN analyses do not indicate
the need to adjust the permit modification.
Review of past NPDES Discharge Monitoring Reports in EPA's Enforcement and Compliance
History Online (ECHO) database3 for the period of this permit indicate no violations of numeric
3 See ECHO database at echo.epa.gov, FRS ID number 110042068473
4
-------
limits from any of the discharges to receiving surface waters. Thus, EPA finds no evidence to
indicate the effluent discharged from the facility poses a significant risk to residents.
The proposed modification does not alter any of the permit limits and monitoring requirements
from Outfall 001, the only authorized outfall to the receiving waterbody. Additionally, the
proposed modification reduces the permitted discharge of bottom ash transport water at internal
Outfall 01E by over 90% compared to the existing permit.
EPA believes that by implementing and requiring compliance with the provisions of the Clean
Water Act, which are designed to ensure full protection of human health, the permit including
the proposed modification, is sufficient to ensure that the permitted effluent discharges will not
cause or contribute to human health risk in the vicinity of the facility, nor would it result in
adverse impacts that would disproportionally affect low-income or minority populations or
contribute to any environmental justice issues.
COMMENT 3: Section 423.19(c) of the current effective regulation requires facilities
proposing to discharge BA transport water to provide in the Initial Certification Statement, "the
primary active wetted bottom ash system volume in §423.1 l(aa)" and "[a] list of all potential
discharges.. .the expected volume of each discharge, and the expected frequency of each
discharge." 40 C.F.R. §423.19(C)(2)(D) and (F). The deadline for submission of this information
was October 13, 2023. To date, APS has failed to provide specific volumes of each discharge
and the frequency of each discharge. Instead, APS proposes to use 2024 to generate data that
"would be used to identify the bottom as purge volume... " APS letter to Gary
Sheth, EPA dated November 1, 2022 and referred to in EPA's draft Fact Sheet. APS' permit
modification application should be denied because, to date, it has failed to provide specific,
concrete data on the volume and frequency of each discharge.
RESPONSE 3: Commenter misinterprets the Initial Certification Statement. The title of the
document contains the word "initial" and yet commenter treats it as the "final" word on purge
needs. While the 2020 Rule did create a nationally applicable requirement for an initial
certification statement that would assist permitting authorities in evaluating purge requests, this
requirement was not intended either to prohibit the permit writer from requesting additional
information when first implementing the 2020 Rule or to prohibit future requests for updated
information that might allow a permit writer to tighten the purge allowance as operational
experience and facts on the ground allow.4
Here, where APS has yet to commission and operate the high recycle rate system at issue, it
would be wholly inconsistent with the permitting authority's determination of an "as soon as
possible" date under 423.1 l(t) to read this initial paperwork submission to demand knowledge
for a system that is not yet operating. APS provided an initial certification statement in May,
2022 and has since provided supplemental information to satisfy EPA's concerns that it justify
4 NPDES regulations prohibit the permitting authority from issuing an individual permit until and unless a
prospective discharger provides a "complete application which includes an application form and any supplemental
information completed to their satisfaction." 40 CFR 122.21(e).
5
-------
the volumes and frequencies of each discharge.5 Volumes and frequencies of even fully
operating systems can never be known with certainty (e.g., stormwater events). Instead, best
estimates are all that is possible at this time, estimates which APS has provided.
To the extent that APS, and subsequently EPA, learn more after the system is commissioned and
begins closed-loop operations, it may become appropriate for EPA to adjust the purge limitations
that get initially established based on the engineering calculations and assumptions provided in
the initial certification statement. In that sense, the limit may naturally tighten over time with the
experience of the system operators. The fact that APS has committed to minimize its purge and
provide data and information to EPA once it becomes available further supports that this is a
reasonable path for compliance.6
COMMENT 4: EPA's proposed modification to NPDES Permit NN0000019 is limited to
issues related to a proposed "BA purge water" exemption request to allow for the discharge of
bottom ash transport water from Internal Outfall 01E. However, both the proposed Fact Sheet
and Draft Permit fail to acknowledge the significant physical and operational changes that have
been made to the Four Corners Power Plant water pollution control systems since EPA last re-
issued this permit on September 30, 2019. These physical and operational changes are
documented in Arizona Public Service's 2022 Annual CCR Impoundment and Landfill
Inspection Report, which is posted to the company's mandated Coal Combustion Residual
("CCR") public website. Attachment 3 hereto. Some of the notable operational and
physical changes to the Four Corners Power Plant water pollution controls systems since
September 30, 2019 include the following:
• "APS stopped discharging to the LAI [Lined Ash Impoundment] on April 2, 2021. At
the time of the October 2022 inspection, the reservoir pool had been removed, leaving
only interstitial water within the impounded ash to drain into the LDWP [Lined Decant
Water Pond] via the Drop Inlet Structure and the Deadpool Sump." Exhibit 1, p. 3.
• "APS constructed the Bottom Ash Sluice Water Recycle (BASWR) Tank to replace the
CWTP [Combined Waste Treatment Pond] in 2020.. .APS ceased discharging to the
CWTP by November 23, 2020." Exhibit 1, pp. 3-4.
• "The RWP [Return Water Pond] is an approximately 5.13-acre lined impoundment
facility for the temporary storage of LAI/LDWP and Pond 3 pump house discharges. The
RWP was constructed in 2019 and was placed into service as a CCR unit on October 20,
2020. Exhibit 1, p. 4. As shown above and in Exhibit 1, the water pollution control system has
been almost entirely modified since EPA's last issuance of NPDES Permit NN0000019 on
September 30, 2019. A review of EPA's September 20, 2019 permit and fact sheet contain no
references to the BASWR Tank, Drop Inlet Structure, Deadpool Sump, or RWP. Further, the
current proposed Draft Permit and Fact Sheet fail to acknowledge all of these significant physical
and operational changes since September 30, 2019. As written, the Draft Permit is factually
5 APS correspondence dated: May 5, 2021, June 21, 2022, November 1, 2022, January 26, 2023, and July 21, 2023.
(See Attachments 3-7).
6 In the June 21, 2022 update to EPA (see Attachment 4), APS states that it will:
"Monitor and, to the maximum extent feasible, minimize BATW discharges from startup to compliance deadline"
and "Regularly report to EPA (e.g., monthly) blowdown volumes, internal water chemistry, etc."
6
-------
inaccurate. More specifically, the Location Map at Attachment C is no longer reflective of
existing coal ash facilities. Moreover, the Wastewater Flow Schematic is also no
longer accurate as it still refers to the "CWTP," fails to identify the BASWR Tank, Drop Inlet
Structure, Deadpool Sump, or RWP, and otherwise displays an inaccurate wastewater flow
schematic. Further, as noted above, APS' permit application fails to prove that it cannot meet the
"no discharge of pollutants in bottom ash" effluent limitation by utilizing the new BASWR
Tank, Drop Inlet Structure, Deadpool Sump, or RWP facilities or adding additional redundant
facilities. In the event EPA proceeds with any permit modification, we ask that EPA re-open the
permit in its entirety to address the numerous factual deficiencies in both the Permit and Fact
Sheet. We ask that EPA amend the Fact Sheet to contain a comprehensive description of the
current wastewater flow at the Four Corners Power Plant. This should include a cradle to grave
description of all water pollution flow paths and where is each path discharges. Because the
Outfall 01E physical location was recently moved, we ask that EPA include an accurate map
identifying all structures and features along the wastewater flow path discussed herein, all outfall
locations, and all monitoring locations. We also ask the EPA replace Attachment C of the current
permit with a legible and currently accurate Location Map and Attachment D with a legible and
currently accurate one-page Wastewater Flow Schematic.
RESPONSE 4: A permit modification is not a review of the entire permit and fact sheet. EPA's
regulations are quite clear on this: "In a permit modification under this section, only those
conditions to be modified shall be reopened when a new draft permit is prepared. All other
aspects of the existing permit shall remain in effect for the duration of the unmodified permit."
40 CFR Section 124.5(c)(2). For that reason, EPA's Public Notice solicited public comment
"only on the modifications as described in the proposed modified permit and factsheet."
This permit modification does not contemplate changes to the location of the authorized
discharge point at Outfall 001 which discharges treated effluent from Morgan Lake into No
Name Wash. EPA wishes to clarify that Outfall 01E is an internal discharge point, upstream of
Outfall 001 and need not be updated.
EPA further notes that significant changes in plant operations were envisioned at the time of
permit issuance in 2020. A fully revised Fact Sheet describing the changed configuration will be
released at the time of any future permit renewal.
COMMENT 5: APS is required by law to maintain a publicly available website where it posts
filings, reports, and data related to certain CCR activities at the Four Corners Power Plant. In the
event EPA proceeds with a permit modification, it should require that APS post all filings, data,
and reports related to the BA purge water exemption to APS' publicly available website. This
information would include, but not be limited to, date(s) of each discharge, volume of each
discharge, the volume of the primary active wetted bottom ash system at the time of each
discharge, the Initial Certification Statement and any amendments thereto, the Best Management
Plan for the recycling of bottom ash transport water, all data, filings, and reports required under
Section 423.19 of the regulations, and all data, filings, and reports required under the proposed
regulation at Section 423.19 that can be found at 88 Fed. Reg. 18900 (March 29, 2023).
7
-------
RESPONSE 5: Commenter appears to be suggesting that this permit modification should
incorporate language that mandates compliance with the operative CCR monitoring, reporting
and disclosure provisions of 40 CFR Section 423.19. EPA declines to do so. As noted, only the
provisions being modified are being reopened in this action. EPA has included in the proposed
modification language appropriate monitoring, documentation and reporting provisions it
believes are necessary to implement the proposed modifications.
EPA notes that the provisions of proposed regulations are inapplicable to this action, unless and
until those proposals are finalized.
Attachment 1: EPA EJ Screen Report, 2015
Attachment 2: EPA E J Screen Community Report, 2023
Attachment 3: APS Draft Initial Certification, May 19, 2022
Attachment 4: APS ELG Project Status Update, June 6, 2021
Attachment 5: APS letter to EPA, Proposed Permit Modification Approach, November 1, 2022
Attachment 6: APS letter to EPA, Permit Modification Approach Request, January 26, 2023
Attachment 7: APS letter to EPA, Supplementary Information Supporting Permit Modification,
July 21, 2023
8
-------
Attachment 1: EJSCREEN Report
-------
EnvJrcsi mental Protection EJSCREEN Report
for 10 mile Ring Centered at 36.599724,-108.500172, NEW MEXICO, EPA Region 6
Approximate Population: 1782
Navajo Mine
Selected Variables
State
Percentile
EPA Region I USA
Percentile | Percentile
EJ Indexes
EJ Index for PM2.5
76
71
81
EJ Index for Ozone
v/'V '
EJ Index for NATA Diesel PM
39
48
62
EJ Index for NATA Air Toxics Cancer Risk
vV: :75
-76 :
EJ Index for NATA Respiratory Hazard Index
61
59
68
EJ Index for NATA Neurological Hazard Index
80 ¦
EJ Index for Traffic Proximity and Volume
50
55
68
EJ Index for Lead Pain? Indicator
63 :
72 ;v,.:
76 ' •
EJ Index for Proximity to NPL sites
64
74
79
EJ Index for Proximity to RMR sites
v.,- 80
• '-;'65 '/'Y;
\r-78 .r-. •
EJ Index for Proximity to TSDFs
84
81
89
EJ Index for Proximity to Major Direct Dischargers v /f
:~:;;,:;;85YvVv:; v'.
0 Index for the Selected Area Compared to All People's Block Groups in the State/Region/US
Regional Percentile §1 USA Percentile
This report shows environmental, demographic, and EJ indicator values. It shows environmental and demographic raw data (e.g., the estimated concentration of
ozone in the air), and atso shows what percentile each raw data value represents. These percentiles provide perspective on how the selected block group or
buffer area compares to the entire state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this means that only 5
percent of the US population has a higher block group value than the average person in the location being analyzed. The years for which the data are available,
and the methods used, vary across these indicators. Important caveats and uncertainties apply to this screening-level information, so it is essentia! to understand
the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using
reports.
August 07, 2015
1/3
-------
H-EPA Ejsviftmwmnfal Proieclion EJSCREEN Report
for 10 mile Ring Centered at 36.599724,-108.500172, NEW MEXICO, EPA Region 6
Approximate Population: 1782
Navajo Mine
August 7. 2015
Hf* Digitized Point
Buffer Ares
1 288,895
-*—i—f—
SSvCt £Vt ;:^3CC5t SK£ #."C «"*&$
uwces-iwa/
August 07, 2015
2/3
-------
UnitcciSiaies _ , _ , _
otdrA Agency EJSCREEN RCpOTt
for 10 mile Ring Centered at 36.599724,-108.500172, NEW MEXICO, EPA Region 6
Approximate Population: 1782
Navajo Mine
Selected Variables
Data
State
Avg.
%ile in
State
EPA
Region
Avg.
%ile in | llc.A I .
1 USA %ile in
FPA 1
„ . 1 Avg. USA
Region 1 !
Environmental Indicators
Particulate Matter (pm 2,s in w/m3)
5.61
7.18
8
9.77
0
9.78
0
Ozone (ppb)
53.3
54.1
44
48.6
74
46.1
86
NATA Diesel PM (ng/m3)"
0.0107
0,387
6
0.733
<5Gth
0.824
<50th
NATA Cancer Risk (lifetime risk per million}*'
20
28
16
' 42
<50th
49
<50th
NATA Respiratory Hazard Index*
0.33
0.88
7
1.4
<50th
2,3
<50th
NATA Neurological Hazard Index*
0.031
0.031
58
0.043
<50th
0.063
<50th
Traffic Proximity and Volume (daily traffic count/distance to road)
4.5
73
16
81
10
110
11
Lead Paint Indicator (%Pre-1960 Housing)
0.058
0.2
39
0.19
42
0.3
27
NPL Proximity (site count/km distance)
0.025
0.1
36
0.063
42
0.096
29
RMP Proximity {facility count/km distance)
0.088
0.13
47
0.42
20
0.31
30
TSDF Proximity (facility count/km distance)
0.05
0.062
63
0,062
62
0.054
73
Water Discharger Proximity (facility count/km distance)
0.11
0.12
62
0.35
38
0.25
42
Demographic Indicators
Demographic Index
81%
51%
91
44%
91
35%
95
Minority Population
100%
60%
97
49%
97
36%
98
Low Income Population
61%
42%
80
39%
81
34%
87
Linguistically Isolated Population
9%
6%
76
6%
75
5%
81
Population With Less Than High School Education
23%
17%
70
18%
67
14%
78
Population Under 5 years of age
8%
7%
65
7%
62
7%
71
Population over 64 years of age
10%
13%
38
11%
49
13%
40
* The National-Scale Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air toxics in the United States. EPA developed the NATA to
prioritize air toxics, emission sources, and locations of interest for further study- It is important to remember that NATA provides broad estimates of health risks
over geographic areas of the country, not definitive risks to specific individuals or locations. More information on the NATA analysis can be found
at: http://www.ep3.gov/ttn/atw/natamain/index.html.
For additional information, see: www.epa.gov/environmentaljustice
EJSCREEN is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysts, or outreach, it does not
provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial
uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this
screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see
EJSCREEN documentation for discussion of these issues before using reports. This screening too! does not provide data on every environmental impact and
demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and local knowledge
before taking any action to address potential EJ concerns,
August 07, 2015 3/3
-------
Attachment 2: EJSCREEN Community Report
-------
v>EPA
EJScreen Community Report
This report provides environmental and socioeconomic information for user-defined areas,
and combines that data into environmental justice and supplemental indexes.
San Juan County,
NM
10 miles Ring Centered at 36.689896,-108.482437
Population: 10,237
Area in square miles: 314.03
A3 Landscape
COMMUNITY INFORMATION
LANGUAGES SPOKEN AT HOME
LANGUAGE
PERCENT
English
60%
Spanish
3%
Other and Unspeci ed
37%
Total Non-English
40%
Low income:
59 percent
People of color: ***?"+
* . school education: households:
73 percent 13 percent
Unemployment:
15 percent
73 years
knnes life
npectanqr
Persons with
disabilities:
16 percent
$18,259
Per capita
SI percent
II
bailor of
households:
2,$17
BREAKDOWN BY RACE
Female:
43 percent
Owner
occupied:
72 percent
White: 27%
Black: 6%
American Indian:
84%
Asian: 1%
Hawaiian/Pacific
¦slander: Q%
Other race: 6%
Two or mere
races: 3%
BREAKDOWN BY AGE
From Ages 1 to 4
From Ages 1 to 18
From Ages 18 and up
From Ages 65 and up
Hispanic: 3%
1%
29%
71%
15%
LIMITED ENGLISH SPEAKING BREAKDOWN
Speak Spanish 13%
Speak Other Indo-European Lanpages 0%
Speak Asian-ftci c Island Languages 7%
Speak Other Languages 80%
Notes: Numbers may not sum to totals due to rounding. Hispanic population can be of any race.
Source: U.S. Census Bureau, American Community Survey (ACS) 2017 -2021. Life expectancy data
comes from the Centers for Disease Control.
-------
Environmental Justice & Supplemental Indexes
The environmental justice and supplemental indexes are a combination of environmental and socioeconomic information. There are thirteen EJ indexes and supplemental indoles in
EJScreen re ecting the 13 environmental indicators. The indexes for a selected area are compared to those for all other locations in the state or nation. For more information and
calculation details on the EJ and supplemental indotes, please visit the EJScreen website.
EJ INDEXES
The EJ indexes help users screen Ibr potential EJ concerns. To do this, the EJ index combines data on low income and people of color
populations with a single environmental indicator.
EJ INDEXES FOR THE SELECTED LOCATION
State Percentile
National Percentile
Particulate Ozone
Matter
Air Air Toxic Traffic
Toxics Toxics Releases Proximity
Cancer Respiratory To Air
Risk* HI*
Lead Superfund RMP Hazardous Underground Wastewater
Paint Proximity Facility Waste Storage Discharge
Proximity Proximity Tanks
SUPPLEMENTAL INDEXES
The supplemental indexes offer a different perspective on community-level vulnerability. They combine data on percent low-income, percent linguistically isolated, percent less than high
school education, percent unemployed, and low life expectancy with a single environmental indicator.
SUPPLEMENTAL INDEXES FOR THE SELECTED LOCATION
100
90
80
70
60
»—
B 50
as
Lbl
40
30
20
10
0
15
5
State Percentile
National Percentile
Particulate
Matter
Diesel
Particulate
Matter
Toxics
Cancer
Risk*
Toxics
Respiratory
HI*
Toxic
Releases
To Air
Traffic
Proximity
Lead Superfund RMP Hazardous Underground Wastewater
Paint Proximity Facility Waste Storage Discharge
Proximity Proximity Tanks
These percentiles provide perspective on how the selected block group or buffer area compares to the entire state or nation.
Report for 10 miles Ring Centered at 36.689896,-108.482437
-------
EJScreen Environmental and Socioeconomic Indicators Data
SELECTED VARIABLES
VALUE
STATE
AVERAGE
PERCENTILE
IN STATE
USA AVERAGE
PERCENTILE
IN USA
POLLUTION AND SOURCES
Particulate Matter (|jg/m3)
4.71
5.16
32
8.08
2
Ozone (ppb)
61
64.7
9
61.6
49
Diesel Particulate Matter (|jg/m3)
0.0573
0.194
26
0.261
5
Air Toxics Cancer Risk* (lifetime risk per million)
19
18
1
25
1
Air Toxics Respiratory HI*
0.25
0.21
29
0.31
4
Toxic Releases to Air
150
29
97
4,600
28
Tra c Proximity (daily tra c count/distance to road)
1.1
84
12
210
4
Lead Paint (% Pre-1960 Housing)
0.094
0.19
47
0.3
34
Superfund Proximity (site count/km distance)
0.038
0.14
43
0.13
34
RMP Facility Proximity (facility count/km distance)
0.049
0.15
33
0.43
10
Hazardous Waste Proximity (facility count/km distance)
0.13
0.73
45
1.9
26
Underground Storage Tanks (count/km2)
0.58
3.3
44
3.9
41
Wastewater Discharge (toxicity-weighted concentration/m distance)
0.0069
0.47
41
22
64
SOCIOECONOMIC INDICATORS
Demographic Index
66%
51%
74
35%
87
Supplemental Demographic Index
23%
17%
78
14%
86
People of Color
74%
62%
65
39%
80
Low Income
58%
40%
77
31%
87
Unemployment Rate
14%
7%
86
6%
90
Limited English Speaking Households
13%
6%
85
5%
88
Less Than High School Education
13%
14%
57
12%
67
Under Age 5
7%
5%
73
6%
71
Over Age 64
15%
19%
43
17%
48
Low Life Expectancy
20%
19%
54
20%
54
* Diesel particulate matter, air toxics cancer risk, and air toxics respiratory hazard index are from the EPA's Air Toxics Data Update, which is the Agency's ongoing, comprehensive evaluation of air toxics in the United
States. This effort aims to prioritize air toxics, emission sources, and locations of interest for further study. It is important to remember that the air toxics data presented here provide broad estimates of health risks
over geographic areas of the country, not definitive risks to specific individuals or locations. Cancer risks and hazard indices from the Air Toxics Data Update are reported to one significant figure and any additional
significant figures here are due to rounding. More information on the Air Toxics Data Update can be found at: https://www.epa.aov/haps/air-toxics-data-update.
Sites reporting to EPA within defined area:
Superfund 0
Hazardous Waste, Treatment, Storage, and Disposal Facilities 0
Water Dischargers 79
Air Pollution 16
Brown elds 0
Toxic Release Inventory 4
Other community features within defined area:
Schools 7
Hospitals 0
Places of Worship 4
Other environmental data:
Air Non-attainment No
Impaired Waters Yes
Selected location contains American Indian Reservation Lands* Yes
Selected location contains a "Justice40 (CEJSTJ disadvantaged community Yes
Selected location contains an EPA IRA disadvantaged community Yes
Report for 10 miles Ring Centered at 36.689896,-108.482437
-------
EJScreen Environmental and Socioeconomic Indicators Data
HEALTH INDICATORS
INDICATOR
HEALTH VALUE
STATE AVERAGE
STATE PERCENTILE
US AVERAGE
US PERCENTILE
Low Life Expectancy
20%
19%
54
20%
55
Heart Disease
6.4
6.2
56
6.1
58
Asthma
12.7
10.3
93
10
95
Cancer
5.2
5.7
33
6.1
27
Persons with Disabilities
15.3%
16.6%
45
13.4%
67
CLIMATE INDICATORS
INDICATOR
HEALTH VALUE
STATE AVERAGE
STATE PERCENTILE
US AVERAGE
US PERCENTILE
Flood Risk
14%
9%
82
12%
78
Wild re Risk
55%
58%
39
14%
86
CRITICAL SERVICE GAPS
INDICATOR
HEALTH VALUE
STATE AVERAGE
STATE PERCENTILE
US AVERAGE
US PERCENTILE
Broadband Internet
42%
22%
87
14%
96
Lack of Health Insurance
15%
9%
81
9%
83
Housing Burden
No
N/A
N/A
N/A
N/A
Transportation Access
Yes
N/A
N/A
N/A
N/A
Food Desert
Yes
N/A
N/A
N/A
N/A
Footnotes
Report for 10 miles Ring Centered at 36.689896,-108.482437
www.epa.gov/ejscreen
-------
Attachment 3: APS Transmittal of Draft Initial
Certification
-------
aps
Jeffrey Jenkins Tel. 505-330-3943 PO Box 355
Plant Manager e-mail: Jeffrev.Jenkins@aps.com Station 4900
Cholla Power Plant Fruitland, NM 87416
May 19, 2022
Electronically submitted
Mr. Gary Sheth
NPDES Permits Section, Water Division (WTR-2-3)
US Environmental Protection Agency, Region 9
75 Hawthorne Street
San Francisco, CA 94105
Subject: TRANSMITTAL OF DRAFT INITIAL CERTIFICATION STATEMENT
SUPPORTING A PERMIT MODIFICATION PURSUANT TO AMENDED
STANDARDS IN THE STEAM ELECTRIC RECONSIDERATION RULE
Arizona Public Service Company Four Corners Power Plant
Fruitland, New Mexico - NPDES Permit NN0000019
Dear Mr. Sheth,
In accordance with 40 CFR 423.19(c)(1), Arizona Public Service Company (APS) hereby
submits the enclosed Draft Initial Certification Statement for review and comment by the
United States Environmental Protection Agency (USEPA). This certification statement supports
a permit modification request for Four Corners Power Plant National Pollutant Discharge
Elimination System (NPDES) permit NN0000019. As a steam electric power generating point
source, APS is in the process of making changes to Four Corners Power Plant that will convert
the once-through bottom ash transport water system into a future high recycle rate bottom
ash transport system. APS is committed to operating this future system in a manner that
limits the discharge of bottom ash transport water pursuant to regulation. However, there will
be instances, as anticipated by §423.13(k)(2)(i), where the discharge of bottom ash transport
water through a NPDES outfall will promote reliability of power plant operations.
APS appreciates USEPA feedback on a previous draft of the certification statement received
on December 10, 2021. We believe that the current version of the document transmitted
herewith is more complete and details the available backup documentation supporting the
analyses requested by the USEPA. Since the planned system has not been constructed or
operated, purge water quantities required to maintain recirculation operations (principally due
to water quality) as well as the rate and volume of water that can be managed within other
systems at the plant (i.e., the flue gas desulfurization process) should be viewed as estimates.
At this time, Four Corners is confronting a number of significant challenges completing major
capital projects as a result of supply chain delays and limited contractor availability. To
mitigate these issues, our design engineering firm assessed long-lead time components and
divided the high-recycle rate bottom ash transport system project scope into multiple design,
procurement, and construction phases (i.e., pumps, controls, valves, chemical feed
equipment, piping, controls, electrical equipment, tanks, piping, the pipe rack, a new low
volume wastewater treatment system, and mechanical equipment). Construction packages
have been awarded for the new Hydrobin overflow tanks, the extensive pipe rack that routes
the recirculation piping, and the low volume wastewater treatment tank. Fieldwork supporting
-------
the pipe rack has begun and construction of foundations for the new tanks will begin later this
month. Procurement of other equipment is in process, and we anticipate completing
construction procurement by Fall of this year.
We plan to provide a more thorough update on project status when construction procurement
is complete. In the meantime, we propose to set up a meeting to address any questions you
might have about the enclosed certification and discuss next steps with respect to the pending
permit modification. Please let us know when you have availability for that meeting at your
earliest convenience.
If you have any questions regarding the enclosed certification prior to the proposed meeting,
please contact Natalie Chrisman Lazarr at 602.316.1324 or via email at
natalie.chrisman@aDS.com.
Jeffrey Jenkins
Plant Manager
Four Corners Power Plant
Enclosure
Cc: Natalie Chrisman Lazarr, Principal Engineer, APS
Jeffrey Allmon, Senior Attorney, APS
Sincerely,
Arizona Public Service
Page 2 of 2
Four Corners Power Plant
-------
MCDONNELL
Initial Certification Statement
Supporting the Discharge of
Bottom Ash Transport Water
^aps
Arizona Public Service Company
Four Corners Generating Station
NPDES Permit No. NN0000019
Project No. 129532 / FCC016494
Revision 0
May 2022
DRAFT
-------
Initial Certification Statement
Supporting the Discharge of
Bottom Ash Transport Water
Prepared for
Arizona Public Service Company
Four Corners Generating Station
NPDES Permit No. NN0000019
Project No. 129532 / FCC016494
Fruitland, NM
Revision 0
May 2022
Prepared by
Burns & McDonnell Engineering Company, Inc.
Kansas City, Missouri
-------
INDEX AND CERTIFICATION
Arizona Public Service Company
Initial Certification Statement
Supporting the Discharge of
Bottom Ash Transport Water
Report Index
Number
J V1 >t\ 01 Pages
1.0 2
; «» \; J> |.\ v, » ^ h vi-nu.v; 18
\pixa Iiv \
\nv;uu\ 3 s ^ ^ .;o Kvumi x aknLti oi
\L>;vuar, D Oi.mi-p, (
,n.v,i,l \ ? c '«'» il V . > s »1
Certification
be
I
3
Digitally signed by
Hansen, Bryan
11:32:10-05'00'
.» ;«.»>> r !
¦ V.v ! evnseNo. 23480)
4 Date: May 16, 202.2
-------
Owner's Certification of Compliance - 40 CFR 122.22
Pursuant to 40 CFR 122.22,1 certify under penalty of law that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations.
On behalf of Arizona Public Service Company:
(Printed Name
(Title
(Date
-------
Certification Letter
Table of Contents
TABLE OF CONTENTS
Page No.
1.0 INTRODUCTION 1-1
2.0 HIGH RECYCLE SYSTEM DESCRIPTION 2-1
2.1 Bottom Ash System Description 2-1
2.2 Water Balance Description 2-6
2.2.1 Process Flows 2-7
2.2.2 Operational Scenarios 2-8
2.3 List of All Potential Discharges under 40 CFR § 423.13(k)(2) i) A) 1) - (4 .... 2-8
2.3.1 Water Balance - Stormwater 2-10
2.3.2 Water Balance - Other Waste Streams 2-11
2.3.3 High Recycle Rate Bottom Ash Chemistry Considerations 2-11
2.3.4 Maintenance 2-16
2.4 Wastewater Treatment Systems at Four Corners 2-17
2.4.1 Low Volume Wastewater Treatment System 2-17
2.4.2 High Recycle Bottom Ash System 2-17
APPENDIX A - WATER BALANCES
APPENDIX B - STORMWATER RUNOFF CALCULATIONS
APPENDIX C - SAMPLING ANALYTICAL RESULTS
APPENDIX D - CHEMISTRY CALCULATIONS
APPENDIX E - GENERAL ARRANGEMENT
APS - Four Corners Generating Station
TOC-1
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
Table of Contents
LIST OF TABLES
Page No.
Table 2-1: Four Corner's Primary Active Wetted Volume Summary 2-5
Table 2-2: Purge Rates for Water Balance Considerations 2-8
Table 2-3: Four Corner's Purge Discharges 2-9
Table 2-4: Key to Scaling Indexes (pH of the system) 2-12
Table 2-5: Four Corners Wastewater Treatment Systems 2-17
APS - Four Corners Generating Station
TOC-2
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter List of Abbreviations
LIST OF ABBREVIATIONS
Abbreviation Term/Phrase/Name
APS Arizona Public Service Company
BA Bottom Ash
BASWR Bottom Ash Sluice Water Recycling
BAT Best Available Technology Economically Achievable
CCR Coal Combustion Residuals
CFR Code of Federal Regulations
ELG Rule Effluent Limitations Guidelines and Standards for the Steam Electric
Power Generating Point Source Category
EPA U.S. Environmental Protection Agency
FGD Flue Gas Desulfurization
Four Corners Four Corners Generating Station
gpm gallons per minute
L-SI Larson-Skold Index
LSI Langelier Scaling Index
MW Megawatt
NPDES National Pollutant Discharge Elimination System
PSI Puckorius Scaling Index
RSI Ryznar Scaling Index
TDS Total Dissolved Solids
TSS Total Suspended Solids
APS - Four Corners Generating Station
i
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
Introduction
1.0 INTRODUCTION
On November 3, 2015, the U.S. Environmental Protection Agency EPA issued the federal Steam Electric
Power Generating Effluent Limit Guidelines and Standards (ELGs); see 80 FR 67838. The 2015 rule
addressed discharges from flue gas desulfurization (FGD) wastewater, fly ash transport water, bottom ash
(BA transport water, flue gas mercury control wastewater, gasification wastewater, combustion residual
leachate, and non-chemical metal cleaning wastes.
The 2015 rule was reconsidered by EPA, with updates finalized on October 13, 2020 (see 85 FR 64650),
and effective as of December 14, 2020. The final rule revises limitations and standards for two of the waste
streams addressed in the 2015 rule: BA transport water and FGD wastewater. For BA transport water, the
final rule establishes Best Available Technology Economically Achievable (BAT) as a high recycle rate
system with a site-specific volumetric purge (defined in the final rule as BA purge water) which cannot
exceed a 30-day rolling average of 10 percent of the BA transport water system's primary active wetted
volume. The purge volume and associated effluent limitations are to be established by the permitting
authority. EPA selected a 95th percentile of total system volume as representative of a 30-day rolling
average, which results in a limitation of 10 percent of total system volume and requires the National
Pollutant Discharge Elimination System NPDES permitting authority to develop a site-specific purge
percentage that is capped at 10 percent. EPA recognizes that some plants may need to improve their
equipment, process controls, and/or operations to consistently meet the limitations included in this final
rule; however, this is consistent with the Clean Water Act, which requires that BAT discharge limitations
and standards reflect the best available technology economically achievable.
This document serves as the Initial Certification Statement required by 40 CFR § 423.19(c)(1). On behalf
of Arizona Public Service Company (APS), this initial certification seeks to discharge BA transport water
pursuant to 40 Code of Federal Regulations CFR § 423.13 (k 2 i at the Four Corners Generating Station
(Four Corners), located in San Juan County, New Mexico in accordance with NPDES Permit NN0000019.
As required by the ELG Rule, this plan includes the following:
A. A statement that the professional engineer is a licensed professional engineer.
B. A statement that the professional engineer is familiar with the regulation requirements.
C. A statement that the professional engineer is familiar with the facility.
D. A calculation of the primary active wetted bottom ash system volume as required per 40 CFR §
423.11(aa).
APS - Four Corners Generating Station
1-1
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
Introduction
E. Material assumptions, information, and calculations used by the certifying professional engineer
to determine the primary active wetted bottom ash system volume.
F. A list of all potential discharges under 40 CFR § 423.13 k) 2) i A 1) through (4 , the expected
volume of each discharge, and the expected frequency of each discharge.
G. Material assumptions, information, and calculations used by the certifying professional engineer
to determine the expected volume and frequency of each discharge, including a narrative
discussion of why such water cannot be managed within the system and must be discharged.
H. A list of all wastewater treatment systems at the facility currently, or otherwise required by a date
certain under this section.
I. A narrative discussion of each treatment system including the system type, design capacity, and
current or expected operation.
The Four Corners Generating Station is a coal-fired mine-mouth generating plant located on the Navajo
Indian Reservation near Fruitland, NM. The plant includes two 770-Megawatt (MW) coal-fired units (Units
4 and 5 . Four Corner's existing once-thru sluicing system is being replaced with a new BAT high recycle
system which will utilize wet sluicing to transport bottom ash through a hydrobin and Bottom Ash Sluice
Water Recycling (BASWR) settling tank system to dewater the bottom ash. The system cannot be operated
as a closed loop without significant water balance, scaling, corrosion, and maintenance challenges and
should be operated as a high recycle rate system with the allowed purge to alleviate these concerns. APS is
requesting to purge up to 10 percent of the total system volume up to 459,435 gallons per day on a
30-day rolling average basis to maintain water balance, address system water chemistry, and
conduct maintenance as allowed under 40 CFR § 423.13(k 2 i A).
APS - Four Corners Generating Station
1-2
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
2.0 HIGH RECYCLE SYSTEM DESCRIPTION
As required by 40 CFR § 423.19(c) 3) D) through I , the following is a description of the bottom ash
system at Four Corners, including the assumptions, information, and calculations used by the certifying
professional engineer to determine the primary active wetted bottom ash system volume and the expected
volume and frequency of each discharge. This section also includes a description of the wastewater
treatment systems at Four Corners.
2.1 Bottom Ash System Description
After combustion, ash that accumulates in the bottom of the boiler is captured in the ash hoppers located
directly beneath the boiler. Bottom ash is then crushed into small pieces by the clinker grinders and sluiced
by jet pumps to a series of unit processes designed to separate the bottom ash from the transport water. At
present, the existing once-thru sluicing system discharges after treatment to an internal outfall identified in
the facility's NPDES permit but in the future bottom ash transport water will be treated and recycled for
reuse in BA sluicing operations.
