## Bailly Generating Station Advanced FlueGas Desulfurization System FINAL 

# ENVIRONMENTAL INFORMATION

VOLUME April 1989



# PureAir
ajcintventurecompany

Mitsubishi Heavy Industries America, Inc.TABLEOFCONTENTS

1.0 Introduction 2.0 The Proposed Action and Its Alternatives 2.1 The Proposed Action 2.1.1 Site Description 2.1.1.1 Site Location 2.1.1.2 Existing Plant Operation 2.1.2 Purpose of Project 2.1.2.1 Objectives 2.1.2.2 Project Justification 2.1.2.3 Economics 2.1.3 Engineering Description of the Proposed Action 2.1.3.1 Description of Project

Phases 2.1.3.2 Description of Process 2.1.3.3 Hazardous Releases 2.1.3.4 Project Source Terms 2.1.3.5 Potential Environmental

Health, Safety and Socioeconomic (EHSS) Receptors 2.2 Alternatives to the Proposed Action 2.2.1 The No-Action Alternative 2.2.2 Alternative Technologies 2.2.3 Alternative Sites 3.0 Existing Environment 3.1
3.2

3.3
3.4 Atmospheric Resources 3.1.1 Site Meteorology 3.1.2 Air Quality Land Resources 3.2.1 Geology 3.2.2 Seismology 3.2.3 Soils 3.2.4 Land Use Water Resources 3.3.1 Ground Water 3.3.2 Surface Water Ecological Resources 3.4.1 Terrestrial 3.4.1.1 Vegetation 3.4.1.2 Vertebrates Page 111 2-l 2-1 ;I; 2-5 2-l ;::: 2-18 2-18 2-18 2-23 2-35 2-38 2-44

2-46 2-46 2-46 2-48 3-l 3-l :I; 33:; 3-8 3';: 3-14 3-14 3-14 3-26 3-26 3-21 3-30TABLEOFCONTENTS(Continued)

3.4.2 Aquatic 3.4.2.1 Fish 3.4.2.2 Benthos 3.4.2.3 Zooplankton 3.4.2.4 Phytoplankton 3.5 Socioeconomic Resources 3.5.1 Population 3.5.2 Land Usage 3.5.2.1 Regional 3.5.2.2 Industrial 3.5.2.3 Agricultural 3.5.3 Public Services 3.5.3.1 Schools, Hospitals and

Nursing Homes 3.5.3.2 Transportation 3.5.3.3 Historical Sites and

Natural Landmarks 3.5.3.4 Recreation 3.6 Energy and Materials Resources 3.7 References 4.0 Consequences (Impacts) of the Project 4.1 Atmospheric Impacts 4.1.1 Construction 4.1.2 Operation 4.2 Land-Use Impacts 4.2.1 Construction 4.2.2 Operation 4.3 Water-Quality Impacts 4.3.1 Ground Water 4.3.1.1 Construction 4.3.1.2 Operation 4.3.2 Surface Water 4.3.2.1 Construction 4.3.2.2 Operation 4.4 Ecological Impacts 4.4.1 Construction 4.4.2 Operation 4.5 Socioeconomic Impacts 4.5.1 Construction 4.5.1.1 Transportation 4.5.1.2 Noise 4.5.1.3 Visual 4.5.2 Operation 4.5.2.1 Transportation 4.5.2.2 Noise 4.5.2.3 Visual Page 3-32 3-32 3-33 3-35 3-37 3-39 3-39 3-39 3-39 3-41 3-41 3-43 3-43 3-43 3-47 3-48 3-50 3-51 4-l
:I: 4-l :I: :I: 4-7 :r: :I; 4% 4-13 4-13 4-15 4-15 4-16 4-16 4-17 4-17 4-17 4-17 4-18

iiTABLEOFCONTENTS(Continued)

4.6 Energy and Materials Impacts 4.6.1 Construction 4.6.2 Operation 4.7 Impact Summaryand Mitigation Measures 4.7.1 Mitigation Measures 4.7.1.1 Atmospheric Mitigation 4.7.1.2 Land-Use Mitigation 4.7.1.3 Water-Quality Mitigation 4.7.1.4 Ecological Mitigation 4.7.1.5 Socioeconomic Mitigation 4.7.1.6 Energy and Materials

&litigation 4.7.2 Monitoring 4.7.2.1 Wastewater Monitoring 4.1.2.2 Air Monitoring 4.7.2.3 Solid-Waste Monitoring 4.7.2.4 Health and Safety

Consideration of Monitoring Requirements 4.8 Reference .: 5.0 Regulatory Compliance 5.1 Regulations and Permit Requirements 5.1.1 Regulations 5.1.1.1 Air Regulations 5.1.1.2 Wastewater Regulations 5.1.1.3 Solid-Waste Regulations 5.1.2 Permit Requirements 5.2 Anticipated Permits/Approvals 5.2.1 Air Emission Permits/Approvals 5.2.2 Solid-Weste Disposal Permits/ Approvals 5.2.3 Wastewater Discharge Permits/ Approvals 5.2.4 Other Permits/Approvals 6.0 Authors and Their Qualifications 6-l 6.1 Air Products and Chemicals, Inc. 6.2 Enviroplan, Inc. 6.3 Northern Indiana Public Service Co. 6.4 Pure Air 6.5 Stearns-Roger Division of United Engineers &Constructors Inc. Page 4-19 4-19 4-19 4-21 4-21 4-21 4-22 4-22 4-23 4-23 4-24 4-24 4-25 4-25 4-26 4-27

4-28 5-l

55::. 5-l 5-2 ;I; ;I:: 5-7 5-8 5-9

iiiLIST OFTABLES

Table 2.1-1:
2.1-2:
2.1-3:
3.2-l: 3.3-l:
3.3-2:
3.3-3:

3.4-l:
3.4-2:

3.4-3:

3.5-l:

3.5-2:

3.5-3:
3.5-4: Innovative Features of AFGDSystem

Versus Conventional FGDTechnology Capital Cost Savings Features of the AFGDSystem Operating Cost Savings Features of the AFGDSystem Modified Mercalli Scale Freshwater Wetland Classification Indicated in Figure 3.3-l Wetlands and Deepwater Habitats Classification Indicated in Figure 3.3-l Summaryof Flood Elevations for Lake Michigan Near Unincorporated Areas of Porter County to Include the Bailly Generating Station Abundant Bird Species Knownto Nest in the Indiana Dunes Area Fish Species Verified in the Aquatic Community of the Bailly Generating Station and Its Vicinity Benthos Commonto Non-Lake Michigan Aquatic Communities of the Bailly Generating Station and Its Vicinity Population Data for Incorporated Communities Within Five Miles of the Bailly Generating Station Major Manufacturing Activity Within a 5-Mile Radius of the Bailly Generating Station Hospitals Within a 12-Mile Radius of the Bailly Generating Station Public School Enrollment for Communities Within a 12-Mile Radius of the Bailly Generating Station Page 2-8
2-19
2-21
3-9 3-16
3-18
3-25

3-31
3-34

3-36

3-40

3-42

3-44
3-44

ivLIST OFTABLES(Continued)

Table 3.5-5:

4.3-l:
4.3-2:

5.1-1:
5.1-2:
A-l:

A-2:

A-3: Nursing Homesand BedTotals Within

a 12-Mile Radius of the Bailly Generating Station Projected Wastewater Composition from the AFGDProcess to On-Site Ponds Comparison Between Existing and Proposed Wastewater Discharge to Lake Michigan, and Preliminary Water Quality Based Permit Limits Anticipated Permits/Approvals and Responsible Agencies Existing Bailly Generating Station NPDESPermit Effluent Limitations Endangered, Threatened and Rare Plants Found in the Indiana Dunes National Lakeshore, Porter County (State of Indiana List) Endangered, Threatened and Rare Animals Found in the Indiana Dunes National Lakeshore, Porter County (State of Indiana List) 1989 Federally Threatened and Endangered Flora and Fauna Found in the Indiana Dunes National Lakeshore Page 3-45

4-10
4-12

5-4
5-6
A-4

A-7

A-9

VLIST OFFIGURES

Figure 2.1-1: 2.1-2: 2.1-3: 2.1-4: 2.1-5: 2.1-6: 2.1-7:
2.1-8: 2.1-9:
3.1-1: 3.2-l:
3.2-2:
3.2-3:
3.2-4: 3.3-l:
3.3-2: 3.4-l: 3.5-l:
C-l: Location Map

Westchester Township Zone Map Proposed Project Schedule Bailly Generating Station Site Plan Proposed AFGDSystem Plot Plan Process Flow Schematic Sulfur, Gypsumand Limestone Balance: AFGDDesign Condition Chloride Balance: AFGDDesign Condition Water Use and GasTemperature: AFGD Design Condition Page 2-2 2-4 2-22 2-26 2-27 2-28 2-29
2-30 2-31
Windrose '84-'86 DuneAcres Data 3-2 ;Fd;a;Ftigraphy of Porter County, 3-6
Surficial Geology in Vicinity of Bailly Generating Station Soil Composition - Bailly Generating Station Area 3-7
3-11
Land-Use Map Wetlands Mapof the Bailly Generating Station Vicinity Seasonal Currents of Lake Michigan Vegetation Analysis Major Roadways and Recreational Land Use 3-13 3-15
3-23 3-28 3-46 Existing Permitted Discharge Locations C-6

ViLIST OFAPPENDICES Page

Appendix A: Information Letter from Indiana A-l

Department of Natural Resources, Information on Endangered, Threatened and Rare Plants and Animals Found in the Indiana Dunes National Lakeshore, Porter County (State of Indiana and Federally Listed Species) Appendix B: Archeological and Historical Surveys B-l Appendix C: Bailly Generating Station Waiver C-l

from Ground Water Monitoring Requirements, and Permits for Wastewater Discharges and Air Emissions Appendix D: Documentation of Agency Contacts Appendix E: U.S. Department of Energy, and

Burns and RoeComments on Draft Environmental Impact Volume D-l E-l

vii1.0 INTRODUCTION
Pure Air, ajoint venture between Air Products and Chemicals, Inc. and Mitsubishi Heavy Industries America, Inc., is proposing to design, construct and operate an advanced flue gas desulfurization (AFGD) system that affords numerous technological and commercial advantages over existing systems. The project will be funded by Pure Air and the U.S. Department of Energy (DOE) as part of the DOE's Innovative Clean Coal Technology Program. The AFGDsystem will be installed and operated at the Northern Indiana Public Service Company's (Northern Indiana) Bailly Generating Station located approximately 12miles northeast of Gary, Indiana onthe southern shore of Lake Michigan.

Significant decreases in sulfur dioxide (S02) emissions from high sulfur coals are expected to result from operation of the AFGDsystem: guaranteed 90 percent reduction during operation, and testing at 95percent. Operation of the system will demonstrate not only ahigh efficiency of SO2 removal on high sulfur coals, but also will demonstrate the following technological features8
1.

2.

3. The applicability and reliability of flue gas desulfurisation (FGD) using asingle module to control emissions from multiple boilers;
The functionality of asingle loop, in-situ oxidation gypsum producing absorber on high sulfur and high chloride coals; and,
The demonstration of an evaporation system to minimize wastewater disposal problems inherent with many FGDsystems.

l-1E-l In addition to these technological features, the

demonstration project will advance several important and highly innovative commercial features that also contribute significantly to agreater reduced cost for achieving SO2 emission overview
1.

2.

3.

4. reductions over conventional FGDsystems. An - of these features follows:
Pure Air will ownand operate the AFGDfacility during the demonstration period of three years and later during commercial operation. This approach will result in substantial operational savings compared to existing FGDsystems. Multiple boilers connected to asingle module will significantly reduce costs at power stations with multiple smaller boiler units.
The production and potential sale of high quality, by-product gypsum (minimum 95weight percent CaS04* 2H20, typically 1.9 weight percent CaC03and 3.1 weight percent inert) will also contribute to the savings achieved by this demonstration project, and minimize the problem of solid-waste disposal. As part of the proposed effort, Pure Air has obtained statements of interest from wallboard manufacturers to purchase the by-product gypsum. Powdered limestone will be used in the AFGDsystem. The purchase and dry charging of powdered limestone, based on preliminary quotes, should significantly reduce the capital and operating costs of the AFGDsystem.
The intent of Pure Air and Northern Indiana to enter into acommercial arrangement whereby Pure Air will continue to ownand operate the AFGDfacility at the Bailly

l-2Station for the 17-year commercial period, after the

successful completion of the demonstration program, constitutes aunique and commercially attractive industrial alternative to the utility own/operate scenario. This commercial operation will result in asignificant reduction of interstate SO2emissions during the 17-year commercial period.
The purpose of this Environmental Information Volume (EIV) is to provide to the DOEadata base, analyses and impact assessments for the AFGDsystem. The EIV follows the guidelines established in the DOE's Environmental Guidance Manual and addresses the environmental issues associated with development and commercial operation of the AFGDsystem.

The comments madeby the Department of Energy on the Draft EIV have been included asAppendix E. Each comment has been numbered and the response is referenced in the text by notation(s).

1-32.0 THEPROPOSED ACTIONANDITS ALTERNATIVES
2.1 THEPROPOSED

ACTION
As indicated in Section 1.0, Introduction, Pure Air proposes to install an advanced flue gas desulfurization (AFGD) system at Northern Indiana's Bailly Generating Station, which occupies a300-acre tract in Porter County, Indiana (Figure 2.1-1). Whenconstructed, the AFGDsystem will occupy approximately four acres of land on the station site.
TheAFGDsystem is designed to process flue gas from coals containing between 2.0 and 4.51 weight percent sulfur, which is typical of coals found in the Illinois/ Indiana basin. The project will utilize Mitsubishi's basic wet limestone flue gas desulfurization technology with many advanced features to achieve high SO2removal efficiency (90 percent capability) on these coals. This will be achieved at extremely low capital and operating costs (approximately 50 percent of the cost of currently available systems). In addition, the system will be operated to demonstrate the potential for reducing solid- or liquid-waste disposal problems. Part of the process' by-product will be ahigh quality gypsum which maybe sold to awallboard manufacturer or other user of high-quality gypsum.

TheAFGDsystem will be run for ademonstration period of three years as part of the U.S. Department of Energy's (DOE) Innovative Clean Coal Technology Program. After the successful completion of this demonstration period, Pure Air and Northern Indiana intend to enter into a commercial arrangement whereby Pure Air will continue to own and operate the AFGDSystem for an additional 17years giving the system a20-year life cycle. E-4

E-2

2-lKAGO

ajoint venture company ADVANCED FLUE2.1.1 Site Description
TheAFGDsystem and supporting facilities will be constructed on a4-acre tract adjacent to Units 7and 8of the existing Northern Indiana Bailly Generating Station. The 300-acre site is entirely owned by Northern Indiana, and was originally purchased in 1932. All activities within the boundaries of the site are currently confined to the generation of electrical power.

Because the site is located in anarea that is well industrialized, access to the site is readily available by way of railroads and main highways. Highway 12 runs along the southeast section of the site as does the Chicago, South Shore &South Bend Railroad. Highway 20 passes within two miles of the site, and Interstate Highway 94 is located five miles south of the site. The Bailly Generating Station is zoned for heavy industry, as indicated on Figure 2.1-2, "Westchester Township Zone Map," and is suitable for the AFGD system.
2.1.1.1 Site Location

As indicated above, the Bailly Generating Station is located in Westchester Township, Porter County, Indiana on the southern end of Lake Michigan. It is 12 miles northeast of the center of Gary, Indiana, between the towns of Ogden Dunes three miles to the west and DuneAcres two miles to the east. Lake Michigan is north of the plant site and Bethlehem Steel Corporation, south and west. Tothe west are the Port of Indiana and Midwest Steel. The Indiana Dunes State Park and Indiana Dunes National Lakeshore are also primarily to the east. The towns of Portage, Burns Harbor, Chesterton and Porter lie within five miles south of the station. Additionally, the downtown Chicago Loop area is about 30

2-3ZONE MAP LEGEN fg ILla., “l.IoI”llAL fg ;~~~,.‘:,~:““;;~~;~~~L “YLIWLE T.YIL” “1,1L%C”71.1 “IIIOL”ll., YO,kl “0115 “LlO”,Ol”cJOD.Y.l”l.. O,,lC,I .w I”lllr”110”~ ,“O,.I”C CC”lC” .“,,*.*I O,“,“)\L ,“sI*Ess LIO”, I”W~T”” C‘“l”ll I*oYsr”. “1.“. I”O”~II” ,O”,CYLIWLL0.C” ‘UCI P”~s1”“*tlc.* lLOO0,L.W 1:&r T-c’- :
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### WESTCHESTER TOWNSHIP 1

PORTER COUNTY, INDIANA PREPARED FORTHEPORTER COUNTY PLAN COMMIS8K)N I



## & Pure Air A ajoint venture company ADVANCED FLUE OAS DESULFURIZATION Westchester Township Zone Map Figure 2.1-2miles northwest; the Illinois-Indiana boundary is about 21

miles due west; Michigan City, Indiana, and the Indiana-Michigan boundary are about 13and 18miles east northeast of the station, respectively.

The legal description of the site is as follows: the west and south l/2 of Section 21, Township 37 North, Range 6West of the Second Principal Meridian in Westchester Township, Porter County, Indiana.
2.1.1.2 Existing Plant Operation

The main plant consists of two high-pressure steam boilers, each connected to its ownsteam turbine generator. The station went into commercial operation on December 1, 1962, when the first unit, Unit 7, rated at 183,000 ICW went "on line". The second unit at the station, Unit 8, entered service in 1968 and is rated at 345,000 KW.

The coal burned in the boilers is delivered to the plant in railroad cars. The boilers consume approximately 1.1 million tons of coal ayear - approximately 50 railroad cars per day. Although coal is the normal fuel, natural gas can also be burned in the boilers.

At full load, Unit 7boiler produces 1,200,OOO pounds of steam per hour at apressure of 2,400 pounds per square inch and atemperature of l,OOO" F. Unit 8produces 2,600,OOO pounds of steam per hour at apressure of 3,500 pounds per square inch and atemperature of l,OOO" F. Each boiler supplies asteam turbine generator rotating at 3,600 RPMand producing electricity at 22,000 volts. After the steam passes through the turbines it is condensed to water and used over again in the boilers.

2-5E-27 The units have acombined gross electrical

capability of 528,000 KW,most of which is distributed to Northern Indiana's customers. The remainder is used to operate plant auxiliaries.

Power from the generators is fed to Northern Indiana's 138,000 volt electrical lines through large transformers. These high voltage lines transmit the electricity to communities served by Northern Indiana in the northern third of Indiana.

Electrostatic precipitators (ESP) are used to control particulate emissions from the Bailly Station and collect fly ash. This fly ash and furnace bottom ash are the two solid-waste streams from the station's boilers. These waste streams are exempted from the Resource Conservation and Recovery Act (RCRA) Subtitle CHazardous Waste Regulations by 40 CFRPart 261.4(b)(4). They are also exempted from Indiana solid-waste regulations as long as they are used for approved beneficial purposes.

Currently the Bailly Station ash is sold to a broker for resale for other uses or for disposal out-of-state. Based on present estimated operating conditions, the approximate distribution of ash is as follows:
Bottom ash to holding ponds 60,000 tons/year

Fly ash to storage silo 39,800 tons/year Fly ash to stack emissions 200 tons/year
The Bailly Generating Station also has awastewater discharge to Lake Michigan. The wastewater initially is directed through aseries of on-site retention ponds and is recycled through the station on an as-needed basis. These discharges are regulated under aNational Pollutant Discharge

2-6Elimination System (NPDES) Permit covering the main outfall,

intake deicing and other internal discharges. Typically 221 E-6 million gallons per day, consisting primarily of non-contact cooling water, are discharged to Lake Michigan (Appendix C). E-53

The station is operated under permits issued by the E-6 Indiana Department of Environmental Management. These permits are discussed in more detail and in relation to the AFGDsystem in Section 5, Regulatory Compliance.
2.1.2 Purpose of Project
2.1.2.1 Objectives

The primary purpose of the project is to demonstrate that significant quantities of SO2emissions can be reduced at acost of approximately 50 percent of the cost of currently available FGDsystems. This will be accomplished by combining wet limestone AFGDtechnology, highly efficient plant operation and maintenance capabilities, and potential gypsum sales.
2.1.2.2 Project Justification

TheAFGDsystem will contain several innovative features as shown in Table 2.1-l. These features have been pilot-tested or commercially applied to various degrees in similar applications, such as oil-fired plants or low sulfur applications. These features have not been combined in a single system in the United States. In addition, the AFGD system has not been operated on medium-to-high sulfur coals typical of the United States power plants that are suitable for retrofitting. TheAFGDsystem is expected to remove E-7 greater than 90percent of the SO2from the inlet flue gas. As part of the 20-year processing agreement with Northern Indiana, Pure Air will guarantee a 90 percent SO2removal

2-7TABLE2.1-1: INNOVATIVE FEATURESOFAFGDSYSTEMVERSUS CONVENTIONALFGDTECHNOLOGY
Advanced Flue Gas Desulfurisation Innovative Feature 528 MWabsorber module 20 ft/sec co-current high velocity absorber Single loop absorber vessel to absorb SO limestone, 4' react with

adoxidise to gyPSum Air rotary sparger combines agitation and oxidation with low air volumes Wastewater Evaporation System demonstrates wastewater reduction capability Potential for no solid or liquid waste from process 90 percent or greater SO2removal Direct injection of pulverised limestone from offsite supplier Nospare module On-line chemical process monitors Operation and ownership by achemical company, separate from power plant operation Conventional Flue Gas Desulfurization Technoloav 125 MWmodules in U.S. 10to 13 ft/sec countercurrent flow Dual loop with separate reaction and oxidation unit operations with complex chemistry and control Separate agitator and oxidation equipment resulting in higher air volumes Produces awastewater stream

Produces solid and/or liquid waste streams Typically 90percent SO removal 2 On-site limestone pulverisation or grinding
At least one spare module Noon-line monitors Utility owns and operates, often with little chemical expertise

2-8efficiency for coals with asulfur content of between 2.0 and

4.51 weight percent. The following discussion expands on the information provided in Table 2.1-l.
A. Absorber Module

This project proposes to install an absorber module to treat the flue gas from the Bailly Station. In the United States the typical practice is to install multiple modules of approximately 125 MW. The multiple module design is seen as providing ahigher degree of reliability by most utilities. In addition, the U.S. Environmental Protection Agency's New Source Performance Standards (NSPS) require continuous operation of the FGDsystem during power-plant operations which leads utilities to install several smaller size modules with one spare. Thus, there is no United States experience with very large sized absorber modules. Large size modules (600 MW)have been successfully operated in Japan. This success indicates that this technological feature is ready for use in the United States on high sulfur coals.
B. Co-Current High Velocity Absorber

The proposed project incorporates aco-current rather than acounter-current flow absorber module. In addition, the flue gas velocity through the absorber is designed to be about twice as high as conventional FGD systems. Conventional processes use acounter-current spray tower design, where the flue gas velocity through the spray tower is typically in the range of eight to 10 feet per second at full load. The proposed co-current design is based on aflue gas velocity of 20 feet per second through the absorber at full load. This higher gas velocity has the effect of decreasing the absorber area requirement by 50 percent thus making it muchmore practical to retrofit this absorber in arestricted space. The co-current tower design

2-9E-8 E-13 E-18 also has the advantage of a reduced pressure drop since both

the liquid and the gas are flowing in the samedirection rather than opposite each other.

Pure Air is of the understanding that the co-current design has been applied in the United States in only two instances. The Tennessee Valley Authority (TVA) tested a 10MWco-current pilot plant FGDscrubber at the Shawnee Power Plant in Paducah, Kentucky. The test reports from this pilot plant were very encouraging and the co-current design was considered asuccessful test. Ona commercial scale, Hoosier Energy in Indiana has installed and successfully operated eight 125 MWco-current absorber vessel FGDsystems at their MeromStation since 1982. The design velocity for these vessels was 12feet per second. Worldwide, Mitsubishi Heavy Industries (MHI) has installed over 12,000 MWof co-current absorber vessels. The high velocity design however, is arecent innovation resulting from pilot plant work at MHI's Hiroshima Technical Institute. From MHI's experience at Hoosier Energy, the higher gas design velocity for the proposed project represents a61 percent increase over technology currently demonstrated.
C. Single-Loop Commercial Gypsum Production

The proposed process includes the design of a single-loop absorber vessel to absorb S02, (inlet concentration of 3,055 ppmdry) react with limestone, and oxidise to gypsum. This process differs from others that produce acommercial gypsum. In both the United States and worldwide, other processes employ adual-loop quencher absorber vessel that relies on complex chemistry and control. Experience in the United States with this dual-loop process has met with limited success in both achieving SO2removal guarantees and producing acommercial gypsum product. Worldwide, the standard process for producing commercial

2-10gypsum requires separate reaction and oxidation unit

operations. The oxidation step is typically carried out in a separate vessel with a lower pHto enhance oxidation. The advantages of the single-loop process are simplicity of operation and cost savings in equipment.

Elsewhere, this EHI process has been applied at the Kuraray Company Ltd. Saijo Plant in Japan. This plant started operation in 1985 and operates on an industrial petroleum coke-fired boiler with acapacity of 3.5 x lo6 cubic feet per hour. MHI supplied the FGDsystem which operates with an inlet SO2concentration of approximately 3,000 ppm. Successful application of the single-loop commercial gypsum process at this plant over the past four years indicates its technical readiness for demonstration on the proposed project. This process has not been applied either in the United States or on acoal-fired power plant elsewhere. As part of the 20-year processing agreement with E-9 Northern Indiana, Pure Air will guarantee the gypsum product purity within arange of coal sulfur content (as specified in Section 2.1.2.2) and normal boiler operation at the Bailly Generating Station. As noted in Section 2.1.2.2, SO2removal is also guaranteed at 90percent by Pure Air.
D. Air Rotary Sparser

The proposed project incorporates aunique air rotary sparger (ARS) system that combines the function of agitation and oxidation. TheARSis aspecially designed agitator with a hollow shaft, arms and holes for air sparging. The rotation of this agitator results in the formation of fine air bubbles that increase the contact area between the air and slurry. Oneadvantage of this design is the decrease in air requirements for oxidation to approximately 40to 50 percent of that required by conventional air sparging systems. Another advantage is the

2-11E-10 reduction of equipment required by combining both the

agitator and air sparging equipment into one design. Conventional systems typically require acomplex network of piping throughout the reaction tank to assure complete oxidaton of the absorbed SO2to gypsum. This unique rotary sparging system has been tested by MHIat their Hiroshima Technical Institute in Japan at a50 MWscale test unit. The ARSis also being tested at the Hoosier Energy, Merom Station.