When plant modifications supporting the high recycle bottom ash system at Four Corners are complete,
major process equipment will consist of the following:
• Two (2) existing ash hoppers with multiple compartments, one per unit
• Eight 8 existing pyrites tanks per unit, sixteen (16) total
• Four (4) existing hydrobins
• Two (2) new hydrobin overflow tanks
• Four (4) new hydrobin overflow tank agitators, two per tank
• Three (3) new hydrobin overflow return pumps
• Three (3) sumps, two new and one existing
• Three (3) new boiler area sump pumps
• Three (3) new hydrobin area sump pumps
• The existing BASWR settling tank system consisting of:
o One (1) primary settling basin
o Two (2) secondary settling basins
o One (1) clearwell chamber
• Two (2) new sluice water pumps
• Two (2) new flush water pumps
• One (1) new low volume wastewater settling tank
APS - Four Corners Generating Station
2-1
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
• Two 2 new bottom ash system makeup pumps
• One (1) existing makeup water storage tank
Appendix A contains a schematic overview of the future bottom ash sluicing system's major components
and interfaces with other plant systems. The hydrobin overflow tanks and two (2 of the sumps are new and
will be installed no later than mid-2023. In addition to these new process units, planned plant modifications
will isolate many of the currently permitted low volume wastewater flows at the facility from the existing
BA sluicing system and will direct these segregated flows to a new low volume wastewater treatment
system prior to discharge through the facility's NPDES permit (see Section 2.4).
The sluiced bottom ash will be initially treated with hydrobins, allowing dewatered bottom ash to be
discharged into trucks prior to being hauled to the site Coal Combustion Residuals CCR) landfill or hauled
offsite for beneficial reuse. The four 4) existing hydrobins will be operated sequentially with a single
hydrobin receiving sluiced ash from both units until it is full. Once a hydrobin is full, the next hydrobin
will be placed into service, and the full hydrobin will be allowed to decant for 10-12 hours prior to
discharging ash to the trucks. Hydrobins will be continuously cycled to allow for filling to capacity,
decanting, and unloading to maintain the system in operation. The two 2) new 111,000-gallon hydrobin
overflow tanks (plumbed in parallel) will receive intermittent overflow from the hydrobins during sluicing
operations. The new hydrobin overflow tanks represent the only surge capacity within the system other than
the freeboard available in the BASWR. The surge capacity in the system provided by the new hydrobin
overflow tanks is needed to allow for operational flexibility in responding to system upset conditions,
equipment failures, and stormwater inflow without having to discharge sluice water from the system or
cause a plant outage.
Bottom ash will also be mechanically removed from the BASWR settling tank system, loaded into trucks,
and hauled to the site CCR landfill. The BASWR settling tank system is a reinforced concrete free-
standing) structure comprised of a single primary settling basin that discharges into two adjacent secondary
settling basins operated in parallel that overflow into a clearwell chamber. The treated transport water that
overflows into the clearwell will then be pumped back to the boiler hoppers for re-use.
Due to proximity and level of effort to segregate flows, seal trough water for the bottom ash hoppers will
be routed with bottom ash hopper overflow to the bottom ash system even though it is technically not
bottom ash transport water. In the future, the seal trough water will be sourced from the bottom ash loop
water and will not add additional fresh water to the system.
APS - Four Corners Generating Station
2-2
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
As part of the design of the future bottom ash high recycle system, APS identified all non-bottom ash
transport flows that are currently combined with bottom ash transport water in the existing once-thru
sluicing system. The intent of this analysis was to segregate low volume wastewater from the future bottom
ash high recycle system to simplify process operations and promote reliability. In addition to the seal trough
water previously discussed, wastewater flows generated during cleaning events in the baghouse enclosure
were identified as a waste stream that should not be directed to a low volume wastewater system due the
high total suspended solids content and variable nature of flows which could lead to performance issues in
the low volume wastewater treatment system. On this basis, the baghouse enclosure sump waste stream
will be routed to the bottom ash system. Routing of this wastewater into the bottom ash system with
treatment in the BASWR tank system allows for efficient removal of these suspended solids. Washdown
of the baghouse area is an infrequent operation, so it does not substantially contribute to the solids loading
in the BASWR tank system.
The site plan below and in Appendix E includes a general overview of the major equipment included in the
proposed high-recycle system design.
APS - Four Corners Generating Station
2-3
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
Figure 2-1: Site Plan Showing Major System Components
BASWR
LVWW
SETTLING
TANK
HYDROBINS
HYDROBIN
OVERFLOW
TANKS
BA HOPPERS AND
PYRITE TANK AREAS
SUMP
UNIT 4
BOILER
UNITS
BOILER
To determine the Four Corners primary active wetted system volume, calculations were performed based
on the major equipment and piping systems. A summary of the system volume calculations is provided in
Table 2-1. The volumes of the existing ash hoppers and pyrites tanks were derived from plant drawings.
The volumes of the existing hydrobins, system sumps, and individual BASWR tank cells were calculated
from dimensions summarized below in Table 2-1) derived either from field measurements and/or plant
drawings. For the BASWR tank system, both secondary cells were included m the calculations because one
secondary cell per electric generating unit is required to be in operation per the original design basis of the
BASWR tank system to achieve the target effluent solids concentration. Finally, the volume of future
interconnecting piping was calculated for the major piping in the system as shown in Table 2-1. Piping
APS - Four Corners Generating Station
2-4
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
sizes and overall estimated lengths of each run are also shown in Table 2-1. Since the final piping design
for the system has yet to be completed, overall piping lengths were estimated based on the equipment layout
shown above. The overall system volume was calculated as the summation of the volumes from the major
components in the system including interconnecting piping.
A water balance analysis used to size new equipment and evaluate future operations is discussed in Section
2.2 and presented in Appendix A.
Table 2-1: Four Corner's Primary Active Wetted Volume Summary
Ash Hoppers
Volume
(cubic ft)
Volume (gals)
Unit 4 Hopper
10,000
74,800
Unit 5 Hopper
10,000
74,800
Total
20,000
149,600
Pyrites Tanks
Volume
(cubic ft)
Volume (gals)
Unit 4 (8 total)
144
1,077
Unit 5 (8 total)
144
1,077
Total
288
2,154
Hydrobins
Diameter (ft)
Height of
Cylinder (ft)
Height of Cone
(ft)
Volume
(cubic ft)
Volume (gals)
Tank 1
35
13.25
27.75
21,648
161,924
Tank 2
35
13.25
27.75
21,648
161,924
Tank 3
35
13.25
27.75
21,648
161,924
Tank 4
35
13.25
27.75
21,648
161,924
Total
86,590
647,694
Sumps
Width/Diameter
(ft)
Length (ft)
Depth (ft)
Volume
(cubic ft)
Volume (gals)
Unit 4 Ash Pit
6
10
283
2,115
Unit 4 Bottom Ash
Area Sump
18
35
13
8,190
61,261
Hydrobin Area Sump
15
10
10
1,500
11,220
Total
9,973
74,596
APS - Four Corners Generating Station
2-5
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
Hydrobin Overflow Tanks
Diameter (ft)
Height (ft)
Volume
(cubic ft)
Volume (gals)
Tank 1
32.5
18
14,932
111,694
Tank 2
32.5
18
14,932
111,694
Total
29,865
223,388
BASWR (Settling) Tank System
Width (ft)
Length (ft)
Depth (ft)
Volume
(cubic ft)
Volume (gals)
Primary
40
200
8.5
68000
508,640
Secondary 1
66
356
8.2
190,915
1,428,043
Secondary 2
66
356
8.2
190,915
1,428,043
Clearwell
60
20
7.8
9,400
70,312
Total
459,230
3,435,039
Piping
Diameter
(in)
Length (ft)
Volume
(cubic ft)
Volume (gals)
Sluice Piping 1
12
1,800
1,414
10,575
Sluice Piping 2
12
1,800
1,414
10,575
Flush Piping 1
12
1,800
1,414
10,575
Flush Piping 2
12
1,800
1,414
10,575
U4 Sump Return 1
10
1,100
600
4,488
U4 Sump Return 2
10
1,100
600
4,488
Hydrobin Overflow
Return 1
10
1,300
709
5,304
Hydrobin Overflow
Return 2
10
1,300
709
5,304
Total
8,273
61,881
Total System Wetted
Volume (gal) =
149,600 + 2,154 + 647,694 + 74,596 + 223,388 +
3,435,039 + 61,881 = 4,594,352
10% gal/day
459,435
10% gal/hr
19,143
10% gpm
319
2.2 Water Balance Description
Three water balance cases were created to evaluate planned operations and are included in Appendix A.
The flows used in the water balance analyses represent best estimates for future operations based on
engineering judgement and flow measurements (where feasible) conducted during existing operations. All
water balances included daily average/max process flows while water balance cases WMB-01 and WMB-
APS - Four Corners Generating Station
2-6
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
03 include 10-year and 100-year design storm events averaged over a 24-hour period, respectively. Water
balance calculations are based on average flows, but maximum flows are also shown in the water balance
figures to demonstrate the magnitude of variability that must be accounted for in routine flow balancing
operations.
2.2.1 Process Flows
As shown on the water balances, the main process flow in the bottom ash sluice system is intermittent and
comes from the sluicing of bottom ash to the hydrobins. Each units' hoppers are sluiced via jet pumps on a
scheduled basis to the hydrobins, at an average rate of2,629 gpm, where bottom ash, 966 tons/day including
35 gpm of entrained water, is removed via trucks. The overflow from the hydrobins, at an average rate of
2,610 gpm, will be captured and sent to the BASWR settling tank system for further treatment prior to reuse
or purge.
The other main flow in the bottom ash system is from seal trough and hopper overflows. The seal trough
consistently overflows to maintain level within the hopper seal trough while the hopper overflows discharge
during/after sluice events. As indicated previously, seal trough overflow is typically not considered a
bottom ash transport stream, but in this case, it will be fed off the high recycle return water system based
on the magnitude and proximity of these flows. Seal trough and hopper overflows will continue to gravity
discharge to an existing drainage trench which will be rerouted to a new sump prior to being forwarded to
the BASWR settling tank for solids settling. The seal trough overflow and hopper overflow average rates
are 1,400 gpm and 1,197 gpm, respectively. The remainder of the flows within the system are due to
miscellaneous water users.
A new low volume wastewater settling tank is also shown on the water balance figures. Various sumps
were evaluated at Four Corners for flow and quality prior to determining adequate treatment for the low
volume waste streams to meet NPDES permitted outfall limits. Typical discharges to the low volume
wastewater tank include reverse osmosis reject and backwash discharges, at an average rate of 200 gpm,
and miscellaneous service water users, at an average rate of 230 gpm. A majority of the plant storm water
runoff will also be directed to the low volume wastewater settling tank for solids settling prior to discharge.
WMB-01 includes a 10-year, 24-hour storm event which is the required system stormwater design basis
per regulation and was used as the design basis for the stormwater calculations. WMB-03 includes a 100-
year, 24-hour event for reference purposes.
APS - Four Corners Generating Station
2-7
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
2.2.2 Operational Scenarios
Existing flow rates for the bottom ash sluice and low volume wastewater systems were measured to evaluate
potential discharges from the future high recycle rate system. Daily average flows were established for the
major system components based on future expected flow rates once the system operates as a high recycle
rate system. WMB-01 and WMB-03 include design storm events for a 10-year, 24-hour and 100-year, 24-
hour storm respectively. Estimated purge flows required from the water balance scenarios evaluated are
listed in Table 2-2 below.
Table 2-2: Purge Rates for Water Balance Considerations
Water Balance Number/Condition
Purge Rate Directed to
a NPDES Outfall
(gpm)
Purge Rate Directed to
Other Systems for
Plant Reuse
(gpm)
WMB-01
Process and 10-year, 24-hour storm
0
156
WMB-02
Process Only
0
79
WMB-03
Process and 100-year, 24-hour storm
32
156
Based on the water balance analyses, routine operations will require a constant purge to the FGD system
once high-recycle operations are initiated. Given the complexity of this system, all purges to the FGD
system will have to be carefully managed. Short duration increases in the purge rate to accommodate storm
surges will be incorporated into the design; however routine discharges exceeding 79 gpm could pose water
management issues in the FGD system and impact plant reliability.
2.3 List of All Potential Discharges under 40 CFR § 423.13(k)(2 i A 1) — 4
APS is designing the high-recycle bottom ash transport system to routinely operate without purging via the
new low volume wastewater treatment to the NPDES outfall water balance case WMB-02 in Appendix
A). However, as 40 CFR §423(k 2 i)(A) anticipates, there will be circumstances that could affect the
reliability of plant operations if the high-recycle bottom ash transport system is overwhelmed. In those
instances, discharges directed to the NPDES outfall would be required and permitted under existing
regulation under four categories of conditions. To inform a case-by-case analysis of the allowable purge
rate for the future high-recycle bottom ash system at Four Corners, Table 2-3 presents the best available
estimate of discharges that could be directed to a NPDES outfall under the four categories of conditions
allowed in regulation:
APS - Four Corners Generating Station
2-8
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
Table 2-3: Four Corner's Purge Discharges
Discharge
Stream
Estimated
Flow/Volume
Description
Estimated Frequency
A 1) Water
Balance -
Stormwater
Stormwater
flows in
excess of
111,000
gallons
Precipitation-related inflows
generated from storm events
exceeding a 10-year storm event of
24-hour or longer duration e.g.,
30-day storm event and cannot be
managed by installed spares,
redundancies, maintenance tanks,
and other secondary bottom ash
system equipment
Following storm events that exceed
the design storm i.e., a storm event
with a return period greater than 10
years and intensity of 24 hours which
is equivalent to 1.54 inches of rainfall,
or 111,000 gallons). This design
storm would be stored within the
freeboard of the BASWR settling tank
system prior to being reused within
the FGD system.
Anything surpassing this storm event
would be purged via the low volume
wastewater treatment system to the
NPDES outfall. A 100-year/24-hour
storm event would contain an
estimated additional 70,000 gallons of
water that would need to be purged
from the system to maintain water
balance and avoid overtopping of the
BASWR settling tank system.
A 2) Water
Balance -
Other Waste
Streams
400 gpm
peak 20 gpm
average
Regular inflows from waste
streams other than bottom ash
transport water that exceed the
ability of the bottom ash system to
accept recycled water
Intermittent flows from sumps that
discharge into the bottom ash system
because they have a high solids
content and/or contribute area
washdown volumes on an irregular
basis have the potential to create
water balance issues if spare/surge
capacity is unavailable. For the
purpose of estimating a potential
'other waste stream' flow, the
intermittent flow from baghouse
enclosure sumps, which discharge
high solids content wastewater, serves
as the basis for the estimated other
inflow rates.
APS - Four Corners Generating Station
2-9
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
Discharge
Stream
Estimated
Flow/Volume
Description
Estimated Frequency
A)(3
Water
Chemistry
319 gpm
To maintain system water
chemistry where installed
equipment at the facility is unable
to manage pH, corrosive
substances, substances or
conditions causing scaling, or fine
particulates to below levels which
impact system operation or
maintenance
Water within the bottom ash system
has corrosive tendencies based on low
alkalinity and elevated sulfate
concentrations in the makeup water
which will become exacerbated when
closed-loop operations begin. The
extent of impacts due to water
chemistry cycling is difficult to
predict with the existing open loop
system configuration. A continuous
purge of up to 10% of the total system
wetted volume (319 gpm could be
required to prevent corrosion in the
future bottom ash system.
A)(4
Maintenance
1,428,043
gallons
To conduct maintenance not
otherwise included in (A) (1), (2 ,
or (3 of this table and not
exempted from the definition of
transport water in § 423.11 p), and
when water volumes cannot be
managed by installed spares,
redundancies, maintenance tanks,
and other secondary bottom ash
system equipment
Although it is difficult to predict the
volumes/discharge frequencies
required for maintenance of a future
system, there will be times when one
secondary BASWR cell will need to
be dewatered for cleaning purposes.
This could occur as frequently as once
a year and is the basis for the estimate
of volume required for maintenance
of the BA system. Maintenance of
smaller vessels at a similar frequency
is anticipated.
2.3.1 Water Balance - Stormwater
Although APS has taken measures in the design of the future bottom ash transport system to limit the inflow
of as much stormwater as possible, there will be purges required for storm events that exceed the design
storm noted in regulation. Calculation of the threshold stormwater volume of 111,000 gallons as well as the
100-year, 24-hour reference storm is detailed in Appendix B and summarized below:
• Stormwater calculations are based on the methodology outlined in the New Mexico Department of
Transportation Drainage Design Manual and the 'Civil Engineering Reference Manual for the PE
Exam,' Lindeburg, M, 2008). Rainfall data for the 1-year, 10-year, and 100-year 24-hour storm
APS - Four Corners Generating Station
2-10
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
were obtained from the National Oceanic and Atmospheric Administration Atlas 14, Volume 8,
Version 2. The assumed design storm is the 10-year, 24-hour storm as identified by regulation.
• The stormwater contribution method begins with estimating the drainage areas and determining the
type of cover for each area which was done from site arrangement drawings. From there we
calculate the total weighted curve number, soil water storage capacity, and initial abstraction values
as inputs to the curve number method runoff equation. This provides the estimated runoff for each
area which in turn is used to calculate the total volume input per area for each storm event.
• The total volume of stormwater that enters the bottom ash handling system is comprised of three
areas: the U4 Bottom Ash Area Sump, the Hydrobin Overflow Sump, and the open top BASWR
settling tank system. For the 10-year, 24-hour storm, these volumes are 35,900 gallons, 14,400
gallons, and 61,000 gallons respectively. This equates to the 111,000 gallons noted above in Table
2-2.
• Forthe 100-year, 24-hour storm, the corresponding stormwater volumes are 57,900 gallons, 23,200
gallons, and 98,400 gallons respectively. This equates to atotal of 179,500 gallons or the difference
of about 70,000 gallons 179,500 - 111,300 = 68,200 gallons) as noted above in Table 2-2.
2.3.2 Water Balance - Other Waste Streams
As noted in Table 2-3 above, there could be other waste streams from intermittent sources that have the
potential to impact the water balance of the bottom ash transport system, especially in the aftermath of a
significant storm when the spare/surge capacity in the system would be full. One example waste stream is
the intermittent discharge of wastewater from the baghouse enclosure sump into the bottom ash system.
The baghouse enclosure sump pumps are rated for 400 gpm which could over short periods cause water
balance issues if the spare/surge capacity of the system is limited. Although this flowrate is not significant
relative to the full process flow of the bottom ash transport recirculation flow, balancing short duration,
high intensity flows could overwhelm an already overwhelmed system.
2.3.3 High Recycle Rate Bottom Ash Chemistry Considerations
In the existing once thru i.e., open loop bottom ash sluicing system, ash is sluiced to the hydrobins which
act as the primary ash separation devices. Overflow and decant sluice water is pumped to the BASWR
settling tank system, where most of the remaining ash settles out to be dewatered and removed. Overflow
from the BASWR settling tank system is discharged thru the permitted NPDES outfall and fresh makeup
water is used for subsequent sluice cycles.
APS - Four Corners Generating Station
2-11
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
After the conversion to a high recycle rate system, it is expected that the future closed-loop water quality
will cycle up to an equilibrium concentration, where the additional mass of constituents introduced per
sluice cycle is equal to the mass exiting the closed-loop system through purge flows and the reuse of treated
sluice water in the FGD system. Since the existing system is not currently operating in a closed-loop
configuration, the corrosiveness or scaling potential in the future high recycle rate configuration cannot be
reliably predicted. However, once operating in a high recycle rate configuration, there will likely be an
increase in total dissolved solids (TDS), total suspended solids TSS), conductivity, aluminum, calcium,
chloride, iron, silica, sodium, sulfates, and other constituents from contact with the bottom ash and due to
evaporation of water in the system.
Several scaling indices can be used to model the scaling and corrosive properties of the water. These are
the Puckorius Scaling Index PSI), The Ryznar Scaling Index (RSI , the Langelier Scaling Index LSI), and
the Larson-Skold Index (L-SI . The PSI, RSI, and LSI all use alkalinity, hardness, temperature, and pH to
estimate calcium scale and corrosivity, comparing the pH of the system to the equilibrium pH and the pH
of saturation. The L-SI looks at the concentrations of carbonate, bicarbonate, sulfate, and chloride to
estimate the tendency for sulfate and chloride to interfere with scale formation and to support corrosion due
to sulfate and chloride chemistry. The target ranges for these indices are shown in Table 2-4.
Table 2-4: Key to Scaling Indexes (pH of the system
PSI
RSI
LSI
L-SI
Extreme Corrosion
>9.0
>9.0
<-2
>4.0
Moderate Corrosion
>7.5-9.0
>7.5-9.0
-2.0- -0.5
1.2-4.0
Slight Corrosion
>7.0-7.5
>7.0-7.5
>-0.5-0.0
0.8-<1.2
In range
>6.0-7.0
>6.0-7.0
>0.0-0.5
<0.8
Slight Scaling
5.0-6.0
5.0-6.0
>0.5 - 2.0
Heavy Scaling
<5.0
<5.0
>2.0
To estimate the effect of future closed loop operations, a series of samples were taken at various locations
in the bottom ash handling system and analyzed for a variety of constituents see analytes and results in
Appendix C as well as sampling locations in the water balance figures presented in Appendix A . Although,
the current system is operating as a once-through system, the intent was to try and capture the impact of
operations on the water quality as it is sluiced through the system and use this information to extrapolate to
the water chemistry in the future closed loop, high-recycle rate bottom ash system design.
APS - Four Corners Generating Station
2-12
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
We compared the expected concentration of various parameters to determine if there was a measurable
increase or decrease in these constituents given the once-through bottom ash system design. The primary
change in water quality evaluated was the effect of adding pulverized bottom ash to makeup water, sluicing
the mixture, and bulk solids removal in the hydrobin system; thus, average concentrations of evaluated
constituents in water samples collected from the hydrobin overflow were compared to samples
representative of makeup water sourced from Morgan Lake. The difference in water quality parameters
from these two samples is mainly from contact of the bottom ash with the sluice water and from evaporation
of water in the bottom ash hoppers and in the BASWR. Parameters that exhibited a measurable change
included conductivity, total dissolved solids, chlorides, sulfates, manganese, calcium, bicarbonate
alkalinity, and temperature.
Appendix D presents a chemistry mass balance model of the bottom ash system which was developed to
try and simulate the existing open loop system on bottom ash chemistry (Baseline Conditions - Open Loop
Configuration). Key input parameters and assumptions into the chemistry mass balance model include:
• Total system volume: 4,594,352 gallons see Table 2-1 above
• System evaporation: 4.0 gpm 5,760 gallons/day) based on the BASWR tank system surface area
and annual average evaporation rates plus 5.79 gpm 8,338 gallons/day) based on evaporation in
the bottom ash hoppers from contact with the bottom of the boiler. Total system evaporation was
estimated at 9.79 gpm (14,098 gallons/day).
• Bottom ash drag out rate amount removed from system) was calculated as follows: 21.2 tons/hour
average bottom production rate per unit * 2 units * 20% assumed moisture content, 21.2 * 2000
2 * 0.2 / 500.4 = 33.9 gpm (48,805.8 gallons/day) water in bottom ash drag out waste stream. This
provided a good correlation to the measured average value of 35 gpm from the hydrobins as shown
on the water balances. Water entrained with the bottom ash removed from the system was assumed
to be the average 3 5-gpm number based on existing flow measurement data.
• Total makeup rate: evaporation + drag out rates = 9.79 + 35.0 = 44.79 gpm (64,498 gallons/day
• The hydraulic residence time of the system is calculated as the total system volume divided by the
makeup rate, or 4,594,353 gallons / 64,498 gallons / day = 71.2 days.
• Selected water quality data was collected over a period of six months from various locations in the
system as shown with blue boxes on the water balance diagrams. The water quality data was
averaged for use in the chemistry model. A summary of the sampling results is contained in
Appendix C.
APS - Four Corners Generating Station
2-13
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
For development of the baseline chemistry model (existing open-loop configuration), we looked at specific
constituents in the bottom ash sluice water inlet and compared them to the same constituents in the sluice
water outlet. Constituents that were compared included conductivity, total dissolved solids, chlorides,
sulfates, magnesium, calcium, pH, and temperature. With an open-loop configuration, we lose some water
to evaporation in the bottom ash hoppers and BASWR while some water is retained in the bottom ash drag
out, see Figure 2-2 below. Evaporation in the bottom ash hoppers and BASWR has a net result of increasing
the constituent concentrations in the water. The water retained in the bottom ash that is removed does not
change the remaining concentrations in the system but does remove some mass from the system. Contact
of the bottom ash material with the water results in some dissolution of constituents from the bottom ash
into the water. The combination of evaporation and contact of bottom ash with the sluice water results in a
change in some of the constituent concentrations.
Figure 2-2: Mass Balance Around Bottom Ash System
EVAPORATION
t
SLUICE IN
Bottom Ash
System
~ SLUICE OUT
RETAINED WITH
BOTTOM ASH
When we compared the measured change in concentration for the compared constituents, we see that the
expected change in concentration from evaporation is greater than the measured concentration changes for
most of the compared constituents. For example, with chlorides we would expect a concentration increase
of 0.76 mg/L due to evaporation alone; however, the measured concentration change was reported as 0.03
mg/L. It is unreasonable to assume that chlorides were removed from the bottom ash water by some
mechanism as chloride salts are super soluble and the system concentrations are nowhere near solubility
limits. Similar results for calcium and magnesium were observed; expected concentration changes due to
evaporation were greater than the measured concentration changes. Alkalinity had a similar result, however,
exposure to the bottom ash could introduce some acidity in the system resulting in the observed decrease
in alkalinity concentration. TDS and sulfates were the only compared constituents that had a measured
concentration change greater than the expected concentration change due to evaporation.
APS - Four Corners Generating Station
2-14
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
With most of compared constituents exhibiting poor chemistry modeling results we concluded that it is
impossible to predict the impact of the future system configuration on the system corrosion or scaling
tendencies. With the current system showing slight to extreme corrosion potential, we assume that the
cycling up of constituents in the future high recycle rate system configuration would only worsen the system
corrosion potential. The ability to purge sluice water from the system will allow operations to maintain a
water chemistry like the current conditions.
An acid feed to lower alkalinity and pH would make the water more corrosive than current conditions. A
caustic feed to increase alkalinity and pH would make the water less corrosive than current conditions. A
soda ash feed to increase alkalinity would also make the water less corrosive than current conditions. There
is no way to quantify if chemical feed systems can improve on system water quality without the need to
purge some wastewater from the system.
The Baseline Conditions - Open Loop conditions show that in the current open-loop configuration the
bottom ash sluice water is moderately corrosive for the PSI value, within range for the RSI value, and
slightly scaling for the LSI value. The L-SI value is showing an extreme corrosion potential due to the
elevated sulfate levels and relatively low alkalinity. Because the makeup water has elevated sulfates and
low alkalinity concentrations, the best we could hope to achieve would be a water quality like the existing
conditions. The addition of some alkalinity from a soda ash feed would improve on the corrosion potential
but we would never be able to eliminate the concern with a chemical feed by itself.
The best possible outcome is with a provision for a future 10% purge rate plus the maximum possible purge
to the WFGD system peak purge rate of 79 gpm and installation of some form of chemical feed
adjustment. Selection of the chemical feed adjustment will not be made until the system can begin operation
in the future high rate recycle configuration when we can monitor changes in system chemistry during
steady state conditions. The provisions for a system purge and chemical feed addition will produce a sluice
water quality that has less scaling potential and comparable corrosion potential to the existing open-loop
bottom ash system configuration. On this basis, provisions for a future chemical feed system have been
incorporated into the design of the planned high recycle rate, closed-loop bottom ash system prior to the
BASWR settling tank system. The chemical feed system will be finalized once the bottom ash system is
put into service in the high-recycle rate, closed-loop configuration and we can measure actual chemistry
changes in the system.
APS - Four Corners Generating Station
2-15
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
2.3.4 Maintenance
Estimates of potential purge volumes required for future maintenance are difficult to predict, especially for
a system that has not been constructed (much less operated). It is anticipated, however, that there will be
scenarios where large volumes of water will need to be drained from the bottom ash transport system for
maintenance. To provide an example maintenance purge volume that would be difficult to retain onsite
given the magnitude of the system, a scenario involving clean out of one of the secondary settling cells of
the BASWRtank was selected.
The existing BASWR system consists of a primary settling cell, two secondary settling cells, and one
clearwell. As noted in Table 2-2 above, there will be times when one 1,428,043-gallon secondary BASWR
cell will need to be dewatered for cleaning purposes which may happen as frequently as once per year.
Under normal operating circumstances, every effort will be made to process drainage of the secondary
settling cell within routine system purges to the FGD system. However, due to the magnitude of volume in
each of the secondary cells, as well as plant operational requirements, a purge through the NPDES outfall
will likely be required.
The BASWR system design requires one secondary settling cell to be in service per unit in operation to
achieve the target TSS removal rates. As noted in Table 2-2 above, there will be times when one secondary
BASWR cell will need to be dewatered for cleaning purposes which may happen as frequently as once per
year. This means that the BASWR tank system is undersized for proper treatment of full flow from both
units and secondary settling cell cleanouts will have to occur during either a scheduled single or dual unit
outage. In the lead up to the scheduled outage, a single secondary settling cell will require over 12 days of
continuous draining to dewater the cell at the FGD bottom ash transport system purge rate identified for
routine operations 79 gpm; see water balance case WMB-02 in Appendix A . This operation could take
longer if there are issues in FGD operations. Further, there may be times when it will be necessary to
dewater a cell very quickly as when an equipment failure could lead to a forced unit outage. In either
instance, maintenance would require a significant purge volume equal to the volume of the cell to be
actively managed with the needs of plant operational requirements. The addition of a third (spare secondary
settling cell was considered for this scenario; however, the cost to incorporate a third settling cell for a
once/year maintenance event does not have a good cost to benefit ratio and physical space for such an
addition was limited.
APS - Four Corners Generating Station
2-16
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
2.4 Wastewater Treatment Systems at Four Corners
Table 2-5 summarizes the water treatment systems that process water that will have the potential to be
discharged in accordance with the NPDES permit at Four Corners (i.e., non-bottom ash transport systems).
Design assumptions and design basis information are discussed in the following sections.
Table 2-5: Four Corners Wastewater Treatment Systems
System
Name
Design Capacity
Current Operation
Expected Operation
Low
Volume
Wastewater
Treatment
System
440 gpm daily average.
1,213 gpm daily max
including stormwater
flows based on a 10-
year, 24-hour storm.
Settling via BASWR prior
to discharge through the
permitted NPDES outfall.
Low volume wastewater will
be segregated from bottom
ash sluice system flows and
re-routed to a new settling
tank prior to discharge
through the permitted
NPDES outfall.
High
Recycle
Bottom Ash
System
Hydrobins - 2,610 gpm
daily average
BASWR-5,642 gpm
daily average
Ash removed via Hydrobins
prior to final settling via
BASWR with polymer
addition prior to discharge
through the permitted
NPDES outfall.
Ash removed via Hydrobins
with newly installed polymer
injection. Chemical feeds
prior to BASWR for
alkalinity and pH
adjustment. Final settling via
BASWR with polymer prior
to reuse within existing FGD
system or purge to LVWTS
and ultimately through the
permitted NPDES outfall.
2.4.1 Low Volume Wastewater Treatment System
Low volume wastewater flows were evaluated based on existing plant data and flowmeter analysis.
Stormwater areas were established to determine runoff volumes that contribute to each low volume
wastewater area. Average/max daily flows were established at each low volume source along with expected
flows from a 10-year, 24-hour storm to establish sizing required for a low volume wastewater treatment
system capable of meeting the NPDES permitted outfall.
2.4.2 High Recycle Bottom Ash System
High-recycle bottom ash system flow rates, based on existing system flow rates averaged over a 24-hour
period, were utilized to establish daily averages. Hydrobins are the primary ash separation step while the
APS - Four Corners Generating Station
2-17
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
BASWR settling tank system settles fines carryover from the Hydrobins along with seal trough and hopper
overflow. Two sumps are included in the high recycle bottom ash system to capture various closed-loop
waters along with any storm water in the bottom ash areas. Polymer injection is expected to be utilized
upstream of the Hydrobins and BASWR settling tank system to enhance fines settling while acid / caustic
injection and/or soda ash may be included in the future for pH adjustment or alkalinity adjustment
respectively. Purge flow to the FGD system or LVWW treatment system (to the NPDES outfall) would be
discharged after the treatment of the closed-loop water by the Hydrobins and BASWR settling tank system
along with any required chemical feed. Purge flow for reuse or outfall discharge is dependent on
considerations listed in Section 2.3.
Wastewater streams generated at the plant that do not discharge through NPDES permitted outfalls include
blowdown from the wet FGD scrubber, sanitary wastewater, and various boiler cleaning solutions.
Blowdown and associated slurries from the wet FGD scrubber are blended with ash and landfilled in an on-
site CCR landfill. Sanitary wastewater and boiler cleaning solutions are discharged to an on-site CCR
surface impoundment where they evaporate or are reused in non-bottom ash sluice water plant operations.
APS - Four Corners Generating Station
2-18
Burns & McDonnell
May 2022 Rev 0
-------
APPENDIX A - WATER BALANCE DRAWINGS
-------
Baghouse
Enclosure
Sumps
20
|
New LVWW Settling Tank 1 new) -
New Bottom Ash System Makeup
Pumps to BASWR 2 new
156 Purge (Note 2)
PRELIMINARY
EPA LETTER UPDATES
z EPA LETTER UPDATES
z EPA LETTER UPDATES
a I Precipitation Included
NOTES:
1. Precipitation values based on 10 year, 24 hour storm
averaged over 24 hour period.
2. Purge based on water balance requirements for the
closed-loop system.
3. All flows shown in gallons per minute (GPM
4. Max flows for normal operation are in parentheses and
may not balance.
5. Water leaving with ash assumed to be 20% moisture.
Hydrobin ash expected to be removed for 4 hour duration
per day. BASWR ash removal expected 3 times per week
and estimated to be removed within 8 hour duration.
6. Purge to maintain system water chemistry up to 319
gpm or 10% of the bottom ash system flow.
7. Maintenance purge to drain one secondary cell of the
BASWR to the LVWW settling tank is not shown.
8. Dashed lines represent intermittent flows.
Sampling Location
PRELIMINARY
^BURNS
^.MCDONNELL
»aps
APS Four Corners
Future Conditions
Process & 10yr Storm water Flows
-------
Baghouse
Enclosure
Sumps
20
|
New LVWW Settling Tank 1 new) -
New Bottom Ash System Makeup
Pumps to BASWR 2 new
79 Purge (Note 2)
PRELIMINARY
EPA LETTER UPDATES
z EPA LETTER UPDATES
z EPA LETTER UPDATES
~ I Precipitation Included
NOTES:
1. Precipitation values based on 10 year, 24 hour storm
averaged over 24 hour period.
2. Purge based on water balance requirements for the
closed-loop system.
3. All flows shown in gallons per minute (GPM
4. Max flows for normal operation are in parentheses and
may not balance.
5. Water leaving with ash assumed to be 20% moisture.
Hydrobin ash expected to be removed for 4 hour duration
per day. BASWR ash removal expected 3 times per week
and estimated to be removed within 8 hour duration.
6. Purge to maintain system water chemistry up to 319
gpm or 10% of the bottom ash system flow.
7. Maintenance purge to drain one secondary cell of the
BASWR to the LVWW settling tank is not shown.