E. Wastewater Evaporation System

The proposed project will demonstrate aprocess step to pumppart of the wastewater produced in the gypsum dewatering operation back to the flue gas upstream of the electrostatic precipitator for evaporation. Lime is used to neutralise the water stream. In existing installations where sufficient ductwork exists between the air heater and precipitator, this wastewater can be sprayed directly into the ductwork for evaporation. At the AFGDdesign condition, the flow and composition of the dried solids which will be produced by the wastewater evaporation system are listed below: Compositon Weight Percent

CaC12 73.1 Ca(OHj2 0.4 &Cl2 15.6 CaS04*2H20 9.4 CaF2 0.2 Others 1.3 Flow, Lbjhr 1181.3
These solids will be collected along with approximately 20,000 lb/hour of fly ash in the existing

2-12electrostatic precipitators. Since the solids are removed at E-12

this point, they do not enter the downstream SO2removal equipment and do not affect SO2removal efficiency. This feature is described later in Section 2.1.3.2 and the water use for the design condition is provided in Figure 2.1-9.

This unique feature is madepossible through the development of aproprietary dual-fluid nozzle by MHI. This nozzle produces avery fine droplet distribution with a minimum of droplets in the larger size ranges typically found in other dual-fluid nozzles.

The wastewater evaporation system technology has been demonstrated by the Kansai Electric Power Company Kainan Station in Japan for the past two years. This plant employs acommercial grade gypsum FGDsystem supplied by MHIon a 125 MWoil-fired boiler. The SO2content of the flue gas is approximately 500 ppmwith a 90 percent reduction by the FGD system. The success of this smaller unit and the extensive development work of the spray nozzles required for humidification indicate that this feature is ready for application to the 500 to 600 MWlevel. This wastewater evaporation system has never been demonstrated at these levels, in the United States or on acoal-fired boiler worldwide. The scale-up of the wastewater evaporation system E-14 from the work at Kainan Station will not affect the performance of the downstream SO2removal equipment. The sulfur balance using the design coal for the AFGD(4.51 weight percent sulfur) and 90percent SO2removal efficiency is provided in Figure 2.1-7 in Section 2.1.3.2; whereas, the E-11 chloride balance is shown in Figure 2.1-8, and water use and gas temperature are shown in Figure 2.1-9.

2-13E-15 F. Potential for NoSolid or Liquid Waste E-16 The proposed AFGDsystem will demonstrate the

potential for producing no solid or liquid waste from any portion of the process. Most operating FGDprocesses in the United States produce asolid-waste stream consisting of scrubber sludge and amixture of fly ash and limestone which is landfilled as aU.S. Environmental Protection Agency, E-15 Resource Conservation and Recovery Act exempt or

non-hazardous waste. The few regenerable FGDprocesses in the United States producing gypsum, sulfur, or sulfuric acid have a liquid wastewater discharge in order to control contaminants in the commercial by-product. The proposed system, through the production of commercial grade gypsum and the use of the wastewater evaporator system, will demonstrate E-16 the potential for producing less liquid or less solid waste

from the process. Of all the FGDsystems operating in the world today, the proposer is aware only of Kansai Electric Power Company's Kainan Station using the wastewater evaporator system and producing no solid- or liquid-waste streams. This process feature has never been demonstrated in the United States or on high sulfur coal applications.
G. High SO2Removal

The proposed AFGDsystem will be designed to operate at an SO2removal efficiency of 90 percent with an E-8 inlet flue gas concentration of SO2of 3,055 ppmdry. In the E-13 United States, a 90 percent SO2removal level is the accepted E-15 technology and corresponds to the current limits of the New

Source Peformance Standards. Although some FGDsystems have been nominally designed for an SO2removal level of 95 percent (City of Muscatine, IA), consistent achievement of this high level has never been demonstrated. Other utilities (Basin Electric - Laramie River) have reported SO2removal levels in this range on a low sulfur coal, but again not on a

2-14consistent basis. High SO2removal designs have recently

been installed in Germany and are currently coming into operation. These designs generally have 95percent or greater SO2removal, but are typically on a low sulfur coal (l-percent level). In Japan, some systems have achieved a 90 to 95 percent SO2level, but again on lower sulfur coals. Thus, high SO2removal has never been demonstrated consistently in acost-effective manner either in the United States, or on ahigh sulfur coal. AFGDperformance guarantees have been described earlier in this section. E-17
H. Direct Injection of Pulverized Limestone

The proposed AFGDsystem is designed to utilize pulverized limestone from a limestone supplier and directly inject this pulverized limestone into the absorber vessel based on process demand. This process feature eliminates the need for on-site limestone unloading equipment (mechanical conveyor and bucket elevators), bulk limestone storage, limestone ball mills, and the limestone slurry tank agitator and pump. This equipment would be replaced by pulverized limestone storage silos and ablower for pneumatic conveying to the process.

The conventional United States practice is on-site wet ball mill grinding in aclosed circuit loop with cyclone classifiers in order to produce the particle size distribution required for the process. The limestone is added to the process by means of a20to 30 percent slurry based on process demand. Conventional foreign practice both in Japan and West Germany is to purchase pulverized limestone with on-site slurrying. The proposed design is aimed specifically at the retrofit market where the economics for a 15- to 20-year retrofit plant are different from those of a 30- to 40-year newgrass roots plant. Onashorter plant life, it makes economic sense to avoid the expensive capital

2-15cost of grinding equipment, and instead purchase pulverised

limestone directly from asupplier. The reduced equipment requirement also enhances the ability to retrofit other existing plants.

Onaworldwide basis, the only plants of which Pure Air is aware that both purchase pulverized limestone and directly inject pulverised limestone to the process are the West German Veba Kraftwerke Ruhr AG's seven FGDunits. These are 370 MWplants using West German brown coal. The earliest one started operation in November 1985. The FGDsystems were designed by MHIto produce acommercial grade gypsum with an inlet SO2concentration of 1,050 ppmdry and an SO2removal efficiency of 95percent. This innovative feature has never been demonstrated in the United States at the 500 to 600 MW E-18 level or on ahigh sulfur coal. Additionally, the proposed

AFGDsystem will have an inlet SO2concentration of 3055 ppm dry.
I. NoSpare Module

E-19 The proposed demonstration project does not intend

to include a spare module in its design while maintaining a high availability of the AFGDsystem for the Bailly Station. The current United States practice is to incorporate at least one spare module and sometimes two to assure the overall high availability of the FGDsystem to the utility. This design practice, to include aspare module, is essentially directed by the current NewSource Performance Standards in effect since 1978. Air emissions from the AFGDsystem and the Bailly Station are discussed in Section 4, Consequences (Impacts) of the Project and Section 5, Regulatory Compliance.

On a worldwide basis, the commonpractice is to design the FGDsystem with no spare module. However, United

2-16States utilities are very reluctant to accept this design

feature until successfully demonstrated in this country. Therefore, Pure Air believes that the demonstration of an AFGDsystem that includes no spare module is an essential part of the proposed process. The cost advantages of the elimination of aspare module are significant.
J. Continuous Chemical Process Control Monitors

The key to the operability and availability of the overall AFGDchemical process is the inclusion of continuous monitors to measure major process parameters. These parameters include chloride, sulfite and carbonate concentrations. The conventional United States practice regarding these three chemical constituents has been to ignore them totally on acontinuous basis since no continuous monitoring devices have been available. Chloride concentration is sometimes monitored on a grab sample basis for systems that produce asaleable gypsum product. MHI has developed acontinuous monitoring capability that has been in service to a limited degree on recent FGDsystems supplied in Japan. The monitors are commercially available, but have never been tested in either the United States or on a high sulfur coal-fired FGDfacility.

K. Ownand Operate AFGDSystem by Chemical Company

The proposed project is structured so that the AFGD system will be designed, constructed, owned, operated, and maintained by acompany separate from Northern Indiana. Although the system will be operated on utility land, all operation and maintenance personnel will be supplied by a separate chemical company (Air Products and Chemicals, Inc.), and the responsibility for the AFGDsystem operation will be totally separated from that of the power plant.

2-17The conventional practice worldwide is for the

utility to own and operate the FGDsystem. Since the utility is ultimately responsible for all emissions from its power plant, it has remained accepted practice for the utility to ownand operate the FGDsystem. The advantage of a separate operator for the AFGDsystem is that Air Products and Chemicals, Inc. has the technical expertise to operate the AFGDsystem, both to minimize the operating cost and to E-20 assure a high availability to Northern Indiana. However,

Northern Indiana is ultimately responsible for SO2 excursions. The air emission operating permit will be in Northern Indiana's name.

Pure Air believes the ownership and operation of an FGDsystem by aseparate company has never been proposed or put into practice anywhere in the world.
2.1.2.3 Economics

The costs developed for the proposed project represent asavings of approximately 50 percent in capital and 50 percent in operating costs over aconventional forced oxidation FGDsystem applied as aretrofit to an existing plant. Tables 2.1-2 and 2.1-3 summarize the capital and operating cost savings of the proposed AFGDsystem.
2.1.3 Engineering Description of the Proposed Action
2.1.3.1 Description of Project Phases

TheAFGDproject will take 81months to complete from selection with an anticipated July 1992 on-stream date as illustrated in Figure 2.1-3. Pure Air will conduct the technology demonstration project in three phases.

2-18TABLE2.1-2: CAPITAL COST SAVINGSFEATURESOFTHE AFGDSYSTEM(l)
AFGDFeature Cost Savinqs 1. 528 MWAbsorber Nodule Asingle module represents approximately a lo-percent cost savings over a multi-module &sign. 2. High Velocity Absorber The design velocity of 20 feet per second for the co-current scrubber as compared to 10feet per second for conventional spray towers results in an absorber area which is 50 percent of conventional and aflat plate perimeter area savings of approximately 30 percent. 3. Single Loop Absorber Vessel Being able to accomplish all process steps (absorption of SO reaction with limZ'

stone, oxidation to gypsum) in a single vessel represents a significant savings over commercially available systems. Other conventional designs include atwo-loop process or aseparate external oxidation step. 4. Air Rotary Sparger

5. Direct Injection of Pulverized Limestone Combining the tank agitation and oxidation into one piece of equipment eliminates the cost of the complex network of air sparger piping normally required in other conventional systems. Purchase and injection of pulverized limestone eliminates the need for on-site wet grinding normally accomplished by ball mills. Typical retrofits with 20years of life or less would benefit from this cost saving feature. 2-19TABLE2.1-2: (Continued)

AFGDFeature 6. NoSpare Module

Note to Table 2.1-2: Cost Savings The ability to maintain high availability with only asingle module is also an essential part of the cost saving features of the proposed technology. Elimination of aspare absorber module represents asignificant cost saving.

(1) Capital cost savings for items 3through 6are estimated to be at least 10percent over conventional FGDsystems.

Z-20TABLE2.1-3: OPERATINGCOSTSAVINGSFEATURESOFTHE AFGDSYSTEM(l)
AFGDFeature 1. Commercial Gypsum

2. Co-Current Tower Design

3. Air Rotary Sparger

4. Single Module

Note to Table 2.1-3: Operating Cost Savings Commercial gypsum represents an $0 or more per ton credit versus approximately a $10 liability for conventional waste-producing systems, for an overall differential of $18 per ton savings for the AFGDsystem. The co-current absorber tower inherently has a lower pressure drop than conventional counter-current spray towers. This savings is somewhat offset by the higher velocity used in the co-current design. The air rotary sparger has ahigher efficiency of oxidation than a conventional system. Approximately 50 percent less air is required for oxidation with the air rotary sparger than in conventional sparging systems. Reduction in the number of equipment items will reduce operation and maintenance costs over competing multi-module systems.

(1) Operating cost savings for each item are estimated to be at least 10percent over conventional FGDsystems.

2-21

## - _ ‘.

. I I I I I I

. .

. .

. .

. .Phase 1: Design and Permittinq
This initial phase will culminate in the detailed design of the AFGDsystem for the Bailly Station. Aprogram plan will be prepared for the equipment construction and demonstration testing.
Phase 2: Construction and Startup

This phase will begin during the second half of Phase 1and will last 27 months. Following DOEapproval, the AFGDequipment will be installed and checked out at the Bailly Station. As presently envisaged, project related structures will be constructed at grade. Building foundations will not extend more than six feet in depth. The stack will be erected on apiled foundation.
Phase 3: Operation, Data Collection, Reportinq and

Disposition
Phase 3will begin'at the completion of Phase 2and will last 36months. Following DOEapproval, the AFGDunit will be tested for three years over arange of conditions. All data and test results will be compiled into afinal report that will be made available to DOE.
2.1.3.2 Description of Process

The AFGDsystem will be ablend of new innovative process technologies and existing process technologies (updated, improved upon and/or scaled upwards from what is seen at existing plants). The AFGDsystem also will be the first-time demonstration of various process features on high sulfur United States coals, and the integration of all of these various process components into asingle scrubbing process.

2-23The final design of the AFGDsystem will be based

on an Illinois/Indiana basin coal having the following ultimate analysis:

Component Percent by Weiqht
S C H H2G N Cl Ash 0 HHV 4.51 maximum 58.81 4.46 13.50 1.14 0.25 maximum 10.25 7.08 10,982 Btu/lb
E-21 The AFGDdesign is based upon this coal, and the E-68 system is capable of processing flue gas from coals which

contain between 2.0 and 4.51 weight percent sulfur and less than 0.25 weight percent chloride. Coals outside of these parameters cannot be burned at the Bailly Generating Station within the operating guarantees of the AFGDsystem. The design parameters were established to show the ability of the AFGDprocess to clean flue gas to stringent emission standards. Northern Indiana's current coal purchasing practices and anticipated future purchasing plans indicate that acoal well within the design parameters will be utilized. The expected coal quality is anticipated to have the following characteristics:
E-7 E-68 Component Minimum Averaae Maximum

Sulfur (%) 2.30 3.10 3.67 Moisture (%) 5.0 10.7 15.0 Ash (pi) 8.0 10.0 13.0 BHV(Btu/lb) 10,408 11,510 13,000
2-24Since the AFGDsystem design accommodates acoal E-17

with agreater sulfur content than the range indicated above, and aguaranteed 90 percent removal efficiency, the likelihood of asuccessful demonstration with respect to this aspect of the project is maximized.

The location of the overall AFGDsystem to the E-5 Bailly Station is shown in Figure 2.1-4 with the currently proposed plot plan illustrated in Figure 2.1-5. Component E-8 balances at design conditions for the following species, S02, E-13 CaS04*2H20, CaC03, and Cl- are presented in Figures 2.1-6 E-18 through 2.1-8, respectively. Temperature and water-use data E-22 appear in Figure 2.1-9. E-2& E-25 TheAFGDsystem is divided into four sections: E-52 Flue Gas Ducting and Fans Section E-60 A. B. Limestone Feed and Handling Section C. SO2Removal Unit Section, and D. GypsumBy-Product Handling Section.
These sections are described below.
A. Flue GasDucting and Fans Section

The flue gas ducting and fans section directs flue gas from the existing Bailly Generating Station electrostatic precipitators (ESP) to the AFGDsystem SO2removal section. Also, this section receives wastewater from the wastewater evaporation system (WES)upstream of the ESP.
B. Limestone Feed and Handlinq Section

The AFGDsystem will receive purchased pulverized limestone from a limestone supplier. The limestone will be

2-25LAKEMICHIGAN

N

I,



### IT 0 cl 0 Figure2.1-4 E-5EL.40’ NORTH-SOUTH SASE LINE
ADMIN.

PRECIPITAmR



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Note: Newconstruction isindicated byshaded areasonfigure. N- 

## & Pure Air JL
a joint venture company ADVANCED FLUE GAS DESULFURIZATION Proposed AFGD System Plot Plen Flgure2.1-5 E-23SO2 REMOVAL UNITSECTION



# p”2to”’ wm” 7!!!5- -

, Gypawn to lsndltll or wUlbo8rd manufacturer



## k Pure Air .k
a joint venture company ADVANCED FLUE GAS DESULFURIZATION Process Flow Schematic
Fiaure 2.1-6 E-60ceco3 58.458 Lb/HI Permit Emieaion Level: 6.0 Lb SOzlMMBtu (Existing)

SO, REMOVAL UNITSECTION
40.136 LblHr 3.066 PPIT dry

SO2 4.019 Lb/Ii I rrrCn

‘YiZl%S 1, \, v v 

# I r‘\-

-

CaS04.2H20 94.240 Lb/HI

==%.CO, 1331 LblHr LJ

ajoint venture company ADVANCED FLUE GAS DESULFURIZATION Sulfur, Gypsum and Limestone Balance: AFGD Design Condition Figure 2.1-7 E-22, 521RE;;;W;O;EED ] SO2 REMOVAL UNIT SECTION c,‘:1.288 LblHr 181 wrn dry C,‘: 0 Lb/W

wTc=-

_ ..m..m Cl-: 488 LblHr 

## k Pure Air 2. ajoint venture company ADVANCED FLUE GAS DESULFURlZATlON Chloride Balance: AFGD Design Condition Figure 2.1-8 E-22, 52SO2 REMOVAL UNIT SECTION

j RE”s;E”T;oEED 1 ~~0: 34.301 Lb/M / PI l=“Fti 

### - 1 I IF!?~ I I\
/ \ 

# J I---@

, Gypsum to landfill or wallboard msnutacturt

Yrn ..m H,O: 22,243 Lb/W

i m TOTAL MAKE-UP 1THROUGH 5: 361,404 Lb/Hrpulverized to 95percent less than 325 mesh. Limestone will

be received in pneumatic trailers and pneumatically unloaded into limestone storage silos. The total limestone storage capacity will be three days. The pulverized limestone will be fed from the storage silos into apneumatic conveying system, that will feed the limestone directly into the absorber hold tank. The limestone feed rate corresponds to a E-24 nominal 1.05 Ca/S molar ratio (based on the SO2removed) to achieve 90percent or higher SO2removal, and results in 10 E-25 percent or less of the station's SO2being emitted to the atmosphere, and by-product gypsum purity.

Hydrated lime will be received by truck, pneumatically conveyed to asmall silo and added directly to the wastewater tank by gravity. The hydrated lime is added to the wastewater stream to raise the pHof the wastewater.

C. SO2Removal Unit Section

The flue gas from the flue gas ducting and fans section will enter the SO2removal unit section absorber at its top where it will be quenched with recirculating slurry. This "wet/dry" interface will be washed intermittently with fresh water to avoid the formation of any deposits.

The single 100 percent absorber module will be a co-current grid packed tower. The absorber tower and reaction tank will be integrated to reduce equipment and space requirements. The co-current design will allow agas velocity as high as 20 feet per second, which accounts for the inherent compact size of the absorber.

The grid packing will provide a large surface area for liquid/gas contact which enhances overall SO2removal efficiency. The absorbed SO2will be partially oxidised by the oxygen in the flue gas as it passes through the

2-32E-55 absorption grids. Complete oxidation will be accomplished in

a reaction tank by using anewly designed air rotary sparger. After flowing downward through the absorption grids, the flue gas will turn, pass over the reaction tank, and turn upward towards the mist eliminator located vertically in the outlet ducting. The recirculation slurry is separated from the gas by the mist eliminator and is collected in the reaction tank.

The absorber reaction tank will be designed to hold an adequate liquid volume to ensure efficient utilization of the limestone, desupersaturation of calcium sulfate, and oxidation of the remaining calcium sulfite. The air rotary sparger system is an innovative mixer that injects air into the reaction tank and prevents solids from settling out in the reaction tank.

The chemistry of absorbing the SO2from the flue gas and converting it to gypsum will be as follows:

SO2+H20 -H2S03
H2S03 - H+f HSq (H++HSO: + 112 O2- 2H++SOT) (2H+ +SOT+CaC03+H20- CaS04*2H20 +C02)
The SO will beabsorbed into H20, then dissociates from H2S03 to H

+2and HSO:. Aportion of the HSOZwill be oxidized by oxygen in the flue gas and converted to H2S04. Calcium carbonate in the slurry will neutralize aportion of the H2S04, helping to balance the slurry pH.

All remaining HSq in the slurry will be oxidized by air from the air rotary sparger and converted to H2S04. It will then be neutralized with CaC03to form CaS04*2H20.

2-33The gypsum slurry will be drawn off to maintain a

20percent to 25percent (by weight) slurry content in the absorber reaction tank. Two 100 percent absorber bleed pumps will transfer the slurry from the absorber to the gypsum slurry tank for further processing. Atwo-stage Chevron type mist eliminator will be located vertically in the outlet duct leading from the absorber tank. Entrained mist reaching the mist eliminator will be minimized by ahorizontal run between the absorber tank and the eliminator. Collected entrainment will be returned to the absorber tank. Awashing spray header system will be installed in front of the mist eliminator elements to wash down intermittently the element surface and avoid any buildup of deposits. After passing through the mist eliminators, the scrubbed flue gas will exit the outlet duct into the exhaust stack for discharge to the atmosphere.
D. GypsumBy-Product Handling Section

In the gypsum by-product handling section two absorber bleed pumps will batch transfer the gypsum slurry from the SO2removal unit section into basket centrifuges which will reduce it to adewatered cake containing 8to 10 percent moisture by weight. Aportion of the filtrate water from the centrifuge operation will be returned to the absorber vessel as process water. The wastewater from the centrifuge operation will be sent to the existing Bailly Station wastewater ponds for disposal. The gypsum cake will be transferred by enclosed conveyor to an enclosed location within the station where it can be taken to awallboard manufacturer or hauled offsite for landfilling.

During the 3-year demonstration phase, aportion of the filtrate water from the centrifuge operation will be sent to the WESfor disposal. In the WES,wastewater from the

2-34E-26 absorber system will be fed to apHadjustment tank. In the

tank, wastewater will be neutralized by hydrated lime. Impurities in the wastewater such as achloride and sulphate ion will be stabilized by the neutralization so that these impurities in liquid phase do not evaporate. After pH adjustment, wastewater will be pressurized by the wastewater spray pumpand pumped to the wastewater evaporators located upstream of each ESPin the flue gas ducting and fans section.
Wastewater will then be atomized by apressure nozzle in the duct and mixed with the flue gas. Wastewater will be evaporated to dryness through the evaporator. After evaporation, the flue gas with dry solids will be ducted to join the main flue gas stream at the evaporator outlet and the dry solids will be removed by the ESP. In those circumstances when the WESis not in operation, the wastewater will be sent to the existing pond system within the Bailly Station.

The potential impact and regulatory issues associated with materials produced in the gypsum by-product handling section,are discussed in Section 4, Consequences (Impacts) of the Project and Section 5, Regulatory Compliance.
2.1.3.3 Hazardous Releases

There are no hazardous releases from the AFGD process. The four potential sources of hazardous releases in any process are feedstocks, chemicals, wastes, and process drains. These four potential sources of hazardous releases are discussed below with respect to the AFGDsystem.

2-35A. Feedstocks
The only reagent feedstocks to the process are limestone and hydrated lime; no organics are used. Limestone (CaC03) is anaturally occurring mineral that is mined from the earth and is classified as non-hazardous. Hydrated lime [Ca(OH)2] is produced by calcining limestone to quicklime (CaO) and then hydrating the quicklime in an atmospheric hydration system. Hydrated lime is also classified as non-hazardous.
B. Chemicals

There are no chemicals used in the AFGDprocess other than the limestone and hydrated lime feedstock.

C. Wastes The only waste stream from the process is the high-chloride wastewater stream from the gypsum cake washing cycle. This wastewater stream also contains dissolved calcium and magnesium salts, and some small amounts of fly ash and inerts from the limestone and hydrated lime feedstock. None of the components of this wastewater stream E-27 is considered to be hazardous based on an examination of U.S. Environmental Protection Agency and Indiana Department of Environmental Management regulations for classifying waste materials.
The saleable by-product that is generated by the process is a high purity gypsum suitable for producing a wallboard building material. There is the potential for producing some quantity of gypsum that would not meet the wallboard manufacturer's specification for free-water, chlorides, calcium carbonate or fly ash content. This off-specification gypsum can generally be blended back into

2-36E-28

Ethe specification gypsum amounts and still meet wallboard

specifications. In someinstances this lower-quality gypsum can be sold to cement manufacturers. In aworst-case scenario, this non-hazardous, off-specification gypsum would be commercially landfilled in an existing landfill, if necessary. The landfill would be selected based on discussions with the Indiana Department of Environmental Management and subsequent negotiations with the selected landfill and/or contract hauler.

18 All major wallboard producers in North America who account for over 95percent of the wallboard produced in North America have been introduced to this project. These producers have expressed interest in purchasing by-product gypsum. TheAFGDsystem will produce between 175,000 and 250,000 tons of gypsum per year depending on operating rates and sulfur content of the coal burned. This range is attractive to wallboard producers for amedium-sized wallboard plant.

Initially, the Indiana Office of Solid and Hazardous Waste Management (OSHWM)will consider the gypsum, whether on-specification or off-specification, as awaste from an industrial pollution control source. The OSHWM will evaluate/classify the gypsum based on the results of analyses from bench tests. Within a 15-mile radius of the Bailly Generating Station, there are currently three landfills that could potentially be used for by-product gypsum disposal.
E-28 Pure Air is facilitating negotiations between

Northern Indiana and wallboard producers. The successful producer will be requested to install an on-site covered gypsum storage building to control fugitive emissions. (Probable size is 5-days' storage or approximately 5000 tons. ) The gypsum conveyor from the AFGDsystem to storage is fully covered to eliminate fugitive emissions.

2-37Ii

In the event the main conveyor has mechanical E-31 problems, an emergency stackout conveyor and building will be installed near the AFGDsystem for 24-hour storage (approximately 1000 tons). The building and conveyor will be covered to control fugitive dust and potential runoff.

Both the main storage and emergency stackout buildings will hold gypsum until transported to wallboard producers or a landfill. E-31

D. Process Drains

Water spilled from the AFGDsystem will be directed E-29 to process drains. These drains will connect to acentral collection sumpwhere the process water will be collected and added back to the absorber hold tank as needed, since its quality will be similar to material in the absorber. This process water is considered to be non-hazardous and will be contained within the process. Also, it will not change or impact removal of SO2by the AFGDsystem.
2.1.3.4 Project Source Terms

This section characterizes the source terms of the AFGDtechnology demonstration project. Source terms can be divided into the categories of project resource requirements and project discharges. The potential impacts of the project E-31 source terms are discussed in Section 4, Consequences (Impacts) of the Project.
A. Project Resource Reouirements

The resource requirements for the project can be segregated into the following five areas and are discussed below:

2-38a. Utilities b. Land C. Labor d. Materials e. Transportation

a. Utilities
The utilities listed below will be required for operation of the proposed AFGDsystem at the Bailly Station. Northern Indiana will provide these utilities to the boundary limits of the AFGDfacility for Pure Air to tie into the AFGD facility.

Utility Estimated Flows (Gal/Min) Service
Process Water 880 Cooling Water 475 Fire Protection Water 1,000 PumpSeal Water 175 Potable Water 70 Quench Water 5,800 Continuous Continuous Intermittent Continuous Intermittent Intermittent
In addition, approximately 7.6 MWof continuous power will be supplied~to the AFGDfacility.

During the construction phase of the AFGDsystem, construction power and some utilities will be provided to the location of the system and to the tank/vessel fabrication area. These construction requirements consist of the following:
1. Power - 480 volt continuous

2. Potable (drinking) water - 70GPM

2-39As previously mentioned, the Bailly Station is

located adjacent to Lake Michigan. Presently lake water is extensively used in the generating facility and readily available in quantities and qualities for use in the proposed AFGDfacility's day-to-day operation.

Based on preliminary design estimates of water requirements stated above, it is envisaged that process water, pumpseal water, cooling water and quench water will be supplied from water within Lake Michigan. Considering the plentiful supply of Lake Michigan water for the proposed AFGD system operating requirements, constraints limiting its use are not projected for the long-term future.

Fire protection water will be used strictly to supply water to various fire protection devices (automatic sprinklers and hand-held fire extinguishing equipment) to protect AFGDequipment from catastrophic failure resulting from fire damage. Northern Indiana will provide sufficient water for this purpose from the Bailly Station's high head service water system. Bailly Station's high head system can be supplied from two independent water sources, the low head and circulating water systems. The supply for both of the systems is Lake Michigan water. Notreatment of this water is required prior to use. Potable water will be provided by tying directly into an existing potable water line located in the generating station. Potable water from on-site sources will be installed to support the construction phase of the AFGDfacility.
The 480-volt construction power will be supplied to support construction of the facility and will originate from aspare 480-volt breaker located inside the Bailly Station. Direct buried cable will be supplied from the breaker to the AFGDboundary limits. Subsequent to construction this cable

2-40E-56 will be abandoned in place. Tosupport the power

requirements for operation of the AFGDfacility, an independent feed will emanate from the Bailly Station's 34 kV yard.
Twonewtransformers will be installed southwest of the main generating facility building. The power from the transformer will be routed along the western property line to switchgear. This switchgear will be located outside the battery limits at the AFGDsystem electric yard.

Considering that both construction and operating power needs emanate from apower generation station, the availability and reliability are not compromised for continuous service to the AFGDfacility.
b. Land
TheAFGDprocess is designed to require aminimum amount of space, and is thereby applicable for difficult retrofit situations. Equipment for the AFGDprocess requires about 75,000 square feet (1.72 acres) of land area; whereas all facilities associated with the AFGDsystem require approximately four acres excluding on-site gypsum storage. The land area required by each section of the process is as follows:

Process Section

1. Limestone feed system 2. Absorber system 3. Gypsumdewatering system 4. Wastewater evaporation system SUBTOTAL Land Use Required (FT') Acres 10,000 0.23 50,000 1.15 10,000 0.23 5,000 0.11
75,000 1.72

2-41Storaqe

5. Primary gypsum storage 40,000 0.92 E-31 Auxiliary Facilities
6. Roads, Buildings, etc. 59,200 1.36

TOTAL 174,200 4.00
The absorber system and the wastewater evaporation system must be located close to the flue gas path and are, therefore, in amore restricted access area.

The limestone feed system and the gypsum dewatering system are also located close to the absorber to minimize piping lengths. Asmall gypsum emergency stackout building will be located near the absorber. Northern Indiana's fly E-31 ash silos are existing and adequate for storage prior to disposal.

C. Labor
The AFGDprocess requires approximately the following amount of operations and maintenance personnel:

Job Description Shifts/Week Operators 16 Maintenance 4 Shift Supervisors 4 Manager 2

TOTAL 16

2-42The plant requires four operators per shift working

five days per week (8.0 hours/shift).

There will also be four maintenance personnel who will normally work during the day shift (Monday to Friday).
d. Materials

The only raw materials required by the process are limestone and hydrated lime. The quantities of these materials required at full load are as follows:

Limestone - 32.0 T/Hr (96.5 percent CaC03) Hydrated Lime - 28.7 Lbs/Hr (95 percent Ca(OH)2)
The limestone is required as the reagent to react with and capture the SO2in the flue gas. The limestone is added based on astoichiometric ratio of 1.05 moles CaC03/1.0 moles SO2removed, and a limestone composition of 96.5 percent CaC03and 3.5 percent inerts by weight. Limestone is found in abundance in the upper midwestern United States.

The hydrated lime is used to neutralize the gypsum wash wastewater before it is sent to either the WESor an on-site wastewater pond. The hydrated lime is added to neutralize the water stream prior to feeding to the WES. Only stable CaC12will be formed when the pHis adjusted to a value of 8.0. The hydrated lime will neutralize the acidic components in the wastewater to achieve aneutral or basic wastewater pH.

e. Transportation

The AFGDprocess requires the transport of the limestone and hydrated lime raw materials into the plant site and the gypsum by-product out of the plant site. The maximum

2-43quantities of these materials which will be transported and

the method of transportation are as follows:

1. 2.

1. RawMaterials
Limestone Hydrated Lime Quantity (Tons/Day)
760 0.34 Method/Frequency

of Transportation
38trucks every day* Onetruck every one to two months By-Product Gypsum 1,358 Continuous conveyor belt to nearby gypsum transfer building
* Based on 20Tons/Truck
The limestone and hydrated lime will be shipped to the plant in trucks.

Delivery of the gypsum to either the landfill or an off-site wallboard manufacturer will be accomplished with an additional 35to 40trucks daily. The impact of this E-30 vehicular traffic is discussed in Sections 4.5.2.1 and 4.5.2.2.
2.1.3.5 Potential Environmental, Health, Safety and

Socioeconomic (EHSS) Receptors
Anumber of EHSSaspects could potentially be impacted by the AFGDsystem construction and operation. These include primarily air quality, surface water quality, various socioeconomic factors, sound levels, and energy and E-32 materials resources. Section 3, Existing Environment, of this EIV focuses on characterizing these probable receptors

2-44and other EHSSaspects of the AFGDproject. Section 4,

Consequences (Impacts) of the Project, evaluates the potential impacts of the AFGDproject on these receptors.

2-452.2 ALTERNATIVESTOTHEPROPOSED ACTION
This subsection discusses three alternatives to the proposed AFGDproject: no action, use of alternative technologies, and alternative sites for the project.
2.2.1 The No-Action Alternative

Under the No-Action Alternative the DOEwould not provide funds to facilitate the demonstration of the unique features of the AFGDsystem. Thus, potential implementation of these features could be hindered and not undertaken in a timely manner. This could also impede the development of alternative technologies to control the precursors of acid rain.
The No-Action Alternative would also involve leaving the existing Bailly Station engineering design and configuration unmodified. This would then allow the station to continue operating at its existing emission levels.
2.2.2 Alternative Technologies

The proposed action is to install anAFGDsystem at the Northern Indiana Bailly Generating Station to provide a demonstration of the effectiveness of anumber of unique features described in Section 1, Introduction and Subsection 2.1.3, Engineering Description of the Proposed Action. These combined features will result in the reduction of SO2 emissions at the station and demonstrate the potential for operating AFGDsystems with reduced solid waste and wastewater disposal problems.

Although the FGDindustry has been in existence for approximately 20years, there are no commercially competitive

2-46processes that produce aconsistently saleable by-product

other than gypsum-producing systems. Both the Wellman-Lord and the Magnesium Oxide processes have received only minor commercial acceptance. Economic projections continue to show that these processes are not economically competitive with either conventional technology or the proposed AFGDsystem unless aunique market situation exists for sales of the B2SO4' elemental sulfur or concentrated SO 2products.
Since the proposed AFGDsystem has the potential to produce no solid waste, it is environmentally superior to other competitive technologies that produce awaste product. Nearly all FGDsystems in operation in the United States at present produce asolid waste. Other competitive technologies such as fluidized bed combustion, sorbent injection, and spray dryer FGDsystems also produce asolid waste. Onaworldwide basis, only the gypsum-producing FGD systems have consistently proven to be capable of reducing SO2emissions while generating no solid wastes.

Many FGDsystems are permitted for wastewater discharges. Gypsum-producing FGDsystems inherently have a wastewater discharge to control the chloride content of the gypsum by-product. The proposed AFGDsystem will demonstrate awastewater evaporating system whereby apart of the wastewater stream produced by the process is recirculated back to the flue gas stream ahead of the electrostatic precipitator and evaporated. Thus, in acommercial application this system has the potential for lower or no wastewater discharge under any conditions of boiler load or coal sulfur content.

The stoichiometric ratio for the system is 1.0 moles of calcium carbonate per mole of SO2in the flue gas, or alternatively 1.05 moles of calcium carbonate per mole of SO2removed for a 95percent SO2removal efficiency. For

2-471,

comparative purposes, circulating fluidized bed boilers typically operate with acalcium/sulfur ratio of 2 for approximately 80 percent removal and acalcium/sulfur ratio of 3to 4for a 90 percent removal. Sorbent injection systems, including furnace sorbent injection, economizer sorbent injection, and duct sorbent injection typically operate with acalcium/sulfur ratio of 2for a40to 60 percent removal level. Spray dryer FGDsystems, which are commercially available, typically operate at acalciumfsulfur ratio of 1.3 to 1.4 for 90 percent removal on a high sulfur coal. Thus, while fluid bed and sorbent injection are often viewed as attractive technologies, the amount of limestone consumed is significantly higher than the proposed AFGD system and a non-saleable waste product is produced. Even spray dryer FGDsystems require 30to 40 percent more limestone for an equivalent SO2removal. From the standpoint of the consumption of anon-renewable resource (limestone), the AFGDsystem is superior to either conventional technology or other emerging competitive technologies.
2.2.3 Alternative Sites

The Bailly Station was selected 1) because of the ability of the proposed AFGDfacility to meet envisaged emission requirements, when acid rain legislation passes, and 2) to demonstrate uniqueness in the AFGDsystem to scrub efficiently one flue gas stream from multiple boilers.

Northern Indiana owns and operates three other generating stations. Each of these stations could potentially have served as asite for the AFGDdemonstration. However, none of these was chosen because of the current operation of the Northern Indiana generating system.

2-483.0 EXISTING ENVIRONMENT

3.1 ATMOSPHERICRESOURCES
3.1.1 Site Meteorology

The climate of the site is continental, characterized by high winds and frequent weather changes. The area is subject to cold, dry winters and warm, moist
summers. These climatic characteristics are the result of storms moving eastward along the northern tier of the United States and storms in the southwest moving toward the Great Lakes. The average temperature for the area is approximately 50°F, with the highest temperatures occurring between Mayand August, while the lowest temperatures occur in the fall and winter.
The area is known for frequent high winds; however, damaging winds are rare. During a lo-year period, 20 tornadoes were identified and reported in the lo latitude and lo longitude sector containing the plant site. Using the Thorntechnique, the cycle for atornado striking apoint in this sector is 635years.

There are important climatological differences between dune areas, which include the plant site, and more urban inland areas. The modifying effect of Lake Michigan is such that the dune areas receive less precipitation than
areas further inland. Ogden Dunes receives only 36.6 inches of precipitation per year, while LaPorte, about 23 miles to the southeast, averages 47.7 inches of precipitation per year. Wind velocity data are summarized in Figure 3.1-1. These data were compiled by Northern Indiana and submitted to

3-lS

Source: Indiana Department of Environmental Management



# r 17-21 r-)21 1-9 WIND SPEED CLASSES

(KNOTS) Note: Wind direction is the direction from which the ,wind is blowing. 

## & Pure Air .t ajoint venture company ADVANCED FLUE GASDESULFURlZATlON Windrose ‘84 - ‘86 Dune Acres Data Figure 3.1-1the Indiana Department of Environmental Management (IDEM) in

accordance with state regulation. The data were used in the E-33 Porter County State Implementation Plan (SIP) development study. The data are collected at the DuneAcres substation located one mile southeast of the Bailly Station.
3.1.2 Air Quality

Air quality is asource of concern in the highly-industralised area adjacent to the Bailly Station. Recently, IDEMconducted astudy to develop acontrol strategy to attain the National Ambient Air Quality Standards (NAAQS)for S02. The result of this study indicated that the E-33 NAAQSfor SO2are being met; however, the concentrations predicted were very close to the standards.

The area is currently designated as "attainment" for most criteria pollutants except ozone (03) and CO, neither of which will be impacted by construction and operation of the AFGDsystem. E-33 E-57

The Bailly Station is located adjacent to Bethlehem Steel's Burns Harbor Plant and Midwest Steel. Steel mills emit a large amount of SO2to the air. Bethlehem Steel and Midwest Steel, combined, emit close to 100,000 tons of SO2 per year. The Bailly Station emits approximately 70,000 tons of SO2per year. The proximity of other industry also contributes to the concentrations of SO2in the air.

Northern Indiana has collected air-quality data at the Bailly Station for over ten years. The Bailly Ambient Air Monitoring Network has been modified as of January 1, 1989 and has nowbeen incorporated into the Porter County SO2 Monitoring Network. Northern Indiana nowoperates three SO2 monitoring sites within the Porter County SO2monitoring network. Meteorological data are collected at two of the

3-3E-34 three SO2monitoring sites. The Northern Indiana SO2

monitoring sites include: 1) Main Office Site SO2data collection 2) Lagoon Site SO2and meteorological data collection 3) DuneAcres Site SO2and meteorological data collection
Northern Indiana does not currently monitor any other criteria pollutants (N02, CO, 03, PMlO) from these sites. Other monitoring stations are operated by the State of Indiana (IDEM), National Park Service and Porter County.

Northern Indiana continuously monitors the plume opacity from the Bailly Station stack. Periodic stack tests are also conducted to determine emission rates for SO2and particulates. The existing air permit allows for an emission level of 6.0 lbs/MMBtu for SO2, 0.22 lbs/MMBtu for particulate matter and anopacity limit not to exceed 40 percent.

3-43.2 LANDRESOURCES

3.2.1 Geology

The Bailly Station is located in astable geological region in which no faults have been identified in either the basement or in the overlying sedimentary rock. It is adjacent to Lake Michigan in an area where the sand dunes have been leveled and stripped of vegetation. Natural dune sands extend from the existing ground surface to depths ranging between 10and 30feet.

The stratigraphy of the region near the Bailly Station is shown in Figure 3.2-l. The surficial geology of the Bailly Station is illustrated in Figure 3.2-2. The sequence consists of lake plain sediments over glacial deposits over dolomitic bedrock of Silurian age. The sands E-69 were deposited as aconsequence of postglacial lake activity. The major component of the glacial deposits is aglacial till deposited by the slow melting of glacial ice. Glacial till is an unsorted, unbedded mixture of silt, clay, sand, gravel and boulders. Bedrock is located 185 feet below the ground surface. The bedrock consists of shales and dolomitic E-69 limestone.
The most pronounced topographic feature in Porter County is the Valparaiso Moraine. It is aterminal mass of rocks, sand and gravel. The Valparaiso Moraine was formed by glaciation of the Wisconsin Age. It serves as the dividing line for drainage into Lake Michigan.

3-5Syrt*m



# B ij H! --Lm Fomwtion

20

10 

# -4

6
18

SO 

# 4 30

27

100

600

700 , to .llOO

2000 to 3300 I QI~claI Dritl o/,‘o, Qkclo-laccutrhe-b.nch men
,,-\J nrm

wlds,moduatdydemo Aquitw ‘ggg$ Qlmlo-l~cu9bifN. @lllY OhY (“7, Glwa-lrclutrtM depdt dlt andlitty clay 

# h

Dolomlt.~; 5andmton.r. Shales

Source: Northern Indiana Public Service Company, ‘Final Environmental Statement Related to Construction ofBailly Qenerating Station Nuclear- 1,‘February 1973 

## & Pure Air A ajoint venture company ADVANCED FLUE GASDESULFURIZATION Site Stratigraphy of Porter County, Indiana Figure 3.2-l

# izl BEACHANDASSOCIATED DUNEDEPOSITS



# m LAKE CLAYSANDMUCK 

### @J

...y OUTWASHSANDSANDGRAVELS liiiiiil TILL

LAKE MlCHlCAN BEVERLY SHORES

Source: Texas InstrumentsJnc.,‘1Q74-1875 Annual Report-SaiUyNuclear ISite”

Surficial Geology inVicinity of Bailly Generating Statior 1 Fisure 3.2-2Ia,

3.2.2 Seismolow

The Bailly Station is located in an area of minor seismic activity where, since the beginning of the 19th century, only seven shocks have been reported for epicenters within 100 miles of the station. Of these seven, only three have occurred within 50miles of the site. The largest occurred in 1938 near the south shore of Lake Michigan and had aModified Mercalli Scale (Table 3.2-l) of IV. This shock was felt indoors by many, but outdoors by few.
3.2.3 Soils

Soils located in the vicinity of the station are composed primarily of five types: Oakville fine sand, Houghton muck, Adrian muck, Maumeeloamy fine sand, and Dune land. The large portion of ground used for industrial purposes in the area is classified as cut and fill. This is illustrated in Figure 3.2-3, "Soil Composition - Bailly Generating Station Area."

Oakville fine sands are located on the older dunes in the area and are vegetated by immature and mature black oak forests. Productivity is limited primarily because of low available water capacity and frequent drought.

Soils in the northern portion of the subdunal area are comprised of Houghton muck. These soils are very poorly drained with athick muck surface layer. The very poorly drained organic material of the soils severely limits the productivity of plants other than wetland species.

The soils of the subdunal area and interdunal ponds are composed primarily of Adrian muck. These soils are very poorly drained and have characteristics similar to Houghton muck.

3-8TABLE3.2-l: MODIFIED MERCALLISCALE

I. Not felt except by afew under especially favorable circumstances.
II. Felt only by afew persons at rest, especially on upper floors of buldings. Delicately suspended objects may swing.
III. Felt quite noticeably indoors, especially on upper floors of buildings, but many people do not recognise it as an earthquake. Standing automobiles mayrock slightly. Vibration like passing of truck. Duration estimated.
IV. During the day felt indoors by many, outdoors by few. At night someawakened. Dishes, windows, doors distubed, walls make creaking sound. Sensation like heavy truck striking building. Automobiles rocked noticeably.
V. Felt by nearly everyone, manyawakened. Some dishes, windows, etc., broken; afew instances of cracked plaster; unstable objects overturned. Disturbance of trees, poles, and other tall objects sometimes noticed. Pendulum clocks maystop.
VI. Felt by all; many frightened and run outdoors. Someheavy furniture moved; afew instances of fallen plaster or damaged chimneys. Damageslight.
VII. Everybody runs outdoors. Damagenegligible in buildings of good-design and construction; slight to moderate in well-built ordinary structures; considerable in poorly built or badly designed structures; somechimneys broken. Noticed by persons driving automobiles.

3-9VIII. Damageslight in specially designed structures;

considerable in ordinary substantial buildings, with partial collapse; great in poorly built structures. Panel walls thrown out of frame structures. Fall of chimneys, factory stacks, columns, monuments, walls. Heavy furniture overturned. Sand and mudejected in small amounts. Changes in well water. Disturbs persons driving autos.
IX. Damageconsiderable in specially designed structures: well-designed frame structures thrown out of plumb; great in substantial buildings, with partial collapse. Buildings shifted off foundations. Ground cracked conspicuously. Underground pipes broken.

X. Some well-built wooden structures destroyed; many masonry and frame structures destroyed with foundations: ground badly cracked. Rails bent. Landslides considerable from river banks and steep slopes. Shifted sand and mud. Water splashed (slopped) over banks.
XI. Few, if any, (masonry) structures remain standing. Bridges destroyed. Broad fissures in ground. Underground pipe lines completely out of service. Earth slumps and land slips in soft ground. Rails bent greatly.
XII. Damagetotal. Wavesseen on ground surfaces. Lines of sight and level distorted. Objects thrown upward into the air.

3-10.’ a.+ Id I”.’ mm’sad , /

Source: Texas InstrumentsJrtc., ‘1Q74-lQ75,, Annual Report-Ballly Nuclear ISite 

## & Pure Air I. ajoint venture company ADVANCED FLUE GAS DESULFURIZATION 

# ISoil Composition - Bailly Generating Station Area 

# I Figure 3.2-3Soils at the southern end of the subdunal area are

composed of Maumeeloamy fine sand. Maumeesoils are very poorly drained, coarse-textured soils that occupy nearby level flats and depressions. These soils are less wet and have shorter periods of standing waters than the subdunal area. Dune land occupies the area extending inland from the shore of Lake Michigan to established sand dunes. The blowing and deposition of sand create conditions that are tolerated by only afew plant species.
3.2.4 Land Use

Figure 3.2-4 graphically depicts the area surrounding the Bailly Generating Station. The station is bordered on the south and west by the Bethlehem Steel Corporation's Burns Harbor Complex. The Indiana Dunes National Lakeshore Park borders the site to the east and the south.
The area to the west of the site is heavily industralised. Lake County, five miles west of the site, includes Gary, Hammondand East Chicago, all of which are canters of heavy industry. Steel manufacturing is the major industry. Very little of the land north of Highway 12 is either suitable or used for agriculture. However, the area south of the Indiana Toll Road is largely devoted to growing corn and soybeans. Approximately 60percent of the land in Porter County is used for agricultural purposes. The closest houses to the Bailly Station are those within the town of DuneAcres, two miles northeast of the station. No unincorporated areas of Porter County, within which persons could be living, are closer than Dune Acres.

3-12

### 1:. $J, T;;J .,,J,.,“;: i+J ~1,,: --f.....- ~-‘-N....-$,,i

LEOEND

m RESIDENTIAL k; ;A;Rl;TlJ.QAL &OTHER LAND m..- a FOREST COVER m INDUSTRIAL ii&if RECREATIONAL (State 6 Federal Parka) BAILLY GENERATING STATION E y’,“,,,

-- HIQHWAY

- SUPER HIGHWAY

. NlKE MISSLE SITE Source: Northern Indiana Public Service Company, ‘Bailly Generating Station Nuclear 1. Environmental Report,’ 1Qtl Note: Concentric Rings are Spaced at l-Mile Intervals 

## & Pure Air .k ajoint venture company ADVANCED FLUE GASDESULFURIZATION
Land - Use Map Figure 3.2-43.3 WATERRESOURCES

3.3.1 Ground Water

Ground water at the station area occurs at depths from 44to 270 feet and flows northward to the lake at a rate of approximately 0.5 feet per day, in two formations. The top formation is comprised of dune materials and is up to 125 feet thick. The lower formation is silt and clayey sand and is up to 150 feet thick. Aquifers for ground water are present in the bedrock, located at adepth of 185 feet. Most of the wells within 10 miles of the Bailly Station were drilled for test purposes by the Indiana Toll Road Commission and State Highway Department. Other wells are used primarily for domestic and public water supply sources. There is only one well within a mile of the station, and atotal of three wells at adistance of two miles. The nearest municipal water system is that of DuneAcres. In DuneAcres, three wells have been drilled to adepth of about 30 feet, approximately 300 feet from the shoreline of Lake Michigan. DuneAcres water contains iron (1 to 6.6 ppm), tannin (2 mm)I and is relatively hard (10 grains/gal). For household purposes, without treatment, ground water in the vicinity of the Bailly Station is of marginal quality. Tannin is found in ground water throughout the Bailly Station area. This indicates that aportion of the ground water originates from the percolation of rain and surface water through the sandy soils of the dune forests and through the bogs and peaty areas in the region.
3.3.2 Surface Water

Springs, streams, rivers and bogs are extensive in the general area of the station as shown in Figure 3.3-l and described in Tables 3.3-1 and 3.3-2. There are, however, no E-35 wetlands on the Bailly Station property. The major watershed

3-14N LAKE f#2lGAN

Site



## k Pure Air .t

ajoint venture company ADVANCED FLUE GAS DESULFURIZATION Wetlands Map of the Bailly Generating Station Vicinity Fiaure 3.3-l E-36TABLE3.3-l: FRESBWATER WETLANDCLASSIFICATION INDICATED IN FIGURE3.3-l System: Palustrine [P) - No Subsystem Class: Rock Bo;~;'co~B) Subclass: 1.

2. Rubble
Class8 Unconsolidated Bottom (UB) Subclass: 1. Cobble/Gravel

? Sand Mud 4. Organic
Class : Aquatic Bed (AB) Subclass: 1.

2. 3. 54: 6. Algae Aquatic Moss Rooted Vascular Floating Vascular Unknown Submergent Unknown Surface
Class: Unconsolidated Shore (US) Subclass: 1.