8. Dashed lines represent intermittent flows.
Sampling Location
PRELIMINARY
^BURNS
^.MCDONNELL
»aps
APS Four Corners
Future Conditions
Process Only Flows
-------
o
0
O
©
X
o
PRELIMINARY
EPA LETTER UPDATES
z EPA LETTER UPDATES
z EPA LETTER UPDATES
0 I Precipitation Included
NOTES:
1. Precipitation values based on 100 year, 24 hour storm
averaged over 24 hour period.
2. Purge based on water balance requirements for the
closed-loop system. Purge to LWVW based on flow
exceeding 10 year storm.
3. All flows shown in gallons per minute (GPM
4. Max flows for normal operation are in parentheses and
may not balance.
5. Water leaving with ash assumed to be 22% moisture.
Hydrobin ash expected to be removed for 4 hour duration
per day. BASWR ash removal expected 3 times per week
and estimated to be removed within 8 hour duration.
6. Purge to maintain system water chemistry up to 319
gpm or 10% of the bottom ash system flow.
7. Maintenance purge to drain one secondary cell of the
BASWR to the LVWW settling tank is not shown.
8. Dashed lines represent intermittent flows.
Sampling Location
PRELIMINARY
BURNS
V^McDONNELL
»aps
APS Four Corners
Future Conditions
Process & 100yr Storm water Flows
-------
APPENDIX B - STORMWATER RUNOFF CALCULATIONS
-------
BURNS ^MSDONNELL
WORKSHEET TITLE Ics
CREATED: 4/26/2021
PERFORMED BY: D ELLIOTT
OBJECTIVE: Determine Runoff Volumes
CALCULATION NO.:
REVISION:
REVIEWED BY:
REFERENCES:
1 Lindeburg, M (2008) Civil engineering reference manual for the PE exam Belmont, CA Professional Publications, Inc
2 Drainange Design Manual - NMDOT
https://dot.state.nm.us/content/dam/nmdot/lnfrastructure/Drairi Design Manual.pdf
3 National Oceanic and Atmospheric Administration (2015) NOAA Atlas 14, Volume 8, Version 2 [Point precipitation frequency estimates
for Farmington, NM, US] Retrieved from http //hdsc nws noaa gov/hdsc/pfds/pfds_map_cont htmPbkmrk=mo
4 United States Department of Agriculture Natural Resources Conservation Service National Engineering Handbook Part 630 Hydrology,
Chapter 15 Time of Concentration Np.nd Web 9 Feb 2016
DESIGN INPUTS:
1 Design storm duration is 24 hours
2 Max intensity duration is 5 minutes
3 Based on Custom Soils Resource Report, soils in the vicinity of the
watershed areas are generally sandy loam Hydrologic Soil Group C
EQUATIONS:
1 SCS Curve Number Method Runoff Equation
0 = (P-la)2/(P-la+S)
2 Soil Water Storage Capacity
S = (1000/CN) -10
3 Initial Abstraction
la = 0 2*S
4 Weighted Curve Number
CNW = (CN,*A,)/At
5 Volume of Runoff
V = Q*A,
VARIABLES:
runoff, in
total drainage area, ac or mi2
soil water storage capacity, in
curve number, unitless
initial abstraction, in
weighted curve number, unitless
total area, ac
total weighted curve number, unitless
CALCULATIONS:
Establish drainage area
Area 1
Area 2
Area 3
Area 4
Area 5
Area 6
Area 7
West Sump
East
Sumo
LVWW
Sump
Baghouse
Area
U4 BA
Area
BASWR
Hyd robin
Area
Ad(ac)
Ad(mi2)
9 61
5 75
9 40
6 50
1 00
1 70
0 40
0 015
0 009
0 015
0 010
0 002
0 003
0 001
Establish rainfall data
SCS Storm
Depth (in)
Reference 3
Reference 3
Reference 3
lyr, 24hr
0 83
lOyr, 24hr
1 54
lOOyr, 24hr
2 36
As shown on the area map figure, see below
Conversion from ac to rr
Establish CN, Percent Impervious Cover, and Initial Abstraction
West Sump
East Sump
LVWW Sump
Baghouse Area
U4 BA Area
BASWR
Hyd robin Area
Land Description
z
u
A," (ac)
S
Z
u
z
u
A," (ac)
CNW
CN,*
A," (ac)
S
Z
u
z
u
A," (ac)
CNW
CN,*
A," (ac)
n
z
n
z
A," (ac)
CNW
CN,*
A," (ac)
n
z
Open space, fair condition
79
0 0
79
0 0
79
0 0
79
0 0
79
0 0
79
0 0
79
0 0
Gravel
96
7 21
72 0
96
5 18
864
96
0 0
96
0 0
96
0 0
96
0 0
96
0 0
Pond
100
0 0
100
0 0
100
0 0
100
0 0
100
0 0
100
1 62
95 0
100
0 0
Pavement
98
2 40
24 5
0 58
98
98
9 40
98 0
6 50
98 0
9 40
98 0
98
0 09
4 9
0 40
98 0
Coal Pile
60
0 0
0 0
60
0 0
0 0
0 0
60
0 0
0 0
At (ac)
WW/ jmd, 96
CNwt
la
Equation 4
Equation 4
Equation 4
Equation 4
Equation 4
Sum
Sum
Equation 2
Equation 3
•Reference 1, Table 20 4, p 20-17 and Design Input 3
1 of 3
-------
BURNS ^MCDONNELL
Establish Runoff Volume based on SCS Curve Number Method
West Sump
East Sump
lvww sump
Baghouse Area
U4 BA Area
BASWR
Hydrobin Area
P f inl
Reference 3
1-yr Storm
Qfin)
Equation 1
V (gal)
Equation 5
Flow (qpm)
P fin)
Reference 3
10-yrStorm
Qfin)
Equation 1
V (gal)
Equation 5
Flow fgpm)
P fin)
Reference 3
Qfin)
Equation 1
V fqal)
Equation 5
Flow (gpm)
Evaporation Calcs 68,200
Area (acres)
Pan Evap
Rate
(in/yr)
Total Evap
(gal/yr)
Average
Evap
(gpm)
BASWR
1 40
55 00
2,090,877
3 98
LVWW
Settling Basin
1 00
55 00
1,493,484
2 84
2 of 3
-------
BURNS^MSDONNELL
Drawing showing relative areas (APS 4C- Google Earth.pdf):
3 of 3
-------
APPENDIX C - SAMPLING ANALYTICAL RESULTS
-------
BURNS^HS DON NELL
Client: APS Four Corners
Date 10/18/2021
Project No. 129532
Notes:
1) Non Detects (ND are not factored into average/max.
2) Blank cells were not analyzed for specific constituent.
isperided Solids, ppm
ssolved Solids, ppm
E
Q_
:y as CaC03, ppm
E
3, ppm
E
E
ppm
E
;d Silica, ppm
E
a
ppm
E
e"
E
E
e"
E
<
E
e"
;d Calcium, ppm
E
E
agriesium, ppm
E
e"
1
seriic, ppm
E
<
E
e"
E
e"
ercury, ppb
;d Mercury, ppb
ileriium, ppb
e"
Q
13
'=
s?
3
S
oT
->
<
->
o
->
-!=
->
5
->
<
->
£
->
5
->
•si
->
Stream Description
Sample Date/Time
E
§
g
g
Q
£
.3
£
.3
Q
Q
Q
Q
Q
Q
Q
£
3/4/21 12:31
8.97
5
721
114
ND
41.1
0.73
ND
ND
8.97
7.92
367
0.215
ND
74.3
72.2
ND
ND
28.7
27.1
ND
ND
ND
ND
ND
ND
3/8/21 12:03
8.92
11
719
142
ND
41.6
0.757
ND
ND
8.54
8.56
361
0.138
ND
74.4
79.6
0.75
ND
28
29.7
ND
ND
ND
ND
ND
ND
3/11/21 9:40
9.06
13
717
101
ND
40.9
0.759
ND
ND
9.03
8.73
367
0.64
0.175
0.101
76.7
74.4
ND
ND
27.5
27.4
ND
ND
ND
ND
ND
ND
3/15/21 10:51
8.81
691
110
ND
40.7
0.742
ND
ND
9.06
8.03
364
0.64
0.222
ND
72.2
74.6
2.48
ND
25.2
26.3
ND
ND
ND
ND
ND
ND
Seal Trough Makeup
(Service Water)
3/18/21 9:59
8.93
7
774
113
ND
41.3
0.75
ND
ND
ND
ND
359
0.64
ND
ND
71.4
78.1
ND
ND
25.3
27.1
ND
ND
ND
ND
ND
ND
9/13/21 13:31
8.77
14
744
105
ND
43.4
0.821
ND
ND
ND
383
ND
ND
77
76.2
ND
ND
31.2
30.2
ND
ND
90.7
114
9/16/21 12:02
8.74
6
762
102
ND
43.6
0.815
ND
ND
ND
396
ND
ND
83
72.1
ND
ND
31.8
27.8
98.2
108
9/17/21 11:13
8.71
7
772
102
ND
43.2
0.815
ND
ND
ND
393
ND
ND
78.4
6S.2
ND
ND
30.2
27.6
91.2
101
Average
9.00
737.50
111.13
41.98
0.77
8.90
8.31
373.75
0.64
0.19
0.10
75.93
74.43
1.62
28.49
27.90
93.37
107.67
Max
14.00
774.00
142.00
43.60
0.82
9.06
8.73
396.00
0.64
0.22
0.10
83.00
79.60
2.48
31.80
30.20
98.20
114.00
3/1/21 14:37
8.85
47
525
128
ND
41
0.738
ND
ND
6.79
5.35
366
ND
ND
70.6
79.4
ND
ND
27.3
27.3
ND
ND
ND
ND
ND
ND
3/4/2111:42
9.09
11
698
128
ND
41
0.727
ND
ND
8.16
8.2
366
0.221
ND
70.5
77.3
2
ND
28.1
27.8
ND
ND
ND
ND
ND
ND
3/8/21 12:54
9
15
728
128
ND
41.6
0.759
ND
ND
8.5
7.86
361
0.1
ND
69.3
73.2
0.832
ND
26
27.9
ND
ND
ND
ND
ND
ND
3/11/219:33
9.05
6
716
123
ND
40.8
0.758
ND
ND
9.06
8.35
366
0.64
0.173
ND
75.5
73.9
ND
ND
27.5
26.7
ND
ND
ND
ND
ND
ND
3/15/21 11:39
8.92
10
699
114
ND
40.7
0.738
ND
ND
7.91
8.11
364
0.64
ND
ND
69.5
71.7
ND
ND
25.4
26.1
ND
ND
ND
ND
ND
ND
Flush Water
3/18/21 9:43
8.88
8
759
113
ND
41.2
0.749
ND
ND
ND
ND
359
2.56
ND
ND
68.8
67.1
ND
ND
25.5
24.4
ND
ND
ND
ND
ND
ND
Max
16.17
47.00
687.50
759.00
122.33
128.00
41.05
41.60
0.74
0.76
8.08
9.06
7.57
8.35
363.67
366.00
1.28
2.56
0.16
0.22
70.70
75.50
73.77
79.40
1.42
2.00
26.63
28.10
26.70
27.90
All SW Average
12.31
716.07
115.93
41.58
0.76
8.45
7.90
369.43
0.96
0.18
0.10
73.69
74.14
1.52
27.69
27.39
93.37
107.67
All SW Max
47.00
774.00
142.00
43.60
0.82
9.06
8.73
396.00
2.56
0.22
0.10
83.00
79.60
2.48
31.80
30.20
98.20
114.00
3/1/21 12:33
8.47
30
664
97
ND
35.9
0.59
1.14
ND
6.19
5.69
350
0.118
ND
56.4
56.9
ND
ND
33.5
32.1
ND
ND
ND
ND
ND
ND
3/4/21 12:16
8.68
15
717
126
ND
40.9
0.727
ND
ND
8.65
7.85
366
0.243
ND
73.3
73.5
ND
ND
27.8
28
ND
ND
ND
ND
ND
ND
3/8/21 11:49
8.74
11
719
119
ND
41.5
0.763
ND
ND
5.2
8.46
361
0.146
ND
68
75.6
ND
ND
26
28.1
ND
ND
ND
ND
ND
ND
3/11/21 10:13
8.64
17
723
120
ND
40.9
0.756
ND
ND
7.44
8.67
367
0.64
0.121
ND
73.2
76.5
ND
ND
26.6
27.8
ND
ND
ND
ND
ND
ND
Seal Trough Overflow
3/15/21 11:23
8.71
91
704
118
ND
40.7
0.759
ND
ND
8.75
7.68
365
0.64
0.417
ND
69.8
72.1
ND
ND
25.4
26.3
ND
ND
ND
ND
ND
ND
3/18/21 10:19
8.74
32
766
114
ND
41.3
0.764
ND
ND
6.33
ND
361
0.64
0.144
ND
73.2
75.7
ND
ND
25.6
26.5
ND
ND
ND
ND
ND
ND
Average
32.67
715.50
115.67
40.20
0.73
1.14
7.09
7.67
361.67
0.64
0.20
68.98
71.72
27.48
28.13
Max
91.00
766.00
126.00
41.50
0.76
1.14
8.75
8.67
367.00
0.64
0.42
73.30
76.50
33.50
32.10
3/1/21 11:55
7.76
140
706
124
ND
40.4
0.768
0.302
ND
6.94
7.67
373
0.463
ND
72.6
72.9
ND
ND
27.1
27.1
ND
ND
ND
ND
ND
ND
3/4/2111:15
9.01
127
710
138
ND
40
0.737
0.449
ND
9.47
7.38
373
0.736
ND
78.7
72.3
ND
ND
28.9
26.5
ND
ND
ND
ND
ND
ND
3/8/2111:29
8.86
11
1080
191
ND
27.3
ND
ND
ND
12.2
12.3
229
0.17
ND
111
114
ND
ND
42.6
42.8
0.004
ND
ND
ND
ND
ND
BASWR Inlet from LVWW
3/11/21 9:15
7.94
300
712
110
ND
39.6
0.796
0.303
ND
18.7
8.13
368
0.64
4.09
0.105
75.7
75.4
2.46
ND
26.5
27
ND
ND
ND
ND
ND
ND
3/15/2110:30
8.59
1420
699
107
ND
40.3
0.793
0.281
ND
7.62
7.62
374
3.2
1.06
ND
73.4
77.1
0.604
ND
26.3
26.1
ND
ND
ND
ND
ND
ND
3/18/21 9:20
8.35
217
776
102
ND
41.1
0.821
0.447
ND
ND
ND
371
4.48
0.852
ND
72.9
22.2
0.436
ND
25.5
24.8
ND
ND
ND
ND
ND
ND
Average
369.17
780.50
128.67
38.12
0.78
0.36
10.99
8.62
348.00
2.77
1.23
0.11
80.72
72.32
1.17
29.48
29.05
0.004
Max
1420.00
1080.00
191.00
41.10
0.82
0.45
18.70
12.30
374.00
4.48
4.09
0.11
111.00
114.00
2.46
42.60
42.80
0.004
-------
BURNS^HS DON NELL
Client: APS Four Corners
Date 10/18/2021
Project No. 129532
Notes:
1) Non Detects (ND are not factored into average/max.
2) Blank cells were not analyzed for specific constituent.
Stream Description
Sample Date/Time
E
Total Suspended Solids, ppm
Total Dissolved Solids, ppm
Dil & Grease, ppm
|
0
1
1
£
"D
u
|
i
o
:luoride, ppm
Mitrate, ppm
Mitrite, ppm
Total Silica, ppm
Dissolved Silica, ppm
Sulfate, ppm
Sulfite, ppm
Total Aluminum,ppm
Dissolved Aluminum,ppm
Total Calcium, ppm
Dissolved Calcium, ppm
Total Iron, ppm
Dissolved Iron, ppm
Total Magnesium, ppm
Dissolved Magnesium, ppm
Total Arsenic, ppm
Dissolved Arsenic, ppm
Total Sodium, ppm
Dissolved Sodium, ppm
Total Mercury, ppb
Dissolved Mercury, ppb
Total Selenium, ppb
Dissolved Selenium, ppb
3/1/21 13:44
7.79
450
736
122
ND
47*2
0.819
ND
ND
6.87
4.74
375
0.858
ND
75
72.7
0.509
ND
27.6
27
ND
ND
ND
ND
ND
ND
3/4/2112:05
8.64
58
750
128
ND
41.5
0.822
ND
ND
9,76
6.3
380
0.579
0.11
75.3
78.2
ND
ND
27.3
28
ND
ND
ND
ND
ND
ND
3/8/2112:24
7.84
924
756
130
ND
41.6
0.806
ND
ND
12.7
8.65
368
1.79
ND
75.1
74.9
0.763
ND
26
27.3
0.00416
ND
ND
ND
ND
ND
3/11/2110:04
8.86
9
712
108
ND
40.9
0.759
0.321
ND
8.1
5.45
367
0.64
ND
ND
68.6
69.8
ND
ND
25.5
25.5
ND
ND
ND
ND
ND
ND
3/15/21 11:04
8.88
29
706
112
ND
40.9
0.83
ND
ND
9.45
9.76
379
1.28
0.214
ND
75.8
83.1
ND
ND
26.7
28.5
ND
ND
ND
ND
ND
ND
3/18/2110:49
8.76
1470
776
104
ND
41.4
0.882
ND
ND
ND
5
367
1.28
0.919
ND
78.2
78.2
ND
ND
25.8
25.8
ND
ND
ND
ND
ND
ND
7/7/2115:54
41.84
7.69
2940
762
107
ND
42.3
0.858
ND
ND
ND
ND
378
1.53
ND
73.8
74.6
0.929
ND
25.2
29.3
0.005
ND
ND
ND
ND
ND
7/8/2114:43
43.52
8.13
512
764
99
ND
42.4
0.918
ND
ND
ND
ND
380
0.256
0.172
79.2
82
ND
ND
27.7
27.4
ND
ND
ND
ND
ND
ND
8/5/217:00
32.90
8.74
1080
8/5/21 7:30
31.70
8.29
667
8/5/218:00
32.70
8.17
637
8/5/21 8:30
32.90
8.2
611
8/5/219:00
34.40
8.07
723
8/5/21 9:30
34.70
7.96
726
8/5/2110:00
34.30
7.98
840
8/5/2110:30
35.70
7.95
575
8/5/2111:00
36.40
7.93
830
8/5/2111:30
35.90
7.89
1320
Unit 4 & 5 Hydrobin
8/5/2112:00
37.90
7.86
1010
Overflow
8/5/2112:30
36.70
8.19
807
8/5/2113:00
37.80
8.05
483
8/5/2113:30
38.00
7.32
292
8/5/2114:00
38.20
7.04
396
8/5/2114:30
38.70
7.85
846
8/5/2115:00
40.30
7.95
496
8/5/2115:30
40.20
8.35
306
8/5/2116:00
35.90
7.92
782
8/5/2116:30
38.10
7.88
643
8/5/2117:00
40.50
7.96
856
8/5/2117:30
38.90
9.61
20
8/5/2118:00
38.50
9.67
8
8/5/2118:30
37.40
9.84
6
9/13/2113:41
34.40
8.04
483
771
104
ND
43.5
0.921
ND
ND
ND
393
2.17
ND
83.5
75.3
ND
ND
30.9
28.2
92.5
108
9/16/21 13:42
34.30
7.93
2000
790
98.5
ND
43.1
0.877
ND
ND
ND
403
ND
ND
84.7
74.9
ND
ND
31.2
28.3
93.6
110
9/17/2113:01
30.70
7.93
1530
783
95.2
ND
43.3
0.929
ND
ND
2.47
407
ND
ND
71.3
72
ND
1.29
28.8
28.1
86.6
108
Average
Max
36.67
43.52
724.71
2940.00
755.09
790.00
109.79
130.00
42.01
43.50
0.86
0.93
0.32
0.32
9.28
12.70
6.05
9.76
381.55
407.00
1.07
1.28
1.04
2.17
0.14
0.17
76.41
84.70
75.97
83.10
0.73
0.93
1.29
1.29
27.52
31.20
27.58
29.30
0.00
0.01
90.90
93.60
108.67
110.00
7/7/2115:00
38.83
7.63
15
747
110
ND
42.1
0.779
ND
ND
ND
ND
367
0.113
ND
66.2
76.9
ND
ND
26.6
29.4
ND
ND
ND
ND
ND
ND
7/8/21 14:05
55.80
7.76
373
773
92
ND
42.7
1.01
ND
ND
ND
ND
392
0.345
ND
79.9
82.6
ND
ND
27.2
27.6
0.00494
0.00462
ND
ND
ND
ND
U4 Hopper Overflow
9/13/21 13:10
27.60
8.66
2.5
781
107
ND
44.1
0.952
ND
ND
ND
394
0.859
0.813
81.4
86.2
ND
ND
29.2
28.4
90.8
123
9/16/21 12:22
31.40
8.36
98
766
103
ND
43.2
0.82
ND
ND
ND
393
ND
ND
79.9
73.3
ND
ND
30.8
29
92.1
114
9/17/21 11:45
29.50
8.54
44
111
102
ND
43.1
0.835
ND
ND
ND
392
ND
ND
83.1
71
ND
ND
30.7
28.5
93.3
111
7/7/21 15:17
55.20
6.85
276
773
82
ND
42.6
1.13
ND
ND
ND
ND
403
1.63
ND
66.9
76.6
0.758
ND
25.8
27.3
0.00618
ND
ND
ND
ND
ND
7/8/21 14:13
54.22
7.81
307
755
90
ND
42.6
1.03
ND
ND
ND
ND
392
0.238
ND
81.1
81.6
ND
ND
28.4
28.4
0.00502
0.00424
ND
ND
ND
ND
9/13/21 13:19
40.30
7.85
98
773
90
ND
43.8
1.06
ND
ND
ND
405
0.514
ND
81.8
80.1
ND
ND
30.9
29
90.1
115
U5 Hopper Overflow
9/16/21 12:03
36.10
7.54
493
776
98.4
ND
43.3
0.953
ND
ND
ND
404
ND
ND
81.6
70.2
ND
ND
31.9
27.3
90.5
103
9/17/21 11:51
38.10
7.64
131
793
89.5
ND
43.6
1.06
ND
ND
2.8
415
ND
ND
73
71.1
ND
ND
28
27.6
86.7
122
Max
183.75
493.00
771.40
793.00
96.39
110.00
43.11
44.10
0.96
1.13
395.70
415.00
0.62
1.63
77.49
83.10
76.96
86.20
0.76
0.76
28.95
31.90
28.25
29.40
0.005
0.006
0.004
0.005
-------
BURNS^HS DON NELL
Client: APS Four Corners
Date 10/18/2021
Project No. 129532
Notes:
1) Non Detects (ND are not factored into average/max.
2) Blank cells were not analyzed for specific constituent.
Stream Description
Sample Date/Time
E
Total Suspended Solids, ppm
Total Dissolved Solids, ppm
Dil & Grease, ppm
|
o
-------
APPENDIX D - CHEMISTRY CALCULATIONS
-------
Baseline Conditions - Open Loop Configuration
Entire system volume
4,594,353
gallons
3,190.52
gpm
Bottom ash hopper volume, total
149,600
gallons
Bottom ash hydro bins, total
647,694
gallons
Makeup (gpm) (dragout + evap)
44.79
gpd
Total Makeup (GPD)
64,504
Dragout
50,400
gpd
35.00
]gpm, from Ash design basis
System Evaporation
14,104
gpd
9.79
gpm | 9.79 |gpm, BASWR evaporation plus bottom ash hopper evaporation
Cycles of Concentration
1.00
Jcurrent system is open loop - no cycling
Hydraulic Residence Time (HRT), day
71.23
Seal trough overflow / agitation nozzles
3,047
gpm
4,387,680
gal/day - assumes seal trough flow is continuous
Sluice rate
2,628
gpm
1,261,440
gal/day - assumes sluicing 2x per day for 2 hours each sluice per unit
This sheet calculates the concentration of solutes added to the system by the ash, for use in projecting water quality under different purge rates. When the estimated
concentrations in red font (Estimated Concentrations row) agree with the measured values (Hydrobin Overflow row), the estimated contribution of the ash to the
solutes in the system from the model is showing good correlation and is considered acceptable.
alk/HC03,
alk/C03,
Water quality data
Cond, uS/cm
TDS, ppm
CI, ppm
S04, ppm
Mg, ppm
Ca, ppm
ppm
ppm
pH, SU
Temp, F
Makeup Water
1,100.75
737.50
41.98
373.75
28.49
75.93
111.13
8.86
70.00
8.12
6.79
1.03
Hydrobin Overflow
1,127.00
755.09
42.01
381.55
27.52
76.41
109.79
8.20
98.01
7.55
6.87
0.66
Current Cycles Observed
1.0239
1.0239
1.0007
1.0209
0.9660
1.0063
0.9879
Change in system concentration
26.25
17.59
0.03
7.80
(0.97)
0.48
(1.34)
28.01
Excess concentration at reported HRT, ppm/day
0.2470
0.0004
0.1095
(0.0136)
0.0067
(0.0188)
Concentration change from evaporation
increase)
13.28
0.76
6.73
0.51
1.37
2.00
<- increase in system concentration from evaporation losses
Concentration input from contact with bottom ash
4.31
(0.73)
1.07
(1-48)
(0.89)
(3.34)
<- negative values do not make sense; should have an increase in concentration
MGD gpm
100.0%
percentage of design basis
Evaporation
0.014
9.79
gpm
Dragout
0.050
35.00
gpm, calculated dragout/system losses to approximate concentration factors
Sluice rate
3.784
2,628.00
gpm, current sluicing rate, open-loop system
Makeup
0.065
44.79
gpm
PSI =
2(pHs)-
pHeq
RSI =2(pHs) -
pHmeasured
LSI =
pHmeasured
- pHs
LS-I
1
-------
APPENDIX E - GENERAL ARRANGEMENT
-------
BASWR
UNIT 4 UNIT 5
80ILER BOILER
i»
HYDROB NS
HYDROBIN
OVERFLOW
TANKS
SUMP
BOILER
FOUR CORNERS
OVERALL SITE
ELG PLANT MODIFICATIONS
GENERAL ARRANGEMENT
129532
FC C016494
08/12/2
MO 03
designed «• MATTHEWS
Z:\CLIENTS\ENR\ARIZONAPS\129532 FCC016494ELG\DESIGN\MECH\CADD\SKETCHES\129532 SKM003.DWG 2/24/2022 4:31 PM KJMATTHEWS
-------
BURNS ||mSDONNELL
CREATE AMAZING.
Burns & McDonnell World Headquarters
9400 Ward Parkway
Kansas City, MO 64114
O 816-333-9400
F 816-333-3690
www.burnsmcd.com
-------
Attachment 4: APS Project Status Update
Presentation
-------
Agenda
• ELG Compliance
Project update
• Timing issues
• Proposed permit
modification approach
aps
-------
ELG Compliance Project Update
Project Planning
• Integration of ELG and CCR Rule for a
comprehensive compliance strategy
• Approval by multiple owners
• Flow monitoring and plant water balance
development
iflR MR ............ \
Design and Procurement
• Continued flow and water quality
characterization
• Plant water balance/unit process refinement
• Identification of long lead items and project
phasing
Hr
Construction & Testing
• Phased construction
• Requirement for 45 Day dual outage
• Testing during full load
• Water quality monitoring to support chemical
amendment analysis
V /
2
aps
-------
Timing Issues
COVID-19 / Ukraine Conflict
• Supply chain disruption
- 10 material bid packages
¦ Pumps
¦ Power Distribution Center
¦ Overflow tanks
¦ Piping material
¦ Electrical cable (40-52 weeks)
¦ Knifegate valves
¦ Control valves (48-60 weeks)
¦ ABB Control Cabinet
¦ Chemical Feed Tanks
- 8 construction bid
packages
3
Testing Requirement
• Startup dependent on outage
schedule
• Operational water quality
cycling evaluation
• Chemical amendment
assessment
-------
Proposed Permit Modification Approach
• Impose a Schedule of Compliance extending the
compliance deadline consistent with the 2020 ELG
Reconsideration Rule "blowdown" limits and "as soon as
possible" deadline
• Base EPA's determination of the BATW blowdown limits on
actual plant closed-loop BATW recirculation operations and
follow this schedule:
- Construct and begin operating the closed-loop BATW
recirculation system by 12/31/23
- Monitor and, to the maximum extent feasible, minimize BATW
discharges from startup to compliance deadline
- Regularly report to EPA (e.g., monthly) blowdown volumes,
internal water chemistry, etc.
4
aps
-------
Attachment 5: APS NPDES Permit
Modification Letter
-------
aps
Tel. 602-250-2414 PO Box 53999
Cell 602-284-3899 Mail Station 9303
e-mail: neal.brown@aps.com Phoenix, Arizona 85072
November 1, 2022
Electronically Submitted
U.S. Environmental Protection Agency, Region 9
NPDES Permits Section, Water Division (WTR-2-3)
Attn: Gary Sheth (Sheth.Garv@epa.QOv)
75 Hawthorne Street
San Francisco, CA 94105
Subject: PROPOSED PERMIT MODIFICATION APPROACH
Information Supporting a Permit Modification Pursuant to
Amended Standards in the Steam Electric Reconsideration Rule
APS Four Corners Power Plant - Fruitland, New Mexico
NPDES Permit No. NN0000019
Dear Mr. Sheth,
As discussed in recent meetings with the U.S. Environmental Protection Agency (EPA), Arizona
Public Service Company (APS) is making progress modifying our once-through bottom ash
transport sluice water system at Four Corners Power Plant (FCPP) into a high-recycle system.
Upon completion of this project, the system will comply with the bottom ash transport water
(BATW) discharge requirements of 40 CFR 423 - Steam Electric Power Generating Point
Source Category (i.e., the 2020 ELG Steam Electric Reconsideration Rule, 85 Fed Reg 64,650
(October 13, 2020)).
Although we are confident that our system will be constructed no later than the compliance
deadline for ceasing BATW discharges in the current FCPP National Pollutant Discharge
Elimination System (NPDES) permit (i.e., December 31, 2023), supply chain disruptions
associated with COVID-19 and the Ukraine conflict will not allow sufficient testing and
evaluation of system operations to support finalization of our Initial Certification detailing the
necessary BATW purge allowance prior to the existing permit compliance deadline.
Attachment A to this letter presents a Schedule Progress Report transmitting documentation
that identifies the specific equipment impacted by the supply chain delays, including backup
correspondence from vendors.
Since the information provided in the Initial Certification forms the basis for EPA's
determination regarding BATW discharges under the amended standards in the 2020 ELG
Steam Electric Reconsideration Rule, see 40 CFR § 423.19(c), APS requests that EPA modify
the FCPP permit in two steps, as warranted:
1. First, establish December 31, 2025 as the permit's "as soon as possible" date for
compliance with amended BATW discharge requirements, consistent with 40 CFR
§§ 423.11(t) and 423.13(k)(l)(i), and impose both interim compliance milestones and
discharge limits for the BATW discharge under the 2020 Rule. FCPP would operate the
high-recycle BATW system starting no later than December 31, 2023, and comply with
interim discharge requirements consistent with 40 CFR § 423.13(k)(2)(i)(A).
2. Second, use actual FCPP operating data based on testing and evaluation of the high-
recycle BATW system documented in a finalized Initial Certification to modify the
permit as appropriate to account for adjustments needed to the BATW discharge limits.
l|
-------
This second step in the process would be finalized no later than December 31, 2025—
the current compliance deadline for BATW allowed for under 40 CFR § 423.13(k)(l)(i).
Basis for December 31. 2025 "As Soon as Possible" Date
Under the 2020 ELG Steam Electric Reconsideration Rule, the "as soon as possible" date for
meeting BATW limitations must be no later than December 31, 2025. 40 CFR
§ 423.13(k)(l)(i). In accordance with 40 CFR § 423.11(t), the "as soon as possible" date
must reflect consideration of: (1) time to plan, design, procure, and install compliance
equipment; (2) changes being made or planned at the facility in response to other
environmental regulations; and (3) other factors, as appropriate.
During the permit process, on April 4, 2019, APS provided EPA with an ELG Compliance Project
Summary, which provided an overview of the proposed projects and timeline to address
compliance with both the 2015 ELG Rule's standards for BATW and requirements under EPA's
coal combustion residuals (CCR) regulations. Based on developments that have occurred
since our last update, APS now provides information that supports a determination under the
§ 423.11(t) factors that the "as soon as possible" date for compliance with amended BATW
discharge requirements should be modified to December 31, 2025.
High-Recycle BATW Project Construction, Testing, & Tuning Timeline
To address BATW requirements and EPA's CCR regulations, APS previously identified the
implementation of three separate, yet interrelated projects at the FCPP: (1) closure of the
Combined Waste Treatment Pond (CWTP), (2) construction of the BATW treatment tank, and
(3) construction of a high-recycle BATW system.
The CWTP historically treated BATW comingled with low volume wastewater prior to discharge
through internal outfall 01E to Morgan Lake. Due to CCR Rule requirements, closure of the
CWTP was necessary and thus the BATW treatment tank was constructed to replace the
function of the CWTP in plant operations. The BATW treatment tank was completed and put
into service in November 2020 concurrent with reissuance of the FCPP NPDES permit. To date,
all flows of NPDES-regulated wastewater, which had been routed through the CWTP, have
been diverted from that unit as it undergoes closure. Closure of the CWTP was previously
integral to construction of the high-recycle BATW system because it was identified as a future
treatment unit for segregated low volume wastewater following unit closure. Given delays in
closing the CWTP, APS has proceeded with the design and construction of a new Low Volume
Waste Tank, uncoupling closure of the CWTP as a required milestone in commissioning the
high-recycle BATW system.
Construction of the high-recycle BATW system is ongoing. As previously identified, the
schedule for development of the high recycle BATW system has been impacted by supply
chain issues related to COVID-19 and the conflict in Ukraine, which has necessitated
advancing design engineering, procurement, and construction along parallel paths.
Engineering of all major systems is near complete and procurement packages have been
issued. Construction of the Hydrobin overflow tanks, the Low Volume Waste Tank, and pipe
rack has begun. Despite our best efforts to progress procurement of long-lead equipment,
supply chain issues have resulted in delays to the completion of the high recycle BATW
system. APS currently meets twice per month with each supplier to discuss production and
delivery status and vendors have indicated that critical elements of the system will not be on-
site until Spring 2023. See Attachment A. The information provided in Attachment A
demonstrates clearly that delays have significantly impacted the "time to plan, design,
procure, and install compliance equipment" at FCPP and, in accordance with 40 CFR
§ 423.11(t), it is appropriate to establish December 31, 2025 as the compliance date for FCPP
as to the 2020 ELG Steam Electric Reconsideration Rule.
APS has scheduled two planned outages for system installation, commissioning, and tuning.
During the initial outage, scheduled for Spring 2023, APS intends to install and check the
function of equipment in the new high recycle BATW system. Over the Summer of 2023, APS
21:
-------
will perform initial testing and balancing of the system, allowing BATW discharges to continue
through the existing 01E outfall as needed to ensure safe and reliable plant operations. Then,
during the Fall 2023 outage, APS will address any issues or concerns that were discovered
over the summer months. Under this schedule, FCPP would fully-rely upon and operate the
high-recycle BATW system starting no later than December 31, 2023—at which point, BATW
discharges would only be allowed in accordance with the interim discharge limits as described
herein.
High-Recycle BATW Project Monitoring, Evaluation, and Initial Certification
To ensure adequate time for testing under consistent and high load after startup, APS
proposes to perform monitoring and evaluation of the system throughout 2024. A year of
testing is required to allow assessment over periods of sustained and variable plant operation
given the impacts recirculation of BATW can have on water chemistry. During this time, APS
would report blowdown volumes and the results of internal water chemistry monitoring to EPA
on a monthly basis, while maintaining strict compliance with interim discharge limits. This
data would be used to identify the bottom ash purge volume needed to maintain system water
chemistry on the newly-installed system consistent with 40 CFR § 423.13(k)(2)(i)(A)(3).