2. CZ;Z;le/Gravel 3. Mud 4. Organic 5. Vegetated
Class: Moss Lichen (ML) Subclassr 1. Moss

2. Lichen
Class: Emergent (EM) Subclass: 1. Persistent

2. Nonpersistent
Class: Scrub Shrub (SS) Subclass: 1. Broad Leaf Deciduous

2. Needle Leaf Deciduous 43: Broad Leaf Evergreen Needle Lead Evergreen 5. Dead

3-16TABLE3.3-l: (Continued)

Class: Forested (FO) Subclass: 1. Broad Leaf Deciduous

5 Needle Leaf Deciduous Broad Leaf Evergreen 4. Needle Lead Evergreen 5. Dead
Class: OpenWater Subclass: Unknown Bottom MODIFYINGTERMS(in order to describe more adequately wetland and aquatic habitats, water regime, water chemistry, soil or special modifiers maybe applied)
Water Regime (Non-tidal) A. Temporary Intermittently Flooded B. Saturated KJ: Artificial C. Seasonal 78. Intermittently Exposed/ D. Seasonal Well-Drained Permanent E. Seasonal Saturated W. Intermittently Flooded/ E: Semipermanent Intermittently Exposed Temporary Y. Saturated/Seasonal/ Ii. Permanent Semipermanent U. Unknown Water Chemistry Inland Salinity i: Hypersaline Eusaline Mixosaline Fresh pHModifiers for Freshwater a. Acid t Circumneutral 1. Alkaline

g. Organic n. Mineral Special Modifiers

:: Beaver
k Partially drained/ditched Farmed Dikedjimpounded r. Artificial s. Spoil X. Excavated
Source : Indiana Department of Natural Resources,

Fish and Wildlife Division

3-17TABLE3.3-2: WETLANDSANDDEEPWATER HABITATSCLASSIFICATION INDICATED IN FIGURE3.3-l System: Lacustrine (L1 Subsystem: Limnetic (11 Class: Rock Bo;~~;~~B) Subclassr 1.

2. Rubble
Class: Unconsolidated Bottom (UB) Subclass: 1.

3: Cobble/Gravel Sand Mud 4. Organic
Class: Aquatic Bed (AB) Subclass: 1. Algae

:: Aquatic Moss Rooted Vascular i: Floating Vascular Unknown Submergent 6. Unknown Surface Subsystem: Littoral (2) Class : Rock Bo;;tzo;;B) Subclass: 1.

2. Rubble
Class: Unconsolidated Bottom (UB) Subclass: 1.

2. ;zZgle/Gravel
43: Mud Organic
Class: Aquatic Bed (AB) Subclass: 1. Algae

2. Aquatic Moss 43: Rooted Vascular Floating Vascular Unknown Submergent Unknown Surface

3-18TABLE3.3-2: (Continued)

Class: Rocky Subclass: 1. s;z;;o;;s 1

2. Rubble Class: Unconsolidated Shore (US) Subclass: 1. Cobble/Gravel

2. Sand 43: Mud Organic 5. Vegetated
Class: Emergent (EM)(l) Subclass: 2. Nonpersistent
Class: OpenWater Subclass: Unknown Bottom System: Riverine (R) Subsystem: Lower Perennial (2)

Upper Perennial (3) Intermittent (4). Unknown Perennial (5)
Class: Emergent (EM)(l) Subclass: Nonpersistent
Class: Rock Bottom (RB) Subclass: 1. Bedrock

2. Rubble
Class: Unconsolidated Bottom (UB) Subclass: 1. Cobble/Gravel

2. Sand Mud Organic



### 3-19TABLE3.3-2: (Continued)

Class: Aquatic Bed IAB) Subclass: 1.

f : 4. 5. 6. Algae' ' Aquatic Moss Rooted Vascular Floating Vascular Unknown Submergent Unknown Surface Class: Stream Subclass: 1.

2. 43: 5. 6. I. EriZE' Rubble Cobble/Gravel Sand Mud Organic Vegetated 

### Class: RockyS;e”;-o~;W Subclass: 1.

2. Rubble
Class: Unconsolidated Shore (US) Subclass: 1.

2. Cobble/Gravel Sand 2 Mud Organic 5. Vegetated
Class: OpenWater Subclass: Unknown Bottom
Note to Table 3.3-2: (1) Emergent class (nonpersistent subclass) is found only in the Lacustrine littoral and the Riverine lower perennial subsystems.
Source : Indiana Department of Natural Resources,

Fish and Wildlife Division

3-20E-36 system is formed by two primary basins -- the Little Calumet

River and Xankakee River systems. The Little Calumet is the critical system with respect to the Indiana Dunes National Lakeshore properties that abut the east side of the station site. Somemarshy areas to the east and south of the Bailly Station empty into Lake Michigan via Dunes Creek in Indiana Dunes State Park. However, muchof the National Lakeshore is within asubwatershed which drains directly toward Lake Michigan through porous soils. The Little Calumet River drains from the Valparaiso Moraine headwaters in LaPorte County to the lake and the Chicago SagCanal. This gradient is slight owing to the development of extensive subsurface clays which impede drainage. Burns Ditch to the west of the station is but one of an extensive system of ditches that were fashioned to facilitate drainage. These surface-water systems are shown in Figure 3.3-l.

Burns Ditch is ahighly polluted canal about 200 feet wide and eight miles long which empties into Lake Michigan. The lower end of Burns Ditch is used as adocking and marina area. Salmon introduced into the lake use Burns Ditch for access to their spawning grounds in the Little Calumet River.

Lake Michigan, to the north of the station, is the third largest of the Great Lakes in area (22,300 square miles) and second in volume (173 trillion cubic feet). Water levels are highest in summerand lowest in late winter and early spring. The lake is divided into two basins by two parallel ridges running in an easterly direction from Milwaukee to Grand Haven. The Bailly Station is located on the shore of the southern basin.

Inshore waters are used for drinking water, recreation (fishing, swimming) and industry. This area

3-21represents 21 percent of the total area of Lake Michigan,

including Green Bay.

The beach water zone is the portion of water that extends from shore to adepth of 30 feet. It is asubarea of the inshore zone that, in Lake Michigan, comprises seven percent of the lake surface, including Green Bay. In this zone are the water intake and discharge structures for the existing Bailly Station coal-fired units.

Over afive-year study (March '74 to December '78), the lake temperatures ranged from 37.4' to 73.4'F. Ice may cover this section of Lake Michigan from January to March. Ice melting and warming of lake waters generally occurs the latter part of March. During this period the so-called "thermal bar" is likely to develop. It is roughly parallel to the shore and is near the temperature of fresh water at its maximumdensity (39OF). The "thermal bar" limits the exchange of inshore-offshore waters.

Lake Michigan has two circulation periods per year, with overturns ocurring early winter and early spring in the southern basin. During each approximately month-long period, vertical mixing is almost complete and the lake approaches an isothermal temperature gradient. These periods of overturn facilitate the upwelling of nutrients from the bottom waters and mayalso stimulate phytoplankton growth. Water movements are also influenced by winds. Prevailing winds blowing in one direction for several days will induce inshore water movement generally parallel to the shore, but bottom topography will alter the direction of the current somewhat. The seasonal current directions are shown in Figure 3.3-2.

Shoreline "run-up" dissipates waves rapidly. Maximumcurrent velocities in the upper layer measured at the

3-22LEGEND: BA1Ll.Y GENERATINQ

STATION DIRECTION

OFCURRENT

SUMMER CIRCULATION S-SWWINDS

$ BAlleLY.::::,I3 STATION

DIRECTION

OFCURRENT

w\NTERCIRCJJCATIO~~ W-NWWINDS

Source: Northern Indiana Public Service Company. ‘Bailly

Generating Station Nuoiear 1, FinalEnvironmental Statement Related toConstruction,’ 1373 SUMMERCIRCuLATIOh N.NEWINDS

WINTERCIRCULATION S-SWWINDS 

# I& Pure Air 2.
ajoint venture company ADVANCED FLUE GAS DESULFURIZATION Seasonal Currents of Lake Michigan Figure 3.3-2station were 40 cm/s. Seiches occur occasionally at the

southern end of the lake. E-37

Anexamination of the Federal Emergency Management E-58 Agency Flood Insurance Rate Mapsand Flood Insurance Studies for Porter County, Townof DuneAcres and Townof Burns Harbor, indicates that the Bailly Generating Station and associated AFGDsystem are above the loo-year flood elevation of Lake Michigan. This elevation is approximately 584 feet, whereas the project is at an elevation of approximately 620 feet based on the U.S. Geological Survey 1.5 minute quadrangle mapfor DuneAcres, Indiana; thus, the AFGDsystem will be constructed 36 feet above the loo-year flood elevation.
"The frequency-elevation data for Lake Michigan was E-58 (sic) developed in aGreat Lakes Flood Level Study prepared by the Detroit District Corps of Engineers. The study uses the manygages on the Great Lakes which have record lengths of 11to 75years. The loo-year lake elevation was studied using the one percent value from the frequency curve of the maximum instantaneous lake level that occurred each year. The lo-, 50-, and SOO-year lake elevations were studied with their respective percentage values from the frequency curves. The lo-, SO-, loo-, and 500-year flood elevation for the Lake Michigan area near the unincorporated areas of Porter County are shown in" Table 3.3-3. (Source: Reference 4.)

3-24E-58 TABLE3.3-3: SUMMARY OFFLOODELEVATIONSFORLAKEMICHIGAN NEARUNINCORPORATED AREASOFPORTERCOUNTYTO INCLUDETHEBAILLY GENERATINGSTATION

Elevations (National Geodetic Vertical Datum - 1929)

lo-Year 50-Year 583.0 583.9 loo-Year 584.2 500-Year

584.8

Source: Federal Emergency Management Agency.

Flood Insurance Study, County of Porter, Indiana Unincorporated Areas. 1981.

3-25iil,

3.4 ECOLOGICALRESOURCES

The area occupied by and surrounding the Bailly Station has adiverse community of terrestrial and aquatic life. The dune region along Lake Michigan in Porter County is estimated to contain at least 40to 50percent of the plant species native to Indiana. Various vegetation types as well as commercial, residential and industrial areas are located within the lake region of the Bailly Station. Each area has its owndistinguishing characteristics. The terrestrial environments provide abeach succession series - dunes, swales, bogs and oak forests. Freshwater habitats include drainage streams, ponds, bogs, springs and Lake Michigan. Appendix Acontains information on the endangered, threatened or rare plants and animals found within the Indiana Dunes National Lakeshore as identified by the State of Indiana, and the federally threatened andendangered species in the Lakeshore. Noneof the plants, amphibians, E-38 reptiles, birds .or mammals listed in Appendix Areside on the site of the proposed AFGDsystem or onthe Bailly Station. The current habitats or migratory patterns of wildlife will E-39 not be disturbed in any wayby the proposed construction of the AFGDsystem.
3.4.1 Terrestrial

The major terrestrial environments near the Bailly Station are the dunes and wind-cleared blow-outs of the Ogden Dunes to the west and the Indiana Dunes National Lakeshore to the east, and their ponds, old field (former farmland) and associated forest components further inland. Each of these
areas has its particular floral composition and fauna1 components, although larger animals can be expected to move freely from place to place. The Cowles and Pinhook Bogs, within the National Lakeshore Boundaries, are two important and intensively- studied bogs; they are typical of other bogs

3-26

### E-39 and wetlands within the vicinity of the site. Outside the

National Lakeshore boundaries, there are anumber of drainage ditches. Burns Ditch is of major importance because it may be asource of locally significant nutrient enrichment of Lake Michigan inshore waters.

The forebeach along Lake Michigan is a riprap zone and is visited principally by insects, blown onto the sands, that feed on carrion (fish and birds) cast up on the shoreline. These insects in turn are preyed upon by shore birds and other insects. Plant life per se is essentially nonexistent. Literature information indicates that most land vertebrates are merely transients, and a large variety of birds use the shore on their migrations.
3.4.1.1 Vegetation

Figure 3.4-l presents agraphic analysis of the vegetation within a S-mile radius of the station. The mid-beach supports afew hardy pioneer plant species (i.e., coarse plants such as the cocklebur and sea rocket). Immediately adjacent to this area, the plant community consists of American beachgrass which is aclump type serving to stabilise the sands. These plants and other grasses are typical of abeach succession ecosystem. In some areas successful changes maybe inhibited or halted along Lake Michigan by the constant shifting of sands, afeature of the normal development of such an ecosystem.

The dune line (foredune) has both active and temporarily stabilized dunes. Manyof the stabilised dunes have forest vegetation, but none is climax. The dominant plants on the more stable foredunes are shrubs, such as cherry and little bluestem grass. Vegetation first develops on the leeward (south) side of the dunes. The ridges are dominated by open forest stands of small black oak, jack



### 3-27..

lVEGETATION ANALYSIS WlTHtN A5-MILE RADIUS OFTHE BAILLY STATION SITE

LECiEND 1Beachwsa~ 11Highway FtidS-ot-~~ 2Baach 12Ima c+nmucld 3Black Oak 13ReeltiM 4Wooded swamp 14Qm was SMwah 15Duln 6RedMa~IelLowlmd Hafdwcad~ 16FYI 7canlfrr 17Bwmlm while oak 6Tramml~lm CarIda 16CQm Fldd 9Orchvd 18CdtIvatad Ftotd 10Military Raemwtim 20MlXbdVvJntti Prepared fmn colw Inbared pkebyaphy obtah-ledm .kma 12. 1874. Fletd backed nd rwlwd &tl, 1676. Source: Texas Inetrumenta, Inc.. ‘1974-1975

Annual Report-Bailly Nuclear IWe’ 

## & Pure Air .k
ajoint venture company ADVANCED FLUE QAS DESULFURIZATION Vegetation Analysis Figure 3.4-lpine, large tooth aspen, chokecherry and witch hazel.

Herbaceous forms such as false solomon's seal, bearberry, huckleberry, sunflower, and bittersweet predominate and are interspersed with seedlings and saplings of black oak and basswood in the understory. White pine are present principally as mature trees. Onactive dunes, the north-facing slopes are covered with bearberry, common junipers, cottonwood, and willow and provide good vertical and horizontal wind shielding.

Forest communities are adjacent to the dunes. The canopy trees are almost all black oak, although basswood is occasionally present. Oakseedlings, wild cherry, sassafras, and witch hazel comprise the understory. The oak forest is classified as both immature and mature. Thevegetational array is similar in these two habitats, but the mature forest has older oaks and a more spotty distribution of herbaceous plants and woody shrubs. Shade-tolerant forms such as bracken fern live under the oaks. There are open areas of sand which are stabilized by sedges and little bluestem grasses. In general, as one goes inland the soils become increasingly clayey (lacustrine deposits) so that they have a higher water and nutrient retention than the dunes. The forests provide diverse microhabitats in the rotting logs, fallen leaves and branches of the forest litter.

The National Lakeshore has anative stand of predominantly red maple and white oak. Sassafras trees and large black oaks are occasionally found in this forest habitat with some 12additional tree species. Most of the saplings are flowering dogwood and red maple. Arrowwood seedlings form dense clumps.

Old field habitats exist within the boundaries of the National Lakeshore. Ponds are commonin the sand dunes of the National Lakeshore. Old field vegetational types are



### 3-29characteristically mosses, sedges and grasses, cattails and

herbs, and maple, cherry and oak saplings.

Cowles and Pinhook Bogs are located to the east of the station and present aclassic picture of abog ecosystem. These are so-called quaking bogs because they have floating mats of sphagnum moss surrounding areas of open water. Other plants are arborvitae and tamarack trees, species which are rare or absent in other places in Indiana. The soils in the bogs support avariety of small indigenous plants such as pitcher plant, cranberry, dwarf birch, leather leaf, bog rosemary, sundew and lady's slipper orchid. There are dense stands of cattails in the center of Cowles Bog. Floating vegetation mats support large numbers of insects.
3.4.1.2 Vertebrates

Vertebrates in the Bailly Generating Station area include small rodent species such as white-footed mice, shrews, voles and squirrels, as well as opossum, skunk, rabbit and woodchuck. Scats (animal fetes) or footprints of deer, raccoon and fox have been observed in the area.

Lower vertebrates encountered in the station area include the red backed salamander, green frog, wood frog, garter snake and Dekay's snake.

Seventy-nine species of birds have been identified in the station area. Eighteen are permanent residents, 29 are summer residents, six are winter residents, and 26 are migrants. Table 3.4-l lists the most abundant species in the area. Abald eagle, arare and endangered species throughout the continental United States has been seen in the National 

### E-40 Lakeshore; however, it has been established that the species

is not aresident of, or nests in the Lakeshore area (Appendix A). The eagle is amigratory bird, and makes its



### 3-30TABLE3.4-l: ABUNDANTBIRDSPECIES KNOWN TONESTIN THEINDIANA DUNESAREA
CommonName Pied-billed Grebe Great Blue Heron Green Heron Canada Goose Mallard Blue-winged Teal Turkey Vulture Red-tailed Hawk CommonBobwhite Sora CommonGallinule American Coot Killdeer American Woodcock Spotted Sandpiper Black Tern Rock Dove Mourning Dove Yellow-billed Cuckoo Chimney Swift Belted Kingfisher CommonFlicker Red-headed Woodpecker DownyWoodpecker Eastern Kingbird Great Crested Flycatcher Acadian Flycatcher Willow Flycatcher Eastern WoodPeewee Horned Lark Tree Swallow Bank Swallow Barn Swallow Purple Martin Blue Jay CommonCrow Tufted Titmouse House Wren Marsh Wren Gray Catbird Brown Trasher American Robin WoodThrush Veer-y Cedar Waxwing Starling Yellow-throated Vireo Red-eyed Vireo Warbling Vireo Blue-winged Warbler Yellow Warbler Cerulean Warbler Ovenbird CommonYellowthroat American Redstart House Sparrow Bobolink Eastern Meadowlark Red-winged Blackbird Northern Oriole CommonGrackle Brown-headed Cowbird Scarlet Tanager Cardinal Rose-breasted Grosbeak Indigo Bunting American Goldfinch Rufous-sided Towhee Chipping Sparrow Field Sparrow SwampSparrow Song Sparrow

Source : Krekeler, Carl Ii.: Ecosystem Study of the

Indiana Dunes National Lakeshore, National: Lakeshore Research Program Report No. 81101, 1981. 3-31habitat in bluffs and flood plains, and around lakes, rivers,

seacoasts and mangroves.

Within the vicinity of the Bailly Station are flyways (migration corridors) of several types of migratory waterfowl including the "dabbling ducks" (such as the mallard, black duck and pintail), the "diving ducks" (such as the redhead and canvasback), Canada goose and the blue goose, also known as the "lesser snow goose." These birds rest in the nearshore waters of the lake and in the interdunal ponds near the lake. The latter provides aprotected resting and feeding area, especially valuable when the lake is turbulent.


### E-38 Nothreatened or endangered amphibian, reptile, 

### E-59 bird or mammalian species are presently known to reside

within the confines of the Bailly Generating Station. Dueto heavy human habitation and the encroachment of industry along the Lake Michigan shoreline of the Chicago-Hammond-Gary area, the Indiana Dunes National Lakeshore and surrounding forested areas provide habitat for anumber of species once present throughout the area (Appendix A).
3.4.2 Aquatic
3.4.2.1 Fish

Fourteen fish species in seven families have been verified in Lake Michigan and several ponds proximal to the Bailly Station (there are no ponds on the Northern Indiana property). Five of these were salmonids, and salmonids comprised the third largest number of organisms, except for alewives and spottail shriners. Perch were also an important species. There are no data to indicate the presence of rare or endangered fish species in the aquatic community (lake, rivers, bogs, marshes, streams, ponds) in the Bailly Station



### 3-32vicinity. Table 3.4-2 lists the fish species identified in

the area. The Bailly Station's thermal plume in Lake Michigan supports moderate to heavy sport fishing in the summer. The fish near the station, probably attracted by the warmer water of the plume, include such gamefish asyellow perch, bluegill and largemouth bass. Several species of minnows and two species of suckers have been found. These fish are important as forage for the gamespecies but are not sought after for sport or food. Five species of importance for sport or food, especially in spring, are coho salmon, lake trout, steelhead trout, chinook salmon and alewives. Other fish of marginal importance, such as carp, bullhead and goldfish, may also appear near the station.

Three fish species have been were verified in ponds in the Bailly Station vicinity, including the green sunfish, mudminnow, and black bullhead, with the green sunfish apparently the most abundant species.
3.4.2.2 Benthos

The hard sand bottom and seasonal water temperatures along the shores of Lake Michigan restrict the numbers and types of soft-bodied, bottom-dwelling macroinvertebrates. Tubificid worms are normal inhabitants of Lake Michigan bottom sediments and have been estimated to comprise slightly more than half of the total benthic organisms present. Somespecies are highly pollution tolerant. Most of the other species of benthic organisms are of atype characteristic of conditions elsewhere in the lake. Represented are leeches, fingernail clams, scuds and midge larvae. Crayfish have also been observed in the station area. The Bailly Station region has extensive areas of

3-33TABLE3.4-2: FISH SPECIESVERIFIED IN THEAQUATIC COMMUNITY OFTHEBAILLY GENERATINGSTATION ANDITS VICINITY

Scientific Name Family Clupeidae Dorosoma cepedianum Alosa pseudoharengus Family Salmonidae Oncorhynchus tschawytscha Oncorhynchus kisutch Salmo trutta Salmo gairdneri Salvelinus namaycush Coregonus clupeaformis Family Umbridae Umbra limi Family Cyprinidae Cyprinus carpio Notropis hudsonius CommonName Herring Family Gizzard Shad Alewife Salmon, Trout and Whitefish Family Chinook Salmon Coho (Silver) Salmon Brown Trout Rainbow (Steelhead) Trout Lake Trout Lake Whitefish Mudminnow Family Central Mudminnow Minnow Family (European) Carp Spottail Shiner Family Ictaluridae Catfish Family Ictalurus melas Black Bullhead Family Centrarchidae Sunfish Family Leponis cyanellus Green Sunfish Family Percidae Perch Family Perca flavescens Yellow Perch

Source : 1974-1975 Annual Report - Bailly Nuclear-l Site,

prepared for Northern Indiana Public Service Company by Texas Instruments Inc., Dallas, TX: June 1975.

3-34iH,

riprap, afavorite habitat of crayfish. Crayfish are a valuable food source for many fish , especially yellow perch.

Table 3.4-3 identifies the macroscopic animals native to the ponds, bogs, creeks, rivers, marshes and ditches that are part of the non-Lake Michigan aquatic community that surround the Bailly Station site.
3.4.2.3 Zooplankton

Zooplankton, by nature of their trophic (feeding) position, serve as the interface between energy contained in the lower trophic levels and the energy requirements higher in the food chain. In a 1970 study conducted by Texas Instruments of the ecosystems in the Bailly Station vicinity, 111 taxa of zooplankton were identified, 46 percent of which were cladocerans, 35percent copepods, and 19percent non-crustacean invertebrates. (It should be noted that during this study, zooplankton samples were collected on one day only.) Of these, Bosmina lonqirostris and copepod copepodids were the most ubiquitously appearing organisms, both temporally and spatially. Other organisms occurring regularly included Cyclops bicuspidatus thomasi, Daphnia retrocurva (lake stations), and Chironomidae larvae (pond stations). Numerical density ranged from 0.44 to 117.79 organisms/liter in the lake and 50.00 to 964.74 organisms/liter in the sampled ponds, a further indication of the higher productivity in the ponds. Spatial and temporal statistical differences were detected between groups of zooplankton stations. These differences reflect the changing habitat or niche structure at the various stations with changing seasons and current characteristics.

Compilation of zooplankton species composition and quantitative distribution indicates that these microcrustaceans were over three times more abundant within

3-35TABLE3.4-3: BENTHOSCOMMON TONON-LAEEMICHIGANAQUATIC COMMUNITIESOFTHEBAILLY GENERATINGSTATION ANDITS VICINITY Family Name Libellulidae Coenagrionidae Corixidae Nepidae Gerridae Mesoveliidae Lymnaeidae Aeschnidae Notonectidae Hebridae Gyrinidae Hydrophilidae Chrysomelidae Gammaridae Hydracarina Physidae Hirydinea Chironomidae Ephemeroptera Lestidae Belostomatidae Veliidae Dytiscidae Planorbidae Sphaeriidae Haliplidae Astacidae Pleidae Sialidae Gelastocoridae Asellidae Elmidae Naucoridae CommonName Dragonflies Damselflies Water Boatmen Water Scorpions Water Striders Water Treaders Pond Snails Dragonflies Backswimmers Velvet Water Bugs Whirligig Beetles Water Scavenger Beetles Leaf Beetles Scuds Water Mites Pouch Snails Leeches Midges Mayflies Damselflies Giant Water Bugs Smaller Water Striders Predaceous Diving Beetles Orb Snails Fingernail Clams Crawling Water Beetles Crayfish PygmyBackswimmers Alder Flies Toad Bugs SOWBugs Riffle Beetles Creeping Water Bugs
Source: Krekeler, Carl H.: Ecosystem Study of the

Indiana Dunes National Lakeshore, NationaT Lakeshore Research Program Report No. 81-01, 1981.

3-36the thermal plume than outside of it. These data suggest

that certain species of zooplankton are either seeking out the warmer water of the plume, reproducing faster in the warmer discharge water, or acombination of the two factors.

Alarge portion of the zooplankton found in the thermal plume had large infestations of fungus ontheir bodies. This was especially apparent in Eurytemora affinis and Daphnia retrocurva, the two most abundant organisms in the thermal plume. These samespecies outside of the thermal plume did not exhibit any infestations of fungus. Copepods and cladocerans in Lake Michigan are rarely observed infested with fungus in offshore waters, but this sometimes occurs in polluted areas such as in southern Green Bay.
3.4.2.4 Phytoplankton

Phytoplankton populations in Lake Michigan reflect seasonal changes in available light, temperature, nutrients and predation. Diatoms dominate the lake flora from mid-fall through early spring. Blue-green algae become briefly dominant in late spring, and green algae dominate in the summer. Diatoms and green algae share dominance in the ponds. Productivity levels in the lake are very low, particularly as compared to nearby river systems. Productivity levels in the ponds are somewhat higher but still within a low range. Arelationship between productivity, biovolume and density of the phytoplankton is apparent. Productivity at the lake stations in the discharge plume is negligible in all months except August, and levels are lower than in the lake, indicating somelocalized inhibition of the phytoplankton population.

3-37After diatoms, the predominant algal group is the

dinoflagellates (Pyrrophyta). Ceratium hirudinella and Peridinium sp. are the most abundant dinoflagellates. These forms have been previously reported from Lake Michigan but not in these concentrations. These organisms are especially abundant in the warmwater discharge.

Blue-green algae (Cyanophyta) are especially abundant in the warmwater. The major species in this population is Gomphosphaeria lacustris.

Other golden-brown algae and green algae are present in smaller concentrations. Dinobrvon sp. is commonly found throughout Lake Michigan. The green algae Scenedesmus protuberans is found throughout the area aquatic habitats. This algae is found in highest volumes in Burns Ditch. With increasing distance from Burns Ditch, this species is found in less volume. This condition is an indication that water and related materials from Burns Ditch are drifting eastward into the vicinity of the Bailly Station discharge plume.

Periphyton are abundant in the discharge area of the station in summerand fall. Most of the genera collected are found in the lake in normal and unpolluted situations. Cladophora glomerata and Lyngbya dignetti, filamentous green and blue-green algae, respectively, are the first and second most commonforms encountered near the Bailly Station. Although Cladophora is normally observed in shoreline habitats of Lake Michigan, it should be noted that its growth is responsive to temperature and nutrient concentration. Under conditions of accelerated growth this species has become anuisance since it can slough off of its substrate, wash ashore, and decompose, producing foul odors. The attached algae harbors several protozoan species and small crustaceans (Gammarus sp.).

3-38/

3.5 SOCIOECONOMICRESOURCES
3.5.1 Population

The residential populations for the incorporated towns within five miles of the Bailly Station are given in Table 3.5-1. In 1989, approximately 42,081 individuals lived in the area. The smallest town, DuneAcres, is aprivate community to which the public in general is not admitted, and is the closest to the Northern Indiana property. Portage is the largest city in the 5-mile vicinity, with apopulation in 1980 of 27,409.

In 1980, the population of Porter County was 119,816. It is projected to be 127,850 in 1990. No population projections are madebelow the county level, so no data are available on migrational trends. The available labor force in 1987 was 53,500 with a7.6 percent unemployment rate countywide. Unemployment figures for individual communities are not available, so no estimate can be madeof the unemployment rate within the Bailly Station vicinity.
3.5.2 Land Usage
3.5.2.1 Regional

Figure 3.2-4, presented previously in Section 3.2, E-41 graphically depicts the regional land use around the Bailly Generating Station. The Bethlehem Steel Corporation, Burns Harbor complex borders the site on the west and south perimeter. The east and south sides of the site are bordered by the Indiana Dunes National Lakeshore Park and Highway 12, respectively.

3-39TABLE3.5-l: POPULATIONDATAFORINCORPORATED(l) COMMUNITIESWITHIN FIVE MILES OFTHEBAILLY GENERATINGSTATION
Community Miles/Direction From Site %Chanqe Dune Acres 2.0 ENE 301 291 -3.3 Burns Harbor 2.5 SSW 1,284 920 -20.2 Porter 3.2 SE 3,058 3,441 12.5 Ogden Dunes 3.5 wsw 1,361 1 Portage 4.5 ssw 19,127 27 Chesterton 4.5 SE 6,177 8 Porter County 87,114 119

Note to Table 3.5-l: 489 9.4 409 43.3 531 38.1 816 37.5

(1) Nocensus data are kept on unincorporated communities.
Sources : U.S. Department of Commerce, Bureau of the

Census. U.S. Census of Population: 1980. Number of Inhabitants, Indiana. Northwestern Indiana Regional Planning Commission, County Profile: Porter County

3-40Fromthe Bailly Station out to two miles very

little permanent residential population exists because of the wide use of the land for purposes other than housing. No applications for industrial building permits have been filed since 1988. Awindshield survey of the Lakeshore area (January 1989) revealed amoderate amount of residential construction underway. Within selected portions of a 5-mile radius of the Bailly Station, however, almost no new homes or condominia were observed under construction.
3.5.2.2 Industrial

The area around the site, and in particular the area to the west, is very heavily industrialized. Lake County, five miles west of the site, includes Gary, Hammond and East Chicago, all of which are centers of heavy industry, particularly the steel manufacturing industry. Besides the steel industry, construction companies and firms producing fabricated metal products aswell as petroleum and coal products have sizeable numbers of employees. Table 3.5-2 illustrates the larger manufacturing concerns in the region. Nearly half of the work force in Porter County is involved with manufacturing, and muchof this work force is employed by Bethlehem Steel adjacent to the Bailly Station.
3.5.2.3 Agricultural

Very little of the land north of Highway 12 is either suitable or used for agriculture. Tothe south of the Indiana Toll Road, the land in Porter, Lake, and LaPorte Counties is largely devoted to growing corn and soybeans. Approximately 60percent of the land in Porter County is used for agricultural purposes.

3-41TABLE3.5-2: MAJOR(l) MANUFACTURING ACTIVITY WITHIN A 5-MILE RADIUSOFTHEBAILLY GENERATING STATION

City Miles/

Direction from Site Chesterton <l/SE
Chesterton 4.5/SE Industry Bethlehem Steel (Burns Harbor) Luria Brothers
Chesterton 4.5/SE Manley Brothers
Portage 4.5/ssw Portage 4.5/ssw Portage 4.5/ssw Portage 4.5/ssw Bethlehem Steel The Levy Co.
Metro Metals Corp. National Steel Corp. (Midwest Div.) No. of

Product Employees Steel mill 6,200 Scrap metal 122 processing Stone, clay, 125 glass products Steel mill 6,000 Stone, clay, 300 glass products Steel foundry 150
Steel mill 1,700

Notes to Table 3.5-2: 

### (1) "Major" manufacturers include those industries with 100 or more employees.

Sources: Indiana Manufacturers Directory, Manufacturers

News, Inc. Chicago: 1988. Iron and Steel Plants Directory, Association of Iron and Steel Engineers. Pittsburgh: 1986. The Dun&Bradstreet Corporation, Million Dollar Directory. Parsippany, NJ: 1988.

3-423.5.3 Public Services

3.5.3.1 Schools, Hospitals and Nursing Homes

Table 3.5-3 lists the six hospitals within a 12-mile radius of the Bailly Generating Station and their respective bed counts. There are no hospitals within five miles; the closest major hospital to the station is Porter Memorial in Valparaiso.

Table 3.5-4 describes the number of public schools in the subject area and provides total student enrollment. Public special education, elementary, junior high and high schools are covered by these data. Day care centers and pre-school facilities are not required to be monitored by the Indiana Department of Education, so no enrollment or location information is available.

Table 3.5-S indicates the nursing homes and number of beds in the station area.
3.5.3.2 Transporation

The site is located in an area where access to transportation facilities is readily available. The two-lane Highway 12borders the site boundary onthe south as does the Chicago South Shore &South Bend Railroad (CSS&SB). A six-lane segment of an interstate highway, I-94, is located about four miles south of the site; another four-lane road, Highway 20, is situated 2.5 miles southeast of the site. Because the Bailly Station is located onthe edge of Lake Michigan, it is possible to reach it by way of the lake. Figure 3.5-l indicates the various routes of transportation near the station. Northern Indiana has arelatively high density of railroad mainlines and principal highways that feed into Chicago from the east and south. The railroad

3-43TABLE3.5-3: HOSPITALSWITHIN A 12-MILE RADIUSOFTHE BAILLY GENERATINGSTATION Hospital Location Porter Memorial Valparaiso Methodist Gary St. Mary Medical Center Hobart Michigan City Memorial Michigan City St. Anthony Michigan City Kingwood Michigan City No. of Beds 379 355 300 102' 190 89

Source : Indiana Department of Public Health, Acute

Care Services Division, Indianapolis, IN. Personal communication: January 1989.

TABLE3.5-4: PUBLIC SCHOOLENROLLMENTFORCOMMUNITIES

WITHIN A 12-MILE RADIUSOFTHEBAILLY GENERATINGSTATION

Community NO.of Schools Chesterton 6 Porter 1 Portage 9 Hebron 3 Valparaiso 19 1988 Pupil Enrollment 4,018 353 8,059 1,425 8,737

Source: Indiana Department of Education, Educational

Information, Indianapolis, IN. Personal communication: January 1989. 3-44TABLE3.5-5: NURSINGHONESANDBEDTOTALSWITHIN A 12-MILE RADIUSOFTHEBAILLY GENERATINGSTATION
Community No. of Nursing Homes Total Beds Chesterton 1 100 Portage 2 215 Valparaiso 4 578

Source: Indiana Department of Public Health, Health

Facilities Division, Indianapolis, IN. Personal communication: January 1989.

3-45LAKE MICHIGAN

Chesterton

FORMER LAKE BOTTOM

Source: Indiana Dunes National Park map,diatributed

bythe National Park Service. 

# ‘U M’LE QRAPHIC SCALE 

# I& Pure Air A
ajoint venture company ADVANCED FLUE GASDESULFURIZATION Major Roadways and Recreational Land Use Figure 3.5-1 E-3, 42lines that were operating within a lo-mile radius of the

Station in 1988 include Conrail and CSX. Direct commuter passenger service to the station entrance is available via the CSS&SBelectrified railroad.

Several principal highways pass within 10 miles of the station, including Interstate Highways 80, 90and 94, 20, 12and 6, all of which run in general east-west direction. Interstate 65 runs north-south through Gary. Highway 12, known also as the Dunes Highway, passes closest to the lakeshore, and the station entrance road leads directly to Highway 12. At present Highway 12passes directly through land that is nowpart of the National Lakeshore. Astudy by the National,Park Service (NPS) is in progress to determine the feasibility of re-designating Highway 12as aparkway according to NPSstandards. Approval of the request by Congress would affect truck traffic along the highway by the Bailly-Bethlehem Steel sites. Results of the study are expected sometime in 1991.
3.5.3.3 Historical Sites and Natural Landmarks

There are no state-supported historical sites in Porter County. Onthe federal level, the Joseph Bailly Homestead and Cemetery are located within two miles of the Bailly Generating Station (Appendix B). The Bailly Homestead E-64 is listed in the National Register of Historic Places.

The South Shore Station at Beverly Shores has been nominated to the National Register of Historic Places as the only surviving example of stations from the early period of South Shore history. Northern Indiana owns the property on which the South Shore Station sits; it is approximately 10 miles from the Bailly Station. The National Park Service has approved the application; the state is currently reviewing

3-47it. If the site passes state criteria, it will be submitted

to and reviewed by the National Register of Historic Places.

There are no known significant deposits or archaeological materials within the Bailly Station boundaries, although three Registered Natural Landmarks are located within a few miles of the site. Cowles Bog, the closest, lies immediately to the east of the station boundary. Dunes Nature Preserve is located within the Indiana Dunes State Park between the towns of DuneAcres and Beverly Shores. Pinhook Bog is situated about 12miles east of the station.
3.5.3.4 Recreation

Except for the three miles of industrial lakeshore occupied by the Bailly Station, the steel mill properties, and the Port~of Indiana, most of the 15 miles of lakeshore in Porter County is used as either public or private swimming beach. Because of the natural sand accumulation, the water is generally shallow within 50 feet of the shore line and is thus arelatively safe water;sport area. The boat docks in the area are primarily in the private marinas that line the shore of Burns Ditch and the public harbor at Michigan City.

The Indiana Dunes State Park and the Indiana Dunes National Lakeshore occupy the area to the east and south of the station. It consists of about 8,000 acres of lakeshore, bogs and marshes. Public Law, 89-7'61, passed in November 1966, authorised the Secretary of the Interior to establish The Indiana Dunes National Lakeshore when sufficient lands had been acquired to be administered effectively as aunit. The Lakeshore was formally established in 1972 and is now administered by the National Park Service.

3-48Fishing in Lake Michigan is apopular recreational

pastime. Anglers fish from boats anchored near the end of the Bailly circulating water discharge plume where salmon, trout and perch are frequently in abundance. The construction and operation of the AFGDsystem will not prevent anglers from continuing to use this excellent fishing spot.
Inland fishing is very limited. The inland lakes are not stocked by the Department of Natural Resources so local fisherman deplete the fish population by the end of the season. Lake Palomara in Chesterton has no fish in it at all. Local fisherman also fish in the Kankakee and Little Calumet Rivers, and on achain of small lakes in the Valparaiso area.

Figure 3.5-l depicts some of the recreational uses of land within a5-mile radius of the Bailly Generating Station.

3-493.6 ENERGYANDMATERIALSRESOURCES
Northern Indiana currently operates two electric generating units at the Bailly Generating Station. The units are coal-fired and rated at 528 MWtotal for both. The station consumes approximately 1.1 million tons of coal per year to generate almost 3,200,OOO WWH,of which the station consumes 200,000 MWIi. Natural gas can also be used as an alternative fuel. The coal is delivered to the station by railcar and stockpiled at the site, whereas the natural gas is delivered by an underground pipeline.

The generating station receives process/cooling water from Lake Michigan at an average of 221 million gallons per day (MGD).

Every two to three years the station must dredge the area surrounding the intake pipe. The dredging is done with the approval of the Army Corps of Engineers and is permitted by the Indiana Department of Natural Resources. The material dredged is generally used for beach enrichment at area beaches.

3-503.3 REFERENCES

1.

2.

3.

4.

5.

6.

7.

8.

9. Collings, Edith. Indiana Department of Public Health, Acute Care Division. Indianapolis, Indiana. Personal communication: January 1989. Directory of Iron and Steel Plants. Association of irgh, Pennsylvania: 1986. Dorell, Susie. State Board of Health, Division of Public Health Statistics. Indianapolis, Indiana. Personal communicationr January 1989. Federal Emergency Management Agency. Flood Insurance Study, County of Porter, Indiana Unincorporated Areas, 1981. E-58

Federal Emergency Management Agency. Flood Insurance Study, Townof Burns Harbor, Indiana Porter County, 1980. E-58

Federal Emergency Management Agency. Flood Insurance Rate Maps: County of Porter, Indiana (Unincorporated Areas). Community-Panel Number 180425 0025B. 1982. Townof DuneAcres, Indiana Porter County. CommunityPanel Number 180205 0001 B, 1981. Federal Emergency Management Agency. Flood Boundary E-58 and Floodway Maps: County of Porter, Indiana Unincorporated Areas). Community-Panel Number 180425 01-0190 1982 Townof Burns Harbor, Indiana Porter County. Community-Panel Numbers 180207 0001 Band 180207 0001-0002, 1981. Harris, Rick. National Park Service, Resource Management. Indiana Dunes National Lakeshore, Porter Indiana. Personal communication: January 1989. Indiana Business Research Center. Indiana University School of Business, Bloomington, Indiana. Personal communication: January 1989. 10. Indiana Department of Environmental Management, Meteorological Data (1984-1986). Compiled for Porter County State Implementation Plan (SIP), Data from Dunes Acres. E-33

11. Indiana Manufacturers Directory Manufacturers New, Inc. Chicago, Illinois: 1988.

3-51REFERENCES(Continued)

12.

13.

14.

15.
16.

17.

18.

19.

20.

21.

22. Krekeler, Carl H.; Reshkin, Mark; Kiefer, Wayne E.; Weber, Neil V.; Brunansky, Louis; EcoSystem Study of The Indiana Dunes National Lakeshore, Vols. Oneand TWO. Indiana Dunes National Lakeshore Report Research Program, Program 81-01. National Park Service, Midwest Region: 1981. Lane, Karen. Indiana Department of Education, Educational Information Systems, Indianapolis, Indiana. Written communication: January 1989. Martin, Michelle L., Indiana Natural Heritage Program, Division of Nature Preserves, Indiana Department of Natural Resources. Indianapolis, Indiana. Written communication: January 1989. Meyers, Robert A., ed. Coal Handbook. Marcel Dekker, Inc. NewYork, NY: 1981. Northern Indiana Public Service Company. Annual Report - Bailly Nuclear-l Site. Prepared by Texas Instruments Inc., Ecological Services. Dallas, Texas 1974 - 1981. Northern Indiana Public Service Company. Bailly Generating Station Nuclear 1- Environmental Report. 1981. Northern Indiana Public Service Company. Bailly Generating Station Nuclear 1- Finai Environmental Statement Related to Construction, 1973. Parch, Dori, Historian. Indiana Dunes National Lakshore, Porter, Indiana. Personal communication: January 1989. Pierce, Frances, Indiana Department of Public Health, Health Facilities Divison. Indianapiolis, Indiana. Personal communication: January 1989. Porter County Convention, Recreation and Visitor Commission. Chesterton, Indiana. Written communication: January 1989. Porter County SO Modeling Analysis, Indiana Department of Enironmental

2. Management, Office of Air Management, Indianapolis, IN. June 1988

3-52REFERENCES(Continued)

23. Rand McNally Handy Railroad Atlas, Rand McNally Company, 1985. 24. Rhein, Lauren. Census and Statistical Data Center. Local Population Estimates, 1982, 1984 and 1986; Population Projections, 1990 - 2020; County Profiler Porter County; Community Profiles: Burns Harbor, Chesterton, Dune Aces, Portage, Oqden Dunes, Porter. Northwestern Indiana Regional Planning Commission, Highland, Indiana. Written communication: January 1989. 25. Studies to Support the Useof ISCST (Rural) for SIP Development in Porter, County, Indiana, Enviroplan, February 3, 1988. 26. U.S. Department of Commerce, Bureau of Census. U.S. Census of Population: 1980 - Number of Inhabitants, d' In iana. Of 1982. U.S. Government Printing

3-534.0 CONSEQUENCES (IMPACTS) OFTHEPROJECT
4.1 ATMOSPHERICIMPACTS
4.1.1 Construction

The potential for air pollution, as a result of site preparation and other construction-related activities, from airborne dust or occasional smoke is small and directly affected by seasonal and daily weather variations. This potential is not considered ahazard to normal activities within or adjacent to the industrial complex surrounding the Bailly Station. In addition, water will be sprayed on roads when necessary, to reduce fugitive dust during construction. E-4

4.1.2 Operation

During operation, both emissions and ground-level concentrations of SO2will be reduced. Whenthe AFGDsystem is not in operation or during an upset condition, combustion products will be directed through the existing stack. Combustion products will bewithin existing Bailly Station emission permit requirements as discussed in Section 5, Permit Requirements. Thus, no additional impact than that currently prevailing will be observed. The area is currently classified as an attainment area with respect to S02. During operation total NO,emissions will remain unchanged, although concentrations of NO, at ground level mayincrease as a result of the lower temperature of the plume. Modeling using E-44 ISCST (Rural) indicated that no contravention of National Ambient Air-Quality Standards will result.

The fugitive emissions from the station may increase due to transfers of pulverised limestone at the site. The limestone will be delivered by truck and

4-lE-45 transferred to astorage silo. Transfer to the AFGDsystem

will be accomplished pneumatically. However, these small fugitive emissions should not cause any discomfort to visitors to the National Lakeshore or to residents of nearby communities. This will be assured by compliance with applicable fugitive dust regulations.

The only air emissions from the AFGDsystem are in the flue gas exiting the scrubber and stack. The existing and newemission rates and emission standards for the regulated compounds are as follows:

Compound Emissions AFGD

Without AFGD Emissions jLB/MMBtu) (LB/MMBtu) Existing Emission Standard LLB/MMBtu)
SD2 5.2 0.52 6.0 No, 1.70 1.70 N/A Particulate 0.10 0.10 0.22 Matter
TheAFGDsystem will reduce the SO2emission rate by 90 percent from 5.2 lbs/MMBtu to 0.52 lbs/MMBtu. This is a significant reduction in SO2emissions, and results in an SO2emission rate that is well below the NewSource Performance Standard (NSPS) of 1.2 lb/MMBtu. The process does not reduce or increase the present NO,or particulate matter emission rates of 1.70 lb/MMBtu and 0.10 lb/MMBtu, respectively. Thewet limestone slurry does not react with the NO, so that no NOxis removed in the SO2absorber.

Noadditional particulate matter is expected to be emitted as aresult of the AFGDsystem. In practice, all FGD systems receive someamount of particulate (nominally 0.1 lb/MMBtu for the Bailly Station) from the electrostatic

4-2I,

precipitator. Approximately 50 percent of this particulate received from the ESPis removed by the AFGDsystem. The AFGDsystem in turn emits aminor amount (0.05 lb/MMBtu of scrubber generated particulate matter). Thus, there is no net increase in particulate matter as measured before and after the AFGDsystem.

4-34.2 LAND-USEIMPACTS

4.2.1 Construction

E-47 Land use impacts during the 24-month construction

period are projected to be minimal, primarily as aresult of the industrial nature of the Bailly Station. Additionally, the AFGDsystem will utilise less than two percent of the land presently dedicated to the Bailly Station.

Initial impacts will result from the installation of utilities and site preparation activities. Laydown areas will be provided for construction equipment, delivery and handling of materials. This land dedication of less than two acres will be temporary in nature, and following construction will be returned to its existing industrial state as debris, temporary structures, equipment and materials are removed.

Noquantities of oil will be utilized during construction sufficient to cause aspill warranting immediate action. Any construction-related spills will be quickly contained by soaking into the soil's surface dressing. If necessary, the affected surface dressing will be removed from the site for disposal in an appropriately-approved landfill. In the unlikely event of such anoccurrence, response would be immediate in accordance with the Spill Prevention, Control and Countermeasure Plan that will be developed.

The construction phase will have aminimal effect on the recreational land area adjacent to the Bailly Station. The park area will be shielded from construction activities E-70 by the "green belt." The green belt is a 300-foot "L" shaped

parcel of land that bounds the eastern side of the Bailly Station and aportion of the northern boundary of the site; both segments abut part of the Indiana Dunes National Lakeshore. This parcel, owned by Northern Indiana, has been

4-4left in its natural state to serve as abuffer zone as shown

in Figure 3.2-3. The Bethlehem Steel Plant to the south and west should also be unaffected by construction because of its industrial environment.

There will be no impact of construction activity on E-64 historic resources. Nohistoric structures or sites have previously been recorded on the Northern Indiana property. Further, the Joseph Bailly Homestead and Cemetery, approximately two miles from the site, are not projected to be impacted by construction related activities., Likewise, the South Shore Station, 10miles from the construction site, proposed for inclusion in the National Register of Historic Places, will not be impacted by construction activity (Appendix B).
4.2.2 Operation

Land-use impacts at the Bailly Station as a result of operations will be minimal since the AFGDsystem operation will be taking place on aheavily industralized site.
E-46

Currently Pure Air is facilitating negotiations with manufacturers of wallboard to become asupplier of gypsum. Successful negotation of acontract would result in this by-product being recycled into auseful product. Alternatively, the gypsum could be landfilled at an existing disposal site. Although this latter disposal option would consume approximately four acres of land annually, assuming disposal of 300,000 tons in 20-foot lifts, use of an existing appropriately-permitted landfill would result in minimal environmental impact. Currently there are landfills within E-49 Porter County that are appropriately permitted.

The quantity of fly ash generated at the Bailly Station with the AFGDsystem will be slightly higher than

4-5E-31 that generated by existing operations as aresult of the WES.

If beneficial uses for the fly ash are not determined, it will be landfilled. This will involve the use of land that has already been dedicated for waste disposal and would have been used for normal station ash disposal. Thus, the AFGD system mayhave minimal impact on available landfill capacity and no impact onwater quality.

Operation of the AFGDsystem is projected to have no impact on existing or proposed historic resources.

4-64.3 WATER-QUALITYIMPACTS

4.3.1 Ground Water
4.3.1.1 Construction

The construction of the AFGDsystem at the Bailly Generating Station will not have any effect on the ground water in the area. There will be no materials used during the construction period that are expected to cause any problem with ground water.

Any construction-related oil spills will be quickly E-47 contained by soaking into the soil's surface dressing. If necessary, the affected surface dressing will be removed from the site for disposal in an appropriately-appoved landfill. In the unlikely event of such anoccurrence, response would be immediate in accordance with the Spill Prevention, Control and Countermeasure Plan that will be developed.
4.3.1.2 Operation

TheAFGDsystem will be designed to minimize wastewater generation. However, there will bewastewater from the sanitary system and someprocess-related high chloride wastewater. These wastewaters will be discharged to wastewater ponds at the Bailly Station. Permitting of this discharge is discussed in Section 5, Regulatory Compliance. E-48

As indicated previously, the process-related wastewater will be high in chloride concentration. However, it is unlikely that chloride will seep into the ground water since the ponds at the Bailly Station are sealed with clay and amembrane liner. The most recent results of ground water monitoring have shown no impact on the ground water.

4-7The Indiana Department of Environmental Management (IDEM) has

waived monitoring requirements for the Bailly Station because E-61 of documentation of no seepage (Appendix C). Therefore, the

operation of the AFGDsystem should pose no hazard to the ground water in the area.
E-46 Solid wastes (e.g., ash and gypsum) generated from E-62 operation of the AFGDsystem maybe put to beneficial use or

disposed in previously mentioned appropriately-permitted state facilities. Asdiscussed in Section 2.1.3.4, on-site gypsum will be stored in buildings prior to removal from the site and will be stored in asilo prior to use in the AFGD system. Thus, the impact on ground water should be minimal.
4.3.2 Surface Water
4.3.2.1 Construction

Water for construction of the AFGDsystem would be obtained directly from Lake Michigan. This usage is not anticipated to have any effect on the lake, nor to affect recreation thereon. Noadditional outfall or docking facilities (permanent or temporary) are planned during construction of the AFGDsystem.
E-35 Areview of the area wetlands (Figure 3.3-l)

indicates that the AFGDsystem structures will not be built on any existing wetlands.
4.3.2.2 Operation

Lake Michigan will provide all process water and meet other lesser water requirements, estimated to be 880 gallons per minute (gpm), or 70x 10' gallons annually, at 100 percent operation. Emergency fire water will be supplied at 1000 gpm, if ever required. The lake will not be impacted

4-8by this use, nor will the wetlands that are characteristic of

the Lakeshore area.

Surface water impacts from the operation of the AFGDsystem will be negligible since the system will be designed to comply with existing NPDESpermit conditions for the Bailly Station.

Small quantities of office waste materials, resulting from normal operations, will be stored in covered containers or trash bins to minimise potential contamination of surface water. These materials will consist primarily of paper, cardboard boxes, plastic bags, small cans, bottles and jars, light bulbs, food scraps and floor sweepings. Subsequently they will be disposed by acontract hauler.

Asdiscussed above, the ash generated from the AFGD system will be placed in astorage silo prior to removal from the site for disposal. Any material spilled around the silo will be picked up to avoid potential contamination of surface water, as is current practice.