Based on such testing and evaluation, APS would thereafter finalize its Initial Certification
using actual FCPP operating data.
In light of the time to procure, install, and test the BATW compliance equipment, consistent
with all three of the identified § 423.11(t) factors, APS requests that EPA establish the "as
soon as possible" date in the current NPDES permit for compliance with amended BATW
discharge requirements to December 31, 2025. This is the soonest date by which APS can
achieve compliance in light of the supply chain and procurement delays that have impacted
system construction and accommodate the time that will be needed for testing of the system
once it is in operation.
Interim Compliance Milestones & Discharge Limits
Between December 31, 2023 and December 31, 2025, APS understands that EPA needs to
include discharge limits in our NPDES permit for the high-recycle BATW system in accordance
with the 2020 ELG Steam Electric Reconsideration Rule. With respect to system water
chemistry in particular, APS conducted supplemental research to assess the experience of
other steam-electric power generating facilities that have implemented high-recycle BATW
systems, including a review of Electric Power Research Institute studies, consultation with our
design engineering firm, and discussion with other utilities. Although there is limited
information that is directly applicable to our facility because systems and operating conditions
are unique, we identified that Duke Energy's Cayuga Station in Indiana has experience
operating their high recycle BATW system and has assessed the impacts that high sulfide
concentrations have in their operations. Based on current operating experience with our once-
through BATW system, FCPP will similarly confront high sulfide concentrations in maintaining
our high recycle BATW system.
For the Cayuga Station Initial Certification documents, a requirement is included to purge up
to 75,400 gallons per day to maintain system water chemistry. In the absence of other
operationally derived data, APS proposes to use the discharge volume proposed for Cayuga
Station, normalized for plant rated capacity, and rounded to the nearest 0.5% as the basis
for our interim discharge limit to maintain system water chemistry:
(75,400 gallons at Cayuga) * (1,540 MW at FC)/(1,104 MW at Cayuga) = 105,178 gallons
105,178 gallons divided by FC total system volume (4,594,352 gallons) = 2.29% - rounded to 2.5%
Thus, our proposed permit modification approach includes:
• Revise the FCPP NPDES permit before December 31, 2023 to establish an "as soon as
possible deadline" of December 31, 2025, and impose a defined schedule of permit
milestones consistent with the 2020 ELG Steam Electric Reconsideration Rule BATW
31:
-------
"blowdown" limits and "as soon as possible" deadline (i.e., no later than December 31,
2025):
- Construct and begin operating a high-recycle BATW system by December 31,
2023;
- Report blowdown volumes and the results of internal water chemistry
monitoring to EPA on a monthly basis during interim operations (i.e., between
December 31, 2023 and the "as soon as possible" date of December 31, 2025);
and
- Submit an updated draft Initial Certification incorporating interim operational
data for the high-recycle BATW recirculation system no later than March 31,
2025 to allow for an update of permit conditions by December 31, 2025.
• During interim operations between December 31, 2023 and December 31, 2025,
impose limits for high-recycle BATW system blowdown discharges based on volumes
identified in our draft Initial Certification (filed on May 19, 2022, and attached here for
reference) for all conditions except those required to maintain water chemistry (where
the limit will be adapted from Cayuga Station permit, as provided above). In sum, the
interim BATW high recycle system blowdown discharge limits applicable as of
December 31, 2023 to FCPP would be:
- Limit stormwater flows to those greater than the 10-Year, 24-Hour Storm (i.e.,
stormwater flows in excess of 111,000 gallons in a 24-hour period);
- Limit discharges required to maintain water balance due to intermittent flows
from other waste streams to 400 gpm peak (20 gpm average) for a period of
no greater than 3 days when spare or surge capacity is limited;
- Limit discharges required to maintain water chemistry to 2.5% of the total
system wetted volume per day (i.e., 114,859 gallons per 24-hour period); and
- Limit discharges required for maintenance to 1,428,043 gallons.
In addition to the individual limits based on discharge condition, the total of all BATW
discharges from the high-recycle system shall be limited to no more than 10% of the
total system wetted volume per day (i.e., 459,435 gallons per day calculated on a 30-
day rolling average basis), consistent with 40 CFR 423.13(k)(2)(i)(B).
APS appreciates EPA's input on our requested permit modification for FCPP. We welcome the
opportunity to discuss any additional feedback you may have on this proposal. If you have
any questions or would like to discuss this approach in more detail, please contact Natalie
Chrisman Lazarr at (602) 316-1324 or via email at natalie.chrismanlazarr@aps.com.
Neal Brown
Environmental Operations Manager
Arizona Public Service Company
Cc: Mr. Jeffrey Jenkins, Plant Manager - APS, Four Corners Power Plant
Ms. Pamela Norris, Environmental Manager - APS, Four Corners Power Plant
Mr. Jeffrey Allmon, Senior Attorney - Pinnacle West Capital Corporation
Attachments
* * * *
Sincerely,
4 I
-------
ATTACHMENT A
SCHEDULE PROGRESS REPORT
-------
FCC016494 ELG PLANT MODIFICATIONS
FOUR CORNERS UNITS 4&5
CONSTRUCTION SCHEDULE
SEPTEMBER 2022
GENERATION ENGINEERING SERVICES
Schedule Progress Report Transmittal
September 26, 2022
WA FCCO16494 - ELG PLANT MODIFICATIONS
This report presents the status of Material Schedule Delivery Dates to meet the December
31, 2023 National Pollutant Discharge Elimination System (NPDES) Permit compliance
deadline for bottom ash transport water at the Four Corners Power Plant. Internally the
capital project being implemented to comply with this deadline is referred to as the ELG
Plant Modification Project which refers to the EPA regulation that requires suspension of
once-through sluicing systems for bottom ash transport water and conversion to a high-
recycle bottom ash transport water recirculation system.
The schedule of the ELG Plant Modification Project has been impacted by supply chain issues
related to COVID and the Ukraine conflict which has necessitated advancing design
engineering, procurement, and construction along parallel paths. To ensure some time for
testing under consistent and high load after startup, APS has scheduled two planned
outages for system installation and maintenance; these outage dates are fixed and can be
considered the dates that all system components must be received by to ensure compliance
with the permit.
Four Corners Planned Outages:
Installation Dual Unit Outage: April 1st, 2023 thru May 15th, 2023
• Completion of all work using the newly installed system to be used and tested
throughout the Summer Run of 2023 for training purposes of balancing the closed
loop water system.
Maintenance Dual Unit Outage: October 15th, 2023 thru November 12th, 2023
• Final checks of the installed system to address issues and items discovered during
the 2023 Summer Run to be prepared for the 2024 operations.
-------
A
FCCO16494 ELG PLANT MODIFICATIONS
FOUR CORNERS UNITS 4&5
CONSTRUCTION SCHEDULE
SEPTEMBER 2022
f aps
Summary of Maior Risks to Installation Outage:
Due to the Supply Chain Management issues throughout 2021 and 2022, our team
progressed the engineering and procurement packages to minimize the delay of materials to
meet the date of the Installation Dual Unit Outage. Critical packages based on feedback
supplied by vendors are summarized below:
PO
Vendor
Plan Outlook Actual
Notes
10G618708ABB
DCS Hardware
3/13/2023 3/13/2023
1
100618300 Okonite
4160 V Cable
12/3/2022 12/03/2022
2
100619766 Graybar
MCC
1/15/2023 3/23/2023
2
100619374
¦ IMI-CCI
Control Valves
2/15/2023 2/24/2023
1
100616045
« Powell
PDC Building
7/31/2022 1/25/2023
2
100616044 PPI
Vertical Turbine Pumps
10/31/2022 1/15/2023
2
1) U45 outage no-go without material
2) Delay in cable would push construction into U45 outage
Summary of Material Delays:
Above are the items that have been ordered and the dates have shifted, or the items are
critical to meeting the needs of the Installation Outage. All parts need to be on-site prior to
the April 1st, 2023, date as ail parts need to be in working order prior to the end of the
Installation outage.
The Major parts that have turned out to be very critical to the outage are the MCC (Motor
Control Center), Control Valves and the DCS hardware.
The other parts are being tracked and are at risk but are trending towards the beginning of
the year.
**APS has meetings twice a month with each supplier to discuss these materials and
trending delivery dates**.
More detailed discussion of critical packages with vendor documentation is presented in the
following pages.
CONFIDENTIAL BUSINESS INFORMATION
-------
FCC016494 - ELG PLANT MODIFICATIONS
FOUR CORNERS UNITS 4&5
CONSTRUCTION SCHEDULE
SEPTEMBER 2022
t aps
Power Distribution Center - Powell PDC - Bid Event
Issued Date of the Purchase Order - 10/17/21 - Delivery Date on Order - 7/30/22
Current tracking date 01/25/23 - Delay of 6 Months
RE_ FCC016494 -
ELG PDC Design Re\/
Email Dated - 2/18/22 - Shipment Date 10/17/22
[3
RE_ FCC016494 F45
ELG Modifications -
Email - Dated - 7/1/22 - Shipment Date 1/16/23
CONFIDENTIAL BUSINESS INFORMATION
-------
A
FCC016494 - ELG PLANT MODIFICATIONS
FOUR CORNERS UNITS 4&5
CONSTRUCTION SCHEDULE
SEPTEMBER 2022
t aps
The Okonite Company - Electrical Cable 4160V
Issued Date - 4/8/22 - Delivery Date 12/03/22 -
Currently tracking in 12/03/22
Notes: Okonite has any delays in this cable will extend the construction of this work scope
into the dual unit outage however it is trending positively.
RE_ Post Award
Meeting .msg
E-mail Dated - 08/31/22 - Shipment Date 12/3/22
CONFIDENTIAL BUSINESS INFORMATION
-------
FCC016494 - ELG PLANT MODIFICATIONS
FOUR CORNERS UNITS 4&5
CONSTRUCTION SCHEDULE
SEPTEMBER 2022
t aps
IMICCI - Control Valves:
Issued Date - 4/25/22 - Delivery Date per specifications - 2/24/23 -
Final Complete Control Valves to be delivered 7/25/23
Notes:
Installation Outage will have the Control Valve Installed, and then in the Maintenance
Outage will readdress the Control Valve Parts for permanent installation after summer run.
RE_
(IMI_TRANSMIT_A79
Email Dated 8/24/22 - Issues with components on the Control Valve
RE_ APS PO
100618499 - IMI CCI
Control Valve Supplier Discussing the Covid Issues as well as the Ukraine Conflict.
CONFIDENTIAL BUSINESS INFORMATION
-------
A
FCC016494 - ELG PLANT MODIFICATIONS
FOUR CORNERS UNITS 4&5
CONSTRUCTION SCHEDULE
SEPTEMBER 2022
t aps
Phoenix Pumps - Vertical Turbine Pumps -
Issued Date - 3/25/22 - Delivery Date per specification - 10/25/22
Updated delivery date of the Vertical Turbine Pumps is 1/15/23
APS Four Corners -
VTP Motors.msg
Ship Date 9/27 as of Email of 7/20
Still tracking and trending behind the 9/27 date but waiting on the final testing from the
shops.
CONFIDENTIAL BUSINESS INFORMATION
-------
FCC016494 - ELG PLANT MODIFICATIONS
FOUR CORNERS UNITS 4&5
CONSTRUCTION SCHEDULE
SEPTEMBER 2022
t aps
Graybar - Motor Control Center -
Design completion - Issued date - 9/12/22 - Delivery per specification - 01/15/23
Updated delivery date to 3/23/23
Notes: The design has to be completed based on the completion of the other engineering
designs and with the delays of MCC turning to 50 weeks and Burns & McDonnell
Engineering to get these timelines moved in - still working with the vendor to improve
these dates.
[3
RE_ ELG - Graybar
MCC Delivery .msg
Email 9/26 - Shipment is 3/23
RE_ MCC - ATS -
Graybar.msg
Email 8/17 - Shipment is still 16 weeks
RE_ MCC - ATS -
Graybar.msg
Email 8/24 - Shipment is 27 Weeks
CONFIDENTIAL BUSINESS INFORMATION
-------
FCC016494 - ELG PLANT MODIFICATIONS
FOUR CORNERS UNITS 4&5
CONSTRUCTION SCHEDULE
SEPTEMBER 2022
ABB Hardware -
Issued Date - 5/10/22 - Deliver per specification - 03/30/23
Notes: The Design team is not expecting this to delay the dual unit outage; however, this is
a high risk for completion of the project.
[3
U324_ APS 4C F45
ELG Modifications P
Email of Meeting Notes from 8/11/22 - Shipment Date of hardware to be worked on by the
end of January for Delivery of 3/30/23
CONFIDENTIAL BUSINESS INFORMATION
-------
ATTACHMENTS
CONFIDENTIAL BUSINESS INFORMATION
-------
From: Von Ruff, Brandon
To: McGarv, Nicolas: Lemieux, Brendan: Lemieux, Brendan: Schroeder, Timothy:
Steven: Austin, Robert: Cole, Dennis
Cc: "brendan.lemieux@mwconsultllc.com": Terry Stewart: 129532
Subject: RE: FCC016494 - ELG PDC Design Review Meeting
Date: Friday, February 18, 2022 9:38:04 AM
Attachments: imaaeOOl.Dna
imaae003.pna
.imaae005,pna
*** CAUTION * * * * * *CAUTION* * * ***CAUTION***
This e-mail is from an EXTERNAL address (brandon.vonruff@powellind.com). DO NOT click on links or open attachments unless you
trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center
at A CDC@aps. com.
Please see the following high level schedule:
Approval Drawings-4/14/2022
Customer Return of drawing to Powell - 4/29/2022
Release to Manufacturing Drawings - 5/20/2022
Record Drawings with wiring diagrams - 6/15/2022
Powell Inspection Start-9/12/2022
Customer Inspection (FAT) -9/19/2022 -9/23/2022
Shipment From Powell - 10/17/2022
For items on this project that we are seeing longer than usual lead times are the following:
LV MCC-Will order buckets/vertical sections as soon as proposed arrangement is approved
MV MCC - ISO Switches - ordering these earlier than typical to offset
Relays - SEL did have a bunch of relays on production hold, but these are starting to come off hold and have longer than typical lead times. Once we
have approval of the relay part numbers we will order.
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902
Cell: (713) 584.5530
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: McGary, Nicolas [mailto:nmcgary@burnsmcd.com]
Sent: Wednesday, February 16, 2022 10:20 AM
To: Brendan.Lemieux@aps.com; Lemieux, Brendan ; Schroeder, Timothy ;
Lawrence.Hunt@mwconsultllc.com; Yazzie, Rachael G ; Mix, Larry ; Stewart, Terry
; Nicholson, Steven ; Austin, Robert ; Cole, Dennis
; Von Ruff, Brandon
Cc: Allen, Chris ; 'brendan.lemieux@mwconsultllc.com1 ; Terry Stewart
; 129532 <129532@burnsmcd.com>
Subject: RE: FCC016494- ELG PDC Design Review Meeting
EXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTSI
All,
Please see attached for this week's meeting minutes. Let me know if you have any questions or comments. Thanks again.
Have a great day!
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
CONFIDENTIAL BUSINESS INFORMATION
-------
* Registered in CO
Original Appointment
From: Brendan.Lemieux@aps.com
Sent: Tuesday, January 4, 2022 3:02 PM
To: Lemieux, Brendan; tschroeder@burnsmcd.com: McGary, Nicolas; Lawrence.Hunt@mwconsultllc.com: Yazzie, Rachael G; Mix, Larry; Stewart,
Terry; Nicholson, Steven; Austin, Robert; Cole, Dennis; Von Ruff, Brandon
Cc: Allen, Chris; 'brendan.lemieux@mwconsultllc.com1; Terry Stewart
Subject: FCC016494 - ELG PDC Design Review Meeting
When: Wednesday, February 16, 2022 8:30 AM-9:00 AM (UTC-07:00) Mountain Time (US & Canada).
Where: Microsoft Teams Meeting
Powell PDC Building Update-
This meeting will be to review the design and the drawings that are ongoing as well as the schedule from Powell Regarding the PDC Building.
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Join with a video conferencing device
teams@vr.aps.com
Video Conference ID: 113 585 817 2
Alternate VTC instructions
Or call in (audio only)
+1 60?-607-1180..15433017?# United States, Phoenix
Phone Conference ID: 154 330 172#
Find a local number | Reset PIN
For best experience, use the Teams mobile app or computer audio instead of dial-in. Limit use of call-me feature to save company money.
I earn More | Meeting options
— NOTICE —
This message is for the designated recipient only and may contain confidential, privileged or proprietary information. If you have received
it in error, please notify the sender immediately and delete the original and any copy or printout. Unintended recipients are prohibited
from making any other use of this e-mail. Although we have taken reasonable precautions to ensure no viruses are present in this e-mail,
we accept no liability for any loss or damage arising from the use of this e-mail or attachments, or for any delay or errors or omissions in
the contents which result from e-mail transmission.
CONFIDENTIAL BUSINESS INFORMATION
-------
From: Von Ruff. Brandon
To: McGarv. Nicolas: Lemieux. Brendan
Cc: Schroeder. Timothy: brendan.Iemieux@mwconsultlIc.com: 129532
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
Date: Friday, July 1, 2022 4:48:48 AM
Attachments: imaaeOOI.pna
imaae006.nna
imaae007.Dna
imane008.nnn
,image009.png
imaaeOIO.pna
imaae011.nna
*** CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (brandon.vonruff@powellind.com). DO NOT click on links or open attachments unless you
trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center
at A CDC@aps. com.
Nick,
Yes I spoke to the Production and Quality teams and based on the SEL Relay dates we propose the following:
Customer Inspection -12/12 - 12/16,
Shipment - 1/16/23
Do you believe you can make these dates work with your schedules?
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902
Cell: (713) 584.5530
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: McGary, Nicolas [mailto:nmcgary@burnsmcd.com]
Sent: Thursday, June 30, 2022 4:09 PM
To: Von Ruff, Brandon ; Brendan.Lemieux@aps.com
Cc: Schroeder, Timothy ; brendan.lemieux@mwconsultllc.com; 129532 <129532@burnsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
IEXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTSI
Brandon,
On another topic, have you received an updated ship date for the PDC itself? We had noted that the relays were going to push things out. i just
wanted to follow up and see if that date had become more clear yet.
Thanks,
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
* Registered in CO
From: Von Ruff, Brandon
Sent: Thursday, June 30, 2022 10:13 AM
To: McGary, Nicolas burnsmcd.CQm>; Brendan.Lgmigux(5>aps.CQm
Cc: Schroeder, Timothy burnsmcd.CQm>; brendan.lgmiguxtamwcQnsultllc.CQm; 129532 <129532(ffburnsmcd.CQm>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
Please see the response from Joe:
CONFIDENTIAL BUSINESS INFORMATION
-------
Per my email yesterday, I am not sure we are going to have a good solution on the large panelboard. We can get the ELG-2 broken up into 3 smaller
panels in 6-8 weeks but I am not getting any responses back that are favorable leads on the "ELG-3 Distribution Panel". Lead times are in the 36-40
range on this panel. I am still waiting on a couple of responses back and will advise. What time is call tomorrow?
I'm not sure if a call will really help with the situation., but we are open to one. There is also still no reply on the ATS/MTS.
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902 Cell: (713) 584.5530
75 Years Of Innovation
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: McGary, Nicolas [mailto:nmcgarv@burnsmcd.coml
Sent: Thursday, June 30, 2022 9:25 AM
To: Brendan.Lemieux@aps.com: Von Ruff, Brandon
Cc: Schroeder, Timothy : brendan.lemieux@mwconsultllc.com: 129532 <129532@bumsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
IEXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTSI
All,
I have availability tomorrow for a meeting. Busy 9-10AM Mountain Time, but available the rest of the day. I would also like to discuss or get an
update on where we are at with ATS/MTS equipment from the various vendors.
Thanks,
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
*Registered in CO
From: Brendan.Lemieux@aps.com
Sent: Wednesday, June 29, 2022 10:55 AM
To: Brandon.VonRuff@powellind.com: McGary, Nicolas
Cc: Schroeder, Timothy : brendan.lemieux@mwconsultllc.com: 129532 <129532@bumsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
Nick and Brandon -
Are we available to have a meeting about this to shore up the pathway forward this week -
I would like to try and get this moving forward this week if this is possible.
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Von Ruff, Brandon
Sent: Wednesday, June 29, 2022 7:44 AM
To: McGary, Nicolas : Lemieux, Brendan
Cc: Schroeder, Timothy : brendan.lemieux@mwconsultllc.com: 129532 <129532@bumsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
CONFIDENTIAL BUSINESS INFORMATION
-------
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (hrandon.vonruff@powp.nind.com). DO NOT click on links or open attachments unless you trust the sender and know the
content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at ACDC(a).aps. com.
See the following:
Got a response backfrom an OEM. 25-36 Week lead times on Cutler Hammer 480V panels. Still waiting on a Siemens OEM to respond.
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902 Cell: (713) 584.5530
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: McGary, Nicolas [mailto:nmcgary@burnsmcd.coml
Sent: Wednesday, June 29, 2022 8:40 AM
To: Von Ruff, Brandon : Brendan.Lemieux@aps.com
Cc: Schroeder, Timothy : brendan.lemieux@mwconsultllc.com: 129532 <129532@burnsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
IEXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTSI
Hey Brandon,
Any updates from Joe on the lead times for those panels?
Thanks,
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
* Registered in CO
From: McGary, Nicolas
Sent: Monday, June 27, 2022 8:58 AM
To: Von Ruff, Brandon : Brendan.Lemieux@aps.com
Cc: Schroeder, Timothy : brendan.lemieux@mwconsultllc.com: 129532 <129532@burnsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
Brandon,
Could you have your vendors take a look at what we could do with using Manual Transfer Switches (MTS) with equivalent ratings to the ATS
equipment? What would that look like in terms of lead times? We are trying to look at all options to get equipment in sooner. We would still need
the ATS equipment, but we could consider using MTSs while waiting for the ATSs to arrive and be installed during a later outage.
Thanks,
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
* Registered in CO
m
1
75 Years Of Innovation
m
CONFIDENTIAL BUSINESS INFORMATION
-------
From: Von Ruff, Brandon
Sent: Thursday, June 23, 2022 1:12 PM
To: Brendan.Lemieux@aps.com: McGary, Nicolas
Cc: Schroeder, Timothy : brendan.lemieux@mwconsultllc.com: 129532 <129532@burnsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
Per our call today, please see the attached and following from Joe. Please review and advise:
See attached drawing and cut sheets. This is an example of building the switchboards in Panelboard config with Siemens. I chose 400A mains on the
3 smaller panels. Customer can tell me what main size they want. Siemens was at 40 weeks on the P5 on the drawing so this would have to come
from an OEM with stock which I am checking on. I have also included a ABB Reliagear datasheet for reference of another mfr.
I will let you know what I find in the market on swbds and these types of panels.
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902
Cell: (713) 584.5530
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: Von Ruff, Brandon
Sent: Tuesday, June 21, 2022 1:07 PM
To: Brendan.Lemieux@aps.com: nmcgary@burnsmcd.com
Cc: tschroeder@burnsmcd.com: brendan.lemieux@mwconsultllc.com: 129532@burnsmcd.com
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
Brendan,
That is what their lead time is right now. They wouldn't commit to improving it either. Simple panelboards from them are extremely long lead time
as well.
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902
Cell: (713) 584.5530
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: Brendan.Lemieux@aps.com [mailto:Brendan.Lemieux@aps.coml
Sent: Monday, June 20, 2022 3:43 PM
To: Von Ruff, Brandon : nmcgary@burnsmcd.com
Cc: tschroeder@burnsmcd.com: brendan.lemieux@mwconsultllc.com: 129532@burnsmcd.com
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
IEXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTSl
Brandon -
CONFIDENTIAL BUSINESS INFORMATION
-------
Are these hard dates that you have or are any of these or is this 41 weeks as it is - which puts us at the end of March which isn't where we want to
be.
thanks
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Von Ruff, Brandon pQWgllind.CQm>
Sent: Monday, June 20, 2022 1:56 PM
To: Lemieux, Brendan : nmcgary@burnsmcd.com
Cc: tschroeder@burnsmcd.com: brendan.lemieux@mwconsultllc.com: 129532@burnsmcd.com
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (hrandon.vonruff@powp.nind.com). DO NOT click on links or open attachments unless you trust the sender and know the
content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at ACDC(a).aps. com.
Brendan,
Still waiting on the quote for the ATS. Please see the following and attached for the Switchboards. Please confirm the drawings and summary below
match what you are needing. The lead time they are quoting right now is 205 working days or about 41 weeks.
u
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902 Cell: (713) 584.5530
CONFIDENTIAL BUSINESS INFORMATION
-------
75 Years Of Innovation
m
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: Brendan.Lemieux(5>aps.CQm [mailtQ;Brendan.Lemieux(5>aps.CQm]
Sent: Monday, June 20, 2022 9:45 AM
To: Von Ruff, Brandon pQwellind.CQm>; nmcgarytaburnsmcd.CQm
Cc: tschrQgdertaburnsmcd.cQm; brendan.lemieux^mwcQnsultllc.cQm; 129532(ffburnsmcd.CQm
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
IEXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTSI
10-4 thank you - looking forward to receiving the pricing.
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Von Ruff, Brandon
Sent: Monday, June 20, 2022 8:43 AM
To: Lemieux, Brendan aps,CQm>; nmcgarytaburnsmcd.cQm
Cc: tschrQedertaburnsmcd.CQm; brendan Jem ieux^mwconsu ltllc.com; 12g532(5>burnsmcd.CQm
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (brandon.vonruff@powellind.com). DO NOT click on links or open attachments unless you trust the sender and know the
content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at ACDC(a).aps. com.
I saw a quote on Friday, but it was incomplete it didn't have the ATS or a lead time for anything. I have asked them to update it to give me the lead
time and the ATS pricing/lead time.
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902
Cell: (713) 584.5530
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: Brendan.Lemieux@aps.com [mailto:Brendan.Lemieux@aps.coml
Sent: Monday, June 20, 2022 9:35 AM
To: Von Ruff, Brandon : nmcgary@burnsmcd.com
Cc: tschrQedertaburnsmcd.CQm; brendan.lemieuxtamwcQnsultllc.cQm; 12g532(5>burnsmcd.CQm
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
IEXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTSI
Brandon -
Where are you at with this quote?
thanks
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
CONFIDENTIAL BUSINESS INFORMATION
-------
From: Von Ruff, Brandon
Sent: Tuesday, June 14, 2022 12:11 PM
To: McGary, Nicolas burnsmcd.com>
Cc: Schroeder, Timothy : Lemieux, Brendan : hrendan.lemieiix@mwconsiiltllc.com:
129532 <1 79.537@hurnsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (hrandnn.vnnrnff@nnwellind.rnm). DO MOT click nn links nr npen attachments unless ynu trust the sender and knnw the
content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at ACDC(a).aps. com.
I talked to him this morning and he still did not have anything backfrom Siemens or Eaton. He pinged them again.
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902
Cell: (713) 584.5530
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: McGary, Nicolas [mailto:nmcgary@burnsmcd.coml
Sent: Tuesday, June 14, 2022 1:08 PM
To: Von Ruff, Brandon
Cc: Schroeder, Timothy ; Brgndan.Lgmiguxtaaps.cQm; brgndan.lgmigux(5>mwcc>nsu ltllc.com; 129532
<129532(5* burnsmcd.CQm>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
IEXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTS!
Good afternoon Brandon,
Have you had any luck with the ATS and switchboard vendors?
Thanks,
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
* Registered in CO
From: Von Ruff, Brandon
Sent: Tuesday, June 7, 2022 1:04 PM
To: McGary, Nicolas burnsmcd.cQm>
Cc: Schroeder, Timothy burnsmcd.CQm>; Brgndan.Lgmigux(5>aps,cQm; brgndan.lgmiguxtffmwcQnsultllc.com; 129532
<129532(5* burnsmcd.CQm>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
Still waiting on the vendors to come back with a quote. I asked for an update yesterday and haven't heard back. Will keep bugging them.
Thank you and best regards,
I
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902 Cell: (713) 584.5530
CONFIDENTIAL BUSINESS INFORMATION
-------
75 Years Of Innovation
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: McGary, Nicolas [mailto:nmcgarv@burnsmcd.coml
Sent: Monday, June 6, 2022 1:07 PM
To: Von Ruff, Brandon
Cc: Schroeder, Timothy : Brendan.Lemieux@ans.com: hrendan.lemieux@mwconsultllc.com: 129532
<129532 @ hurnsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
EXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTSl
Good morning Brandon,
Could you give us a status update on the switchboard and ATS quotes please?
Thanks, and have a great day!
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
*Registered in CO
From: McGary, Nicolas
Sent: Tuesday, May 17, 2022 7:36 AM
To: Von Ruff, Brandon
Cc: Schroeder, Timothy : Brendan.Lemieux@ans.com: hrendan.lemieux@mwconsultllc.com: 129532
<129532 @ hurnsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
Brandon,
Preference would be Eaton, but we are willing to look at other options depending on the lead times we get from Eaton.
Thanks,
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
*Registered in CO
From: Von Ruff, Brandon
Sent: Monday, May 16, 2022 3:02 PM
To: McGary, Nicolas
Cc: Schroeder, Timothy : Brendan.Lemieux@ans.com: hrendan.lemieux@mwconsultllc.com: 129532
<129.532@hurnsmcd.com>
Subject: RE: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
Nick,
Is there a certain switchboard manufacture we should be using or just the best lead-time?
CONFIDENTIAL BUSINESS INFORMATION
-------
Thank you and best regards,
Brandon Von Ruff, PMP
Senior Project Manager
Direct: (713) 948.4902
Cell: (713) 584.5530
The information contained in this message may be privileged, confidential and protected from disclosure. If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering this message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by replying to this message and deleting it from your computer.
From: McGary, Nicolas [mailto:nmcgary@burnsmcd.coml
Sent: Monday, May 16, 2022 3:08 PM
To: Von Ruff, Brandon
Cc: Schroeder, Timothy ; Brendan.Lemieuxtaaps.cQm; brendan Jem ieuxt® mwcQnsultllc.com: 129532
<129532(5* burnsmcd.CQm>
Subject: FCC016494 F45 ELG Modifications - Powell PO # 100616045 WO # 246247 - Additional Equipment for Quote
IEXTERNAL SENDER - BEWARE OF LINKS/ATTACHMENTS!
Good morning Brandon,
Per our meeting last week, please reach out to your vendors and provide quotes and lead times for the following equipment:
• One (1) 480V, 800A, 3-phase, 3 wire, 42kAIC rated switchboard
o See attached drawings 230689-2A, -2B for associated single lines
• One (1) 480V, 800A, 3-phase, 3 wire, 65kAIC rated switchboard
o See attached drawing 230689-3 for associated single line
• One (1) 480V, 600A, 3-phase, 3 wire, 42kAIC rated fused automatic transfer switch
o See attached drawing 230689-1 for associated single line
o Note that the MCC shown on this drawing is the MCC in the PDC (already provided by y'all)
• One (1) 480V, 600A, 3-phase, 3 wire, 65kAIC rated fused automatic transfer switch
o See attached drawing 230689-3 for associated single line
• One (1) 480V, 800A 3-phase, 3 wire, 42kAIC rated fused automatic transfer switch
o See attached drawings 230689-2A, -2B for associated single lines
Note the following items common for all equipment:
• Rated for outdoor installation - NEMA 3R minimum
o Please check on availability for NEMA 4/4X as well
Please let me know if you need any further information for these preliminary quotes.
Thank you!
Nick McGary, PE* \ Burns & McDonnell
Senior Electrical Engineer, Energy Division
O 720-826-9852 \ M 406-698-0214 \ F 303-721-0563
nmcaary@burnsmcd.com \ burnsmcd.com
9785 Maroon Circle \ Centennial, CO 80112
*Registered in CO
NOTICE —
This message is for the designated recipient only and may contain confidential, privileged or proprietary information. If you have received
it in error, please notify the sender immediately and delete the original and any copy or printout. Unintended recipients are prohibited
from making any other use of this e-mail. Although we have taken reasonable precautions to ensure no viruses are present in this e-mail,
we accept no liability for any loss or damage arising from the use of this e-mail or attachments, or for any delay or errors or omissions in
the contents which result from e-mail transmission.
CONFIDENTIAL BUSINESS INFORMATION
-------
Attachments:
Tonv Larkin
Lemieux. Brendan: Slupinski. Melinda
RE: Post Award Meeting
Wednesday, August 31, 2022 10:25:22 AM
imaaeOOI.pna
imaaeOQ2.pna
.ORDER-006-2833-007.xl«x
ORDER-005-1340-008.xlsx
* *;*CAUTION* * * * * *CAUTION** * * * *CAUTION* * *
This e-mail is from an EXTERNAL address (T.Larkin@okonite.com). DO NOT click on links or open attachments unless you trust the
sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at
A CDC@aps.com.
Brendan,
As of today, the order shows on schedule to ship per the confirmation dates attached. As we get closer to the finish date of the cable, I should be able to get you a more accurate
ETA.
Please let me know if there are any questions.
Tony Larkin
District Manager
(925) 719-0015 cell
From: Brendan.Lemieux@aps.com
Sent: Monday, August 29, 2022 2:27 PM
To: Tony Larkin ; Melinda.Slupinski@aps.com
Subject: RE: Post Award Meeting
Importance: High
I CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know
the content is safe.
Tony
Do you have an updated Date for the shipment of the Electrical Cable to the site?
Thanks
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Tony Larkin
Sent: Friday, April 22, 2022 10:59 AM
To: Slupinski, Melinda : Lemieux, Brendan
Subject: RE: Post Award Meeting
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (T.Larkin@okonite.com). DO NOT click on links or open attachments unless you trust the
sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at
ACDC(5)aps.com.
PO has been approved and released to plant, see signed copy attached. I will forward you our plant order acknowledgement when it's available.
Please let me know if there are any questions in the meantime.
Tony Larkin
District Manager
(925) 719-0015 cell
From: Melinda.Slupinski@aps.com
Sent: Friday, April 22, 2022 8:21AM
To: Brendan.Lemieux@aps.com: Tony Larkin
Subject: RE: Post Award Meeting
I CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know
the content is safe.
Hi,
See attached for revised Appendix A as well as the POCN indicated this updated document to this order.
Thank you,
CONFIDENTIAL BUSINESS INFORMATION
-------
MELINDA S LUPIN SKI
Procurement Specialist II
Ext 81-3396 Tel 602 250 3396 Cell 480 734 1903
Melinda.Slupinski@aps.CQm aps.com
From: Lemieux, Brendan
Sent: Friday, April 22, 2022 7:43 AM
To: Tony Larkin : Slupinski, Melinda
Subject: RE: Post Award Meeting
Tony-
Melinda is working on this for your company-once you get it please review for signature.
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Tony Larkin
Sent: Friday, April 22, 2022 8:22 AM
To: Lemieux, Brendan : Slupinski, Melinda
Subject: RE: Post Award Meeting
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (T.Larkin@okonite.com). DO NOT click on links or open attachments unless you trust the
sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at
ACDC(a)aps.com.
Brendan,
Just a follow up; have not received the revised Purchase Order yet. Once I get that, my HQ will be able to release the order for production.
Tony Larkin
District Manager
(925) 719-0015 cell
From: Brendan.Lemieux@aps.com
Sent: Wednesday, April 20, 2022 4:36 PM
To: Tony Larkin - Melinda.Sliipinski@aps.rom
Subject: RE: Post Award Meeting
I CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know
the content is safe.
10-4
We are working on this -
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Tony Larkin
Sent: Wednesday, April 20, 2022 2:19 PM
To: Lemieux, Brendan : Slupinski, Melinda
Subject: RE: Post Award Meeting
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (T.Larkin@okonite.com). DO NOT click on links or open attachments unless you trust the
sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at
ACDC(a)aps.com.