Limestone and gypsum also will be stored in buildings to prevent run-off to the surrounding area.

The WESwill be designed to evaporate part of the wastewater from the process, and result in lower water discharges from the process. Provisions will be madeto dispose of the remainder of the process wastewater in on-site ponds. These ponds can be discharged to Lake Michigan on the north side of the station. Thewastewater flow rate at normal AFGDsystem load and the estimated or predicted wastewater composition are shown in Table 4.3-l.

The quantity of the water shown in Table 4.3-l is based on the assumption that the wastewater evaporation E-50

E-46

E-46

E-51 E-53

4-9E-26 TABLE4.3-l: PROJECTEDWASTEWATER COMPOSITIONFROMTHEAFGD E-51 PROCESS~0 ON-SITE PONDS

Parameter Quantity, gpm Total Suspended Solids, wt.% CaS04*2H20 Fly Ash &Inerts Total Dissolved Solids, mg/l

Ca++ Mg++
soaclF- (total) s20; Level 116.8 (total flow) 5.6 5.15 0.45
7,186 4,035 1,293 23,072 1,095 605

4-10system is not operating. Even under this extreme condition

(based on discussions with the Indiana Department of Environmental Management, Office of Water Management), the projected wastewater discharge composition for key parameters will be below preliminary water quality standards which are based on permit limits in the receiving water body (Lake Michigan) as shown in Table 4.3.2. This table also includes information on the current discharge from the Bailly Station.

4-11TABLE4.3-2: COMPARISONBETWEENEXISTING ANDPROPOSED WASTEWATER DISCHARGETOLAKEMICHIGAN, ANDPRELIMINARYWATER QUALITY BASEDPERMITLIMITS

Parameter Flow, MMgpd Ca++ Mg++ so;clF- (total) Total Dissolved Solids Current

Discharqe (mq/l) 220.9 36.0 12.3 23.6 10.6
no data
no data Preliminary

Proposed Water Quality Based AFGDSystem Permit Limits (mq/l) Discharqe (mq/l) Averaqe Maximum 221.1 220.9 443.2 41.7 N/A N/A 15.5 N/A N/A 24.6 176.5 410.7 29.0 162.4 377.8 0.9 1.4 3.3 150.0 529.5 1,232.0

Note to Table 4.3-2: The current Bailly Station discharge includes cooling water, treated sanitary water, deicing water (cold weather only), and wastewater from the on-site ponds.

4-124.4 ECOLOGICALIMPACTS

4.4.1 Construction

Construction activity related to development of the AFGDsystem is anticipated to have little or no impact on the area's ecological systems. The area proposed for construction is presently free of vegetation thus negating the need for clearing of potential habitat. The major impact of construction onwildlife will be that which occurs as a result of increased humanactivities. This impact maybe observed on the less mobile species such as amphibians, reptiles and small rodents, and to a lesser degree on avian species, if present. However, it is believed that sufficient habitat exists adjacent to the construction area to permit relocation.
It is anticipated that construction activity will not increase the silt load on any surface waters. Anerosion and sedimentation control plan will be developed to assure no detrimental impact on aquatic species.
4.4.2 Operation

As a result of the increased humanactivity associated with operation, it is expected that species resident, if any, mayleave the area to seek newhabitat. None of the species known to occur in the area has a restricted homerange. Overall, there is no detrimental effect projected for the species identified in the site environs, as a result of humanactivity during AFGDsystem operation.
Nostate or federally listed threatened or endangered plant or animal species, or critical habitat for

4-13such species, are present onthe Bailly Station or are

expected to be impacted by the proposed project within the site environs (Appendix A).

Additionally upon completion, the newstack will be appropriately marked which should minimise the effects on flying species.

TheAFGDsystem will conform to the requirements of the NPDESpermit as administered by the IDEM. This will not only assure strict effluent discharge limitations, but also monitoring requirements as set forth in Section 4.7.2. Hence, no detrimental impact on aquatic resources is projected.

4-144.5 SOCIOECONOMICIMPACTS

4.5.1 Construction

Anassessment of the relative impact of the construction of the AFGDsystem on population, employment and housing in Porter County indicates abenefit will result with respect to these attributes of the area. The construction work force for the system will consist of approximately 200 to 300 construction employees at the peak level. In terms of population changes, no significant increase is expected due to plant construction, as the area presently experiences limited construction activity on aregular basis. Also, no unusual demands for additional school or emergency medical services are anticipated.

Experience from previous projects indicates that most of the workers will commute to the job site. This suggests that anumber of workers maycomefrom within Porter County and adjacent counties. Apermanent work force of 25 to 30 full-time employees will be required once the AFGD system is operational. This will contribute to an improved employment outlook in Porter County.

Construction of the AFGDsystem will not have any significant impact onthe housing demands in the area. Only those employees who live too far from the site to commute, and those whowill be permanently assigned to the site once the AFGDsystem is operational, will have aneed initially for temporary and subsequently for permanent housing. This will constitute arelatively small percentage of employees requiring permanent residence, but will provide apositive benefit to the local economy.

4-154.5.1.1 Transporation

E-43 Primary access to the proposed construction site

will be from Highway 12and the nearby interstate system. The anticipated increase in traffic volumes averaging from 100 to 150vehicles per day will easily be accommodated by the existing transportation network thereby reducing potential impact as aresult of vehicular congestion. Parking will be provided on-site at existing and temporary facilities. This will further minimise impact. The lack of residential and commercial enterprise in the area will further minimize impacts or disruption of activities as a result of construction activities.
4.5.1.2 Noise

Increased sound levels will be generated from AFGD system construction activities and from delivery of materials to the site by truck. However, the proposed location of the site, where the majority of construction activity will occur, is such that the closest residence is approximately 8,400 feet away. At this distance, there will be asignificant reduction in the levels of construction noise at the nearest residential receptor.

Present sound levels around the Bailly Station will be measured and documented. Based upon these levels and an examination of current and potential noise regulations, design sound-level criteria for the site will be established to minimise the effects of construction on present sound levels.
Adverse effects from noise produced during construction activity will be further mitigated by avoiding, to the greatest extent practical, the scheduling of on-site

4-16II

construction activity during evening hours, weekends and holidays.
4.5.1.3 Visual

Visual exposure of construction activities will be obscured except during construction of the newstack.
4.5.2 Operation

The impact on population, employment and housing as a result of operation of the AFGDsystem will be positive for Porter County and the region surrounding the Bailly Station. Permanent employees of Pure Air will require housing, but will not place a large demandon the real estate market.
4.5.2.1 Transportation

The addition of from 110to 120vehicle-trips on a 24-hour basis will not impact the existing vehicular network. Parking will be easily accommodated on-site on apermanent basis.
4.5.2.2 Noise

Because of the industrial nature of the Bailly Station area and the distance to sensitive noise receptors, the net increase in area noise will be imperceptible beyond E-30 the plant boundary. Based on data from the Akoo power plant E-32 of the Kanasi Electric Company (600 MW),during normal operations, sound levels immediately adjacent to the FGD system were observed to be 111 dB(A). At the nearest residential receptor (8400 feet) the AFGDsystem operating at the Bailly Station, acomparable facility (528 MW),would produce asound level of 58dB(A). The vehicular traffic

4-17projected in Section 4.5.2.1 would increase this level by

less than 0.1 dB(A).
4.5.2.3 Visual

In all likelihood, the AFGDsystem will be perceived asvisually blending with the other structures on-site at the Bailly Station, except for the new stack that will be required for operation of the system. The new stack height will be 480 feet or less. This is necessary to ensure asuccessful and environmentally sound operation. Operation of the newstack will produce avisible steam plume characteristic of FGDsystems.

4-184.6 ENERGYANDMATERIALSIMPACTS

4.6.1 Construction

During the construction phase of the AFGDsystem heavy construction equipment aswell as construction materials such as steel, cement and concrete will be needed. Electrical connections and other auxiliaries will be necessary. Power will be supplied from the existing Bailly Generating Station. Temporary structures and warehousing will be built to accommodate the equipment and materials necessary during construction.
4.6.2 Operation

Limestone and coal will be the main raw materials and gypsum will be the by-product from the AFGDsystem. The raw materials to be consumed and gypsum produced for this project have been estimated as follows, with the coal consumption based on current Bailly Station demand:

Estimated Annual Consumption
Coal l,lOO,OOO tons/yr Limestone 160,000 tons/yr
Estimated Annual Production Gypsum 300,000 tons/yr
In addition, water and electricity will be required for AFGDsystem operation as follows:

4-19Estimated Average Consumption
Process water 880 gallons per minute Electrical usage 7.6 MW Projected Emerqencv Consumption
Fire water 1,000 gallons per minute Quenching water 5,800 gallons per minute
The annual estimates are based on an estimated capacity factor of 65percent and the AFGDdesign coal (4.51 weight percent sulphur) data in Section 2.1.3.2, while the average and emergency estimates are based onthe preliminary process design.

Limestone will be used as an absorbent. It is inexpensive and widely available: 46of the 50 states produce limestone. Depending on market condition and availability, limestone can be acquired from one of the main limestone producers (Illinois, Ohio, Michigan or Indiana).

Lake Michigan will serve as the source for the additional water necessary for the AFGDsystem.

4-204.7 IMPACTSUMMARY ANDMITIGATION MEASURES
4.7.1 Mitigation Measures

Because the AFGDsystem will be installed in a heavily industrialized area, no significant EHSSimpacts are expected during the construction and operation of the system, other than the beneficial impact of the reduction of SO2 emissions. However, the following mitigation measures will be implemented for the indicated areas to minimise potential impacts.
In addition to improved air quality, implementation of the demonstration program will create permanent employment and produce apotentially saleable by-product. More importantly, however, the successful operation of the system will substantially reduce aprecursor of acid rain with a technology applicable at other locations throughout the United States.
4.7.1.1 Atmospheric Mitigation

During construction, temporary access roads and laydown facilities will be treated to minimise fugitive dust emissions. Noopen burning will be allowed. Cleared areas will be covered with hay to minimise potential wind erosion.

TheAFGDsystem will reduce SO2emissions to the environment during normal operations, thus enhancing air quality. Whennot on-line or during an upset condition, stack emissions will be redirected to the existing stack, thus avoiding an unexpected impact on ground-level concentrations. This mitigating measure will begaccommodated in the system design.

4-21Bulk loading of pulverised limestone or by-product

gypsum will be done with enclosed transfer systems, minimising fugitive emissions from these activities. Trucks transporting hydrated lime or by-product gypsum will be covered, further minimising on-site emissions to the atmosphere.
4.7.1.2 Land-Use Mitigation

During construction, the primary impact on land use will result from the occasional increase in sound levels resulting from this activity. Limiting such activity to daytime and avoiding construction onweekends and holidays, when possible, will substantially mitigate any unusual perception of increased noise levels during these periods.

The site is sufficient to absorb parking for the work force in existing and planned permanent parking areas. During operation the increase in traffic from trucks and the work force will not impact traffic flow, because of the existing capacity of the road network; therefore, no mitigation measures are planned.

Disposal of ash and other solid wastes will be in appropriately designated areas. Thus, mitigation measures are not required for this aspect of the project.

Finally, compliance with zoning requirements and the remote location of the AFGDaystem within a highly industrialised area will mitigate any significant impact of construction and operation of the AFGDsystem.
4.7.1.3 Water-Quality Mitigation

Prior to actual construction, asoil erosion and sedimentation plan will be developed. It will incorporate

4-22I

features such as treating open areas to avoid erosion of these areas by runoff. Any spills will be cleaned up immediately. These procedures will eliminate contaminating surface and ground water resources. Additionally, any runoff will be intercepted and diverted to the existing stormwater system. Borrow will be used for backfill and cover; construction areas will be closed and graded upon completion of construction.

The WESconstitutes one of the major alternative designs for the AFGDsystem. Containment of somedischarges is asignificant means of addressing impact on both ground and surface water. If wastewater is diverted to the on-site ponds, it will be contained as the existing ponds do not discharge to the ground water. Discharges from the ponds to the lake will be controlled and monitored under an NPDES permit.
4.7.1.4 Ecological Mitigation

No major impacts of construction or operation of the AFGDsystem are projected for the negligible ecological resources of the Bailly Station. The mitigating measures specified in Section 4.7.1.3 to protect water resources will also protect aquatic resources.
4.7.1.5 Socioeconomic Mitigation

Nomitigation measures are proposed for socioeconomic impacts, since no significant impacts are projected during construction and operation of the AFGD system. TheAFGDsystem is viewed as abenefit to the area's socioeconomic setting.

4-234.7.1.6 Energy and Materials Mitigation
The generation of electrical power is by nature consumptive of natural resources. The production of auseful by-product, gypsum, constitutes amitigation of this overall activity from the overview perspective. Alarge portion of the SO2in the stack gas will be converted to a,saleable product. Finally, the plant will be afforded the option of burning awidely available, economical high-sulfur coal, while lowering SO2emissions from their present,levels.
4.7.2 Monitoring

Environmental monitoring for the AFGDproject will focus on collecting on-site technical, environmental and operating data. Thus, monitoring will be primarily for environmental characterisation of the process and compliance with regulatory agency conditions. Four monitoring areas will be addressed: wastewater, air, solid waste, and health and safety.
Environmental monitoring data will be collected using continuous monitoring equipment, adistributed control system, and intermittent or periodic sampling. Continuous monitoring equipment is expected to include monitors for opacity, S02, O2and slurried chloride, sulfite and carbonate concentrations. Other process data (e.g., major anions and cations) will be collected on adistributed control system with ahigh sampling frequency such that these data can be considered essentially continuous. Finally, somedata will be collected on aset sampling schedule primarily as part of compliance monitoring to meet regulatory agency permit conditions.

4-244.7.2.1 Wastewater Monitoring
The Bailly Generating Station has awastewater discharge to Lake Michigan. Thewastewater initially goes to aseries of on-site retention ponds and then is recycled by the station on an as-needed basis. This discharge is under an NPDESpermit and covers the main outfall and intake discharges (Appendix C).

The proposed AFGDsystem will demonstrate the potential for reducing liquid waste from any portion of the process. If the proposed WESis not used as currently planned, then wastewater from the AFGDsystem will be discharged into anon-site pond. Additional wastewater discharges resulting from the AFGDsystem mayinclude sanitary wastes and stormwater runoff. These additional discharges will be handled by existing facilities.

Noadditional wastewater monitoring will be required as aresult of the AFGDsystem, since no newoutfall points are proposed. The current wastewater outfall monitoring will be maintained as required by the IDEM, Office of Water Management (OWM). Thewater quality information required by the OWM mayinclude chlorides, pHand TSS, as required for the existing outfall.
4.7.2.2 Air Monitoring

The Bailly Station currently measures plume opacity from the existing stack. Biennial stack tests are also conducted to measure SO2and particulate matter emission rates. The current IDEM, Office of Air Management (OAM) permit allows for an emission level of 6.0 lbs/MMBtu for S02, 0.22 lbs/MMBtu for particulate matter and anopacity limit not to exceed 40 percent (Appendix C).

4-25Northern Indiana also conducts ambient air

monitoring as part of the Porter County SO2Monitoring Network. Northern Indiana collects SO2data from three monitoring sites, two of which also collect meteorological data. The proposed AFGDsystem should not introduce any additional air pollutants into the Bailly Station area; in fact, this system is designed to reduce SO2emissions by 90 percent or greater.

Anexisting air monitoring network can be used to determine the impacts of the AFGDsystem. Source tests for SO2and particulate8 will be conducted and plume opacity will be checked so that all air emissions are within the established air permit conditions. Acontinuous opacity monitor will be installed after the electrostatic precipitator.
As part of the AFGDsystem, continuous chemical process control monitors are expected to be installed. These instruments will continuously monitor chloride, SO3and CO3 concentrations.
4.7.2.3 Solid-Waste Monitoring

The Bailly Station currently uses an electrostati,c precipitator to control particulate emissions and fly ash. The fly ash and furnace bottom ash are the two solid-waste streams produced by the station's boilers. These waste streams are exempt from the Resource Conservation and Recovery Act Subtitle CHazardous Waste Regualtions by 40 CFR Part 261.4 (b)(4). They are also exempted from Indiana solid-waste regulations as long as they are used for approved beneficial purposes. If they are not, these materials'must be disposed in an appropriate landfill. Currently the Bailly Station ash is marketed through abroker for resale or for

4-26Iu

other uses. The remaining ash is disposed of in an out-of-state landfill.

Coal and limestone samples representative of those feed stocks to be used during the AFGDdemonstration phase will be processed in atest unit to produce by-product gypsum. This representative material will be characterized by EPtoxicity tests and analyzed for chlorides.
4.7.2.4 Health and Safety Consideration of

Monitoring Requirements
The current procedures and monitoring requirements for health and safety at the Bailly Station will be continued with the installation of the AFGDsystem. This newsystem will result in additional noise at the plant and also produce (non-hazardous) gypsum.

Abackground sound survey will be conducted prior to AFGDsystem construction. Oncethe system is operational, additional sound-level studies can be conducted to verify the design basis to mitigate increases in noise levels.

4-274.0 REFERENCE

1. Boynton, Robert S. and Limestone. 

### Chemistry and Technoloqy

NewYork of Lime Sons, Inc., 1967. , NewYork: John Wiley &

4-285.0 REGULATORYCOMPLIANCE

5.1 REGULATIONSANDPERMITREQUIREMENTS
5.1.1 Regulations

The environmental regulations with which the AFGD system must comply are those governing air quality and emissions, water quality and discharges, and solid and hazardous wastes with which the Bailly Generating Station must also comply. The U.S. Environmental Protection Agency (EPA) has delegated authority to implement these regulations to the appropriate offices within the Indiana Department of Environmental Management (IDEM). Existing health and safety regulations directed at employees will continue to be implemented.
5.1.1.1 Air Regulations

In Indiana the IDEM, Office of Air Management (OAR) is responsible for enforcement of the state's Air Pollution Control Lawand existing regulations. The air regulations governing the existing Bailly Generating Station will also govern the proposed AFGDsystem. The installation of the AFGDsystem is not in response to any regulatory requirements. The IDEM, OAMhas indicated that the AFGD system does not fall under Prevention of Significant Deterioration (PSD) regulations. The OAMwill require a Permit to Construct application. As part of this application the OAMwill issue aTechnical Support Document (TSD). The TSDwill contain aproposed air emission permit with emission limitations and conditions. The IDEM, OABwill also set maximum limits onvarious parameters (S02, particulates, opacity) to protect air quality and determine compliance.

5-1Stack tests to verify actual emissions will be required and a

Permit to Operate will be issued.
5.1.1.2 Wastewater Regulations

The Indiana Water Pollution Control Lawand associated regulations are enforced by IDEM, Office of Water Management (OWM). Surface water discharges are authorized by these regulations under the NPDESprogram.

The existing Bailly Station NPDESpermit requires that any anticipated facility process modifications that result in new, different or increased wastewater discharges must be reported. Therefore, anewNPDESpermit application with somemodifications to the current NPDESpermit for discharge of additional wastewater maybe required. The only waste stream from the AFGDprocess is the high-chloride wastewater from the gypsum cake washing cycle. The proposed AFGDsystem is designed to evaporate someof the wastewater produced in the gypsum dewatering and cake washing cycle.
5.1.1.3 Solid-Waste Regulations

Authorixation for disposal of solid and hazardous wastes in Indiana is governed by the Solid Waste Management Lawand Permit Regulations, and the Hazardous Waste Management Regulations. These regulations are implemented by the IDEM, Office of Solid and Hazardous Waste Management (OSHWM).
The solid waste or by-products that would be generated by the AFGDsystem are ash and gypsum. Currently the Bailly Generating Station's ash is sold to abroker for resale, for other uses or for disposal out-of-state. The gypsum produced as aby-product will be astable compound (no pre-treatment or stabilization required). It is asaleable

5-2III

by-product, and is asuitable raw material for wallboard manufacturing. There is the potential for producing some quantity of gypsum that would not meet the wallboard manufacturer's specification. In the event that this gypsum could not be sold, it would be landfilled. Coal and limestone samples representative of those feed stocks to be used during the AFGDsystem demonstration phase will be processed in atest unit to produce by-product gypsum. This representative material will be characterized by EPtoxicity tests and analyzed for chlorides. Pure Air will conduct the testing necessary to receive approval from the IDEMfor disposing of the gypsum prior to AFGDsystem start-up.
5.1.2 Permit Requirements

Permit requirements for the AFGDsystem are described below based on contact with the appropriate regulatory agencies. Relevant excerpts from these contacts are included in Appendix D. Permits for the AFGDsystem are E-63 expected to be obtained between April 1989 and August 1992.

The Bailly Generating Station currently has permits or approvals for air emissions, water discharges and the existing stack. The station does not require asolid waste disposal permit since the coal ash is exempt from regulatory control and the ash and other waste materials are removed from the site by acontract hauler for disposal or reuse. The station also has an EPAIdentification Number as a generator of routine power-plant hazardous wastes. It is expected that Pure Air will obtain another EPAIdentification Number for construction and operation of the AFGDsystem (see Table 5.1-1).

The station's Permit to Operate for air emissions is issued by the IDEM, OAR. The permit has the following emission conditions for each of the two coal-fired boilers:

5-3TABLE5.1-l: ANTICIPATED PERMITS/APPROVALSANDRESPONSIBLE AGENCIES Permit/Approval
Federal Notice of Proposed Construction or Alteration Proposed Approval Date: April 1989 Identification Number for Hazardous Waste Activity Proposed Approval Date: March 1990
State Permit to Construct/Permit to Operate Proposed Approval Date: March 1990 (Permit to Construct); August 1992 (Permit to Operate) Solid Waste Disposal Approval (Ash, Gypsum) Proposed Approval Date: March 1990 National Pollutant Discharge Elimination System Permit Modification/Approval Proposed Approval Date: March 1990 Foundation Release/Construction Design Release/Fire Suppression System Proposed Approval Date: Engineering Approvals to be obtained as design proceeds from August 1990 to March 1992
Local Improvement Location Permit Proposed Approval Date: March 1990 Responsible Agency

Federal Aviation Administration
U.S. Environmental Protection Agency

Indiana Department of Environmental Management (IDEM), Office of Air Management IDEM, Office of Solid and Hazardous Waste Management IDEM, Office of Water Management

Indiana Department of Fire and Building Services

Porter County Plan Commission

5-4Parameter Emission Level
SO2 Particulate Matter Opacity 6.0 lbs/MEBtu 0.22 lbs/MEBtu 40percent
In addition to the above boiler emission requirements, the station's fugitive dust emissions shall comply with the Indiana Air-Pollution Control Law.

TheAFGDsystem will require obtaining new Permits to Construct and Operate from the IDEM, OAM.

Wastewater discharges from the Bailly Generating Station are authorized under the NPDESprogram administered by the IDEM, OWM. The NPDESpermit specifies effluent limitations for within station discharge points and the overall discharge shown in Table 5.1-2. In addition to the requirements shown in Table 5.1-2, the discharges shall not result in foaming at the main outfall or contain oil or other substances in amounts sufficient to create avisible film or sheen on the receiving waters.

The existing NPDESpermit requires that any anticipated facility process modifications that result in new, different or increased wastewater discharges must be reported. Thus, anewNPDESpermit application maybe submitted to the IDEM, OWMfor either the combined Bailly Generating Station and AFGDsystem wastewater, or only for the latter discharge, if any. E-26

The Bailly Generating Station also currently has Federal Aviation Administration (FAA) approval for the existing stack. The FAAwill provide approvals for the AFGD system's newstack and operation of construction cranes.

5-5TABLE5.1-2: EXISTING BAILLY GENERATINGSTATIONNPDES PERMITEFFLUENTLIMITATIONS
Discharge Point or Outfall Parameter OOl-Main Outfall Flow Temperature 002-Intake Deicing Total Residual Chlorine

Within Station Discharges lOO-Miscellaneous LowVolume Bypass
lOl-Ash Pond

Ill-Metal Cleaning Waste 201-Sewage Treatment Plant

301-Boiler Blowdown

003-Coal Pile Runoff Flow

TSS Oil &Grease PB Flow TSS Oil &Grease PB Flow Total Iron Total Copper Flow BOD Fe& Coliform Total Residual Chlorine Flow TSS Oil &Grease PR Flow PB Quality or Concentration

Monthly Daily Average Maximum Units Report Report Report Report

0.2

30 100 15 20 w/l 6.0-9.0 w/l

units
20 15 2": w/l 6.0-9.0 w/l

units
Y.0 1.0
30 440:

2.0

30 100 w/l 15 20 6.0-9.0 mgll

units
6.0-9.0 - units

OF mg/l

41 w/l
mdl 100 ml w/l

5-65.2 ANTICIPATED PERMITS/APPROVALS
As indicated previously, the AFGDsystem will require permits/approvals from both federal and state agencies. In addition to those discussed in relation to the existing Bailly Generating Station permits, the AFGDsystem will require various construction releases from the state and Porter County. The anticipated permits/approvals for the AFGDsystem are shown in Table 5.1-1 and described below.
5.2.1 Air Emission Permits/Approvals

Discussions with the IDEM, DAMindicate that the modified air emissions will be permitted separately from the Bailly Generating Station air emissions. This will require that Pure Air obtain a Permit to Construct prior to initiating construction activities. It is expected that the permit conditions will specify compliance with limits for at least the sameparameters that are in the existing station Operating Permit (i.e., S02, particulate matter, opacity).

The air emission limits will be based on modeling the newstack's physical parameters. Oncethe AFGDsystem is in operation, source testing will be conducted to determine actual stack emissions. AnOperating Permit will then be issued by the IDEM, OAM. The Operation Permit also will specify compliance with the Indiana Air-Pollution Control Law for fugitive dust emissions.
5.2.2 Solid-Waste Disposal Permits/Approvals

TheAFGDsystem will have solid wastes associated with both construction and operation. Non-hazardous wastes from construction do not require approval for disposal and will be disposed in an environmentally acceptable manner. Construction wastes that are deemed hazardous (e.g.,

5-7E-26 miscellaneous solvents/paints/cleaners; waste oil, and acid

and caustic aqueous solutions) will be removed from the site and disposed by an approved contract hauler in an approved site/facility. At the AFGDsystem site these hazardous waste activities will be under an EPAIdentification Number. Similar wastes, if any, generated during operation also will be disposed under this Identification Number.

AFGDsystem operational wastes or by-products will consist primarily of coal ash and gypsum. These wastes may be removed from the site by acontract hauler for disposal or sale for other uses. Under these circumstances the contract hauler maybe responsible for obtaining any necessary permits/approvals, in particular if the wastes or by-products are taken out of Indiana. However, the AFGDsystem project maybe required to obtain approval for disposing of operational wastes if they are not used for beneficial use. This approval will be obtained from IDEM, OSHWM if waste disposal is in Indiana.
5.2.3 Wastewater Discharge Permits/Approvals

TheAFGDsystem will have sanitary and possibly process-related wastewater discharges. Initially a letter describing these discharges will be sent to the IDEM, OWM. If the latter views the discharges as being insignificant with respect to existing Bailly Generating Station wastewater discharges, the IDEM, OWM will issue a letter approval for the AFGDsystem wastewater discharges. If the additional wastewater discharges from the AFGDsystem are viewed by the IDEM, OWMas having asignificant impact on the existing wastewater discharge system, or there are additional point discharges, anewNPDESpermit will be required.

If a newNPDESpermit is required, the IDEM, OWM has indicated that parameters similar to those in the Bailly

5-8Station's existing permit would be monitored. However,

additional parameters may be monitored depending on the discharges and their constituents.
5.2.4 Other Permits/Approvals

In addition to the cited permits/approvals for air emissions, solid-waste disposal and wastewater discharges, the project will be required to obtain construction or engineering design permits/approvals. As shown in Table 5.1-1 and discussed below, these will be obtained from federal, state and local agencies.

Afederal approval from the FAAwill be obtained for construction of the newAFGDsystem stack (Notice of Proposed Construction or Alteration). This approval also involves obtaining approval for the cranes to be used during construction of the AFGDsystem.

The Indiana Department of Fire and Building Services (DFB) is responsible for enforcing building codes and fire safety regulations. In order to accomplish this the DFBwill require that the AFGDproject submit design information for plan review. The design information submitted will include information on electrical, plumbing and mechanical systems, and compliance with the Indiana Energy Conservation Code. Oncethe review is complete, building permits will be issued such as afoundation release, construction design release and fire suppression system approval.
The state of Indiana does not have aCoastal Zone Management Act Plan. However, projects along the lake maybe subject to environmental review by the IDEMif the construction will have an adverse effect on endangered wildlife or plant life. If the construction is located in a

5-9

### flood plain or requires dredging or filling of awaterway the

project will besubject to review bythe Department of Natural Resources (DNR)Water Division. Since the AFGD system project will neither impact the flood plain, nor be built onthe lakeshore, andwetlands are not present, Pure Air does not anticipate involvement of the DNR.

Theonly anticipated local approval for the AFGD project will beissued bythe Porter County Plan Commission. This will involve issuance of anImprovement Location Permit andCertificate of Occupancy. This approval involves submitting asite plan for the project andinformation on drainage control from the site. It will also involve coordinating construction inspections with the county and state building inspectors.

5-10

### 6.0 AUTHORS ANDTHEIRQUALIFICATIONS
6.1 AIRPRODUCTS

ANDCHEMICALS,INC. Kunz, Robert G., B.Ch.E., M.S., Ph.D., P.E.

Dr. Kuns, aChemical andEnvironmental Engineer, is the Managerof Environmental Engineering Design for Air Products andChemicals, Inc. Process System 

### Group. Hehas over 20years of industrial experience in chemical and refinery technology, process engineering, andenvironmental assessment, control andpermitting. Hehascontributed to the published literature in the areas of environmental control andwater andwastewater treatment, andis a recipient of the Harrison Prescott EddyMedal from the Water Pollution Control Federation.
6.2 ENVIROPLAN,INC. Hacue, Obaidul, B.S., M.S.

Mr. Haque, aChemical Engineer, served asaProject Engineer for preparation of the Environmental Information Volume. Hehasextensive experience in environmental studies estimating air pollution emissions for different chemical, petroleum, andmanufacturing plants. Heis also experienced in community exposure, risk assessment, andair quality modeling for various industrial clients.

Huston, J. Spenser, B.S., M.S.

Mr. Huston served asProject Managerfor preparation of the Environmental Information Volume (EIV). Hehasover 20years experience in environmental assessment

6-l

### andreporting in support of capital development varying from

$250,000 to over $1billion. Theseactivities include nuclear-fueled power plants, petrochemical plants andsynfuel facility development under DOEauspices. Mr. Huston is a Certified Consulting Meteorologist (296). Kowalskv, Laura, B.A.

Ms. Kowalsky, Project Investigator for the EIV, writes marketing brochures andproposals, andhaswritten, edited andproduced manyof Enviroplan's publications, proposals andreports. Shehasbeenajournalist and technical editor/writer specialising in environmental subjects. Lackaye, Robert W., B.S.

Mr. Lackaye served asProject Scientist in the preparation of the Environmental Information Volume. Hehas extensive experience conducting air pollutant sampling and analysis projects. His project experience has included source testing utilising EPAMethods, fugitive emission studies, ambient air monitoring andindustrial hygiene studies for various pollutants. Mr. Lackaye hasconducted air sampling projects to determine compliance with Federal, state andlocal air pollution regulations, andalso to assess environmental quality. Simpson, Estelle B., B.S.

Ms. Simpson, aChemical Engineer, is aProject Engineer for preparation of the EIV. Shehasextensive experience in environmental studies of hazardous emissions from industrial facilities. Thesestudies include comprehensive emission studies, community exposure, accidental releases, andrisk assessment. Sheis also

6-2

### involved in air-quality modeling of hazardous pollutants for

various chemical clients.
6.3 NORTHERN

INDIANAPUBLICSERVICECO. Ross, JohnM., B.A., M.B.A.

Mr. Rossis the Superintendent of Environmental Planning in Northern Indiana's Environmental Programs Department. Heacted asNorthern Indiana's project coordinator for the preparation of the EIV. During the past 11year8, Mr. Rosshasheld various environmental positions at Northern Indiana to include ambient air monitoring system design andoperation, estimation of air pollution emissions, performance andreview of EPAsource tests; application and operation of continuous emissions monitors. Mr. Rosshas also been involved in the analysis of environmental regulation andpolicy to the extent that it impacts on Northern Indiana operations.
6.4 PUREAIR Bolinsky, Francis T., B.S.

Mr. Bolinsky, aChemical Engineer, is the Senior Project Managerfor PureAir. Hehasover 18years of experience in industrial plants andhasbeenextensively involved in permitting in manystates. 6.5 STEARNS-ROGER

DIVISIONOFUNITEDENGINEERS & CONSTRUCTORS

INC. Dennis, D. Steve, B.S., M.S., Ph.D.

Dr. Dennis, anEnvironmental Engineer, coordinated the overall development of the Environmental Information

6-3

### Volume. Hehasover 19years experience with environmental

studies andover 12years experience with permitting industrial projects. Theseprojects have included coal, copper, uranium andprecious metal mines; natural gas processing facilities; coal liquefaction andpyrolization; underground coal gasification andpotash solution mining; uranium processing from phosphoric acid; coal-fired generating facilities; crude oil pipelines; lowdensity polyethylene plant; oil shale processing: CO2enhanced oil recovery: coastal spaceport facility, andanammonium perchlorate plant. Brown, Gary D., B.S.

Mr. Brown, aChemical Engineer, served asaProcess Engineer for preparation of the EIV. Hehasextensive experience in technical feasibility andeconomic studies of SO2control processes for the Electric PowerResearch Institute (EPRI) andprivate utilities. Mr. Brownis a Registered Professional Engineer in Colorado (Registration No. 20713) andis aprocess engineer in the PowerDivision of Stearns-Roger. Ireland, Paul A., B.S.

Mr. Ireland wasresponsible for several project/process related sections of the EIV. Hehas20years experience in the flue gasdesulfurization (FGD)industry, has served as lead process engineer for twomajor FGD projects (600MWand 1,000 MW)andhastraveled throughout the U.S., Japan andEuropevisiting FGDinstallations.

6-4

### APPENDIXA INFORMATION

LETTERFROMINDIANA DEPARTMENT

OFNATURAL

RESOURCES
AND INFORMATION

ONENDANGERED,

THREATENED ANDRAREPLANTSANDANIMALSFOUND INTHE INDIANADUNES

NATIONALLAKESHORE, PORTER COUNTY (STATEOF

### INDIANAANDFEDERALLY LISTEDSPECIES)

A-l

### E-59

INDIANA DEPARTMENTOFNATURAL RESOURCES
Division of Nature Preserves 6058 State Office Buildlng Indianapolis, Indiana 46204.2267 

### 317-232-4052 zicw?fPm-~m~m 

### Patrick R. Ralston, Director

April 5, 1989 Laura Kowalsky Enviroplan 59Main Street WestOrange, NJ07052 DearMs. Xowalsky: In response to your request of March 30, 1989, I will address each question individually. Migratory patterns andnesting information onthe bald eagle in relation to the Bailly Site: E-40 Historically, bald eagles (Haliaeetus leucocephalus) nested along the shore of LakeMichigan in Indiana. In 1898, Amos Butler reported that bald eagles "bred quite commonly" in Lake County andthere were numerous reports of nesting near the lakeshore. In recent years, however, wehave seennoindication of nesting along the lakeshore. Certainly, based onyour description of the Bailly Site, nobald eagles nest within it. However, eagles are often seen in the area. Bald eagles have beenreported annually since 1978in the area andare most often seennear the lakeshore. Thesebirds are not local nesters. Anyfederally or state endangered, threatened, or protected wildlife within the confines of the Bailly Station: E-38
I have checked the Indiana Natural Heritage Program's database. This is the most comprehensive database of endangered, threatened, andrare wildlife in the state. Weare unaware of the existence of anyfederally or state endangered, threatened, or rare species within the boundaries of the Bailly Generating Station. Given the site description asper our phone conversation, there doesn't appear to besuitable habitat.
Does 

### transient migration of land vertebrates occur in the area: E-39 Becauseof the site's proximity to LakeMichigan andthe Indiana DunesNational Lakeshore, it is probable that land vertebrates travel into or across the site. However, nodata are available to confirm that species door donot usethe site in their normal movements.

“EQUAL OPPORTUNITY EMPLOYER”

### Page 2

Information onthe migratory patterns of birds in the National Lakeshore: TheDepartment of Natural Resources hasnocompiled information onthe migratory patterns of birds in the Lakeshore area. This information maybefound in "Birds of the Indiana Dunes."by Kenneth J. Brock published bythe Indiana University Press in Bloomington, Indiana in 1986. According to Brock, thousands of migrating birds navigating to wintering grounds in the autumn are funneled along the shores of LakeMichigan into the Dunes area at the toe of the lake. During spring flights, migrating hawksare concentrated in abelt immediately adjacent to the lake. It is important to note that, during the fall raptor movements, the federally endangered peregrine falcon (Falco peregrinus) is often seenflying along the beaches. Please contact meif I canbeof further assistance. sincerely, [f ,,.($& ,$ &Ji.,( Michelle L. Martin Indiana Natural Heritage Program

cc: Scott Johnson, Division of Fish andWildlife Noel Pavlovic, Indiana DunesNational Lakeshore

A-3

### u

TABLEA-l: ENDANGERED, THREATENED

ANDRAREPLANTSFOUNDIN THEINDIANADUNES

NATIONALLAKESHORE, PORTER COUNTY (STATEOF 

### INDIANALIST1 Key: E=Endangered T=Threatened R=Rare SPECIESNAME SPECIESCOMMON AME Actaea Rubra RedBaneberry Amelanchier Humilis Running Serviceberry AndromedaGlaucophylla BogRosemary Arabis Glabra Tower-Mustard Aralia Hispida Bristly Sarsaparilla Arctostaphvlos Uva-Ursi Bearberrv Arenaria-Stricta Aristida Intermedia Aristida Tuberculosa Aster Furcatus Aster Juncifonnis Aster Sericeus Baptisia Tinctoria Betula Papyrifera Botrychium Matricariifolium Botrychium Simplex Buchnera Americana Cakile Edentula Var Lacustris Calla Palustris Carex Alata CarexAurea Carex Chordorrhixa Carex Debilis Var Rudgei Carex Eburnea Carex Flava Carex Folliculata Carex Garberi Carex Leptonervia Carex Limosa Carex Pedunculata Carex Seorsa CarexWoodii Caralpa Speciosa Chimaphila Umbellata Var Cisatlantica Chrysosplenium Americanum Cirsium Pitcheri Coeloglossum Viride VarVirescens Cornus Canadensis Cornus Rugosa Stiff Sandwort Slim-Spike Three-Awn Grass SeabeachNeedlegrass Forked Aster RushAster Eastern Silvery Aster Yellow Wild-Indigo Paper Birch Matricary Grape-Fern Least Grape-Fern Bluehearts American Sea-Rocket Wild Calla Broadwing Sedge Goldenfruit Sedge Creeping Sedge Sedge EbonySedge Yellow Sedge LongSedge Elk Sedge Finely-Nerved Sedge MudSedge Longstalk Sedge WeakStellate Sedge Pretty Sedge Northern Catalpa Common Wintergreen American Golden-Saxifrage DuneThistle Bracted Orchid Bunchberry Roundleaf Dogwood STATUS T T T T E R ; T E R R R E E s E R T E T T E E E i T T T R T E T T E T

A-4

### TABLEA-l: (Continued)

SPECIESNAME Cypripedium Candidum Diervilla Lonicera Drosera Intermedia Eleocharis Geniculata Eleocharis Melanocarpa Eleocharis Pauciflora Epigaea Repens Eriophorum Angustifolium Euphorbia Polygonifolia Gentiana Alba Gentiana Puberulenta Geranium Bicknellii Hudsonia Tomentosa Isotria Verticillata Juncus Pelocarpus Juniperus Communis Lathyrus Venosus Liatris Pycnostachya Ludwigia Sphaerocarpa Lycopodium Clavatum Lycopodium Inundatum Lycopodium Obscurum Lycopodium Tristachyum Malaxis Unifolia MelampyrumLineare Milium Effusum Myosotis Laxa Myriophyllum Verticillatum NemopanthusMucronatus Oenothera Perennis Oryzopsis Asperifolia Prysopsis Racemosa PanaxTrifolius Panicum Boreale Panicum Leibergii PanicumVerrucosum Pinus Banksiana Platanthera Ciliaris Platanthera Clavellata Platanthera Flava Var Herbiola Platanthera Hyperborea Platanthera Psycodes SPECIESCOMMON AME STATUS Small White Lady's-Slipper R BushHoneysuckle R Spoon-Leaved Sundew R Capitate Spike-Rush E Black-Fruited Spike-Rush E Fewflower Spikerush R Trailing Arbutus R Narrow-Leaved Cotton-Grass T Seaside Spurge T Yellow Gentian DownyGentian Bicknell Northern Crane' Sand-Heather Large Whorled Pogonia Brown-Fruited Rush GroundJuniper SmoothVeiny Pea Cattail Gay-Feather Globe-Fruited False-Loosestrife Running Pine Northern BogClubmoss Tree Clubmoss Deep-Root Clubmoss GreenAdder's-Mouth American Cow-Wheat Tall Millet-Grass Smaller Forget-Me-Not Whorled Water-Milfoil T 's-Bill E

T T T R R E E T E T i T T E T Mountain Holly R Small Sundrops R White-Grained E Mountain-Ricegrass Black-Fruit Mountain-Ricegrass E Dwarf Ginseng R Northern Panic Grass R Leiberg's Witchgrass E Warty Panic Grass E Jack Pine R Yellow-Fringe Orchis E Small 

### GreenWoodlandOrchis R Northern Rein-Orchid R Leafy Northern GreenOrchis T Small 

### Purple-Fringe Orchis R

A-5

### TABLEA-l: (Continued)

SPECIESNAME SPECIESCOMMON AME PoaAlsodes Grove 

### MeadowGrass PoaPaludigena BogBluegrass Pogonia Ophioglossoides RosePogonia Polygala Paucifolia Gay-WingMilkwort Polygonella Articulata Eastern Jointweed PolygonumOpelousanum Smartweed VarAdenocalyx Potamogeton Pusillus Slender Pondweed Potamogeton Redheadgrass Richardsonii Potamogeton Robbinsii Flatleaf Pondweed Potentilla Anserina Silverweed Prunus Pensylvanica Fire Cherry Psilocarya Scirpoides Long-Beaked Baldrush Pyrola Elliptica Pyrola Rotundifolia Elliptical-Leaf Wintergreen American Wintergreen VarAmericana RhusTrilobata Var BeachSumac Arenaria Rhynchospora Globularis Globe Beaked-Rush Var Recognita Rhynchospora Tall Beaked-Rush Macrostachya Ribes Hirtellum SmoothGooseberry RubusOdoratus Purple Flowering Raspberry Salix Cordata Heartleaf Willow Scirpus Hallii Hall's Bullrush Scirpus Smithii Weakstalk Bullrush Scleria Pauciflora Fewflower Nutrush Scleria Reticularis Netted Nutrush Selaginella Rupestris LedgeSpike-Moss Solidago Deamii DeamGoldenrod Solidago Spathulata Sticky Goldenrod VarGillmanii Sparganium Androcladum Branching Bur-Reed Stipa Avenacea Blackseed Needlegrass Talinum Rugospermum Prairie Fame-Flower Thuja Occidentalis Arbor-Vitae Utricularia Cornuta Horned Bladderwort Utricularia Geminiscapa Hidden-Fruited Bladderwort Utricularia Purpurea Purple Bladderwort Vaccinium Oxycoccos Small Cranberry Veronica Glandifera Speedwell Wisteria Macrostachya WoodwardiaAreolata Kentucky Wisteria Netted Chainfern Xyris Caroliniana Carolina Yellow-Eyed Grass STATUS T T R E T T R E
i R T R R T E R R T T E R E E T E T E E E E T E R T
: E T

Source: Indiana Department of Natural Resources,

Division of Nature Preserves (Indiana Natural Heritage Program), Indianapolis, IN. Personal communication: January 1989.

A-6

### TABLEA-2: ENDANGERED, THREATENED

ANDRAREANIMALSFOUND INTHEINDIANADUNES NATIONALLAKESHORE, PORTER COUNTY (STATEOFINDIANALIST1 Key: E=Endangered T=Threatened SC=Special WL=WatchList 00=Status Under Review SPECIESNAME Amphibians Ambystoma 

### Laterale Hemidactylium Scutatum Pseudacris Triseriata RanaPipiens Reptiles ClemmysGuttata Emydoidea Blandingii Opheodrys Vernalis Blanchardi Ophisaurus Attenuatus Attenuatus Sistrurus Catenatus Catenatus Thamnophis Proximus Birds Ardea Herodias Botaurus Lentiginosus Buteo Lineatus Dendroica Cerulea Dendroica Pensylvanica Ixobrychus Exilis Lanius Ludovicianus Mniotilta Varia Nycticorax Nycticorax Rallus Elegans Vermivora Chrysoptera Wilsonia Canadensis Wilsonia Citrina Mammals Spermophilus Franklinii SPECIESCOMMON AME
Blue-Spotted Salamander Four-Toed Salamander Striped Chorus Frog Northern Leopard Frog
Spotted Turtle Blanding's Turtle Western SmoothGreenSnake Western Slender Grass Lizard Eastern Massasauga Western Ribbon Snake

Great Blue Heron American Bittern Red-Shouldered Hawk Cerulean Warbler Chestnut-Sided Warbler Least Bittern Loggerhead Shrike Black-and-White Warbler Black-Crowned Night-Heron King Rail Golden-Winged Warbler CanadaWarbler HoodedWarbler

Franklin's GroundSquirrel Concern STATUS

SC T SC SC

T SC T 00 T SC

WL E % 00 SC E SC E E E

A-7

### TABLEA-2: (Continued)

SPECIESNAME Insects SPECIESCOMMON NAME STATUS

Euchloe Olympia Olympia Marblewing T Lycaeides Melissa Karner Blue Butterfly E Samuelis Source: Indiana Department of Natural Resources,

Division of Nature Preserves (Indiana Natural Heritage Program), Indianapolis, IN. Personal communication: January 1989.

A-8

### TABLEA-3: 1989FEDERALLY THREATENED

ANDENDANGERED FLORAANDFAUNAFOUND INTHEINDIANADUNES NATIONALLAKESHORE Key: E=Endangered T=Threatened SPECIESNAME COMMON AME Cirsium Pitcheri DuneThistle STATUS T Dendroica Kirtlandii Kirtland's Warbler T Falco Peregrinus Peregrine Falcon E Haliaeetus Leucocephalus Bald Eagle (migrant) E Myotis Sodalis Indiana Bat E Myotis Grisescens Gray Bat E

Source: Indiana DunesNational Lakeshore; National Park

Service - Resource ManagementDivision. Personal communication: January 1989.

A-9I I

APPENDIXB
ARCHAEOLOGICALANDHISTORICAL SURVEYS

AND
INFORMATIONLETTERFROMINDIANA DEPARTMENT

OFNATURALRESOURCES

B-lI I

In a letter dated September 25, 1970 the Advisory Council on Historic Preservation stated that "no National Register properties have been identified within the immediate vicinity" of the Bailly Station. This letter was sent to a regulatory agency in response to previously proposed construction at the Bailly Station. In this Appendix is a E-64 copy of a letter dated March 29, 1989 from the Indiana Department of Natural Resources, Division of Historic Preservation and Archaeology stating that no site now in or eligible for inclusion in the National Register of Historic Places will be affected by construction of the AFGDsystem. According to the National Register, the closest historic site to the Bailly Station is the Joseph Bailly Homestead and Cemetery as stated in Section 3.5.3.3, Historic Sites and Natural Landmarks located within two miles of the Bailly Station. There have been no additions to the National Register in the Bailly vicinity between 1970 and present. However, the South Shore Station at Beverly Shores has been nominated to the National Register. The South Shore Station is approximately 10miles from the Bailly Station.

B-2INDIANA DEPARTMENTOFNATURAL RESOURCES, Division of Historic Preservation and Archaeology 251 East Ohio Street, Suite 880 Indianapolis, Indiana 46204 PATRICK R.RALSTON, DIRECTOR

E-64 March 29, 1989

Laura Kowalsky Marketing Services Manager Enviroplan 59 Main Street West Orange, NewJersey 07052 Dear Ms. Kowalsky: We have reviewed the proposed construction of an advanced flue gas desulfurization (AFGD) system at the Northern Indiana Public Service Company's Bailly Generating Station located in Porter County, Indiana. No known historical, architectural, or archaeological sites listed on or eligible for inclusion in the National Registe'r of Historic Places will be affected by this project. If any archaeological artifacts are uncovered during construction, work will stop and the discovery will be reported to our Division of Historic Preservation and Archaeology. Weappreciate the opportunity to be of service. Very truly yours,

te Historic Preservation Officer PRR:SBG:vk

B-3 “EQUAL OPPORTUNITY EMPLOYER”APPENDIXC
BAILLY GENERATINGSTATION WAIVERFROM GROUND WATERMONITORINGREQUIREMENTS,ANDPERMITS FORWASTEWATER

DISCHARGESANDAIR EMISSIONS

C-lI I

WAIVERFROMGROUND WATER MONITORINGREQUIREMENTS

c-2A ilbr

ENVIRONMElYTAL MANAGE\lENT BOARD 

# STATE -t/INDIANA
INDIANAPOLLS 46206- 1964

December 8. 1983
Mr. C.Y. Karn. Manager cnviroameocal Affairs Nerchcm Indiana Public Service Company 5265 Eohnrn Awnue E-cd, IN 46320 Dear I¶r. Kern: Re: wsivcr Demoostrscioo hF11y Gmeratic$ Scacion. Porter County IND 000718114 This letter vi11 serve as l Notice of Uaivar from rhe ground water monitoring r~quirrmcntr amset forth uodcr 40CFRPart 265. Subpart P (320 IAC O-6). The sampling for orgmics in your vaste stream is still recommended by staff lo U.S. EPAhas indicated the possibillry of requiring facilities vho have been granted aaexemptloo fra the ground water monitoring requirements or adelisting of vastes to prove organlcs armnot present. If at l lacer date ft ir found thsc orpnic vssres are present in the lagooar , enforcement action -7 be cakmn for rubmisrloo of misleading waiver info-tloo.

If you have aa7 questions rcSardiaS this corrcspoodmce. 

### phase ~oc~act 

### Hr. Ilobert Dovnm7 lcAC317/b)]-6676.

C. Pi&ad Technical Secretaq Footnote A: Neither the Bailly Generating Station or the proposed AFGDsystem operations will result in discharges of organic materials as a wastestream.

c-3I I

WASTEWATER

DISCHARGE(NPDES)PERMIT

c-4I

DESCRIPTION OFEXISTING DISCHARGES E-53 E-66 Water for Bailly Generating Station uses is obtained from Lake Michigan. Discharge is through two outfalls to Lake Michigan and several internal outfalls (Figure C-l). Outfalls 001 and 002 are to Lake Michigan and consist of the total plant discharge, which is mostly once through condenser cooling water discharged at Outfall 001. Outfall 002 is an intermittent discharge in front of the plant intake structure to prevent freezing in cold weather. Chlorine maybe used in the cooling water, but generally is not needed.
Outfall 101 is the internal discharge from the ash ponds to Outfall 001. This water is usually recycled in-plant causing the discharge to be intermittent. Outfall 301 (boiler blowdown) also contributes to the main Outfall 001.
Periodic metal cleaning wastes (Outfall 111) are discharged to the wastewater treatment facility, thence the ash ponds. Other wastestreams contributing to the ash ponds are the discharge from the sewage plant (Outfall 201), ash sluicing and slag recovery, air heater wash, and precipitation on the surfaces of the ponds.

Outfall 100 is an emergency bypass of the ash ponds of certain low volume wastestreams (floor drains, filter backwash, and water treatment wastes).