Price is locked, just need the PO revised.
Tony Larkin
District Manager
(925) 719-0015 cell
From: Brendan.Lemieux@aps.com
Sent: Wednesday, April 20, 2022 1:18 PM
To: Tony Larkin - Melinda.Sliipinski@aps.rom
Subject: RE: Post Award Meeting
CONFIDENTIAL BUSINESS INFORMATION
-------
CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know
the content is safe.
Tony-
We will see what we can do on our end however I need your team to lock in the price and order the cable -
Melinda will work with you on this and Melinda let me know if this is something you need my assistance with.
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Tony Larkin
Sent: Wednesday, April 20, 2022 2:00 PM
To: Lemieux, Brendan - Slupinski, Melinda
Subject: RE: Post Award Meeting
Importance: High
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (T.Larkin@okonite.com). DO NOT click on links or open attachments unless you trust the
sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at
ACDC (daps, com.
Brendan,
Attached is the revised firm quote along with our red-line exceptions to Master: Appendix A-Compensation portion of the PO. Okonitealso requests a slight modification to the
purchase agreement;
"We cannot accept "lot" pricing. Please have APS break out each item individually with the footage, unit cost, and total cost."
What my HQ would like to see would be something like this;
Item 1-63,000' l/c500 8kV $16,103/m $1,014,489
Item 2-21,000' 1/c 4/0 600v/1000V $5,008/m $105,168
Once we get the revised PO, we can get this entered and have plant confirm ship dates.
Please let me know if there are any questions.
Tony Larkin
District Manager
(925) 719-0015 cell
From: Brendan.Lemieux@aps.com
Sent: Tuesday, April 19, 2022 2:03 PM
To: Melinda.Slupinski@aps.com: Tony Larkin
Subject: RE: Post Award Meeting
I CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know
the content is safe.
Tony-
Please purchase the metals to firm up the pricing and send over any possible change this would have caused -
Let me know if this works or if you have anything further from.
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Slupinski, Melinda
Sent: Tuesday, April 19, 2022 2:35 PM
To: Lemieux, Brendan : Tony Larkin
Subject: RE: Post Award Meeting
Yes, this was sent to Tony on the 8th and is pending his signature:
CONFIDENTIAL BUSINESS INFORMATION
-------
Tony, I hit the "reminder" in our system so hopefully that generates another email for you to reference. Signatures are executed through DocuSign. Let me know if you stiii do not
receive it.
Thank you,
MELINDA S LUPIN SKI
Procurement Specialist II
Ext 81-3396 Tel 602 250 3396 Cell 480 734 1903
Melinda.Slupinski@aps.com aps.com
From: Lemieux, Brendan
Sent: Tuesday, April 19, 2022 1:22 PM
To: Tony Larkin : Slupinski, Melinda
Subject: RE: Post Award Meeting
Importance: High
Melinda -
Can you send the PO 100618300 to Tony as he has not seen this purchase order as of yet and I thought he was the one to be copied on it -
Thanks
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Tony Larkin
Sent: Tuesday, April 19, 2022 1:41 PM
To: Lemieux, Brendan
Subject: RE: Post Award Meeting
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (T.Larkin@okonite.com). DO NOT click on links or open attachments unless you trust the
sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at
ACDC(a)aps.com.
We still have not received a PO for this one; who was sending it over and what e-mail address did it go to?
Tony Larkin
District Manager
(925) 719-0015 cell
From: Brendan.Lemieux@aps.com
Sent: Tuesday, April 19, 2022 12:27 PM
To: Tony Larkin
Subject: RE: Post Award Meeting
I CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know
the content is safe.
Just want to verify the purchase order you received and we are full go forward -
Thanks
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
From: Tony Larkin
Sent: Tuesday, April 19, 2022 1:10 PM
To: Lemieux, Brendan
Subject: RE: Post Award Meeting
***CAUTION***
CONFIDENTIAL BUSINESS INFORMATION
-------
This e-mail is from an EXTERNAL address (T.Larkin@okonite.com). DO NOT click on links or open attachments unless you trust the
sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at
ACnC/Saps. com.
HI Brendan,
I am available tomorrow 8-llam or 2-3pm, and Thursday morning 8-ll:30am. Please let me know what would work best for you.
Anything I need to prepare for the discussion?
Tony Larkin
District Manager
(925) 719-0015 cell
From: Rrendan.l emieux@aps.com
Sent: Tuesday, April 19, 2022 8:59 AM
To: Tony Larkin
Subject: Post Award Meeting
I CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know
the content is safe.
Tony-
Can you send me over some times that will work for the post contract award -
Thanks for your help
Brendan Lemieux
Brendan.lemieux@aps.com
480-688-0252
— NOTICE —
This message is for the designated recipient only and may contain confidential, privileged or proprietary information. If you have received it in error, please notify the
sender immediately and delete the original and any copy or printout. Unintended recipients are prohibited from making any other use of this e-mail. Although we have
taken reasonable precautions to ensure no viruses are present in this e-mail, we accept no liability for any loss or damage arising from the use of this e-mail or
attachments, or for any delay or errors or omissions in the contents which result from e-mail transmission.
CONFIDENTIAL BUSINESS INFORMATION
-------
From:
To:
Cc:
Subject:
Date:
Attachments:
Sorsher, Monica
Schroeder. Timothy: Huff, Samuel: Notarnicola, Shellev: Lemieux, Brendan: Ramirez. Samantha: Siupinski. Meiinda
129532: Ramirez, Gil: McGarv, Nicolas: Diaz, Emmanuel G: Davis, Jonathan
RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document Submittal
Wednesday, August 24, 2022 11:18:32 AM
imaaeOOI.pna
imane007.nnn
imaae003.pna
imane004.nnn
***CAUTION***
***CAUTION***
***CAUTION***
This e-mail is from an EXTERNAL address (monica.sorsher@imi-critical.com). DO NOT click on links or open attachments unless you
trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center
at A CDC@aps. com.
Tim and Samuel,
We just received the below feed back from AUMA:
The proposed terminal connection is our standard cage clamp. They will need to open the terminal with a screw driver and insert the wire. The
terminal will tighten down onto the wire utilizing a spring. We can certainly supply ring tongue terminals. However¦ we are having supply chain issues
with these components now; therefore, delivery would be 52 weeks.
We can supply our screw type compression terminals. This would allow the customer to tighten a screw on each wire rather than rely on the spring
from the cage clamp. This will not include the requested ring tongue terminals however. Please let me know how you would like to proceed.
We have not placed the PO with AUMA yet as our understanding was that we could proceed with AUMA if the comment from Electrical/l&C is
acceptable, which was awaiting feedback from AUMA.
Please confirm we can proceed with the AUMA actuators based on the above response, with the details finalized during submittal review.
Best Regards,
Monica Sorsher (Reinwald)
Sr. Project Manager
IMI CCI
Tel: +1 949 835 8361
Mobile: +1 949 434 3723
Email: monica.sorsher@imi-critical.com
www.imi-critical.com
From: Schroeder, Timothy
Sent: Wednesday, August 24, 2022 4:07 AM
To: Sorsher, Monica ; Huff, Samuel ; Notarnicola, Shelley ; Brendan.lemieux@aps.com; Samantha.ramirez@aps.com; Melinda.slupinski@aps.com
Cc: 129532 <129532@burnsmcd.com>; Ramirez, Gil ; McGary, Nicolas ; Diaz, Emmanuel
G ; Davis, Jonathan
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
[External email]
Monica,
Can you confirm the order for the AUMA actuators has been placed? I think we can work out this detail during submittal review.
Timothy (Tim) Schroeder, PE \ Burns & McDonnell
Associate Mechanical Engineer
O 618-380-4915 \ M 314-602-6782 \ F 314-682-1600
tschroeder@burnsmcd.com\ burnsmcd.com
425 S. Woods Mill Road, Suite 300 \ Chesterfield, MO 63017
From: Sorsher, Monica
Sent: Tuesday, August 23, 2022 7:16 PM
iBj
CONFIDENTIAL BUSINESS INFORMATION
-------
To: Huff, Samuel : Notarnicola, Shelley : Brendan.lemieux@aps.com:
Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <129532@burnsmcd.com>: Schroeder, Timothy : Ramirez, Gil : McGary,
Nicolas : Diaz, Emmanuel G : Davis, Jonathan
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
Samuel,
Just an update that we are still waiting on a response from AUMA on this question. I have also asked about the possibility of a conference call as we
discussed if needed, but have not received any feedback yet.
Best Regards,
Monica Sorsher (Reinwald)
Sr. Project Manager
imicci
Tel: +1 949 835 8361
Mobile: +1 949 434 3723
Email: monica.sorsher@Jmi-critical.com
From: Huff, Samuel
Sent: Friday, August 19, 2022 11:54 AM
To: Sorsher, Monica : Notarnicola, Shelley : Brendan.lemieux@aps.com:
Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <129532@burnsmcd.com>: Schroeder, Timothy : Ramirez, Gil : McGary,
Nicolas : Diaz, Emmanuel G : Davis, Jonathan
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
11 xleinnl emnill
Monica,
Comment from Electrical/l&C is that they would want the ring/screw connectors for the wiring. The area where the valves will be located will have
some vibration and the bare wire/screw terminals would be subject to this and have a risk of coming loose.
If this is acceptable to AUMA, please proceed forward with the actuators. We will review submittals once they come in.
Thanks,
Samuel A Huff, PE* \ Bums & McDonnell
Associate Mechanical Engineer
M 314-599-1480 \ F 314-682-1600
425 South Woods Mill Rd, Suite 300 \ Chesterfield, MO 63017
*Registered in: MO, OH
From: Sorsher, Monica
Sent: Wednesday, August 17, 2022 10:23 AM
To: Huff, Samuel : Notarnicola, Shelley : Brendan.lemieux@aps.com:
Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <129532@bumsmcd.com>: Schroeder, Timothy : Ramirez, Gil : McGary,
CONFIDENTIAL BUSINESS INFORMATION
-------
Nicolas : Diaz, Emmanuel G : Davis, Jonathan
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
Samuel,
Please see AUMA's responses below.
Best Regards,
Monica Sorsher (Reinwald)
Sr. Project Manager
IMI CCI
Tel: +1 949 835 8361
Mobile: +1 949 434 3723
Email: monica.sorsher@imi-critical.com
www.imi-critical.com
ii
From: Huff, Samuel
Sent: Monday, August 8, 2022 7:14 AM
To: Sorsher, Monica : Notarnicola, Shelley : Brendan.iemieux@aps.com:
Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <129532@burnsmcd.com>: Schroeder, Timothy : Ramirez, Gil : McGary,
Nicolas ; Diaz, Emmanuel g bu rnsmcd.com>; Davis, Jonathan
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
[External email]
Monica,
Responses below.
• Is min temp acceptable? is this temp with internal heater on or off?
o The actuator heater is on continuously. The specified temperature is the external ambient temperature.
APS FOUR CORNERS design temp is -25degF to +105degF for outdoors. Actuator temps range is -22degF to +158degF, Accepted.
• VERIFY THAT MOTOR HEATER IS POWERED FROM CONTROL POWER TRANSFORMER
o The standard actuator heater is internally powered. The current motor heater is 120V, per spec requirement, and the
power will need to be supplied externally. We can modify the motor heater to 460V and have it internally powered. Please
advise if we are to make this revision.
Modify for 460V connection to heater.
Noted and modified to 460V.
• WHAT DOES THIS MEAN? WHAT IS AM/SEM/AC?
o This is the standard electrical connection/ plug & socket used to connect the actuator, SA, to local controls AC.
Acceptable.
• Verify that actuator is shipped with Bluetooth OFF, disabled.
o The current product is configured to ship with Bluetooth on. This is a programmable selection. We can modify the product
to ship with Bluetooth disabled if desired. Please advise desired option.
Please ship with Bluetooth off/Disabled.
Noted and modified to disabled Bluetooth.
• HOW ARE ELECTRICAL CONNECTIONS MADE? SOCKET, OR SCREW TERMINAL CONNECTION?
o The proposed product includes our standard plug and socket connections not screw terminals.
Confirm that field connections to DCS, as well as power connections for the 480V motor leads will not require a special plug or
socket connection. If so, this is acceptable.
No special tools are required to wire to the plug and socket, simply put the cable in and tighten the screw. Please see attached
picture for details.
• Officially submit all these drawings
o To receive an official submittal package we will need to formally proceed with order from AUMA.
Acceptable.
CONFIDENTIAL BUSINESS INFORMATION
-------
Thanks,
Samuel A Huff, PE* \ Burns & McDonnell
Associate Mechanical Engineer
M 314-599-1480 \ F 314-682-1600
shuff@burnsmcd.CQm \ burnsmccUom
425 South Woods Mill Rd, Suite 300 \ Chesterfield, MO 63017
* Registered in: MO, OH
From: Sorsher, Monica
Sent: Monday, August 1, 2022 1:08 PM
To: Huff, Samuel : Notarnicola, Shelley : Brendan.iemieux@aps.com:
Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <129532@burnsmcd.com>: Schroeder, Timothy : Ramirez, Gil : McGary,
Nicolas : Diaz, Emmanuel G : Davis, Jonathan
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
Samuel,
AUMA provided the following responses to the comments in the attached datasheet:
• Is min temp acceptable? is this temp with internal heater on or off?
o The actuator heater is on continuously. The specified temperature is the external ambient temperature.
• VERIFY THAT MOTOR HEATER IS POWERED FROM CONTROL POWER TRANSFORMER
o The standard actuator heater is internally powered. The current motor heater is 120V, per spec requirement, and the
power will need to be supplied externally. We can modify the motor heater to 460V and have it internally powered. Please
advise if we are to make this revision.
• WHAT DOES THIS MEAN? WHAT IS AM/SEM/AC?
o This is the standard electrical connection/ plug & socket used to connect the actuator, SA, to local controls AC.
• Verify that actuator is shipped with Bluetooth OFF, disabled.
o The current product is configured to ship with Bluetooth on. This is a programmable selection. We can modify the product
to ship with Bluetooth disabled if desired. Please advise desired option.
. HOW ARE ELECTRICAL CONNECTIONS MADE? SOCKET, OR SCREW TERMINAL CONNECTION?
o The proposed product includes our standard plug and socket connections not screw terminals.
• Officially submit all these drawings
o To receive an official submittal package we will need to formally proceed with order from AUMA.
Best Regards,
Monica Sorsher (Reinwald)
Sr. Project Manager
IMI CCI
Tel: +1 949 835 8361
Mobile: +1 949 434 3723
Email: monica.sorsherfg)imi-critical.com
www.imi-critical.com
il
From: Sorsher, Monica
Sent: Tuesday, July 26, 2022 3:46 PM
To: Huff, Samuel : Notarnicola, Shelley : Brendan.iemieux@aps.com:
Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <129532@burnsmcd.com>: Schroeder, Timothy : Ramirez, Gil : McGary,
Nicolas : Diaz, Emmanuel G : Davis, Jonathan
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
CONFIDENTIAL BUSINESS INFORMATION
-------
Samuel,
Received thank you. These questions are with AUMA and we will provide an update as soon as we receive a response.
Best Regards,
Monica Sorsher (Reinwald)
Sr. Project Manager
IMI CCI
Tel: +1 949 835 8361
Mobile: +1 949 434 3723
Email: monica.sorsherfg)imi-critical.com
www.imi-critical.com
m
From: Huff, Samuel
Sent: Monday, July 25, 2022 4:18 PM
To: Sorsher, Monica : Notarnicola, Shelley : Brendan.iemieux@aps.com:
Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <129532@burnsmcd.com>: Schroeder, Timothy : Ramirez, Gil : McGary,
Nicolas: Diaz, Emmanuel G
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
[External email]
Monica,
Attached are the comments to the AUMA actuators. Please let us know if there are any questions.
Thanks,
Samuel A Huff, PE* \ Burns & McDonnell
Associate Mechanical Engineer
M 314-599-1480 \ F 314-682-1600
shuff@burnsmcd.CQm \ burnsmcdcom
425 South Woods Mill Rd, Suite 300 \ Chesterfield, MO 63017
* Registered in: MO, OH
From: Sorsher, Monica cmonica.sorsher@imi-critical.com>
Sent: Monday, July 18, 2022 10:43 AM
To: Huff, Samuel : Notarnicola, Shelley : Brendan.iemieux@aps.com:
Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <129532@burnsmcd.com>: Schroeder, Timothy : Ramirez, Gil
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
Samuel,
See attached marked up revision to tag which actuator is intended for each valve.
Best Regards,
Monica Sorsher (Reinwald)
Sr. Project Manager
IMI CCI
Tel: +1 949 835 8361
Mobile: +1 949 434 3723
Email: monica.sorsher@imi-critical.com
www.imi-critical.com
CONFIDENTIAL BUSINESS INFORMATION
-------
From: Huff, Samuel
Sent: Friday, July 15, 2022 3:15 PM
To: Notarnicola, Shelley : Brendan.lemieux@ans.com: Samantha.ramirez@ans.com:
Melinda.sluninski@ans.com
Cc: 129532 <129532@hurnsmcd.com>: Schroeder, Timothy : Ramirez, Gil : Sorsher,
Monica
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
Please get these tagged for us, even if just a bluebeam title on the cover pages, on Monday. Our l&C and Electrical engineers are very overbooked
at the moment and I have a few hours of their time on Monday to look at these.
Thanks,
Samuel A Huff, PE* \ Burns & McDonnell
Associate Mechanical Engineer
M 314-599-1480 \ F 314-682-1600
425 South Woods Mill Rd, Suite 300 \ Chesterfield, MO 63017
*Registered in: MO, OH
From: Huff, Samuel
Sent: Thursday, July 14, 2022 8:32 AM
To: Notarnicola, Shelley : Brendan.lemieux@ans.com: Samantha.ramirez@ans.com:
Melinda.sluninski@ans.com
Cc: 129532 <129532@hurnsmcd.com>: Schroeder, Timothy : Ramirez, Gil : Sorsher,
Monica
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
Can you tag which actuator is intended for which valve? I don't see a nomenclature on there to say which goes with which.
Thanks,
Samuel A Huff, PE* \ Burns & McDonnell
Associate Mechanical Engineer
M 314-599-1480 \ F 314-682-1600
425 South Woods Mill Rd, Suite 300 \ Chesterfield, MO 63017
*Registered in: MO, OH
From: Notarnicola, Shelley
Sent: Wednesday, July 13, 2022 4:56 PM
To: Brendan Jem ieux@aps.com: Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <129532@bumsmcd.com>: Schroeder, Timothy : Huff, Samuel : Ramirez, Gil
: Sorsher, Monica
Subject: RE: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
Brendan, Samuel,
Attached are the Auma Datasheets per our discussion.
Can you please review and confirm that they are in line with what you need?
11 xleinnl emnill
Shelley/Monica,
Shelley,
CONFIDENTIAL BUSINESS INFORMATION
-------
Regards,
Shelley Notarnicola
Senior Upgrades Inside Sales Engineer
IMI CCI
Tel: +1 949 835 8176
Email: shelley.notarnicola@imi-critical.com
www.imi-critical.com
¦
¦
From: Vijayakumar, Dinesh
Sent: Wednesday, July 13, 2022 1:16 AM
To: Brendan.lemieux@aps.com: Samantha.ramirez@aps.com: Melinda.slupinski@aps.com
Cc: 129532 <12g532(5>burnsmcd.com>; Schroeder, Timothy burnsmcd.COm>; Huff, Samuel burnsmcd,CQm>; Ramirez, Gil
; Notarnicola, Shelley ; Sorsher, Monica ;
Ortega, Alexandria ; Madheswaran, Manoj ; Punnyiakotti,
Dhanasekar ; CCIAmericasDocPortal
Subject: (IMI_TRANSMIT_A79533US_04), ARIZONA PUBLIC SERVICE COMPANY - Four Corners, PO# 100618499, Level Control Valve - Document
Submittal
Doc-Control,
Please find the attached transmittal of the following documents for the subject project.
No.
IMI CCI Document Name
Customer Document No
Rev
1
A79533US-ITP
G-6
1
2
A79533US-STORAGE AND HANDLING
PROCEDURES
G-ll
1
Project Details
CUSTOMER
ARIZONA PUBLIC SERVICE COMPANY
PROJECT
Four Corners
PO NO
100618499
CCI REF#
A79533US
Transmittal Status - For Your Review and Approval
Request Your Approvals Before - 27-Jul-2022
Notes:
1. This transmittal is issued so that our customer gets an opportunity to verify that the valves sizes, connection types, materials of
fabrication, pressure classes, and actuators are all in accordance with their PO requirements.
2. Our approval/comments returns procedure is changed and henceforth request you to send the returns (both approvals and comments)
to "CCIAmericasDocPortal@ccivalve.com" instead of sending it to my email address.
Kindly add CCIAmericasDocPortal@ccivalve.com [Document Control] to your mailing list for return transmittals pertaining to
comments and approvals. This ID will dispatch a copy to all Documentation people in CCI who are engaged in this project.
Thank you.
Dinesh Kumar V
Lead - Document Controller
IMI CCI
Tel: +91 044 40155020
Mobile: +91 9840546496
Email: dinesh.vijayakumar@imi-critical.cQm
www.imi-critical.com
CONFIDENTIAL BUSINESS INFORMATION
-------
m
IMI Critical Engineering, Control Component India Pvt Ltd, KRM Plaza, First Floor, South Tower, No.2, Harrington Road.Chetpet, Chennai -600 031, India.
Registered number: U51909KA2006FTC040140
Registered office: Control Component India Pvt. Ltd., Ground, 1st & 2nd Floor, Tower 4, SJR i park, Plot# 13 14&15, EPIP Zone Phase 1, Whitefield Road, Bangalore 560066
The contents of this email and any attachments are confidential. If you are not the intended recipient, please delete it and notify us immediately by contacting servicedeskffiimi-
critical.com and/or the sender via return email. If not intended for you, you should not use, copy or disclose the contents to any other person.
CONFIDENTIAL BUSINESS INFORMATION
-------
From: Notarnicola, Shellev
To: Slupinski, Melinda
Cc: Lemieux, Brendan: Ramirez. Gil: Davis. Jonathan: Jared Harris: Sorsher. Monica: Blew. Mona: Lunine. Jessica
Subject: RE: APS PO 100618499 - IMI CCI Proposal 220127-014211-1 Bottom Ash Valves
Date: Tuesday, May 10, 2022 2:26:18 PM
Attachments: imaaeOOI.pna
imaneOO.I.nnn
imaae004.Dna
imaneOO.S.nnn
,imaae006.iDa
100618499 042522 APS Four Corners.pdf
IMI CCI Pronosal 770177-014711-1 Boiler Bottom Ash Valves Rev 3.ndf
*** CAUTION*** *** CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (shelley.notarnicola@imi-critical.com). DO NOT click on links or open attachments unless
you trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense
Center at ACDC@aps.com.
Hi Melinda,
A few slight edits on the wording below.
in view of the Ukraine-crisis (the "Crisis") and the SARS- CoV-2 pandemic (the "Pandemic"), Customer acknowledges that the Supplier may
adjust and change the delivery date or performance date of the service even after acceptance of the Contract due to circumstances in
connection with the Crisis or the Pandemic, including but not limited to governmental acts or decrees, quarantine restrictions, disruption of
procurement or transportation channels. In such case, Supplier shall not be liable for delay or any liquidated damages, provided however that
the Supplier shall use its best efforts to minimize any impact thereof in close mutual coordination with the Customer.
Amid unprecedented challenges with the cost and availability of raw materials, IMI CCI reserves the right to apply a material surcharge to any
items in this proposal in the event raw material costs increase 3% or higher based on the London Metal Exchange (LME) index from the date of
the last proposal to the purchase of raw materials. In the event a significant delay or price increase of raw material occurs during the
performance of the contract through no fault of IMI CCI, then (a) either Party-APS may terminate the Order, or (b) the Contract price, time of
completion or contract requirements may be equitably adjusted by a Change Order in accordance with the procedures of the Contract
documents.
Also, on the conference call today, Brendan Lemieux confirmed that APS will be handling shipping so the shipping costs need to be subtracted from
the PO. IMI CCI Ready-ln-Box date will be 1 March 2023, with every effort to improve.
The PO amount of $219,796 includes shipping costs estimated by IMI CCI. The amount without shipping costs is $178,814.
Regards,
Shelley Notarnicola
Senior Upgrades Inside Sales Engineer
IMI CCI
Tel: +1 949 835 8176
Email: shellev.notarnicola@imi-critical.com
www.imi-critical.com
m
Hi
From: Melinda.Slupinski@aps.com
Sent: Friday, May 6, 2022 1:49 PM
To: Notarnicola, Shelley
Cc: Brendan.Lemieux@aps.com; Ramirez, Gil ; Davis, Jonathan ; Jared Harris
Subject: RE: APS PO 100618499 - IMI CCI Proposal 220127-014211-1 Bottom Ash Valves
[External email]
Hi Shelley,
Our Legal reviewed your proposed language and we can accept with the following revisions. Please confirm if you are in agreement and then I can
CONFIDENTIAL BUSINESS INFORMATION
-------
add it as a clause to the Purchase Order:
in view of the Ukraine-crisis (the "Crisis") and the SARS- CoV-2 pandemic (the "Pandemic"), Customer acknowledges that the Supplier may
adjust and change the delivery date or performance date of the service even after acceptance of the Contract due to circumstances in
connection with the Crisis or the Pandemic, including but not limited to governmental acts or decrees, quarantine restrictions, disruption of
procurement or transportation channels. In such case, Supplier shall not be liable for delay or any liquidated damages, provided however that
the Supplier shall use its best efforts to minimize any impact thereof in close mutual coordination with the Customer.
Amid unprecedented challenges with the cost and availability of raw materials, IMI CCI reserves the right to apply a material surcharge to any
items in this proposal in the event raw material costs increase 3% or higher based on the London Metal Exchange (LME) index. In the event a
significant delay or price increase of raw material occurs during the performance of the contract through no fault of IMI CCI, APS may
terminate the Order or the Contract price, time of completion or contract requirements shall may be equitably adjusted by a Change Order in
accordance with the procedures of the Contract documents.
Thank you,
¦
MELINDA SLUPINSKI
Procurement Specialist II
Ext 81-3396 Tel 602 250 3396 Cell 480 734 1903
Melirida.Slupiriski@aps.com aps.com
From: Notarnicola, Shelley
Sent: Friday, April 29, 2022 9:29 AM
To: Slupinski, Melinda
Cc: Lemieux, Brendan : Ramirez, Gil : Davis, Jonathan : J a red Harris
Subject: RE: APS PO 100618499 - IMI CCI Proposal 220127-014211-1 Bottom Ash Valves
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (shelley.notarnicola@imi-critical.com). DO NOT click on links or open attachments unless you
trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center
at ACDC(a) aps.com.
Melinda,
Thank you for the attached Purchase Order! Please confirm that per the PO we will be processing the order per FCA IMI CCI Factory South Korea
incoterms with a ready-in-box date of March 1, 2023 (44 weeks from PO date). A member of our Project Management team will be formally
acknowledging the PO shortly.
Due to market instability at this time, we request to add the following clauses to the purchase order that were part of our proposal:
In view of the Ukraine-crisis (the "Crisis") and the SARS- CoV-2 pandemic (the "Pandemic"), Customer acknowledges that the Supplier may
adjust and change the delivery date or performance date of the service even after acceptance of the Contract due to circumstances in
connection with the Crisis or the Pandemic, including but not limited to governmental acts or decrees, quarantine restrictions, disruption of
procurement or transportation channels. In such case, Supplier shall not be liable for delay or any liquidated damages, provided however that
the Supplier shall use its best efforts to minimize any impact thereof in close mutual coordination with the Customer.
Amid unprecedented challenges with the cost and availability of raw materials, IMI CCI reserves the right to apply a material surcharge to any
items in this proposal in the event raw material costs increase 3% or higher based on the London Metal Exchange (LME) index. In the event a
significant delay or price increase of raw material occurs during the performance of the contract through no fault of IMI CCI, the Contract price,
time of completion or contract requirements shall be equitably adjusted by a Change Order in accordance with the procedures of the Contract
documents.
Please note that Appendix C has a date that is in the past. We assume that this is an on-site date. IMI CCI will follow the purchase order.
m
Also, the email addresses for IMI CCI sales personnel are incorrect.
Please use Gil.Ramirez@imi-critical.com ph 949-285-6762 and shelley.notarnicola@imi-critical.com ph 949-835-8176
Please confirm that APS will be handling transit from our factory in South Korea to the Four Corners site. The PO includes shipping instructions, but
the PO amount of $219,796 includes shipping costs. The amount without shipping costs is $178,814.
CONFIDENTIAL BUSINESS INFORMATION
-------
Regards,
Shelley Notarnicola
Senior Upgrades Inside Sales Engineer
iiVUCCi
Tel: +1 949 835 8176
Email
www.imi-critical.com
From: Nayak, Sandeep
Sent: Wednesday, April 27, 2022 10:19 AM
To: Ramirez, Gil : Notarnicola, Shelley
Cc: Davis, Jonathan : Kathavi, Priyavrath
Subject: Fwd: APS PO 100618499
Gil, Shelley,
Looks like this is the PO for Four Corners Ashdown valve for around $200K. You may see this from Jared as well.
Congratulations and good work!
Sandeep Nayak
Sales Manager- Aftermarket Sales & Service|Western USA
I MI CCI
Mobile: t-1 949 212 8325
Email: saiifleen.navak(&
From: Jared Harris
Sent: Wednesday, April 27, 2022 10:14:57 AM
To: Nayak, Sandeep
Subject: FW: APS PO 100618499
11 xlernal email |
FYI
Kind Regards,
Jared fkms
New Mexico Territory Manager
6411 Castle Rock Ct
Farmington, NM 87402
Main Cell: 505-220-3830
Alternate: 505-258-2025
Office : 888-715-6203
Email: jared@instandcontrols.com
Linkedln Profile: https://www.nnkedin.com/jaredmharris/
CONFIDENTIAL BUSINESS INFORMATION
-------
[Hi
• Instrumentation Measurement & Control
• Filtration
• Valves. Actuators. Piping. Fittings. Fans & Material Handling
• Communications
• Services
From: Melinda.Sluninskifilans.com
Sent: Wednesday, April 27, 2022 11:04 AM
To: Jared Harris instandcontrols.com>
Cc: Rrendan.l emieuxfilaps.com
Subject: FW: APS PO 100618499
HiJared,
Please see attached for PO 100618499. My apologies for not including you on the original email.
Thank you,
MELINDA SLUPINSKI
Procurement Specialist II
Ext 81-3396 Tel 602 250 3396 Cell 480 734 1903
Melinda.Sluninskiiaans.com aps.com
From: Slupinski, Melinda
Sent: Monday, April 25, 2022 4:06 PM
To: shellv.notarnicolafilimi-critical.com: gil.ramire7filimi.critical.com
Cc: Lemieux, Brendan
Subject: APS PO 100618499
Hello,
Please confirm receipt of attached PO # 100618499. Please sign under the supplier block section located on the last page & return to me.
Please email the invoice(s) to: Pavahlesfiians.com to expedite processing and avoid delays by the USPS. When submitting invoices, please be sure
to include PO # 100618499 and supporting documents as necessary.
Thank you II
MELINDA SLUPINSKI
Procurement Specialist II
480 734 1903
Melinda.Sluninskiiaans.com aps.com
— NOTICE —
This message is for the designated recipient only and may contain confidential, privileged or proprietary information. If you have received
it in error, please notify the sender immediately and delete the original and any copy or printout. Unintended recipients are prohibited
from making any other use of this e-mail. Although we have taken reasonable precautions to ensure no viruses are present in this e-mail,
we accept no liability for any loss or damage arising from the use of this e-mail or attachments, or for any delay or errors or omissions in
the contents which result from e-mail transmission.
The contents of this email and any attachments are confidential. If you are not the intended recipient, please delete it and notify us immediately by contacting servicedesk(g)imi-
critical.com and/or the sender via return email. If not intended for you, you should not use, copy or disclose the contents to any other person.
CONFIDENTIAL BUSINESS INFORMATION
-------
From: Preston Pierce
To: Brown. Mason A
Cc: 129532: TSchroeder@burnsmcd.com: Lemieux. Brendan: Projects
Subject: APS Four Corners - VTP Motors
Date: Wednesday, July 20, 2022 1:27:11 PM
Attachments: imaaeOOI.pna
imane007.nnn
imaae003.Dna
imane004.nnn
,image005.png
imaae006.pna
Pi jmn-1 nstal I ati on 4ef?06d h- 7 e7 R-463 R- aRfc- 69d Rh944hhR6. nnn
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (ppierce@phoenixpumps.com). DO NOT click on links or open attachments unless you trust
the sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at
A CDC@aps. com.
Good afternoon Mason, current ship date for these motors is 9/27. Thank you,
Preston Pierce
Projects
Phoenix Pumps, Inc.
www.phoenixpumps.com
E: ppierce@phoenixpumps.com | D: 602-491-0959 | O: 602-232-2994
» Customer Satisfaction Survey
¦
From: Brown, Mason A
Sent: Friday, July 15, 2022 6:14 AM
To: Preston Pierce
Cc: 129532 <129532@burnsmcd.com>
Subject: VTP Motors
Preston,
Can we get an update from Nidec on the motors for the VTPs? When will they be ready/shipped?
Thanks,
Mason Brown, PE \ Burns & McDonnell
Staff Mechanical Engineer \ Energy Group
0 314-501 -1452 \ M 901 -827-8873 \ F 314-682-1600
mabrown@burnsmcd.com \ burnsmcd.com
425 S. Wood Mills Rd, Ste 300 \ Chesterfield, MO 63017
~~ ~ ~ ~ i i
Proud to be one of FORTUNES 100 Best Companies to Work For
*Registered in: MO
CONFIDENTIAL BUSINESS INFORMATION
-------
From: Fred Panczer
To: Lemieux. Brendan
Cc: Tommy. borobi a @ mwconsul tl I c. com
Subject: RE: ELG - Graybar MCC Delivery
Date: Monday, September 26, 2022 10:01:30 AM
Attachments: 09262022 ELG PLANT MODS STATUS.xIsx
*** CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (prvs=52684flaf0=fredrick.panczer@graybar.com). DO NOT click on links or open
attachments unless you trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the
APS Cyber Defense Center at ACDC@aps.com.
Brendan,
Here is the latest shop schedule. It has both orders listed on status. Square D is telling me that they are not expediting any orders currently, i am
going to get someone from Square D on our next call.
Thank you
From: Brendan.Lemieux@aps.com
Sent: Thursday, September 22, 2022 2:40 PM
To: Fred Panczer
Cc: Tommy.borobia@mwconsultllc.com
Subject: RE: ELG - Graybar MCC Delivery
Fred-
I wanted to make sure that I copied Tommy for our records -
Thanks for your help
Brendan Lemieux
Brendan .lemieuxtagps,com
480-688-0252
From: Lemieux, Brendan
Sent: Thursday, September 22, 2022 8:06 AM
To: 'Fred Panczer1
Subject: RE: ELG - Graybar MCC Delivery
Fed -
Is there anything that we can do on our side of the table to get the MCC moved up in the line - also do you have a date of what the second set of
MCC's look like now that we have two of them -
thanks
Brendan Lemieux
Brendan .lemieuxtagps,com
480-688-0252
From: Fred Panczer
Sent: Thursday, September 22, 2022 5:37 AM
To: McGary, Nicolas : Lemieux, Brendan : Bushman, Daniel :
Yazzie, Rachael G : Schroeder, Timothy : Brendan.Lemieux
: Tommy.borobia@mwconsultllc.com: Heidi Crowe 11
Cc: Angela Salinas
Subject: RE: ELG - Graybar MCC Delivery
***CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (prvs=5264e57e8a=fredrick.panczer@gravbar. com). DO NOT click on links or open
attachments unless you trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the
APS Cyber Defense Center at AC DC (a) aps.com.
Team,
The attached is the response I received from Square D on trying to expedite the MCC's. I will try to get Square D to join our next conference call.
Thank you
CONFIDENTIAL BUSINESS INFORMATION
-------
From: McGary, Nicolas
Sent: Thursday, September 15, 2022 11:13 AM
To: Brendan.Lemieux@aps.com: Daniel.Bushman@aps.com: Rachael.Yazzie@aps.com: Schroeder, Timothy :
Brendan.Lemieux@mwconsultllc.com: Tommy.borobia@mwconsultllc.com: Heidi Crowell : Fred Panczer
Subject: RE: ELG - Graybar MCC Delivery
All,
Please see the attached minutes from our meeting. Let me know if you have any questions or comments. Thanks.
Have a great day!
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
* Registered in CO
Original Appointment
From: Brendan.Lemieux@aps.com
Sent: Tuesday, September 13, 2022 10:55 AM
To: Brendan.Lemieux@aps.com: Daniel.Bushman@aps.com: Rachael.Yazzie@aps.com: Schroeder, Timothy; McGary, Nicolas;
Brendan.Lemieux@mwconsultllc.com: Tommy.borobia@mwconsultllc.com: heidi.crowell@graybar.com: Fredrick.Panczer@graybar.com
Subject: ELG - Graybar MCC Delivery
When: Thursday, September 15, 2022 11:00 AM-11:30 AM (UTC-07:00) Mountain Time (US & Canada).
Where: Microsoft Teams Meeting
Meeting with Graybar for reviewing the MCC schedule for delivery-
As well as the spare MCC-
thanks
Microsoft Teams meeting
Join on your computer, mobile app or room device
Click here to join the meeting
Meeting ID: 282 404 987 50
Passcode: mFGBKT
Download Teams | loin on the web
Join with a video conferencing device
teamsfcuvc aps com
Video Conference ID: 115 008 720 4
Alternate VTC instructions
Or call in (audio only)
+ 1 hrp-6n7-11«n..sqi775q4h# United States, Phoenix
Phone Conference ID: 591 775 946#
Find a local number | Reset PIN
For best experience, use the Teams mobile app or computer audio instead of dial-in. Limit use of call-me feature to save company money.
earn More | Meeting options
— NOTICE —
This message is for the designated recipient only and may contain confidential, privileged or proprietary information. If you have received
it in error, please notify the sender immediately and delete the original and any copy or printout. Unintended recipients are prohibited
from making any other use of this e-mail. Although we have taken reasonable precautions to ensure no viruses are present in this e-mail,
CONFIDENTIAL BUSINESS INFORMATION
-------
we accept no liability for any loss or damage arising from the use of this e-mail or attachments, or for any delay or errors or omissions in
the contents which result from e-mail transmission.
CONFIDENTIAL BUSINESS INFORMATION
-------
From:
To:
Cc:
Subject:
Date:
Attachments:
Fred Panczer
McGarv, Nicolas: Lemieux, Brendan: Schroeder. Timothy: Tommv.borobia@mwconsultlIc.com: Brendan.Lemieux
179537
RE: MCC - ATS - Graybar
Wednesday, August 17, 2022 12:12:55 PM
APS ELG PLANT MODS Q-3529247-PD-001 Full Submittal Package .pdf
***CAUTION***
***CAUTION***
***CAUTION***
This e-mail is from an EXTERNAL address (prvs=4228f37df8=fredrick.panczer@graybar.com). DO.NOT click on links or open
attachments unless you trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the
APS Cyber Defense Center at ACDC@aps.com.
All,
Please review the attached submittals for the MCC's without the power meters. The lead time for these units without the meters is 16 weeks. The
power meters were pushing the lead times out to the 34 weeks. We can quote them separately and have Square D field services install them on site
later, i am waiting on the ASCO submittals. I will forward them as soon as I receive them.
Thank you
From: McGary, Nicolas
Sent: Wednesday, August 17, 2022 12:51 PM
To: Brendan.Lemieux@aps.com; Schroeder, Timothy ; Tommy.borobia@mwconsultllc.com;
Brendan.Lemieux@mwconsultllc.com; Fred Panczer
Cc: 129532 <129532@burnsmcd.com>
Subject: RE: MCC - ATS - Graybar
Please see the attached minutes document from this morning's Kickoff Meeting. Let me know if you have any questions or comments. Thanks.
Have a great day!
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
* Registered in CO
Original Appointment
From: Brendan.Lemieux@aps.com
Sent: Monday, August 15, 2022 10:46 AM
To: Brendan.Lemieux@aps.com: McGary, Nicolas; Schroeder, Timothy; Tommy.borobia@mwconsultllc.com: Brendan.Lemieux@mwconsultllc.com:
Fredrick.Panczer@graybar.com
Subject: MCC - ATS - Graybar
When: Wednesday, August 17, 2022 10:30 AM-11:00 AM (UTC-07:00) Mountain Time (US & Canada).
Where: Microsoft Teams Meeting
Wanted to schedule a all with you over the two purchase orders you received from APS -
MCC and ATS-
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Meeting ID: 264 100 524 758
Passcode: hLZLwy
Download Teams | loin on the web
Join with a video conferencing device
teamsfcuvc aps com
Video Conference ID: 116 189 421 4
Alternate VTC instructions
All,
Fred-
CONFIDENTIAL BUSINESS INFORMATION
-------
Or call in (audio only)
United States, Phoenix
Fh fie _ nfeten e ID 627 222 933#
. _. j mobile app or computer audio instead of dial-in. Limit use of call-me feature to save company money.
— NOTICE —
This message is for the designated recipient only and may contain confidential, privileged or proprietary information. If you have received
it in error, please notify the sender immediately and delete the original and any copy or printout. Unintended recipients are prohibited
from making any other use of this e-mail. Although we have taken reasonable precautions to ensure no viruses are present in this e-mail,
we accept no liability for any loss or damage arising from the use of this e-mail or attachments, or for any delay or errors or omissions in
the contents which result from e-mail transmission.
CONFIDENTIAL BUSINESS INFORMATION
-------
From: Fred Panczer
To: McGarv, Nicolas: Lemieux. Brendan: Schroeder. Timothy: Tommv.borobia@mwconsultlIc.com: Brendan.Lemieux
Cc: 129532: Angela Salinas
Subject: RE: MCC - ATS - Graybar
Date: Wednesday, August 24, 2022 5:04:58 AM
Attachments: APS BACK-UP MCC'S.pdf
*** CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (prvs=4235368beb=fredrick.panczer@graybar.com). DO NOT click on links or open
attachments unless you trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the
APS Cyber Defense Center at ACDC@aps.com.
Nick,
Here is the quote of for the second set of MCC's. The lead time is now 27 weeks.
Thank you
From: McGary, Nicolas
Sent: Tuesday, August 23, 2022 3:18 PM
To: Fred Panczer ; Brendan.Lemieux@aps.com; Schroeder, Timothy ;
Tommy.borobia@mwconsultllc.com; Brendan.Lemieux@mwconsultllc.com
Cc: 129532 <129532@burnsmcd.com>; Angela Salinas
Subject: RE: MCC - ATS - Graybar
Fred,
Can you provide a quote and timeline for a second set of MCCs, please? We are considering purchasing a redundant set. MCCs would be identical
to the ones we just approved.
Please let us know if you have any questions.
Thanks, and have a great day!
Nick McGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
* Registered in CO
From: Fred Panczer
Sent: Monday, August 22, 2022 10:34 AM
To: McGary, Nicolas : Brendan.Lemieux@aps.com: Schroeder, Timothy :
Tommy.borobia@mwconsultllc.com: Brendan.Lemieux@mwconsultllc.com
Cc: 129532 <129532@burnsmcd.com>: Angela Salinas
Subject: RE: MCC - ATS - Graybar
All,
Please see the revised submittals for the MCC's.
Thank you
From: McGary, Nicolas
Sent: Monday, August 22, 2022 8:18 AM
To: Fred Panczer : Brendan.Lemieux@aps.com: Schroeder, Timothy :
Tommy.borobia@mwconsultllc.com: Brendan.Lemieux@mwconsultllc.com
Cc: 129532 <129532@burnsmcd.com>: Angela Salinas
Subject: RE: MCC - ATS - Graybar
Fred,
Please see the attached. The ATS submittal is approved. Per the meeting last week, please confirm the expected delivery date for the ATS
equipment.
Please resubmit the MCC package with the changes noted (and discussed this morning).
Let me know if you have any further questions. Thanks again. Have a great day!
CONFIDENTIAL BUSINESS INFORMATION
-------
NickMcGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
* Registered in CO
From: Fred Panczer graybar.CQm>
Sent: Thursday, August 18, 2022 7:35 AM
To: McGary, Nicolas burnsmcd .CQm>; Brendan.Lemieuxts aps.com; Schroeder, Timothy ;
Tommy.borobia@mwconsultllc.com: Brendan.Lemieux@mwconsultllc.com
Cc: 129532 <129532@burnsmcd.com>: Angela Salinas
Subject: RE: MCC - ATS - Graybar
Team,
Please see the attached ASCO submittals.
Thank you
From: Fred Panczer
Sent: Wednesday, August 17, 2022 1:06 PM
To: McGary, Nicolas burnsmcd .CQm>; Brendan.Lemieuxt^aps.com; Schroeder, Timothy ;
TQmmy.bQrQbia(5>mwcQnsultllc.cQm; Brendan.Lemieux(5>mwcQnsultllc.cQm
Cc: 129532 <129532(5* burnsmcd .CQm>
Subject: RE: MCC - ATS - Graybar
All,
Please review the attached submittals for the MCC's without the power meters. The lead time for these units without the meters is 16 weeks. The
power meters were pushing the lead times out to the 34 weeks. We can quote them separately and have Square D field services install them on site
later, i am waiting on the ASCO submittals. I will forward them as soon as I receive them.
Thank you
From: McGary, Nicolas
Sent: Wednesday, August 17, 2022 12:51 PM
To: Brendan.Lemieuxt^aps.cQm; Schroeder, Timothy ; TQmmy.bQrQbia(5>mwcQnsultllc.cQm;
Brendan.Lemieux^mwcQnsultllc.cQm; Fred Panczer graybar.cQm>
Cc: 129532 <129532(5* burnsmcd .CQm>
Subject: RE: MCC - ATS - Graybar
All,
Please see the attached minutes document from this morning's Kickoff Meeting. Let me know if you have any questions or comments. Thanks.
Have a great day!
NickMcGary, PE*
Burns & McDonnell, Denver, Energy Division
Denver Office 720-826-9852
Cell 406-698-0214
* Registered in CO
Original Appointment
From: Brendan.Lemieuxtaaps.cQm a ps.com>
Sent: Monday, August 15, 2022 10:46 AM
To: Brendan.Lemieuxtaaps.com; McGary, Nicolas; Schroeder, Timothy; Tommy.borQbiata mwconsultllc.com; Brendan.Lemieux(5> mwconsultllc.com;
Fredrick.Panczertagraybar.com
Subject: MCC - ATS - Graybar
When: Wednesday, August 17, 2022 10:30 AM-11:00 AM (UTC-07:00) Mountain Time (US & Canada).
Where: Microsoft Teams Meeting
Fred-
Wanted to schedule a all with you over the two purchase orders you received from APS -
MCC and ATS-
CONFIDENTIAL BUSINESS INFORMATION
-------
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Meeting ID: 264 100 524 758
F 1 Je hLZLwy
Join with a video conferencing device
:t£ama(
-------
From: John B. Rodin
To: Lemieux, Brendan: James Clauss: Carl Litzler: Diaz. Emmanuel G
Cc: lawrence.hunt@mwconsultllc.com: Kevin S. Mcmanicile: tschroeder@burnsmcd.com: Stewart. Terrv: Patrick Morgan: Wiltbank. Devlin: John Papini: Tommy Borobia
Subject: U324: APS 4C F45 ELG Modifications Project Review Meeting Minutes 081122 (DOC1009129)
Date: Thursday, August 11, 2022 12:23:32 PM
Attachments: imaaeOOI.pna
11374 Project Review Meeting Minutes 0R1177.docx
*** CAUTION*** ***CAUTION*** ***CAUTION***
This e-mail is from an EXTERNAL address (john.b.rodin@us.abb.com). DO NOT click on links or open attachments unless you trust
the sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at
ACDC@aps.com.
All,
Please see attached meeting minutes from today, actions in red and updates highlighted in yellow.
Best Regards,
John
m
John B. Rodin
Senior Project Manager, Energy Industries
ABB Inc.
23000 Harvard Road
Cleveland, Ohio 44122 USA
Phone: +1 440 585 5394
Mobile: +1 440 336 5746
abb.com
Original Appointment
From: John B. Rodin
Sent: Wednesday, June 22, 2022 4:30 PM
To: John B. Rodin; Brendan.Lemieux@aps.com; James Clauss; Carl Litzler; Diaz, Emmanuel G
Cc: lawrence.hunt@mwconsultllc.com; Kevin S. Mcmanigle; tschroeder@burnsmcd.com; terry.stewart@aps.com; Patrick Morgan;
Devlin.Wiitbank@aps.com; John Papini; Tommy Borobia
Subject: U324: APS 4C F45 ELG Modifications Project Review Meeting (DOC1009129)
When: Thursday, August 11, 2022 2:00 PM-2:30 PM (UTC-05:00) Eastern Time (US & Canada).
Where: Microsoft Teams Meeting
All,
Please advise if you are available for this reoccurring meeting for subject project, please forward as needed, if we need to adjust the schedule just
let me know.
Topics to include:
1. Project Status Review
2. Action items review
3. Schedule Review
4. Any issues or concerns
Feel free to contact me outside of this meeting as needed.
Best Regards,
John
il
John B. Rodin
Senior Project Manager, Energy Industries
ABB Inc.
23000 Harvard Road
Cleveland, Ohio 44122 USA
Phone: +1 440 585 5394
Mobile: +1 440 336 5746
abb.com
CONFIDENTIAL BUSINESS INFORMATION
-------
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Join with a video conferencing device
teams@video.abb.rom
Vi Je . rifeieri e ID 128 900 308 0
Or call in (audio only)
ted States, Columbus
Fh ne ^ rifeieri e ID 27S 809 31#
CONFIDENTIAL BUSINESS INFORMATION
-------
ATTACHMENT B
DRAFT INITIAL CERTIFICATION
-------
BURNS | MCDONNELL
Initial Certification Statement
Supporting the Discharge of
Bottom Ash Transport Water
} aps
Arizona Public Service Company
Four Corners Generating Station
NPDES Permit No. NN0000019
Project No. 129532 / FCC016494
Revision 0
May 2022
-------
Initial Certification Statement
Supporting the Discharge of
Bottom Ash Transport Water
Prepared for
Arizona Public Service Company
Four Corners Generating Station
NPDES Permit No. NN0000019
Project No. 129532 / FCC016494
Fruitland, NM
Revision 0
May 2022
Prepared by
Burns & McDonnell Engineering Company, Inc.
Kansas City, Missouri
-------
I
INDEX AND CERTIFICATION
Arizona Public Service Company
Initial Certification Statement
Supporting the Discharge of
Bottom Ash Transport Water
Report Index
lllkifici
\m n h l I l j.l ;1JJ U j fill.'
I ii Inir.tn'ijrn.>u -
?,u I !;tL'h ^:k* Sv-.icHi ! ipsv;.
\pp.:i'ij'\ V, ,:ici Kii.mC;;'
AppCM'.liv: B Sionii'.v ,v>C' i 'it. ulai ,i in %
'XppeuiMvi S,in^ril'iu \iMlvru'-i!
\p|'i'.iuh \ D L'hc;:n,-it \ ( jkuUSMU;.
\ppi.-'ni?r < «eni'v! \tr,n!,2i, iru'Cl
Certification
! 1 e:i '•(''» • iji i n <, . i, Pi i-se »*,f¦>;.,i5 ( • .'i-xi in in.. V.ii>1 Nc* |l i iN \ l,.e !nr.-i nuiii.vi 11. 'I-,,
Ji M i,!hi T 'A';! , is'.Mi'iljl.-i' ;n»i-;t . f. .j ¦ [\*t v i Kp'Vv. 'f.Uio'H
It. l\ii 'H,< F'uMi. !t,\: ! ur>:i,t>iv ¦ .>,i¦ ci - *«;n.> '•pn.• in. \c. <''L. i i>n t>t
>>,, ,1 ^'1 I" Hi.; 5 i!" ._" 1 ! c I l[h. , l! Vm!' '|t ^ r • r. ^-Ii It" !'!i' V V-iv,
Puh1.. . I ,i|,i i i r-.'i,, \ i "u„'i r i r. .j s,,iUt .i' fi i. .i-1 c .i>-.iji'iij 'U-iL-t". "c; i..i
ni 'ci:,,'1. imi P.. ,<.J uTi i"n;, hii.i. !c, iiv it' m ,<"ii .i . iik! he tJ ..f't1 n rt -
I itsli Sti'H U.Nl
Digitally signed by
Hansen, Bryan
11:32:10-05'00'
Bryan D. Hansen, P.fc.
(New Mexico License No. 23480)
May i 6 2022 9:22 AM Pate: May 16, 2022
-------
Owner's Certification of Compliance - 40 CFR 122.22
Pursuant to 40 CFR 122.22,1 certify under penalty of law that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations.
On behalf of Arizona Public Service Company:
(Printed Name
(Title
(Date
-------
Certification Letter
Table of Contents
TABLE OF CONTENTS
Page No.
1.0 INTRODUCTION 1-1
2.0 HIGH RECYCLE SYSTEM DESCRIPTION 2-1
2.1 Bottom Ash System Description 2-1
2.2 Water Balance Description 2-6
2.2.1 Process Flows 2-7
2.2.2 Operational Scenarios 2-8
2.3 List of All Potential Discharges under 40 CFR § 423.13(k)(2) i) A) 1) - (4 .... 2-8
2.3.1 Water Balance - Stormwater 2-10
2.3.2 Water Balance - Other Waste Streams 2-11
2.3.3 High Recycle Rate Bottom Ash Chemistry Considerations 2-11
2.3.4 Maintenance 2-16
2.4 Wastewater Treatment Systems at Four Corners 2-17
2.4.1 Low Volume Wastewater Treatment System 2-17
2.4.2 High Recycle Bottom Ash System 2-17
APPENDIX A - WATER BALANCES
APPENDIX B - STORMWATER RUNOFF CALCULATIONS
APPENDIX C - SAMPLING ANALYTICAL RESULTS
APPENDIX D - CHEMISTRY CALCULATIONS
APPENDIX E - GENERAL ARRANGEMENT
APS - Four Corners Generating Station
TOC-1
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
Table of Contents
LIST OF TABLES
Page No.
Table 2-1: Four Corner's Primary Active Wetted Volume Summary 2-5
Table 2-2: Purge Rates for Water Balance Considerations 2-8
Table 2-3: Four Corner's Purge Discharges 2-9
Table 2-4: Key to Scaling Indexes (pH of the system) 2-12
Table 2-5: Four Corners Wastewater Treatment Systems 2-17
APS - Four Corners Generating Station
TOC-2
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter List of Abbreviations
LIST OF ABBREVIATIONS
Abbreviation Term/Phrase/Name
APS Arizona Public Service Company
BA Bottom Ash
BASWR Bottom Ash Sluice Water Recycling
BAT Best Available Technology Economically Achievable
CCR Coal Combustion Residuals
CFR Code of Federal Regulations
ELG Rule Effluent Limitations Guidelines and Standards for the Steam Electric
Power Generating Point Source Category
EPA U.S. Environmental Protection Agency
FGD Flue Gas Desulfurization
Four Corners Four Corners Generating Station
gpm gallons per minute
L-SI Larson-Skold Index
LSI Langelier Scaling Index
MW Megawatt
NPDES National Pollutant Discharge Elimination System
PSI Puckorius Scaling Index
RSI Ryznar Scaling Index
TDS Total Dissolved Solids
TSS Total Suspended Solids
APS - Four Corners Generating Station
i
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
Introduction
1.0 INTRODUCTION
On November 3, 2015, the U.S. Environmental Protection Agency EPA issued the federal Steam Electric
Power Generating Effluent Limit Guidelines and Standards (ELGs); see 80 FR 67838. The 2015 rule
addressed discharges from flue gas desulfurization (FGD) wastewater, fly ash transport water, bottom ash
(BA transport water, flue gas mercury control wastewater, gasification wastewater, combustion residual
leachate, and non-chemical metal cleaning wastes.
The 2015 rule was reconsidered by EPA, with updates finalized on October 13, 2020 (see 85 FR 64650),
and effective as of December 14, 2020. The final rule revises limitations and standards for two of the waste
streams addressed in the 2015 rule: BA transport water and FGD wastewater. For BA transport water, the
final rule establishes Best Available Technology Economically Achievable (BAT) as a high recycle rate
system with a site-specific volumetric purge (defined in the final rule as BA purge water) which cannot
exceed a 30-day rolling average of 10 percent of the BA transport water system's primary active wetted
volume. The purge volume and associated effluent limitations are to be established by the permitting
authority. EPA selected a 95th percentile of total system volume as representative of a 30-day rolling
average, which results in a limitation of 10 percent of total system volume and requires the National
Pollutant Discharge Elimination System NPDES permitting authority to develop a site-specific purge
percentage that is capped at 10 percent. EPA recognizes that some plants may need to improve their
equipment, process controls, and/or operations to consistently meet the limitations included in this final
rule; however, this is consistent with the Clean Water Act, which requires that BAT discharge limitations
and standards reflect the best available technology economically achievable.
This document serves as the Initial Certification Statement required by 40 CFR § 423.19(c)(1). On behalf
of Arizona Public Service Company (APS), this initial certification seeks to discharge BA transport water
pursuant to 40 Code of Federal Regulations CFR § 423.13 (k 2 i at the Four Corners Generating Station
(Four Corners), located in San Juan County, New Mexico in accordance with NPDES Permit NN0000019.
As required by the ELG Rule, this plan includes the following:
A. A statement that the professional engineer is a licensed professional engineer.
B. A statement that the professional engineer is familiar with the regulation requirements.
C. A statement that the professional engineer is familiar with the facility.
D. A calculation of the primary active wetted bottom ash system volume as required per 40 CFR §
423.11(aa).
APS - Four Corners Generating Station
1-1
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
Introduction
E. Material assumptions, information, and calculations used by the certifying professional engineer
to determine the primary active wetted bottom ash system volume.
F. A list of all potential discharges under 40 CFR § 423.13 k) 2) i A 1) through (4 , the expected
volume of each discharge, and the expected frequency of each discharge.
G. Material assumptions, information, and calculations used by the certifying professional engineer
to determine the expected volume and frequency of each discharge, including a narrative
discussion of why such water cannot be managed within the system and must be discharged.
H. A list of all wastewater treatment systems at the facility currently, or otherwise required by a date
certain under this section.
I. A narrative discussion of each treatment system including the system type, design capacity, and
current or expected operation.
The Four Corners Generating Station is a coal-fired mine-mouth generating plant located on the Navajo
Indian Reservation near Fruitland, NM. The plant includes two 770-Megawatt (MW) coal-fired units (Units
4 and 5 . Four Corner's existing once-thru sluicing system is being replaced with a new BAT high recycle
system which will utilize wet sluicing to transport bottom ash through a hydrobin and Bottom Ash Sluice
Water Recycling (BASWR) settling tank system to dewater the bottom ash. The system cannot be operated
as a closed loop without significant water balance, scaling, corrosion, and maintenance challenges and
should be operated as a high recycle rate system with the allowed purge to alleviate these concerns. APS is
requesting to purge up to 10 percent of the total system volume up to 459,435 gallons per day on a
30-day rolling average basis to maintain water balance, address system water chemistry, and
conduct maintenance as allowed under 40 CFR § 423.13(k 2 i A).
APS - Four Corners Generating Station
1-2
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
2.0 HIGH RECYCLE SYSTEM DESCRIPTION
As required by 40 CFR § 423.19(c) 3) D) through I , the following is a description of the bottom ash
system at Four Corners, including the assumptions, information, and calculations used by the certifying
professional engineer to determine the primary active wetted bottom ash system volume and the expected
volume and frequency of each discharge. This section also includes a description of the wastewater
treatment systems at Four Corners.
2.1 Bottom Ash System Description
After combustion, ash that accumulates in the bottom of the boiler is captured in the ash hoppers located
directly beneath the boiler. Bottom ash is then crushed into small pieces by the clinker grinders and sluiced
by jet pumps to a series of unit processes designed to separate the bottom ash from the transport water. At
present, the existing once-thru sluicing system discharges after treatment to an internal outfall identified in
the facility's NPDES permit but in the future bottom ash transport water will be treated and recycled for
reuse in BA sluicing operations.
When plant modifications supporting the high recycle bottom ash system at Four Corners are complete,
major process equipment will consist of the following:
• Two (2) existing ash hoppers with multiple compartments, one per unit
• Eight 8 existing pyrites tanks per unit, sixteen (16) total
• Four (4) existing hydrobins
• Two (2) new hydrobin overflow tanks
• Four (4) new hydrobin overflow tank agitators, two per tank
• Three (3) new hydrobin overflow return pumps
• Three (3) sumps, two new and one existing
• Three (3) new boiler area sump pumps
• Three (3) new hydrobin area sump pumps
• The existing BASWR settling tank system consisting of:
o One (1) primary settling basin
o Two (2) secondary settling basins
o One (1) clearwell chamber
• Two (2) new sluice water pumps
• Two (2) new flush water pumps
• One (1) new low volume wastewater settling tank
APS - Four Corners Generating Station
2-1
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
• Two 2 new bottom ash system makeup pumps
• One (1) existing makeup water storage tank
Appendix A contains a schematic overview of the future bottom ash sluicing system's major components
and interfaces with other plant systems. The hydrobin overflow tanks and two (2 of the sumps are new and
will be installed no later than mid-2023. In addition to these new process units, planned plant modifications
will isolate many of the currently permitted low volume wastewater flows at the facility from the existing
BA sluicing system and will direct these segregated flows to a new low volume wastewater treatment
system prior to discharge through the facility's NPDES permit (see Section 2.4).
The sluiced bottom ash will be initially treated with hydrobins, allowing dewatered bottom ash to be
discharged into trucks prior to being hauled to the site Coal Combustion Residuals CCR) landfill or hauled
offsite for beneficial reuse. The four 4) existing hydrobins will be operated sequentially with a single
hydrobin receiving sluiced ash from both units until it is full. Once a hydrobin is full, the next hydrobin
will be placed into service, and the full hydrobin will be allowed to decant for 10-12 hours prior to
discharging ash to the trucks. Hydrobins will be continuously cycled to allow for filling to capacity,
decanting, and unloading to maintain the system in operation. The two 2) new 111,000-gallon hydrobin
overflow tanks (plumbed in parallel) will receive intermittent overflow from the hydrobins during sluicing
operations. The new hydrobin overflow tanks represent the only surge capacity within the system other than
the freeboard available in the BASWR. The surge capacity in the system provided by the new hydrobin
overflow tanks is needed to allow for operational flexibility in responding to system upset conditions,
equipment failures, and stormwater inflow without having to discharge sluice water from the system or
cause a plant outage.
Bottom ash will also be mechanically removed from the BASWR settling tank system, loaded into trucks,
and hauled to the site CCR landfill. The BASWR settling tank system is a reinforced concrete free-
standing) structure comprised of a single primary settling basin that discharges into two adjacent secondary
settling basins operated in parallel that overflow into a clearwell chamber. The treated transport water that
overflows into the clearwell will then be pumped back to the boiler hoppers for re-use.
Due to proximity and level of effort to segregate flows, seal trough water for the bottom ash hoppers will
be routed with bottom ash hopper overflow to the bottom ash system even though it is technically not
bottom ash transport water. In the future, the seal trough water will be sourced from the bottom ash loop
water and will not add additional fresh water to the system.
APS - Four Corners Generating Station
2-2
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
As part of the design of the future bottom ash high recycle system, APS identified all non-bottom ash
transport flows that are currently combined with bottom ash transport water in the existing once-thru
sluicing system. The intent of this analysis was to segregate low volume wastewater from the future bottom
ash high recycle system to simplify process operations and promote reliability. In addition to the seal trough
water previously discussed, wastewater flows generated during cleaning events in the baghouse enclosure
were identified as a waste stream that should not be directed to a low volume wastewater system due the
high total suspended solids content and variable nature of flows which could lead to performance issues in
the low volume wastewater treatment system. On this basis, the baghouse enclosure sump waste stream
will be routed to the bottom ash system. Routing of this wastewater into the bottom ash system with
treatment in the BASWR tank system allows for efficient removal of these suspended solids. Washdown
of the baghouse area is an infrequent operation, so it does not substantially contribute to the solids loading
in the BASWR tank system.
The site plan below and in Appendix E includes a general overview of the major equipment included in the
proposed high-recycle system design.
APS - Four Corners Generating Station
2-3
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
Figure 2-1: Site Plan Showing Major System Components
To determine the Four Corners primary active wetted system volume, calculations were performed based
on the major equipment and piping systems. A summary of the system volume calculations is provided in
Table 2-1. The volumes of the existing ash hoppers and pyrites tanks were derived from plant drawings.
The volumes of the existing hydrobins, system sumps, and individual BASWR tank cells were calculated
from dimensions summarized below in Table 2-1) derived either from field measurements and/or plant
drawings. For the BASWR tank system, both secondary cells were included m the calculations because one
secondary cell per electric generating unit is required to be in operation per the original design basis of the
BASWR tank system to achieve the target effluent solids concentration. Finally, the volume of future
interconnecting piping was calculated for the major piping in the system as shown in Table 2-1. Piping
APS - Four Corners Generating Station
2-4
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
sizes and overall estimated lengths of each run are also shown in Table 2-1. Since the final piping design
for the system has yet to be completed, overall piping lengths were estimated based on the equipment layout
shown above. The overall system volume was calculated as the summation of the volumes from the major
components in the system including interconnecting piping.
A water balance analysis used to size new equipment and evaluate future operations is discussed in Section
2.2 and presented in Appendix A.
Table 2-1: Four Corner's Primary Active Wetted Volume Summary
Ash Hoppers
Volume
(cubic ft)
Volume (gals)
Unit 4 Hopper
10,000
74,800
Unit 5 Hopper
10,000
74,800
Total
20,000
149,600
Pyrites Tanks
Volume
(cubic ft)
Volume (gals)
Unit 4 (8 total)
144
1,077
Unit 5 (8 total)
144
1,077
Total
288
2,154
Hydrobins
Diameter (ft)
Height of
Cylinder (ft)
Height of Cone
(ft)
Volume
(cubic ft)
Volume (gals)
Tank 1
35
13.25
27.75
21,648
161,924
Tank 2
35
13.25
27.75
21,648
161,924
Tank 3
35
13.25
27.75
21,648
161,924
Tank 4
35
13.25
27.75
21,648
161,924
Total
86,590
647,694
Sumps
Width/Diameter
(ft)
Length (ft)
Depth (ft)
Volume
(cubic ft)
Volume (gals)
Unit 4 Ash Pit
6
10
283
2,115
Unit 4 Bottom Ash
Area Sump
18
35
13
8,190
61,261
Hydrobin Area Sump
15
10
10
1,500
11,220
Total
9,973
74,596
APS - Four Corners Generating Station
2-5
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
Hydrobin Overflow Tanks
Diameter (ft)
Height (ft)
Volume
(cubic ft)
Volume (gals)
Tank 1
32.5
18
14,932
111,694
Tank 2
32.5
18
14,932
111,694
Total
29,865
223,388
BASWR (Settling) Tank System
Width (ft)
Length (ft)
Depth (ft)
Volume
(cubic ft)
Volume (gals)
Primary
40
200
8.5
68000
508,640
Secondary 1
66
356
8.2
190,915
1,428,043
Secondary 2
66
356
8.2
190,915
1,428,043
Clearwell
60
20
7.8
9,400
70,312
Total
459,230
3,435,039
Piping
Diameter
(in)
Length (ft)
Volume
(cubic ft)
Volume (gals)
Sluice Piping 1
12
1,800
1,414
10,575
Sluice Piping 2
12
1,800
1,414
10,575
Flush Piping 1
12
1,800
1,414
10,575
Flush Piping 2
12
1,800
1,414
10,575
U4 Sump Return 1
10
1,100
600
4,488
U4 Sump Return 2
10
1,100
600
4,488
Hydrobin Overflow
Return 1
10
1,300
709
5,304
Hydrobin Overflow
Return 2
10
1,300
709
5,304
Total
8,273
61,881
Total System Wetted
Volume (gal) =
149,600 + 2,154 + 647,694 + 74,596 + 223,388 +
3,435,039 + 61,881 = 4,594,352
10% gal/day
459,435
10% gal/hr
19,143
10% gpm
319
2.2 Water Balance Description
Three water balance cases were created to evaluate planned operations and are included in Appendix A.
The flows used in the water balance analyses represent best estimates for future operations based on
engineering judgement and flow measurements (where feasible) conducted during existing operations. All
water balances included daily average/max process flows while water balance cases WMB-01 and WMB-
APS - Four Corners Generating Station
2-6
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
03 include 10-year and 100-year design storm events averaged over a 24-hour period, respectively. Water
balance calculations are based on average flows, but maximum flows are also shown in the water balance
figures to demonstrate the magnitude of variability that must be accounted for in routine flow balancing
operations.
2.2.1 Process Flows
As shown on the water balances, the main process flow in the bottom ash sluice system is intermittent and
comes from the sluicing of bottom ash to the hydrobins. Each units' hoppers are sluiced via jet pumps on a
scheduled basis to the hydrobins, at an average rate of2,629 gpm, where bottom ash, 966 tons/day including
35 gpm of entrained water, is removed via trucks. The overflow from the hydrobins, at an average rate of
2,610 gpm, will be captured and sent to the BASWR settling tank system for further treatment prior to reuse
or purge.
The other main flow in the bottom ash system is from seal trough and hopper overflows. The seal trough
consistently overflows to maintain level within the hopper seal trough while the hopper overflows discharge
during/after sluice events. As indicated previously, seal trough overflow is typically not considered a
bottom ash transport stream, but in this case, it will be fed off the high recycle return water system based
on the magnitude and proximity of these flows. Seal trough and hopper overflows will continue to gravity
discharge to an existing drainage trench which will be rerouted to a new sump prior to being forwarded to
the BASWR settling tank for solids settling. The seal trough overflow and hopper overflow average rates
are 1,400 gpm and 1,197 gpm, respectively. The remainder of the flows within the system are due to
miscellaneous water users.
A new low volume wastewater settling tank is also shown on the water balance figures. Various sumps
were evaluated at Four Corners for flow and quality prior to determining adequate treatment for the low
volume waste streams to meet NPDES permitted outfall limits. Typical discharges to the low volume
wastewater tank include reverse osmosis reject and backwash discharges, at an average rate of 200 gpm,
and miscellaneous service water users, at an average rate of 230 gpm. A majority of the plant storm water
runoff will also be directed to the low volume wastewater settling tank for solids settling prior to discharge.
WMB-01 includes a 10-year, 24-hour storm event which is the required system stormwater design basis
per regulation and was used as the design basis for the stormwater calculations. WMB-03 includes a 100-
year, 24-hour event for reference purposes.
APS - Four Corners Generating Station
2-7
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
2.2.2 Operational Scenarios
Existing flow rates for the bottom ash sluice and low volume wastewater systems were measured to evaluate
potential discharges from the future high recycle rate system. Daily average flows were established for the
major system components based on future expected flow rates once the system operates as a high recycle
rate system. WMB-01 and WMB-03 include design storm events for a 10-year, 24-hour and 100-year, 24-
hour storm respectively. Estimated purge flows required from the water balance scenarios evaluated are
listed in Table 2-2 below.
Table 2-2: Purge Rates for Water Balance Considerations
Water Balance Number/Condition
Purge Rate Directed to
a NPDES Outfall
(gpm)
Purge Rate Directed to
Other Systems for
Plant Reuse
(gpm)
WMB-01
Process and 10-year, 24-hour storm
0
156
WMB-02
Process Only
0
79
WMB-03
Process and 100-year, 24-hour storm
32
156
Based on the water balance analyses, routine operations will require a constant purge to the FGD system
once high-recycle operations are initiated. Given the complexity of this system, all purges to the FGD
system will have to be carefully managed. Short duration increases in the purge rate to accommodate storm
surges will be incorporated into the design; however routine discharges exceeding 79 gpm could pose water
management issues in the FGD system and impact plant reliability.
2.3 List of All Potential Discharges under 40 CFR § 423.13(k)(2 i A 1) — 4
APS is designing the high-recycle bottom ash transport system to routinely operate without purging via the
new low volume wastewater treatment to the NPDES outfall water balance case WMB-02 in Appendix
A). However, as 40 CFR §423(k 2 i)(A) anticipates, there will be circumstances that could affect the
reliability of plant operations if the high-recycle bottom ash transport system is overwhelmed. In those
instances, discharges directed to the NPDES outfall would be required and permitted under existing
regulation under four categories of conditions. To inform a case-by-case analysis of the allowable purge
rate for the future high-recycle bottom ash system at Four Corners, Table 2-3 presents the best available
estimate of discharges that could be directed to a NPDES outfall under the four categories of conditions
allowed in regulation:
APS - Four Corners Generating Station
2-8
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
Table 2-3: Four Corner's Purge Discharges
Discharge
Stream
Estimated
Flow/Volume
Description
Estimated Frequency
A 1) Water
Balance -
Stormwater
Stormwater
flows in
excess of
111,000
gallons
Precipitation-related inflows
generated from storm events
exceeding a 10-year storm event of
24-hour or longer duration e.g.,
30-day storm event and cannot be
managed by installed spares,
redundancies, maintenance tanks,
and other secondary bottom ash
system equipment
Following storm events that exceed
the design storm i.e., a storm event
with a return period greater than 10
years and intensity of 24 hours which
is equivalent to 1.54 inches of rainfall,
or 111,000 gallons). This design
storm would be stored within the
freeboard of the BASWR settling tank
system prior to being reused within
the FGD system.
Anything surpassing this storm event
would be purged via the low volume
wastewater treatment system to the
NPDES outfall. A 100-year/24-hour
storm event would contain an
estimated additional 70,000 gallons of
water that would need to be purged
from the system to maintain water
balance and avoid overtopping of the
BASWR settling tank system.
A 2) Water
Balance -
Other Waste
Streams
400 gpm
peak 20 gpm
average
Regular inflows from waste
streams other than bottom ash
transport water that exceed the
ability of the bottom ash system to
accept recycled water
Intermittent flows from sumps that
discharge into the bottom ash system
because they have a high solids
content and/or contribute area
washdown volumes on an irregular
basis have the potential to create
water balance issues if spare/surge
capacity is unavailable. For the
purpose of estimating a potential
'other waste stream' flow, the
intermittent flow from baghouse
enclosure sumps, which discharge
high solids content wastewater, serves
as the basis for the estimated other
inflow rates.
APS - Four Corners Generating Station
2-9
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
Discharge
Stream
Estimated
Flow/Volume
Description
Estimated Frequency
A)(3
Water
Chemistry
319 gpm
To maintain system water
chemistry where installed
equipment at the facility is unable
to manage pH, corrosive
substances, substances or
conditions causing scaling, or fine
particulates to below levels which
impact system operation or
maintenance
Water within the bottom ash system
has corrosive tendencies based on low
alkalinity and elevated sulfate
concentrations in the makeup water
which will become exacerbated when
closed-loop operations begin. The
extent of impacts due to water
chemistry cycling is difficult to
predict with the existing open loop
system configuration. A continuous
purge of up to 10% of the total system
wetted volume (319 gpm could be
required to prevent corrosion in the
future bottom ash system.
A)(4
Maintenance
1,428,043
gallons
To conduct maintenance not
otherwise included in (A) (1), (2 ,
or (3 of this table and not
exempted from the definition of
transport water in § 423.11 p), and
when water volumes cannot be
managed by installed spares,
redundancies, maintenance tanks,
and other secondary bottom ash
system equipment
Although it is difficult to predict the
volumes/discharge frequencies
required for maintenance of a future
system, there will be times when one
secondary BASWR cell will need to
be dewatered for cleaning purposes.
This could occur as frequently as once
a year and is the basis for the estimate
of volume required for maintenance
of the BA system. Maintenance of
smaller vessels at a similar frequency
is anticipated.
2.3.1 Water Balance - Stormwater
Although APS has taken measures in the design of the future bottom ash transport system to limit the inflow
of as much stormwater as possible, there will be purges required for storm events that exceed the design
storm noted in regulation. Calculation of the threshold stormwater volume of 111,000 gallons as well as the
100-year, 24-hour reference storm is detailed in Appendix B and summarized below:
• Stormwater calculations are based on the methodology outlined in the New Mexico Department of
Transportation Drainage Design Manual and the 'Civil Engineering Reference Manual for the PE
Exam,' Lindeburg, M, 2008). Rainfall data for the 1-year, 10-year, and 100-year 24-hour storm
APS - Four Corners Generating Station
2-10
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
were obtained from the National Oceanic and Atmospheric Administration Atlas 14, Volume 8,
Version 2. The assumed design storm is the 10-year, 24-hour storm as identified by regulation.
• The stormwater contribution method begins with estimating the drainage areas and determining the
type of cover for each area which was done from site arrangement drawings. From there we
calculate the total weighted curve number, soil water storage capacity, and initial abstraction values
as inputs to the curve number method runoff equation. This provides the estimated runoff for each
area which in turn is used to calculate the total volume input per area for each storm event.
• The total volume of stormwater that enters the bottom ash handling system is comprised of three
areas: the U4 Bottom Ash Area Sump, the Hydrobin Overflow Sump, and the open top BASWR
settling tank system. For the 10-year, 24-hour storm, these volumes are 35,900 gallons, 14,400
gallons, and 61,000 gallons respectively. This equates to the 111,000 gallons noted above in Table
2-2.
• Forthe 100-year, 24-hour storm, the corresponding stormwater volumes are 57,900 gallons, 23,200
gallons, and 98,400 gallons respectively. This equates to atotal of 179,500 gallons or the difference
of about 70,000 gallons 179,500 - 111,300 = 68,200 gallons) as noted above in Table 2-2.
2.3.2 Water Balance - Other Waste Streams
As noted in Table 2-3 above, there could be other waste streams from intermittent sources that have the
potential to impact the water balance of the bottom ash transport system, especially in the aftermath of a
significant storm when the spare/surge capacity in the system would be full. One example waste stream is
the intermittent discharge of wastewater from the baghouse enclosure sump into the bottom ash system.
The baghouse enclosure sump pumps are rated for 400 gpm which could over short periods cause water
balance issues if the spare/surge capacity of the system is limited. Although this flowrate is not significant
relative to the full process flow of the bottom ash transport recirculation flow, balancing short duration,
high intensity flows could overwhelm an already overwhelmed system.
2.3.3 High Recycle Rate Bottom Ash Chemistry Considerations
In the existing once thru i.e., open loop bottom ash sluicing system, ash is sluiced to the hydrobins which
act as the primary ash separation devices. Overflow and decant sluice water is pumped to the BASWR
settling tank system, where most of the remaining ash settles out to be dewatered and removed. Overflow
from the BASWR settling tank system is discharged thru the permitted NPDES outfall and fresh makeup
water is used for subsequent sluice cycles.
APS - Four Corners Generating Station
2-11
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
After the conversion to a high recycle rate system, it is expected that the future closed-loop water quality
will cycle up to an equilibrium concentration, where the additional mass of constituents introduced per
sluice cycle is equal to the mass exiting the closed-loop system through purge flows and the reuse of treated
sluice water in the FGD system. Since the existing system is not currently operating in a closed-loop
configuration, the corrosiveness or scaling potential in the future high recycle rate configuration cannot be
reliably predicted. However, once operating in a high recycle rate configuration, there will likely be an
increase in total dissolved solids (TDS), total suspended solids TSS), conductivity, aluminum, calcium,
chloride, iron, silica, sodium, sulfates, and other constituents from contact with the bottom ash and due to
evaporation of water in the system.
Several scaling indices can be used to model the scaling and corrosive properties of the water. These are
the Puckorius Scaling Index PSI), The Ryznar Scaling Index (RSI , the Langelier Scaling Index LSI), and
the Larson-Skold Index (L-SI . The PSI, RSI, and LSI all use alkalinity, hardness, temperature, and pH to
estimate calcium scale and corrosivity, comparing the pH of the system to the equilibrium pH and the pH
of saturation. The L-SI looks at the concentrations of carbonate, bicarbonate, sulfate, and chloride to
estimate the tendency for sulfate and chloride to interfere with scale formation and to support corrosion due
to sulfate and chloride chemistry. The target ranges for these indices are shown in Table 2-4.
Table 2-4: Key to Scaling Indexes (pH of the system
PSI
RSI
LSI
L-SI
Extreme Corrosion
>9.0
>9.0
<-2
>4.0
Moderate Corrosion
>7.5-9.0
>7.5-9.0
-2.0- -0.5
1.2-4.0
Slight Corrosion
>7.0-7.5
>7.0-7.5
>-0.5-0.0
0.8-<1.2
In range
>6.0-7.0
>6.0-7.0
>0.0-0.5
<0.8
Slight Scaling
5.0-6.0
5.0-6.0
>0.5 - 2.0
Heavy Scaling
<5.0
<5.0
>2.0
To estimate the effect of future closed loop operations, a series of samples were taken at various locations
in the bottom ash handling system and analyzed for a variety of constituents see analytes and results in
Appendix C as well as sampling locations in the water balance figures presented in Appendix A . Although,
the current system is operating as a once-through system, the intent was to try and capture the impact of
operations on the water quality as it is sluiced through the system and use this information to extrapolate to
the water chemistry in the future closed loop, high-recycle rate bottom ash system design.
APS - Four Corners Generating Station
2-12
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
We compared the expected concentration of various parameters to determine if there was a measurable
increase or decrease in these constituents given the once-through bottom ash system design. The primary
change in water quality evaluated was the effect of adding pulverized bottom ash to makeup water, sluicing
the mixture, and bulk solids removal in the hydrobin system; thus, average concentrations of evaluated
constituents in water samples collected from the hydrobin overflow were compared to samples
representative of makeup water sourced from Morgan Lake. The difference in water quality parameters
from these two samples is mainly from contact of the bottom ash with the sluice water and from evaporation
of water in the bottom ash hoppers and in the BASWR. Parameters that exhibited a measurable change
included conductivity, total dissolved solids, chlorides, sulfates, manganese, calcium, bicarbonate
alkalinity, and temperature.
Appendix D presents a chemistry mass balance model of the bottom ash system which was developed to
try and simulate the existing open loop system on bottom ash chemistry (Baseline Conditions - Open Loop
Configuration). Key input parameters and assumptions into the chemistry mass balance model include:
• Total system volume: 4,594,352 gallons see Table 2-1 above
• System evaporation: 4.0 gpm 5,760 gallons/day) based on the BASWR tank system surface area
and annual average evaporation rates plus 5.79 gpm 8,338 gallons/day) based on evaporation in
the bottom ash hoppers from contact with the bottom of the boiler. Total system evaporation was
estimated at 9.79 gpm (14,098 gallons/day).
• Bottom ash drag out rate amount removed from system) was calculated as follows: 21.2 tons/hour
average bottom production rate per unit * 2 units * 20% assumed moisture content, 21.2 * 2000
2 * 0.2 / 500.4 = 33.9 gpm (48,805.8 gallons/day) water in bottom ash drag out waste stream. This
provided a good correlation to the measured average value of 35 gpm from the hydrobins as shown
on the water balances. Water entrained with the bottom ash removed from the system was assumed
to be the average 3 5-gpm number based on existing flow measurement data.
• Total makeup rate: evaporation + drag out rates = 9.79 + 35.0 = 44.79 gpm (64,498 gallons/day
• The hydraulic residence time of the system is calculated as the total system volume divided by the
makeup rate, or 4,594,353 gallons / 64,498 gallons / day = 71.2 days.
• Selected water quality data was collected over a period of six months from various locations in the
system as shown with blue boxes on the water balance diagrams. The water quality data was
averaged for use in the chemistry model. A summary of the sampling results is contained in
Appendix C.
APS - Four Corners Generating Station
2-13
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
For development of the baseline chemistry model (existing open-loop configuration), we looked at specific
constituents in the bottom ash sluice water inlet and compared them to the same constituents in the sluice
water outlet. Constituents that were compared included conductivity, total dissolved solids, chlorides,
sulfates, magnesium, calcium, pH, and temperature. With an open-loop configuration, we lose some water
to evaporation in the bottom ash hoppers and BASWR while some water is retained in the bottom ash drag
out, see Figure 2-2 below. Evaporation in the bottom ash hoppers and BASWR has a net result of increasing
the constituent concentrations in the water. The water retained in the bottom ash that is removed does not
change the remaining concentrations in the system but does remove some mass from the system. Contact
of the bottom ash material with the water results in some dissolution of constituents from the bottom ash
into the water. The combination of evaporation and contact of bottom ash with the sluice water results in a
change in some of the constituent concentrations.
Figure 2-2: Mass Balance Around Bottom Ash System
EVAPORATION
t
SLU!CE IN
Bottom Ash
System
~ SLUtCE OUT
RETAINED WITH
BOTTOM ASH
When we compared the measured change in concentration for the compared constituents, we see that the
expected change in concentration from evaporation is greater than the measured concentration changes for
most of the compared constituents. For example, with chlorides we would expect a concentration increase
of 0.76 mg/L due to evaporation alone; however, the measured concentration change was reported as 0.03
mg/L. It is unreasonable to assume that chlorides were removed from the bottom ash water by some
mechanism as chloride salts are super soluble and the system concentrations are nowhere near solubility
limits. Similar results for calcium and magnesium were observed; expected concentration changes due to
evaporation were greater than the measured concentration changes. Alkalinity had a similar result, however,
exposure to the bottom ash could introduce some acidity in the system resulting in the observed decrease
in alkalinity concentration. TDS and sulfates were the only compared constituents that had a measured
concentration change greater than the expected concentration change due to evaporation.
APS - Four Corners Generating Station
2-14
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
With most of compared constituents exhibiting poor chemistry modeling results we concluded that it is
impossible to predict the impact of the future system configuration on the system corrosion or scaling
tendencies. With the current system showing slight to extreme corrosion potential, we assume that the
cycling up of constituents in the future high recycle rate system configuration would only worsen the system
corrosion potential. The ability to purge sluice water from the system will allow operations to maintain a
water chemistry like the current conditions.
An acid feed to lower alkalinity and pH would make the water more corrosive than current conditions. A
caustic feed to increase alkalinity and pH would make the water less corrosive than current conditions. A
soda ash feed to increase alkalinity would also make the water less corrosive than current conditions. There
is no way to quantify if chemical feed systems can improve on system water quality without the need to
purge some wastewater from the system.
The Baseline Conditions - Open Loop conditions show that in the current open-loop configuration the
bottom ash sluice water is moderately corrosive for the PSI value, within range for the RSI value, and
slightly scaling for the LSI value. The L-SI value is showing an extreme corrosion potential due to the
elevated sulfate levels and relatively low alkalinity. Because the makeup water has elevated sulfates and
low alkalinity concentrations, the best we could hope to achieve would be a water quality like the existing
conditions. The addition of some alkalinity from a soda ash feed would improve on the corrosion potential
but we would never be able to eliminate the concern with a chemical feed by itself.
The best possible outcome is with a provision for a future 10% purge rate plus the maximum possible purge
to the WFGD system peak purge rate of 79 gpm and installation of some form of chemical feed
adjustment. Selection of the chemical feed adjustment will not be made until the system can begin operation
in the future high rate recycle configuration when we can monitor changes in system chemistry during
steady state conditions. The provisions for a system purge and chemical feed addition will produce a sluice
water quality that has less scaling potential and comparable corrosion potential to the existing open-loop
bottom ash system configuration. On this basis, provisions for a future chemical feed system have been
incorporated into the design of the planned high recycle rate, closed-loop bottom ash system prior to the
BASWR settling tank system. The chemical feed system will be finalized once the bottom ash system is
put into service in the high-recycle rate, closed-loop configuration and we can measure actual chemistry
changes in the system.
APS - Four Corners Generating Station
2-15
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
2.3.4 Maintenance
Estimates of potential purge volumes required for future maintenance are difficult to predict, especially for
a system that has not been constructed (much less operated). It is anticipated, however, that there will be
scenarios where large volumes of water will need to be drained from the bottom ash transport system for
maintenance. To provide an example maintenance purge volume that would be difficult to retain onsite
given the magnitude of the system, a scenario involving clean out of one of the secondary settling cells of
the BASWRtank was selected.
The existing BASWR system consists of a primary settling cell, two secondary settling cells, and one
clearwell. As noted in Table 2-2 above, there will be times when one 1,428,043-gallon secondary BASWR
cell will need to be dewatered for cleaning purposes which may happen as frequently as once per year.
Under normal operating circumstances, every effort will be made to process drainage of the secondary
settling cell within routine system purges to the FGD system. However, due to the magnitude of volume in
each of the secondary cells, as well as plant operational requirements, a purge through the NPDES outfall
will likely be required.
The BASWR system design requires one secondary settling cell to be in service per unit in operation to
achieve the target TSS removal rates. As noted in Table 2-2 above, there will be times when one secondary
BASWR cell will need to be dewatered for cleaning purposes which may happen as frequently as once per
year. This means that the BASWR tank system is undersized for proper treatment of full flow from both
units and secondary settling cell cleanouts will have to occur during either a scheduled single or dual unit
outage. In the lead up to the scheduled outage, a single secondary settling cell will require over 12 days of
continuous draining to dewater the cell at the FGD bottom ash transport system purge rate identified for
routine operations 79 gpm; see water balance case WMB-02 in Appendix A . This operation could take
longer if there are issues in FGD operations. Further, there may be times when it will be necessary to
dewater a cell very quickly as when an equipment failure could lead to a forced unit outage. In either
instance, maintenance would require a significant purge volume equal to the volume of the cell to be
actively managed with the needs of plant operational requirements. The addition of a third (spare secondary
settling cell was considered for this scenario; however, the cost to incorporate a third settling cell for a
once/year maintenance event does not have a good cost to benefit ratio and physical space for such an
addition was limited.
APS - Four Corners Generating Station
2-16
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
2.4 Wastewater Treatment Systems at Four Corners
Table 2-5 summarizes the water treatment systems that process water that will have the potential to be
discharged in accordance with the NPDES permit at Four Corners (i.e., non-bottom ash transport systems).
Design assumptions and design basis information are discussed in the following sections.
Table 2-5: Four Corners Wastewater Treatment Systems
System
Name
Design Capacity
Current Operation
Expected Operation
Low
Volume
Wastewater
Treatment
System
440 gpm daily average.
1,213 gpm daily max
including stormwater
flows based on a 10-
year, 24-hour storm.
Settling via BASWR prior
to discharge through the
permitted NPDES outfall.
Low volume wastewater will
be segregated from bottom
ash sluice system flows and
re-routed to a new settling
tank prior to discharge
through the permitted
NPDES outfall.
High
Recycle
Bottom Ash
System
Hydrobins - 2,610 gpm
daily average
BASWR-5,642 gpm
daily average
Ash removed via Hydrobins
prior to final settling via
BASWR with polymer
addition prior to discharge
through the permitted
NPDES outfall.
Ash removed via Hydrobins
with newly installed polymer
injection. Chemical feeds
prior to BASWR for
alkalinity and pH
adjustment. Final settling via
BASWR with polymer prior
to reuse within existing FGD
system or purge to LVWTS
and ultimately through the
permitted NPDES outfall.
2.4.1 Low Volume Wastewater Treatment System
Low volume wastewater flows were evaluated based on existing plant data and flowmeter analysis.
Stormwater areas were established to determine runoff volumes that contribute to each low volume
wastewater area. Average/max daily flows were established at each low volume source along with expected
flows from a 10-year, 24-hour storm to establish sizing required for a low volume wastewater treatment
system capable of meeting the NPDES permitted outfall.
2.4.2 High Recycle Bottom Ash System
High-recycle bottom ash system flow rates, based on existing system flow rates averaged over a 24-hour
period, were utilized to establish daily averages. Hydrobins are the primary ash separation step while the
APS - Four Corners Generating Station
2-17
Burns & McDonnell
May 2022 Rev 0
-------
Certification Letter
High Recycle System Description
BASWR settling tank system settles fines carryover from the Hydrobins along with seal trough and hopper
overflow. Two sumps are included in the high recycle bottom ash system to capture various closed-loop
waters along with any storm water in the bottom ash areas. Polymer injection is expected to be utilized
upstream of the Hydrobins and BASWR settling tank system to enhance fines settling while acid / caustic
injection and/or soda ash may be included in the future for pH adjustment or alkalinity adjustment
respectively. Purge flow to the FGD system or LVWW treatment system (to the NPDES outfall) would be
discharged after the treatment of the closed-loop water by the Hydrobins and BASWR settling tank system
along with any required chemical feed. Purge flow for reuse or outfall discharge is dependent on
considerations listed in Section 2.3.
Wastewater streams generated at the plant that do not discharge through NPDES permitted outfalls include
blowdown from the wet FGD scrubber, sanitary wastewater, and various boiler cleaning solutions.
Blowdown and associated slurries from the wet FGD scrubber are blended with ash and landfilled in an on-
site CCR landfill. Sanitary wastewater and boiler cleaning solutions are discharged to an on-site CCR
surface impoundment where they evaporate or are reused in non-bottom ash sluice water plant operations.
APS - Four Corners Generating Station
2-18
Burns & McDonnell
May 2022 Rev 0
-------
APPENDIX A - WATER BALANCE DRAWINGS
-------
Baghouse
Enclosure
Sumps
20
|
New LVWW Settling Tank 1 new) -
New Bottom Ash System Makeup
Pumps to BASWR 2 new
156 Purge (Note 2)
PRELIMINARY
EPA LETTER UPDATES
z EPA LETTER UPDATES
z EPA LETTER UPDATES
e I Precipitation Included
NOTES:
1. Precipitation values based on 10 year, 24 hour storm
averaged over 24 hour period.
2. Purge based on water balance requirements for the
closed-loop system.
3. All flows shown in gallons per minute (GPM
4. Max flows for normal operation are in parentheses and
may not balance.
5. Water leaving with ash assumed to be 20% moisture.
Hydrobin ash expected to be removed for 4 hour duration
per day. BASWR ash removal expected 3 times per week
and estimated to be removed within 8 hour duration.
6. Purge to maintain system water chemistry up to 319
gpm or 10% of the bottom ash system flow.
7. Maintenance purge to drain one secondary cell of the
BASWR to the LVWW settling tank is not shown.
8. Dashed lines represent intermittent flows.
Sampling Location
PRELIMINARY
BURNS
VvM9DONNELL
£)aps
APS Four Corners
Future Conditions
Process & 10yr Storm water Flows
-------
PRELIMINARY
EPA LETTER UPDATES
E EPA LETTER UPDATES
E EPA LETTER UPDATES
~ Precipitation Included
NOTES:
1 Precipitation values based on 10 year, 24 hour storm
averaged over 24 hour period
2 Purge based on water balance requirements for the
closed-loop system
3 All flows shown in gallons per minute (GPM
4 Max flows for normal operation are in parentheses and
may not balance
5 Water leaving with ash assumed to be 20% moisture
Hydrobin ash expected to be removed for 4 hour duration
per day BASWR ash removal expected 3 times per week
and estimated to be removed within 8 hour duration
6 Purge to maintain system water chemistry up to 319
gpm or 10% of the bottom ash system flow
7 Maintenance purge to drain one secondary cell of the
BASWR to the LVWW settling tank is not shown
8 Dashed lines represent intermittent flows
Sampling Location
PRELIMINARY
BURNS
v MCDONNELL,
aps
APS Four Corners
Future Conditions
Process Only Flows
-------
PRELIMINARY
EPA LETTER UPDATES
E EPA LETTER UPDATES
E EPA LETTER UPDATES
e Precipitation Included
NOTES:
1 Precipitation values based on 100 year, 24 hour storm
averaged over 24 hour period
2 Purge based on water balance requirements for the
closed-loop system Purge to LVWVV based on flow
exceeding 10 year storm
3 All flows shown in gallons per minute (GPM
4 Max flows for normal operation are in parentheses and
may not balance
5 Water leaving with ash assumed to be 22% moisture
Hydrobin ash expected to be removed for 4 hour duration
per day BASWR ash removal expected 3 times per week
and estimated to be removed within 8 hour duration
6 Purge to maintain system water chemistry up to 319
gpm or 10% of the bottom ash system flow
7 Maintenance purge to drain one secondary cell of the
BASWR to the LVWW settling tank is not shown
8 Dashed lines represent intermittent flows
Sampling Location
PRELIMINARY
-------
APPENDIX B - STORMWATER RUNOFF CALCULATIONS
-------
BURNS 7 MPDONNELL
WORKSHEET TITLE: APS 4C ('.il.:'.
CREATED: 4/26/2021
PERFORMED BY: D ELLIOTT
OBJECTIVE: Determine Runoff Volumes
CALCULATION NO.:
REVISION:
REVIEWED BY:
REFERENCES:
1 Lindeburg, M (2008) Civil engineering reference manual for the PE exam Belmont, CA Professional Publications, Inc
2 Drainange Design Manual - NMDOT
https://dot.state.nm.us/content/dam/nmdot/lnfrastructure/Drairi Design Manual.pdf
3 National Oceanic and Atmospheric Administration (2015) NOAA Atlas 14, Volume 8, Version 2 [Point precipitation frequency estimates
for Farmington, NM, US] Retrieved from http //hdsc nws noaa gov/hdsc/pfds/pfds_map_cont htmPbkmrk=mo
4 United States Department of Agriculture Natural Resources Conservation Service National Engineering Handbook Part 630 Hydrology,
Chapter 15 Time of Concentration Np.nd Web 9 Feb 2016
DESIGN INPUTS:
1 Design storm duration is 24 hours
2 Max intensity duration is 5 minutes
3 Based on Custom Soils Resource Report, soils in the vicinity of the
watershed areas are generally sandy loam Hydrologic Soil Group C
EQUATIONS:
1 SCS Curve Number Method Runoff Equation
0 = (P-la)2/(P-la+S)
2 Soil Water Storage Capacity
S = (1000/CN) -10
3 Initial Abstraction
la = 0 2*S
4 Weighted Curve Number
CNW = (CN,*A,)/At
5 Volume of Runoff
V = Q*A,
VARIABLES:
runoff, in
total drainage area, ac or mi2
soil water storage capacity, in
curve number, unitless
initial abstraction, in
weighted curve number, unitless
total area, ac
total weighted curve number, unitless
CALCULATIONS:
Establish drainage area
Area 1
Area 2
Area 3
Area 4
Area 5
Area 6
Area 7
West Sump
East
Sumo
LVWW
Sump
Baghouse
Area
U4 BA
Area
BASWR
Hyd robin
Area
> >
3 £
9 61
5 75
9 40
6 50
1 00
1 70
0 40
0 015
0 009
0 015
0 010
0 002
0 003
0 001
Establish rainfall data
SCS Storm
Depth (in)
Reference 3
Reference 3
Reference 3
lyr, 24hr
0 83
lOyr, 24hr
1 54
lOOyr, 24hr
2 36
As shown on the area map figure, see below
Conversion from ac to rr
Establish CN, Percent Impervious Cover, and Initial Abstraction
West Sump
East Sump
LVWW Sump
Baghouse Area
U4 BA Area
BASWR
Hyd robin Area
Land Description
z
u
A," (ac)
S
Z
u
z
u
A," (ac)
CNW
CN,*
A," (ac)
S
Z
u
z
u
A," (ac)
CNW
CN,*
A," (ac)
n
z
n
z
A," (ac)
CNW
CN,*
A," (ac)
n
z
Open space, fair condition
79
0 0
79
0 0
79
0 0
79
0 0
79
0 0
79
0 0
79
0 0
Gravel
96
7 21
72 0
96
5 18
864
96
0 0
96
0 0
96
0 0
96
0 0
96
0 0
Pond
100
0 0
100
0 0
100
0 0
100
0 0
100
0 0
100
1 62
95 0
100
0 0
Pavement
98
2 40
24 5
0 58
98
98
9 40
98 0
6 50
98 0
9 40
98 0
98
0 09
4 9
0 40
98 0
Coal Pile
60
0 0
0 0
60
0 0
0 0
0 0
60
0 0
0 0
At (ac)
WW/ jmd, 96
CNwt
la
Equation 4
Equation 4
Equation 4
Equation 4
Equation 4
Sum
Sum
Equation 2
Equation 3
•Reference 1, Table 20 4, p 20-17 and Design Input 3
1 of 3
-------
BURNS ^NISDON NELL
**Measured in Microstation
Establish Runoff Volume based on SCS Curve Number Method
West Sump
East Sump
LVWW Sump
Baghouse Area
U4 BA Area
BASWR
Hydrobin Area
P (in)
0.83
0.83
0.83
0.834
0.834
0.834
0.834
Reference 3
1-yr Storm
Q (in)
0.55
0.48
0.63
0.63
0.63
0.63
0.63
Equation 1
V(gal)
Equation 5
Flow (gpm)
P (in)
1.54
1.54
1.54
1.54
1.54
1.54
1.54
Reference 3
"10-yr Storm
Q (in)
1.22
1.13
1.32
1.32
1.32
1.32
1.32
Equation 1
V (gal)
Equation 5
Flow (gpm)
P (in)
2.36
2.36
2.36
2.36
2.36
2.36
2.36
Reference 3
100-yr Storm
Q (in)
2.03
1.92
2.13
2.13
2.13
2.13
2.13
Equation 1
V(gal)
Equation 5
Flow (gpm)
Evaporation Calcs 68,200
Area (acres)
Pan Evap
Rate
(in/yr)
Total Evap
(gal/yr)
Average
Evap
(gpm)
BASWR
1.40
55.00
2,090,877
3.98
LVWW
Settling Basin
1.00
55.00
1,493,484
2.84
2 of 3
-------
BURNS^MSDONNELL
Drawing showing relative areas (APS 4C - Google Earth.pdf):
3 of 3
-------
APPENDIX C - SAMPLING ANALYTICAL RESULTS
-------
BURNS ^MSDONNELL.
Client: APS Four Corners
Date 10/18/2021
Project No. 129532
Notes:
1) Non Detects (ND are not factored into average/max.
2) Blank cells were not analyzed for specific constituent.
isperided Solids, ppm
ssolved Solids, ppm
E
Q_
:y as CaC03, ppm
E
3, ppm
E
E
ppm
E
;d Silica, ppm
E
a
ppm
E
e"
E
E
e"
E
<
E
e"
;d Calcium, ppm
E
E
agriesium, ppm
E
e"
1
seriic, ppm
E
<
E
e"
E
e"
ercury, ppb
;d Mercury, ppb
ileriium, ppb
e"
Q
13
'=
s?
3
S
oT
->
<
->
o
->
-!=
->
5
->
<
->
£
->
5
->
•si
->
Stream Description
Sample Date/Time
E
§
g
g
Q
£
.3
£
.3
Q
Q
Q
Q
Q
Q
£
3/4/21 12:31
8.97
5
721
114
ND
41.1
0.73
ND
ND
8.97
7.92
367
0.215
ND
74.3
72.2
ND
ND
28.7
27.1
ND
ND
ND
ND
ND
ND
3/8/21 12:03
8.92
11
719
142
ND
41.6
0.757
ND
ND
8.54
8.56
361
0.138
ND
74.4
79.6
0.75
ND
28
29.7
ND
ND
ND
ND
ND
ND
3/11/21 9:40
9.06
13
717
101
ND
40.9
0.759
ND
ND
9.03
8.73
367
0.64
0.175
0.101
76.7
74.4
ND
ND
27.5
27.4
ND
ND
ND
ND
ND
ND
3/15/21 10:51
8.81
691
110
ND
40.7
0.742
ND
ND
9.06
8.03
364
0.64
0.222
ND
72.2
74.6
2.48
ND
25.2
26.3
ND
ND
ND
ND
ND
ND
Seal Trough Makeup
(Service Water)
3/18/21 9:59
8.93
7
774
113
ND
41.3
0.75
ND
ND
ND
ND
359
0.64
ND
ND
71.4
78.1
ND
ND
25.3
27.1
ND
ND
ND
ND
ND
ND
9/13/21 13:31
8.77
14
744
105
ND
43.4
0.821
ND
ND
ND
383
ND
ND
77
76.2
ND
ND
31.2
30.2
ND
ND
90.7
114
9/16/21 12:02
8.74
6
762
102
ND
43.6
0.815
ND
ND
ND
396
ND
ND
83
72.1
ND
ND
31.8
27.8
98.2
108
9/17/21 11:13
8.71
7
772
102
ND
43.2
0.815
ND
ND
ND
393
ND
ND
78.4
68.2
ND
ND
30.2
27.6
91.2
101
Average
9.00
737.50
111.13
41.98
0.77
8.90
8.31
373.75
0.64
0.19
0.10
75.93
74.43
1.62
28.49
27.90
93.37
107.67
Max
14.00
774.00
142.00
43.60
0.82
9.06
8.73
396.00
0.64
0.22
0.10
83.00
79.60
2.48
31.80
30.20
98.20
114.00
3/1/21 14:37
8.85
47
525
128
ND
41
0.738
ND
ND
6.79
5.35
366
ND
ND
70.6
79.4
ND
ND
27.3
27.3
ND
ND
ND
ND
ND
ND
3/4/21 11:42
9.09
11
698
128
ND
41
0.727
ND
ND
8.16
8.2
366
0.221
ND
70.5
77.3
2
ND
28.1
27.8
ND
ND
ND
ND
ND
ND
3/8/21 12:54
9
15
728
128
ND
41.6
0.759
ND
ND
8.5
7.86
361
0.1
ND
69.3
73.2
0.832
ND
26
27.9
ND
ND
ND
ND
ND
ND
3/11/21 9:33
9.05
6
716
123
ND
40.8
0.758
ND
ND
9.06
8.35
366
0.64
0.173
ND
75.5
73.9
ND
ND
27.5
26.7
ND
ND
ND
ND
ND
ND
3/15/21 11:39
8.92
10
699
114
ND
40.7
0.738
ND
ND
7.91
8.11
364
0.64
ND
ND
69.5
71.7
ND
ND
25.4
26.1
ND
ND
ND
ND
ND
ND
Flush Water
3/18/21 9:43
8.88
8
759
113
ND
41.2
0.749
ND
ND
ND
ND
359
2.56
ND
ND
68.8
67.1
ND
ND
25.5
24.4
ND
ND
ND
ND
ND
ND
Max
16.17
47.00
687.50
759.00
122.33
128.00
41.05
41.60
0.74
0.76
8.08
9.06
7.57
8.35
363.67
366.00
1.28
2.56
0.16
0.22
70.70
75.50
73.77
79.40
1.42
2.00
26.63
28.10
26.70
27.90
All SW Average
12.31
716.07
115.93
41.58
0.76
8.45
7.90
369.43
0.96
0.18
0.10
73.69
74.14
1.52
27.69
27.39
93.37
107.67
All SW Max
47.00
774.00
142.00
43.60
0.82
9.06
8.73
396.00
2.56
0.22
0.10
83.00
79.60
2.48
31.80
30.20
98.20
114.00
3/1/21 12:33
8.47
30
664
97
ND
35.9
0.59
1.14
ND
6.19
5.69
350
0.118
ND
56.4
56.9
ND
ND
33.5
32.1
ND
ND
ND
ND
ND
ND
3/4/2112:16
8.68
15
717
126
ND
40.9
0.727
ND
ND
8.65
7.85
366
0.243
ND
73.3
73.5
ND
ND
27.8
28
ND
ND
ND
ND
ND
ND
3/8/2111:49
8.74
11
719
119
ND
41.5
0.763
ND
ND
5.2
8.46
361
0.146
ND
68
75.6
ND
ND
26
28.1
ND
ND
ND
ND
ND
ND
3/11/21 10:13
8.64
17
723
120
ND
40.9
0.756
ND
ND
7.44
8.67
367
0.64
0.121
ND
73.2
76.5
ND
ND
26.6
27.8
ND
ND
ND
ND
ND
ND
Seal Trough Overflow
3/15/21 11:23
8.71
91
704
118
ND
40.7
0.759
ND
ND
8.75
7.68
365
0.64
0.417
ND
69.8
72.1
ND
ND
25.4
26.3
ND
ND
ND
ND
ND
ND
3/18/21 10:19
8.74
32
766
114
ND
41.3
0.764
ND
ND
6.33
ND
361
0.64
0.144
ND
73.2
75.7
ND
ND
25.6
26.5
ND
ND
ND
ND
ND
ND
Average
32.67
715.50
115.67
40.20
0.73
1.14
7.09
7.67
361.67
0.64
0.20
68.98
71.72
27.48
28.13
Max
91.00
766.00
126.00
41.50
0.76
1.14
8.75
8.67
367.00
0.64
0.42
73.30
76.50
33.50
32.10
3/1/21 11:55
7.76
140
706
124
ND
40.4
0.768
0.302
ND
6.94
7.67
373
0.463
ND
72.6
72.9
ND
ND
27.1
27.1
ND
ND
ND
ND
ND
ND
3/4/21 11:15
9.01
127
710
138
ND
40
0.737
0.449
ND
9.47
7.38
373
0.736
ND
78.7
72.3
ND
ND
28.9
26.5
ND
ND
ND
ND
ND
ND
3/8/21 11:29
8.86
11
1080
191
ND
27.3
ND
ND
ND
12.2
12.3
229
0.17
ND
111
114
ND
ND
42.6
42.8
0.004
ND
ND
ND
ND
ND
BASWR Inlet from LVWW
3/11/21 9:15
7.94
300
712
110
ND
39.6
0.796
0.303
ND
18.7
8.13
368
0.64
4.09
0.105
75.7
75.4
2.46
ND
26.5
27
ND
ND
ND
ND
ND
ND
3/15/21 10:30
8.59
1420
699
107
ND
40.3
0.793
0.281
ND
7.62
7.62
374
3.2
1.06
ND
73.4
77.1
0.604
ND
26.3
26.1
ND
ND
ND
ND
ND
ND
3/18/21 9:20
8.35
217
776
102
ND
41.1
0.821
0.447
ND
ND
ND
371
4.48
0.852
ND
72.9
22.2
0.436
ND
25.5
24.8
ND
ND
ND
ND
ND
ND
Average
369.17
780.50
128.67
38.12
0.78
0.36
10.99
8.62
348.00
2.77
1.23
0.11
80.72
72.32
1.17
29.48
29.05
0.004
Max
1420.00
1080.00
191.00
41.10
0.82
0.45
18.70
12.30
374.00
4.48
4.09
0.11
111.00
114.00
2.46
42.60
42.80
0.004
-------
BURNS ^MSDONNELL.
Client: APS Four Corners
Date 10/18/2021
Project No. 129532
Notes:
1) Non Detects (ND are not factored into average/max.
2) Blank cells were not analyzed for specific constituent.
Stream Description
Sample Date/Time
E
Total Suspended Solids, ppm
Total Dissolved Solids, ppm
Dil & Grease, ppm
|
0
1
1
£
"D
u
|
i
o
:luoride, ppm
Mitrate, ppm
Mitrite, ppm
Total Silica, ppm
Dissolved Silica, ppm
Sulfate, ppm
Sulfite, ppm
Total Aluminum,ppm
Dissolved Aluminum,ppm
Total Calcium, ppm
Dissolved Calcium, ppm
Total Iron, ppm
Dissolved Iron, ppm
Total Magnesium, ppm
Dissolved Magnesium, ppm
Total Arsenic, ppm
Dissolved Arsenic, ppm
Total Sodium, ppm
Dissolved Sodium, ppm
Total Mercury, ppb
Dissolved Mercury, ppb
Total Selenium, ppb
Dissolved Selenium, ppb
3/1/21 13:44
7.79
450
736
'122
ND
41.2
0.819
ND
ND
6.87
4.74
375
0.858
ND
75
72.7
0.509
ND
27.6
27
ND
ND
ND
ND
ND
ND
3/4/21 12:05
8.64
58
750
128
ND
41.5
0.822
ND
ND
9,76
6.3
380
0.579
0.11
75.3
78.2
ND
ND
27.3
28
ND
ND
ND
ND
ND
ND
3/8/21 12:24
7.84
924
756
130
ND
41.6
0.806
ND
ND
12.7
8.65
368
1.79
ND
75.1
74.9
0.763
ND
26
27.3
0.00416
ND
ND
ND
ND
ND
3/11/21 10:04
8.86
9
712
108
ND
40.9
0.759
0.321
ND
8.1
5.45
367
0.64
ND
ND
68.6
69.8
ND
ND
25.5
25.5
ND
ND
ND
ND
ND
ND
3/15/21 11:04
8.88
29
706
112
ND
40.9
0.83
ND
ND
9.45
9.76
379
1.28
0.214
ND
75.8
83.1
ND
ND
26.7
28.5
ND
ND
ND
ND
ND
ND
3/18/21 10:49
8.76
1470
776
104
ND
41.4
0.882
ND
ND
ND
5
367
1.28
0.919
ND
78.2
78.2
ND
ND
25.8
25.8
ND
ND
ND
ND
ND
ND
7/7/21 15:54
41.84
7.69
2940
762
107
ND
42.3
0.858
ND
ND
ND
ND
378
1.53
ND
73.8
74.6
0.929
ND
25.2
29.3
0.005
ND
ND
ND
ND
ND
7/8/21 14:43
43.52
8.13
512
764
99
ND
42.4
0.918
ND
ND
ND
ND
380
0.256
0.172
79.2
82
ND
ND
27.7
27.4
ND
ND
ND
ND
ND
ND
8/5/21 7:00
32.90
8.74
1080
8/5/21 7:30
31.70
8.29
667
8/5/21 8:00
32.70
8.17
637
8/5/21 8:30
32.90
8.2
611
8/5/21 9:00
34.40
8.07
723
8/5/21 9:30
34.70
7.96
726
8/5/21 10:00
34.30
7.98
840
8/5/21 10:30
35.70
7.95
575
8/5/21 11:00
36.40
7.93
830
8/5/21 11:30
35.90
7.89
1320
Unit 4 & 5 Hydrobin
8/5/21 12:00
37.90
7.86
1010
Overflow
8/5/21 12:30
36.70
8.19
807
8/5/21 13:00
37.80
8.05
483
8/5/21 13:30
38.00
7.32
292
8/5/21 14:00
38.20
7.04
396
8/5/21 14:30
38.70
7.85
846
8/5/21 15:00
40.30
7.95
496
8/5/21 15:30
40.20
8.35
306
8/5/21 16:00
35.90
7.92
782
8/5/21 16:30
38.10
7.88
643
8/5/21 17:00
40.50
7.96
856
8/5/21 17:30
38.90
9.61
20
8/5/21 18:00
38.50
9.67
8
8/5/21 18:30
37.40
9.84
6
9/13/21 13:41
34.40
8.04
483
771
104
ND
43.5
0.921
ND
ND
ND
393
2.17
ND
83.5
75.3
ND
ND
30.9
28.2
92.5
108
9/16/21 13:42
34.30
7.93
2000
790
98.5
ND
43.1
0.877
ND
ND
ND
403
ND
ND
84.7
74.9
ND
ND
31.2
28.3
93.6
110
9/17/21 13:01
30.70
7.93
1530
783
95.2
ND
43.3
0.929
ND
ND
2.47
407
ND
ND
71.3
72
ND
1.29
28.8
28.1
86.6
108
Average
36.67
724.71
755.09
109.79
42.01
0.86
0.32
9.28
6.05
381.55
1.07
1.04
0.14
76.41
75.97
0.73
1.29
27.52
27.58
0.00
90.90
108.67
Max
43.52
2940.00
790.00
130.00
43.50
0.93
0.32
12.70
9.76
407.00
1.28
2.17
0.17
84.70
83.10
0.93
1.29
31.20
29.30
0.01
93.60
110.00
7/7/21 15:00
38.83
7.63
15
747
110
ND
42.1
0.779
ND
ND
ND
ND
367
0.113
ND
66.2
76.9
ND
ND
26.6
29.4
ND
ND
ND
ND
ND
ND
7/8/21 14:05
55.80
7.76
373
773
92
ND
42.7
1.01
ND
ND
ND
ND
392
0.345
ND
79.9
82.6
ND
ND
27.2
27.6
0.00494
0.00462
ND
ND
ND
ND
U4 Hopper Overflow
9/13/21 13:10
27.60
8.66
2.5
781
107
ND
44.1
0.952
ND
ND
ND
394
0.859
0.813
81.4
86.2
ND
ND
29.2
28.4
90.8
123
9/16/21 12:22
31.40
8.36
98
766
103
ND
43.2
0.82
ND
ND
ND
393
ND
ND
79.9
73.3
ND
ND
30.8
29
92.1
114
9/17/21 11:45
29.50
8.54
44
111
102
ND
43.1
0.835
ND
ND
ND
392
ND
ND
83.1
71
ND
ND
30.7
28.5
93.3
111
7/7/21 15:17
55.20
6.85
276
773
82
ND
42.6
1.13
ND
ND
ND
ND
403
1.63
ND
66.9
76.6
0.758
ND
25.8
27.3
0.00618
ND
ND
ND
ND
ND
7/8/21 14:13
54.22
7.81
307
755
90
ND
42.6
1.03
ND
ND
ND
ND
392
0.238
ND
81.1
81.6
ND
ND
28.4
28.4
0.00502
0.00424
ND
ND
ND
ND
9/13/21 13:19
40.30
7.85
98
773
90
ND
43.8
1.06
ND
ND
ND
405
0.514
ND
81.8
80.1
ND
ND
30.9
29
90.1
115
U5 Hopper Overflow
9/16/21 12:03
36.10
7.54
493
776
98.4
ND
43.3
0.953
ND
ND
ND
404
ND
ND
81.6
70.2
ND
ND
31.9
27.3
90.5
103
9/17/21 11:51
38.10
7.64
131
793
89.5
ND
43.6
1.06
ND
ND
2.8
415
ND
ND
73
71.1
ND
ND
28
27.6
86.7
122
Average
183.75
771.40
96.39
43.11
0.96
395.70
0.62
77.49
76.96
0.76
28.95
28.25
0.005
0.004
Max
493.00
793.00
110.00
44.10
1.13
415.00
1.63
83.10
86.20
0.76
31.90
29.40
0.006
0.005
-------
BURNS ^MSDONNELL.
Client: APS Four Corners
Date 10/18/2021
Project No. 129532
Notes:
1) Non Detects (ND are not factored into average/max.
2) Blank cells were not analyzed for specific constituent.
Stream Description
Sample Date/Time
E
Total Suspended Solids, ppm
Total Dissolved Solids, ppm
Dil & Grease, ppm
|
o
-------
APPENDIX D - CHEMISTRY CALCULATIONS
-------
Baseline Conditions - Open Loop Configuration
Entire system volume
4,594,353
gallons
3,190.52
gpm
Bottom ash hopper volume, total
149,600
gallons
Bottom ash hydro bins, total
647,694
gallons
Makeup (gpm) (dragout + evap)
44.79
gpd
Total Makeup (GPD)
64,504
Dragout
50,400
gpd
35.00
]gpm, from Ash design basis
System Evaporation
14,104
gpd
9.79
gpm | 9.79 |gpm, BASWR evaporation plus bottom ash hopper evaporation
Cycles of Concentration
1.00
Jcurrent system is open loop - no cycling
Hydraulic Residence Time (HRT), day
71.23
Seal trough overflow / agitation nozzles
3,047
gpm
4,387,680
gal/day - assumes seal trough flow is continuous
Sluice rate
2,628
gpm
1,261,440
gal/day - assumes sluicing 2x per day for 2 hours each sluice per unit
This sheet calculates the concentration of solutes added to the system by the ash, for use in projecting water quality under different purge rates. When the estimated
concentrations in red font (Estimated Concentrations row) agree with the measured values (Hydrobin Overflow row), the estimated contribution of the ash to the
solutes in the system from the model is showing good correlation and is considered acceptable.
alk/HC03,
alk/C03,
Water quality data
Cond, uS/cm
TDS, ppm
CI, ppm
S04, ppm
Mg, ppm
Ca, ppm
ppm
ppm
pH, SU
Temp, F
Makeup Water
1,100.75
737.50
41.98
373.75
28.49
75.93
111.13
8.86
70.00
8.12
6.79
1.03
Hydrobin Overflow
1,127.00
755.09
42.01
381.55
27.52
76.41
109.79
8.20
98.01
7.55
6.87
0.66
Current Cycles Observed
1.0239
1.0239
1.0007
1.0209
0.9660
1.0063
0.9879
Change in system concentration
26.25
17.59
0.03
7.80
(0.97)
0.48
(1.34)
28.01
Excess concentration at reported HRT, ppm/day
0.2470
0.0004
0.1095
(0.0136)
0.0067
(0.0188)
Concentration change from evaporation
increase)
13.28
0.76
6.73
0.51
1.37
2.00
<- increase in system concentration from evaporation losses
Concentration input from contact with bottom ash
4.31
(0.73)
1.07
(1-48)
(0.89)
(3.34)
<- negative values do not make sense; should have an increase in concentration
MGD gpm
100.0%
percentage of design basis
Evaporation
0.014
9.79
gpm
Dragout
0.050
35.00
gpm, calculated dragout/system losses to approximate concentration factors
Sluice rate
3.784
2,628.00
gpm, current sluicing rate, open-loop system
Makeup
0.065
44.79
gpm
PSI =
2(pHs)-
pHeq
RSI =2(pHs) -
pHmeasured
LSI =
pHmeasured
- pHs
LS-I
1
-------
APPENDIX E - GENERAL ARRANGEMENT
-------
BASWR
SUMP
UNIT 4
date 08/12/21
(designee! «•_ MATTHEWS
FOUR CORNERS
OVERALL SITE
ELG PLANT MODIFICATIONS
GENERAL ARRANGEMENT
129532
FCC016494
M003
HYDROBINS
st' t - fJ •_ 11
K?f9l
-v- J
UNIT 5
BOILER
BOILER
HYDROBIN
OVERFLOW
TANKS
Z:\CLIENTS\ENR\ARIZONAPS\129532 FCC016494ELG\DESIGN\MECH\CADD\SKETCHES\129532 SKM003.DWG 2/24/2022 4:31 PM KJMATTHEWS
-------
BURNS MCDONNELL
CREATE AMAZING,
Burns & McDonnell World Headquarters
9400 Ward Parkway
Kansas City, MO 64114
O 816-333-9400
F 816-333-3690
www.burnsmcd.com
-------
Attachment 6: APS NPDES Permit
Modification Update
-------
aps
Tel. 602-250-2414 PO Box 53999
Cell 602-284-3899 Mail Station 9303
e-mail: neal.brown@aps.com Phoenix, Arizona 85072
January 26, 2023
Electronically Submitted
U.S. Environmental Protection Agency, Region 9
NPDES Permits Section, Water Division (WTR-2-3)
Attn: Gary Sheth (Sheth.Garv@epa.QOv)
75 Hawthorne Street
San Francisco, CA 94105
Subject: PERMIT MODIFICATION APPROACH REQUEST
Information Supporting a Permit Modification Pursuant to
Amended Standards in the Steam Electric Reconsideration Rule
APS Four Corners Power Plant - Fruitland, New Mexico
NPDES Permit No. NN0000019
Dear Mr. Sheth,
Further to your discussion with our staff, this letter provides an update on the construction of
a high recycle bottom ash transport water (BATW) recirculation system at the Arizona Public
Service Company (APS) Four Corners Power Plant (FCPP) and requests a minor change to the
schedule identified in our Proposed Permit Modification Approach transmitted to the U.S.
Environmental Protection Agency (EPA) on November 1, 2022. This request would not affect
APS's request that EPA establish December 31, 2025 as the "as soon as possible" date for
compliance with current BATW ELG requirements, nor does it affect the date by which APS
will complete construction of the FCPP BATW high-recycle rate water recirculation system
(i.e., December 31, 2023); this request only concerns certain interim milestones APS
addressed in its November 1, 2022 letter.
In that letter, we indicated that two planned outages had been scheduled for BATW
recirculation system installation, commissioning, and tuning. The first outage was to begin in
April 2023 (the 2023 Spring Outage) and be complete before 2023 "Summer Run," which
refers to a period that begins on June 1 each year when FCPP operates day-in, day-out at full
capacity and provides a critical supply of electricity to the western United States. During
recent "Summer Runs," FCPP has proven essential to keeping the lights on within APS's
service territory and elsewhere in the region. The second outage was scheduled to begin in
October 2023 (the 2023 Fall Outage) to address any issues or concerns that were discovered
over the summer months of system startup operations.
Unfortunately, several global supply chain and material availability constraints outside of
APS's control have compounded to make it impossible to complete the installation and
commissioning of our high-recycle BATW recirculation system prior to the 2023 Summer Run.
APS previously identified several critical equipment items that must be on-site and verified to
be in working order at the beginning of the 2023 Spring Outage to ensure the system is
installed and connections are made before the end of the outage. In particular, the delivery
of previously identified long-lead critical equipment has been delayed such that it is no longer
possible to complete this work during the Spring Outage. Affected equipment includes, but
is not limited to control valves, DCS hardware, automatic transfer switches, and project-
specific electrical cable.
Even with APS's best efforts to secure the needed equipment as soon as possible, receipt of
this equipment is still in question until it arrives onsite and the outlook as to vendors actually
l|
-------
meeting projected delivery dates remains highly uncertain. On this basis, we have had to
revisit our plans over the past month for the 2023 Spring Outage. Power plant outages are
carefully scheduled—involving the orchestrated activities of multiple stakeholders both onsite
and offsite—to prevent adverse impacts to the grid and ensure the availability of replacement
capacity while FCPP is offline. We still intend to conduct the 2023 Spring Outage, for items
supporting construction of the BATW recirculation system as well as other plant maintenance;
however, our objective has shifted from completing project installation to minimizing the work
that must be conducted during the 2023 Fall Outage to reduce future risk to the project
schedule.
We believe that our supply chain issues should be resolved no later than June 2023, but our
operating obligations for the 2023 "Summer Run" will postpone making final equipment
connections and startup of the new recirculation system. That work must now be completed
during the scheduled 2023 Fall Outage in order to ensure continued operations of FCPP and
regional electric grid reliability.
Since this change in schedule results in no opportunity to perform initial testing and balancing
of the new BATW recirculation system before the planned transition to full-time operation of
this system on January 1, 2024, APS requests a change to the Company's currently pending
permit modification reouest. Instead of interim discharge limits taking effect on January 1.
2024 (as described in our November 1. 2022 letter), our permit modification should reflect a
start date of June 30. 2024 for when the interim discharge limits apply. We propose that prior
to June 30, 2024, operation of the high-recycle BATW recirculation system be required (as of
January 1, 2024) but that BATW discharges would be allowed to continue through the existing
01E outfall on an as-needed basis to ensure safe and reliable plant operations for a six-month
system startup period while APS identifies and addresses potential issues prior to the 2024
"Summer Run". No changes are reguired or reouested to the following aspects of the proposed
permit modification: the compliance date for construction of the hioh-recvcle BATW
recirculation system (i.e.. December 31. 20231. the submittal date for an updated draft Initial
Certification incorporating interim operational data for the system (i.e.. March 31. 2025). or
the "as soon as possible" date in the NPDES permit for compliance with amended BATW
discharge reguirements (i.e.. December 31. 20251.
APS is committed to successfully operating the new high-recycle BATW system. As previously
discussed with EPA, FCPP is a key resource for ensuring regional grid reliability over the near
term while APS transitions away from coal-fired plant ownership and operations by 2031.
APS appreciates EPA's input on our requested permit modification for FCPP. We welcome the
opportunity to discuss any additional feedback you may have on this proposal. If you have
any questions or would like to discuss this request in more detail, please contact Natalie
Chrisman Lazarr at (602) 316-1324 or via email at natalie.chrismanlazarr@aps.com.
Neal Brown
Environmental Operations Manager
Arizona Public Service Company
Cc: Mr. Jeffrey Jenkins, Plant Manager - APS, Four Corners Power Plant
Ms. Pamela Norris, Environmental Manager - APS, Four Corners Power Plant
Mr. Jeffrey Allmon, Senior Attorney - Pinnacle West Capital Corporation
Mr. Phil Smithers, APS, Director of Safety, Environmental, & Human Performance
* * * *
Sincerely,
2|
-------
Attachment 7: APS NPDES Permit
Modification Supplementary Information
-------
" - aps
Tel. 602-250-2414 PO Box 53999
Cell 602-284-3899 Mail Station 9303
e-mail: neal.brown@aps.com Phoenix, Arizona 85072
July 21, 2023
Electronically Submitted
U.S. Environmental Protection Agency, Region 9
NPDES Permits Section, Water Division (WTR-2-3)
Attn: Gary Sheth (Sheth.Garv@epa.QOv')
75 Hawthorne Street
San Francisco, CA 94105
Subject: SUPPLEMENTARY INFORMATION
Supporting a Permit Modification Pursuant to
Amended Standards in the Steam Electric Reconsideration Rule
APS Four Corners Power Plant - Fruitland, New Mexico
NPDES Permit No. NN0000019
Dear Mr. Sheth,
Pursuant to your request, this letter transmits supplementary information supporting
modification of the Four Corners Power Plant (FCPP) National Pollutant Discharge Elimination
System (NPDES) permit (No. NN0000019) pursuant to amended standards for bottom ash
transport water (BATW) in 40 CFR 423 - Steam Electric Power Generating Point Source
Category (i.e., the 2020 ELG Steam Electric Reconsideration Rule, 85 Fed Reg 64,650
(October 13, 2020)). Specifically, enclosed as Attachment 1 is a photograph log documenting
the substantial progress FCPP has made towards transforming our once-through BATW
system into a high-recycle BATW system. FCPP is on track to complete construction activities
before the end of 2023, and plans to conduct startup and testing between January 1, 2024
and June 29, 2024, as proposed in our January 26, 2023 letter. This letter also presents
estimated BATW flows to be discharged via our new low volume wastewater (LVWW) system
through outfall 01E during that 6-month high-recycle BATW system start-up period, which
will represent a 93% reduction from once-through BATW operations.
Discussion of Photograph Log. As depicted in Attachment 1, Arizona Public Service Company
(APS) has advanced installation of the high-recycle BATW system since our last update; we
are on track to complete construction activities during our planned 2023 Fall Outage and
conduct initial system commissioning with equipment checks before the end of the year. When
complete, we will have installed:
• 20,000 linear feet (ft) of pipe
• 15 new pumps (four vertical turbine, three centrifugal, and eight submersible pumps)
• 70,000 linear ft of medium voltage cable
• Greater than 100,000 linear ft of low voltage cable; and
• 177 tons of structural steel associated with the pipe rack and pipe supports
The attached photograph log, which provides photos taken on June 27, 2023 (unless
otherwise noted), shows the substantial progress FCPP has made to convert operations to the
high-recycle BATW system. The photograph log notes multiple process improvements that
will increase the treatment efficiency of our future system including (1) the addition of a new
polymer system upgradient of the Hydrobin system, (2) the installation of a new chemical
amendment system for pH/alkalinity control, (3) upgrades to the existing polymer system
upgradient of the Bottom Ash Sluice Water Return (BASWR) tank system for better
l|
-------
distribution, and (4) transition to hydraulic dredging of solids from the primary chamber of
the BASWR tank system in lieu of mechanical dredging.
Other improvements that are being made to the future BATW high recycle system include the
addition of two new 112,000-gallon Hydrobin Overflow Return Tanks that will provide
substantial surge capacity and flow equalization to recirculation system operations. Based on
the normal operating water level (7 ft) of these a 22-ft tall tanks, the surge capacity of this
tank system is 136,000 gallons. Additional surge capacity (149,000 gallons) is available in
the existing BASWR tank system which has 1 ft 9 inches of freeboard to its design capacity.
In summary, our efforts to improve treatment efficiency and add surge capacity will promote
system reliability and limit the need for future discharges of BATW from recirculation
operations due to water balance, water chemistry, and maintenance concerns. Even in the
face of supply chain and material availability constraints, FCPP has worked diligently to
convert the system and has made substantial progress to ensure that construction will be
complete before the end of 2023.
Estimate of BATW Discharges During Startup. As noted in our January 26, 2023 letter to EPA,
several global supply chain and material availability constraints outside of APS's control have
compounded to make startup and testing of our new BATW high recycle system impossible
before the end of 2023. Based on APS's request for a six-month startup period during which
recirculation operations will be required but interim discharge limits will not apply, EPA has
asked APS for an estimate of how much BATW could potentially be discharged during this
startup period with a comparison to how much would be discharged if once-through BATW
operations continued.
The latter is readily estimated based on past discharges as well as projected levels of electrical
generating unit operation from January 2024 through June 2024. As indicated in the graph
below, APS's generation of BATW in our once-through system is relatively consistent during
the months of June through December but can be more variable in the first half of the year
based on demand. Given lower demand for electricity in our service area from January through
May each year, APS generally schedules generating unit outages at FCPP for maintenance
during this time of year. For 2024, single unit outages for each of our electrical generating
units are planned. On this basis, theoretical BATW flows through internal outfall 01E (if the
recirculation system was not in place) would range from approximately 100 to 220 million
gallons per month, or 920 million gallons, during the first six months of 2024.
1 2022 Flow > 2024 Flow Without Recirculation
1 2023 Flow (to date) 2024 Startup Flow Estimate
_ 250.0
m £ X S \ f jr
d) i 150.0 \ X
to <2 \ /
-5 § loo.o
Q
CU
Ctf)
50.0
*—I1 n
o — _ +% 3m ^
1 0.0 V ** ^ ^
^ &
/ /• ^ ^ «/ /¦
-------
purging the system would take some time given the maximum rate at which BATW can be
purged from BATW recirculation operations to the LVWW system (i.e., 500 gallons per minute)
and the number of turnover volumes that would be required for a reset. Based on these
constraints, a conservative estimate of BATW discharges during startup would be 22 million
gallons per month for up to three months (65 million gallons) assuming three months of zero-
liquid discharge and three months of purging at the maximum recirculation system purge rate
to the LVWW system (which discharges to internal outfall 01E). This volume represents a 93%
reduction over the six-month startup period from once-through BATW operations.
APS appreciates EPA's input on and prompt consideration of our requested permit modification
for FCPP. We welcome the opportunity to discuss this supplementary information. If you
have any questions or would like to discuss this letter in more detail, please contact Natalie
Chrisman Lazarr at (602) 316-1324 or via email at natalie.chrismanlazarr@aDs.com.
Neal Brown
Environmental Operations Manager
Arizona Public Service Company
Attachment 1 - BATW Recirculation Project Photograph Log (Four Corners Power Plant)
Cc: Mr. Jeffrey Jenkins, Plant Manager - APS, Four Corners Power Plant
Ms. Pamela Norris, Environmental Manager - APS, Four Corners Power Plant
Mr. Jeffrey Allmon, Senior Attorney - Pinnacle West Capital Corporation
Mr. Phil Smithers, APS, Director of Safety, Environmental, & Human Performance
* * * *
Sincerely,
3|
-------
ATTACHMENT 1
BATW Recirculation Project Photograph Log (Four Corners Power Plant)
4|
-------
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
>aps
Photograph 1
Bottom ash hopper under
Unit4's boiler. Process flow
in the bottom ash
transport water (BATW)
sluice system begins with
the collection of bottom
ash from under each unit's
boiler. There are currently
two electrical generating
units operating at Four
Corners (Units 4 and 5)
and each unit has three
bottom ash hoppers to
collect bottom ash and
slag generated during coal
combustion.
Photograph 2.
Bottom ash sluice piping
located under the clinker
grinder at the base of one
of the bottom ash hoppers
of Unit 5. Ash and slag that
falls into each of the
bottom ash hoppers is
ground and then sluiced
with water from under
each unit. The BATW is
routed to a common sluice
pipeline system that
conveys the water and
solids to multiple BATW
treatment unit processes.
As depicted in this
photograph, the lack of
clearance below the
hoppers renders infeasible
the installation of
alternative bottom ash
handling technologies.
Page 1 of 10
-------
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
Daps
Photograph 3.
BATW sluice piping. After
collecting the sluice water
carrying bottom ash from
the individual hoppers, the
BATW sluice piping (one
pipe for Unit 4 and the
other for Unit 5) is routed
from the power block area
(where the units are
located) to a nearby ash
processing area.
Photograph 4.
New polymer amendment
system upstream of the
Hydrobin system. The APS
engineering team
identified the need to
enhance the performance
of the Hydrobin system in
planned recirculation
operations. The system is
installed and has been
operational since June
2023 (connections were
completed during the
Spring 2023 outage).
AS-1640
Page 2 of 10
-------
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
Photograph 5.
Hydrobins associated with
Units 4 and 5 (viewed from
beiow in the ash processing
area). Four Corners Power
Plant has used Hydrobin
systems to separate
bottom ash from sluice
water for much of its
operational history. BATW
laden with bottom ash is
directed to one of four
162,000-gallon Hydrobins
sequentially, promoting
reliable, gravity-driven
solids separation.
Photograph 6.
View of a filled Hydrobin
from the top of the bin
prior to the polymer
amendment upgrade in
March 2023. BATW laden
with bottom ash
discharges into one of the
bins until full; discharges
are then directed to the
next empty bin. Hydrobin
overflow water from the
bin is recovered either by
overflowing the serrated
weir located around the
bin perimeter or flowing
through a system of fine
mesh screen decanters
located along the sides of
the bins.
Photograph taken on March 23, 2023
Page 3 of 10
-------
Photograph 8.
View inside a Hydrobin
after sluice water has
drained from the bin.
Bottom ash drains readily;
the cycle time to drain a
bin is less than six hours.
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
Photograph 7.
View of a filled Hydrobin
from the top of the bin
after the polymer
amendment upgrade in
June 2023. Visible
increases in the treatment
performance of the
Hydrobin system were
observed following the
addition of polymer
upgradient of this system.
Page 4 of 10
-------
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
Photograph 9.
View inside a Hydrobin
after the bin has been
emptied of bottom ash.
Fine mesh decant screens
are visible along the sides
of the bin interior.
Photograph 10.
Ash haul truck being filled
from overhead Hydrobin
system. After filling, this
truck will transport the
bottom ash which has a
moisture content of
approximately 20% by
weight to an on-site Coal
Combustion Residuals
landfill.
Page 5 of 10
-------
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
Oaps
Photograph 11.
One of two new 112,000-
gallon Hydrobin Overflow
Return Tanks. Sluice water
separated from bottom
ash by the Hydrobin
system will be directed to
these tanks when
recirculation operations
begin. These tanks can be
operated individually or as
a coupled tank system to
provide surge capacity and
flexibility. Tanks and
pumps are in place;
electrical and
instrumentation
connections were in
progress in June 2023.
Photograph 12.
Hydrobin Overflow Return
Pumps. These pumps will
be used to convey water
processed in the Hydrobin
system to the Bottom Ash
Sluice Water Recycle
(BASWR) tank system for
additional treatment
during recirculation
operations. Three pumps
are installed; two pumps
are required for combined
U4 and U5 operations and
the third is an installed
spare for redundancy.
Page 6 of 10
-------
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
£>aps
Photograph 13.
i r>
1
<¦
New chemical amendment
system. Multiple pumps
InSSP
1
and metering equipment
jbb ' — - JffF W
1 ¦ tj& W
have been installed
II /^HL
immediately downstream
1 1 |
of the Hydrobin overflow
return pumps to inject
either acid, caustic or soda
1
ash (to supply alkalinity)
1 —- 'iX» . m 1
from future chemical feed
| 4| m m 1
totes. Since it is currently
unknown which chemical
I J | ^ Jjfj
1
adjustments could be
M 1 ri'f® >* -•
necessary, pumps and
/ ft if -J M|S^,r Kaff
¦
associated equipment
have been provided for an
/¦ 1 ¦inrnlS ~~ *
array of likely metering
P /
rates and chemical
v.V
compatibilities.
Photograph 14.
Piping routed through
baghouse area between the
ash processing area and
the BASWR tank system.
Multiple pipes are shown
because some pipes
convey flows from the
Hydrobin overflow tanks
and the bottom ash area
return sump to the BASWR
tank system for treatment
and some pipes convey
treated flows from the
BASWR tank system back
to Unit 4 and 5 for sluicing
and flush water. All
pipelines routed through
the congested areas of the
plant were in place as of
June 2023.
Page 7 of 10
-------
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
£>aps
Photograph 15.
Pipe rack upstream of the
BASWR tank system
influent. An exposed
pipeline conveyance
system was constructed to
ensure any issues
associated with this critical
system can be identified
and addressed
immediately. The area that
the pipe rack is routed
through is a high traffic
area which required that
the rack be elevated.
Photograph 16.
Discharge into the primary
ceil of the BASWR tank. In
addition to upgrading the
existing polymer
amendment system
upstream of the BASWR
tank to enhance polymer
distribution, a new method
of removing solids from
the BASWR system was in
place as of June 2023. In
lieu of mechanically
removing solids, hydraulic
dredging is now
performed to limit
disturbance of settling in
other portions of the pond
resulting in better
treatment performance of
the tank system.
Page 8 of 10
-------
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
Oaps
Photograph 17.
View looking west with the
pipe rack on the right and
the BASWR tank system on
the left. This portion of the
pipe rack supports piping
conveying treated water
from the BASWR tank
system back to the Unit 4
and 5 sluice and flush
water systems. The piping
is in place; electrical and
instrumentation
connections were in
progress in June 2023.
Photograph 18.
Sluice and flush pumps
above the BASWR tank
system clear well. Two high
pressure sluice pumps and
two low pressure flush
pumps are installed above
the BASWR tank system
clear well to recirculate
treated BATW back to
Units 4 and 5. Work to
complete pump intake
piping, electrical
connections, and control
system installation was in
progress in June 2023.
Photograph taken on July 7 7, 2023
Page 9 of 10
-------
BATW Recirculation Project
FOUR CORNERS POWER PLANT
Photographs taken on June 27, 2023 (unless otherwise noted)
£>aps
Photograph 19.
Secondary cells of the
BASWR tank system (to the
left) and the new Low
Volume Wastewater
(LVWW) treatment tank (to
the right). The LVWW
system was undergoing
concrete curing in June
2023. The concrete
contains a Xypex
admixture for
waterproofing. After
curing, the tank will be
leak tested in accordance
with ACI Standard 350.1
and independent oversight
by the design engineer.
Photograph taken on June 28, 2023
Photograph 20.
Valving on the flush water
system. During the Spring
2023 outage, recirculation
piping connections to the
sluice and flush water
systems at both units were
completed. Valving or
spectacle blinds were
installed during this
outage to isolate the new
recirculation piping from
existing systems so that
the plant could be placed
back into operation for
Summer Run. Valving and
spectacle blinds can
readily be repositioned for
the startup of recirculation
operations in the Fall of
2023.
Page 10 of 10
------- |