Sanitary wastewater (201) is treated by an activated sludge plant with chemical coagulation capability, sand filtration, and effluent chlorination. Coal pile run off (Outfall 003) is by the existing wastewater discharge permit.
C-5Lake Michigan


# 0 im

Coal Power Plant
Sewage Treatment Plant 201 Wastewater

,Treatment

0’ 1 Ash Ponds



## h Pure Air A
ajoint venture company ADVANCED FLUE GAS DESULFURIZATION Existing Permitted Discharge Locations Figure c-1 E-53, 66iJage I of 20 Permit No. IN 0000132

INDIANA DEPARTMENT OFENVIRONMENTAL

MANAGEMENT AUTHORIZATIONTODISCHARGEUNDERTHE NATIONALPOLLUTANTDISCHARGEELIMINATION SYSTEM

In compliance with the provisions of the Federal Water Pollution Control Act, as amended (33 U.S.C. 1251et seq., the "Act"), and the Indiana Environmental Management Act, asamended (IC 13-71,

NORTHERNINDIANA PUBLICSERVICECOMPANY

BAILLY GENERATINGSTATION is authorized to discharge from a coal fired power plant which Is located at 246 Bailly Station Road. Chesterton, Indiana, to receiving waters namedLake Michigan and to the groundwater in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I and II hereof. The permit shall become effective on November 1, 1988 This permit and the authorizatlon to discharge shall expire at midnight August 31 , 1993. In order to receive authorisation to discharge beyond the date of expiration, the permittee shall submit such information and forms as are required by the Indiana Department of Environmental Management no later than 180days prior fo the date of expiration. Signed this 29th day of September Department ofvironmental Management. , 1988, for the Indiana



# gg&a3~ Charles 8. Bardonnar Assistant Commissioner Office of Water Management

C-7Permit No. IN 0000132

TREATMENTFACILITY CLASSIFICATION The discharger has aClass Cindustrial wastewater treatment plant, classified in accordance with 327 IAC S-12, Classification of Water and Wastewater Treatment Plants. PARTI A. EFFLUE?ITLIMITATIONS ANDMONITORINGREQUIREMENTS 1. During the period beginning onthe effective date of this permit and lasting until the expiration date, the permittee is authorized to discharge from Outfall 001 - main outfall and 002 - intake deicing discharge. Such discharge shall be limited and monitored by the permittie as specified bilow:

Parameter Qm-,ttty or Loading Quality or G3ncentrrtion Monthly Daily Monthly Daily Average Yaxfmm units Avcraqe Haxflnnn units

FlOw+ Temperature* Total Residual Cb10ble+ DurstfonOf mlorlnatfon+ chlorfnotfon Frequency+ Report Report MO

-- --

-- _-

_- _-

_- __ _- em Report Report mg/l

_- 0.2 qg/l

_- _-

-- -- *Flow maybe estimated by engineering calculations. **See Other Requirements. Part III of Permit. Monitoring rkquiremcnts M.3~SUrWWXlt SUp1e Frequency Type Daily 2L-Hr. rota Daily Continuour Daily++ Grab
Nonthly Report t4anthly Report

+Total Residual Chlorine (TRC) maynot be discharged from any single generating unit (condenser) for more than two hours per day. Frequency and Duration of chlorination need only be reported for Outfall 001. +tDuring discharge of chlorine bearing wastewater.

a. The discharge shall not cause excessive foam in the receiving waters. The discharge shall be essentially free of floating and settleable solids. b. The discharge shall not contain oil or other substances in amounts sufficient to create avisible film or sheen on the receiving waters. C. Samples taken in compliance with the monitoring requirements above shall be taken at apoint representative of the discharge but prior to entry into Lake Michigan.

C-8II

Page 3of 20 Permit No. IN 0000132

2. During the period beginning onthe effective date of this permit and lasting until the expiration date, the permittee is authorfred to discharge from Outfall 100- Miscellaneous LowVolume Bypass. Such discharge shall be limited andmonitored by the permittee as specified below:

Parameter ~antity or Loading Quality or Concenrration Monitoring Requirements Ymthly Daily Monthly Daily Measurement Sample Averaee !laximrrm units Averaqe ?laximm Units --- -- Frequency Lx!% Flow Report TSS .- Oil hGrease -- Report MGD

__ _- Dally* 24-w. rota

__ 30 100 w/l D.S11y* Grab -_ 15 20 w DSilP Creb *During discharge

a.

b.

c.

d. The pHshall nor be less than 6.0 nor greater than 9.0. ThepH shall be monitored as follows: by adaily grab sample, during discharge. The discharge shall not cause excessive foam in the receiving waters. Thedischarge shall be essentially free of floating and settleable solids. The discharge shall not contain oil or other substances in amounts sufficient to create avisible film or sheen on the receiving waters. Samples taken in compliance with the monitoring requirements above shall be taken at apoint representative of the discharge but prior to mixing with other wastewaters.

c-9Permit No. IN 0000132

3. During the period beginning on the effective date of this permit and lasting until the expiration date; the permittee is authorised to discharge from Outfall 101- Ash Pond Discharge. Such discharge shall be limited and monitored by the permittee as specified below:

P~r.XMter

FlOW TSS Oil &crease Quantity or Loading Quality or Co”cc”tration Monitoring Requirements Monthly Dafly Monthly Dally Measurcmc”t Sample Averaqe naximrnn units

-- Avcraqe Yaximum Units Frequencv T?rpe Report Report MGD .. .. Weekly 24-Hr. Tota:

.. ._ 20 30 rn8/1 Weekly 24.Hr. Camp.

.. .. 15 20 mdl Weekly Grab

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall be monitored as follows: by aweekly grab sample, except during discharge of metal cleaning wastes from Outfall 111 sampling is to be conducted daily. b. The discharge shall not cause excessive foam in the receiving waters. The discharge shall be essentially free of floating and settleable solids.

c. The discharge shall not contain oil or other substances in amounts sufficient to create avisible film or sheen onthe receiving waters. d. Samples taken in compliance with the monitoring requirements above shall be taken at apoint representative of the discharge but prior to mixing with other wastewaters.

c-10/age 5of 20 Permit No. IN OOOC132

Parameter

FlOW T. Iron r. copper4. During the period beginning onthe effective date of this permit and

lasting until the expiration date, the permittee is authorised to discharge from Outfall 111- metal cleaning waste discharge from the wastewater treatment facility. Such discharge shall be limited and monitored by the permittee as specified below:

Quantity or Loading Quality or Concentration Honitotlng Requircwnts Monthly hi 1y Yonthly Daily f4easuremenc ample A_verage \faximum units Haxlmu!n Units

-- Averaee Frequency
Report RepOTt nco __ -- DailP Zk-HI-. Iota
_- _- _- 1.0 mg/l DoLlr Zk-Hr. Comp

-- __ _- 1.0 as/1 Dailp Zk-Hr. camp *These limitations andmonitoring requirements apply only during discharge of metal cleaning wastes. The term “metal cleaning wastes” means any wastewater (including chemical cleaning liquor, incinerated metal cleaning wastes (ash), rinse water and passivation solution) resulting from cleaning (with or without chemical compounds) any metal process equipment, including, but not limited to boiler tube cleaning. boiler fireside cleaning and air preheater cleaning. Thevolume of boiler cleaning waste to which these limitations apply is two boiler volumes, including the initial cleaning solution and the first rinse. For the purpose of this permit, air preheater wash, although defined under 40 CPR423.12(b)(S) as ametal cleaning waste, is to be considered as a low volume wastestream.

a. Samples taken in compliance with the monitoring requirements above shall be taken at apoint representative of the discharge but prior to mixing with other wastestreams.

c-11Permit go. IN 0000132

5. During the period beginning onthe effective date of this permit and lasting until the expiration date, the permittee is authorised to discharge from Outfall 201 - sewage Treatment plant. Such discharge shall be limited and monitored by the permittee as specified below:

Parameter Quantity or Loading Quality or Concentration Monitoring Requirements Monthly Daily Monthly Daily b!eeasurement Sample AVerWe ?(axim"m units Average !4axi,m"munits Fre~U.TlCV -- Lx!% Flow MD) Report Rep0rt BOD

__ -- Fe& Coliform* -_ -- I. R.Chlorine* -_ -- _- 30 _-
-- _- Weekly Zk-Hr. rota: 4s mgll Weekly 8-W. camp. 400 100ml Weekly Crab 2.0 w/l 2xWeekly Grab *Fetal coliform and chlorine limitations apply only from April 1 through October 31annually. Sampling is not required, and chlorination should not be practiced November 1through March 31.

a. Samples taken in compliance with the monitoring requirements above shall be taken at apoint representative of the discharge but prior to mixing other wastewaters.

c-12r’age 7of 20 Permit No. IN 0000132

6. During the period beginning onthe effective date of this permit and lasting until the expiration date, the permittee is authorired to discharge from Outfall 301 - boiler blowdown. Such discharge shall be limited andmonitored by the permittee as specified below:

Qu.mt:t:~ or Loading Qwdiey or Concentration Wanitoring Requirements Uonthly Daily Xonthly Daily Me.WXWJent Sample Average vaximum L!nlts Y(aXimm Unit3

-- D -- Frequencv ISIpe FIOW ISS Oil &crease RepOrC Report ?fGD _- __ 2xMonthly 24-m. lota,
-- __ 30 100 mgil 2X!lonthly 2L-Hr.wmp
-- -_ 15 20 mgJ1 2X.%nChly Crab

a. The pHshall not be less than 6.0 nor greater than 9.0. The pH shall be monitored as follows: by agrab sample twice monthly. b. Thedischarge shall not cause excessive foam in the receiving waters. Thedischarge shall be essentially free of floating and settleable solids. C. The discharge shall not contain oil or other substances in amounts sufficient to create avisible film or sheen on the receiving waters. d. Samples taken in compliance with the monitoring requirements above shall be taken at apoint representative of the discharge but prior to mixing with other wastewaters, except for pg. which maybe sampled after mixing with the main discharge. For TSSand oil 6grease, the representative location maybe from the boiler drum rather than at end-of-pipe.

c-13Z-ilBle 0 “1 L?I Permit No. IS 0000132

7. During the period beginning onthe effective date of this permit and lasting until the expiration date, the permittee is authorized to discharge from Outfall 003 - coal pile runoff. Such discharge shall be limited and monitored by the permittee as specified below:

Parameter
FlOW Qxmtity or Loading Quality orConccn~ratian Honitoring Requirements Monthly Dai1y ?lonthly Daily xeasuremenc sample AvcraKe -

Y~Ximmunits Average Msximm Units Fl-.eqMnCV LYFC Report Report 3GD

__ -- WeeklP ZL-Hr.lotal *Flow is to be estimated based onprecipitation. All parameters are to be monitored weekly during periods of discharge of coal pile runoff to the ground absorption area.
a. The pHshall not be less than 6.0 nor greater than 9.0. ThepH shall be monitored as follows: by aweekly grab sample, during periods of discharge. b. The discharge shall not contain oil or other substances in amounts sufficient to create avisible film or sheen on the receiving waters.

c. Samples taken in compliance with the monitoring requirements above shall be taken at apoint representative of the discharge but prior to entry into the ground absorption area.



### c-14Page9of 20 Permit No. IN 0000132

B. MONITORINGANDREPORTING 1. Representative Sampling Samples and measurements taken as required herein shall be representative of the volume andnature of the monitored discharge. 2. Reporting The permittee shall submit discharge monitoring reports (DMR-I Form) to the Indiana Department of Environmental Management containing results obtained during the previous month and shall bepostmarked no later than the 28th day of the month following each completed monitoring period. The first report shall be submitted by the 28th day of the month following the month in which the permit becomes effective. If there is to occur asubstantial period of time during which there will be no discharge from anauthorised outfall, then the permittee maysubmit awritten request to the Indiana Department of Environmental Management for relief from reporting requirements. The Commissioner maythen suspend reporting requirements without public notice or opportunity for public hearing. The Regional Administrator mayrequest the permittee to submit monitoring reports to the Environmental Protection Agency if it is deemed necessary to assure compliance of the permit. 3. Definitions

a. Monthly Average (1) Weight Basis - The“monthly average” discharge means the total discharge byweight during acalendar month divided by the number of days in the month that the production or commercial facility was discharging. Where less than daiIy sampling is required by this permit, the monthly average discharge shall be determined by the summation of the measured daily discharges byveight divided by the number of days during the calendar month when the measurements were made. 

### (2) Concentration Basis - The “monthly average” concentration means the arithmetic average (proportional to flow) of all daily determinations of concen;ra;ion madeduring a calendar month. Daily determinations of concentration madeusing acomposite sample shall be the concentration of the composite sample. Whengrab samples are used, the daily determination of concentration shall be the arithmetic average (weighted by flow value) of all the samples collected during the calendar day.



### c-15rage IV01LU Permit No. IN 0000132

b.

c.

d.

e.

f. “Daily Maximum” Discharge (1) Weight Basis - The “daily maximum” discharge means the total discharge by weight during any calendar day. (2) Concentration Basis - The “daily maximum” concentratfon means the dailv determination of concentration for any calendar day. 24-Hour Composite Sample--Consists of at least 2 individual flow-proportioned samples of wastewater which are taken at approximately equally spaced time intervals during a24-hour period andwhich are combined prior to analysis. Concentration--The weight of any given material present in a unit volume of liquid. Unless otherwise indicated in this permit, concentration values shall be expressed in milligrams per liter (mg/l). The “Regional Administrator” is defined as the Region V Administrator, U.S. EPA, located at 230 South Dearborn Street, Chicago, Illinois 60604. The “Commissioner” is defined as the Commissioner of the Indiana Department of Environmental Management, which is located at the following address: 105 South Meridian Street, Indianapolis, Indiana 46225. 4. Test Procedures The analytical and sampling methods used shall conform to the current version of 40 CFR, Part 136. The approved methods maybe included in the texts listed below. However, different but equivalent methods are allowable if they receive the prior written approval of the State agency and the U.S. Environmental Protection Agency. (1) Standard Methods for the Examination of Water andWastewater 16th Edition, 1985, American Public Health Association, Washington, D.C. 20005. (2) A.S.T.M. Standards, Part 23, Water: Atmospheric Analysis 1972American Society for Testing and Materials, Philadelphia, PA 19103. (3) Methods for Chemical Analysis of Water andWastes June 1974, Revised, March 1983, Environmental Protection Agency, Water Quality Office, Analytical Quality Control Laboratory, 1014Broadway, Cincinnati. OH 45202. 5. Recording of Results For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: 

### C-16LJage11of 20 Permit No. IN 0000132

a. Theexact place, date, and time of sampling; b. The dates the analyses were performed;

c. The person(s) whoperformed the analyses: d. The analytical techniques or methods used; and

e. The results of all required analyses. 6. Additional Monitoring by Permittee If the permittee monitors any pollutant at the, location(s) designated herein more frequently than required by this permit, using approved analytical methods as specified above, the results of such monitoring shall be included in the calculation and reporting of the values required in the Monthly Discharge Monitoring Report. Such increased frequency shall also be indicated. 7. Records Retention All records and information resulting from the monitoring activities required by this permit, including all records of analyses performed and calibratfon and maintenance of instrumentation and recording from continuous monitoring instrumentation, shall be retained for a minimum of three (3) years, or longer, if requested by the Regional Administrator or the Indiana Department of Environmental Management. C. REOPENINGCLAUSE 1.

2. Whenthe U.S. EPAand the State of Indiana finalfze apolicy regarding the implementation of 40 CFR122.26, which addresses stormwater discharges, this permit maybemodified, after public notice and opportunity for hearing, to incorporate revised limitations for the control of such discharges. This permit maybe modified, or, alternatively revoked and reissued, after public notice and opportunity for hearing, to incorporate revised effluent limitations, with appropriate schedule(s) of compliance, if necessary, after final promulgation and effectiveness of revised Indiana Water Quality Standards.



### c-17. ..ec A_ Y. &” Permit No. IS 0000132

PARTII STANDARDCONDITIONSFORNPDESPERMITS FORINDUSTRIAL FACILITIES

SECTIONA. GENERALCONDITIONS 1. Duty to Comply The permittee shall comply with all conditions of this permit. Any permit noncompliance constitutes aviolation of the Clean Water Act and the Indiana Environmental Management Act and is grounds for enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application. 2. Penalties for Violations of Permit Conditions Pursuant to the Indiana Environmental Management Act, any person whoviolates apermit condition implementing sections 301, 302, 306, 307, 318, or 405 of the Clean Water Act is subject to acivil penalty not to exceed S25.000 per day of such violation. Any person whowillfully or negligently violates permit conditions implementing sections 301, 302, 306, 307, or 308 of the Clean Water Act is subject to afine of not less than $2,500 nor more than 525,000 per day of violation, or by imprisonment for not more than 1year or both. If the conviction is for aviolation committed after afirst conviction of such person under this provision, punishment shall be afine of not more than fifty thousand dollars ($50,000) per day of violation, or by imprisonment for not more than two (2) years, or both. Except as provided in permit conditions on“Bypassing,” Section B, Paragraph 2 and “Upsets,” Section B, Paragraph 3, nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. 3. Duty to Mitigate Thepermittee shall take all reasonable steps to minimise or correct any adverse impact on the environment resulting from noncompliance with the permit. 4. Permit Actions This permit maybe modified, revoked and reissued, or terminated for cause, including, but not limited to. the following:

a. Violation of any terms or conditions of this permit; b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; or
c. Achange in any condition that requires either a temporary or permanent reduction or elimination of the authorized discharge.



### C-181 I IH

Page 13of 20 Permit No. IS 0000132

The filing of (I) a request by the permittee for apermit modification, revocation and reissuance, or termination, or (ii) anotificaclon of planned changes or anticipated noncompliance does not stay any permit condition. 5. Dutv to Provide Information Thepermittee shall furnish to the Commissioner, within areasonable time, any information which the Commissioner mayrequest to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. Thepermittee shall also furnish to the Commissioner, upon request, copies of records required to be kept by this permit. 6. Duty to Reapply If the permittee wishes to continue anactivity regulated by this permit after the expiration date of this permit, rhe permittee must apply for and obtain a newpermit. Theapplication should besubmitted at least 180days before the expiration date of this permit. TheCommissioner maygrant permission to submit anapplication less than 180days in advance but no later than the permit expiration date. 7. Transfers This permit is nontransferable to any person except after notice to the Commissioner pursuant to Regulation 327 IAC 5-2-6(c). The Commissioner may require modification or revocation and reissuance of the permit to change the nameof the permittee and incorporate such other requirements as maybe necessary under the Clean Water Act. 8. Toxic Pollutants Notwithstanding Paragraph A-4, above, if atoxic effluent standard or prohibition (including any schedule of compliance specified in such effluent standard or prohibition) is established under Section 307(a) of the Clean Water Act for a toxic pollutant which is present in the discharge and such standard or prohibition is more stringent than any limitation for such pollutant in this permit, this permit shall bemodified or revoked and reissued to conform to the toxic effluent standard or prohibition. Thepermittee shall comply with effluent standards or prohibitions established under section 307(a) of the Clean Water Act for toxic pollutants injurious to humanhealth within the time provided in the regulations that establish those standards or prohibitions, even if the permit has not yet been modified to incorporate the requirement. 9. Containment Facilities Whencyanide or cyanogen compounds are used in any of the processes at this facility, the permittee shall provide approved facilities for the containment of any losses of these compounds in accordance with the requirements of Water Pollution Control Board Regulation 327 IAC 2-2-l.


### c-19rage ,‘I or ‘U Permit No. IN 0000132

10. Ooerator Certification The permittee shall have the waste treatment facilities under the direct supervision of anoperator certified by the Commissioner as required by IC 13-1-6. 11. Oil and Hazardous Substance Liability Nothing in this permit shall be construed to relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject under Section 311of the Clean Water Act. 12. Property Rights The issuance of this permit does not convey any property rights of any sort or any exclusive privileges, nor does it authorize any injury to private property or an invasion of personal rights, nor any infringement of Federal, State, or local laws or regulations. 13. Severability The provisions of this permit are severable and, if any provision of this permit or the application of any provision of this permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this permit shall not be affected thereby. 14. Inspection and Entry The permittee shall allow the Commissioner, or an authorized representative, upon the presentation of credentials and other documents as maybe required by law, to:

a. Enter upon the permittee’s premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of this permit; b. Have access eoand copy, at reasonable times, any records that muse be kept under the conditions of this permit;

c. Inspect at reasonable eimes any facilities. equipment (including monitoring and control equipment), praceices, or operations regulated or required under this permit; and d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise authorised by the Clean Water Act, any substances or parameters at any location. 15. Construction Permit The permittee shall not construct, install, or modify any water pollution control facility without avalid construction permit issued by the Indiana Department of Environmental Management pursuant to 327 IAC 3-2.



### c-20i’age 15of 20 Permit No. IN 0000132

SECTIONB. MANAGEMENT REQUIREMENTS 1. Proper Operation andMaintenance Thepermittee shall at all times maintain in good working order and efficiently operate all facilities and systems for wastewater collection and treatment which are installed or used by the permittee andwhich are necessary for achieving compliance with the terms and conditions of this permit. 2. Bypass of Treatment Facilities

a. Definitions: (1) “Bypass” means the intentional diversion of awaste stream from any portion of atreatment facility normally utilired for treatment of the waste stream. (2) “Severe property damage” meanssubstantial physical damageto property, damageto the treatment facilities which would cause them to become inoperable, or substantial andpermanent loss of natural resources which can reasonably beexpected to occur in the absence of abypass. Severe property damagedoes not mean economic loss caused by delays in production at the permittee’s facility. b. (Prohibition of Bypass) Bypass which causes or is likely to cause applicable effluent limitations to be exceeded is prohibited unless the following three conditions are met: 

### (1)

(2)

(3) Bypass is unavoidable to prevent loss of life, personal injury or severe property damage: There are nofeasible alternatives to bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal period of equipment down-time: and The permittee submits notice of anunanticipated bypass to the Commissioner within 24hours of becoming aware of the bypass (if this information is provided orally, awritten submission must be provided vithin five days). Where the permittee knows or should have known in advance of the need for abypass, this prior notification shall be submitted for approval to the Commissioner, if possible, at least ten days before the date of the bypass.
C. Ananticipated bypass which meets the three criteria of Paragraph b of this subsection maybe allowed under conditions determined to be necessary by the Commissioner to minimise any adverse effects.

c-21rage lb or i!o Permit No. IN 0000132

3. i’pset Conditions

a. Definition: “Upset” means anexceptional incident in which there is unintentional and temporary noncompliance with technology-based permit effluent limitations because of factors beyond the reasonable control of the permittee. Anupset does not include noncompliance to the extent caused by operational error, improperly designed treatuznt facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation. b. (Effect of anupset) Anupset shall constitute an affirmative defense to an action brought for noncompliance with such technologybased permit effluent limitations if the requirements of Paragraph c of this subsection are met.

c. (Conditions necessary for ademonstration of upset) Apermittee who wishes to establish the affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs or other relevant evidence, that: (1) Anupset occurred and the permittee has identified the specific cause(s) of the upset, if possible; (2) The permitted facility was at the time being operated in compliance with proper operation and maintenance procedures; and (3) The permittee complied with any remedial measures required under Paragraph A.3 of this Part. 4. Removed Substances Solids, sludges, filter backwash, or other pollutants removed from or resulting from treatment or control of wastewaters shall be disposed of in a manner such as to prevent any pollutant from such materials from entering waters of the State and to be in compliance with all Indiana statutes and regulations relative to liquid and/or solid waste disposal.

SECTIONC. REPORTINGREQUIREMENTS
1. Planned Changes in Facility or Discharge Anyanticipated facility expansions, production increases, or process modifications which will result in new, different, or increased discharges of pollutants must be reported by submission of anewXPDESapplication or, if such changes will not violate the effluent limitations specified in this permit, by advance notice to the permit issuing authority of such changes. Following such notice, the permit maybemodified to revise existing pollutant limitations and/or to specify and limit any pollutants not previously limited.



### c-22r

Page 17of 20 Permit No. IN 0000132

2. Smitoring Reports Nonitoring results shall be reported at the intervals and in the form specified in Part I.B.2. 3. Compliance Schedules Reports of compliance or noncompliance with interim and final requirements contained in any compliance schedule of this permit shall be submitted no later than 14days following each schedule date. Any reports of noncompliance shall include the cause of noncompliance, any remedial actions taken, and the probability of meeting the next scheduled requirement. 4. Twenty-Four Hour Reporting The permittee shall report information onthe following types of noncompliance within 24 hours from the time permittee becomes aware of such noncompliance:

a. Any unanticipated bypass which exceeds any effluent limitation in the permit: b. Violation of amaximumdaily discharge limitation for any of the pollutants listed by the Commissioner in the permit to be reported within 24hours: and

c. Any noncompliance which maypose asignificant danger to human health or the environment. Awritten submission shall also be provided within 5days of the time the permittee becomes aware of the circumstances. Thewritten submission shall contain adescription of the noncompliance and its cause: the period of noncompliance, including exact dates and times , and if the noncompliance has not been corrected the anticipated time it is expected to continue; and steps taken or planned to reduce and eliminate the noncompliance and prevent its recurrence. The Commissioner maywaive the written report on acase-by-case basis if the oral report has been received within 24hours. 5. Other Noncompliance The permittee shall report any instance of noncompliance not reported under Paragraph 3or 4of this Section at the time the pertinent Discharge Monitoring Report is submitted. The report shall contain the information specified in Paragraph 4of this Section. 6. Other Information Where the permittee becomes aware that hefailed to submit any relevant facts or submitted incorrect information in apermit application or in any report to the Commissioner, the permittee shall promptly submit such facts or corrected information.

C-23.-e- A” “h ..” Permit No. IN 0000132

7. Changes in Discharge of Toxic Substances Thepermittee shall notify the Commissioner as soon as it knows or has reason to believe:

a. That any activity has occurred or will occur which would result in the discharge of any pollutant identified as toxic, pursuant to Section 307(a) of the Clean Water Act which is not limited in the permit, if that discharge will exceed the highest of the following “notification levels:” (1) Onehundred micrograms per liter (100 ug/l); (2) Twohundred micrograms per liter (200 us/l) for acrolein and acrylonitrile; five hundred micrograms per liter (500 ug/l) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/l) for antimony; (3) Five (5) times the maximumconcentration value reported for that pollutant in the permit application; or (4) The level established in Part III of the permit by the Commissioner. b. That it has begun or expects to begin to use or manufacture as an intermediate or final product or byproduct any toxic pollutant which was not reported in the permit application. 8. Signatory Requirements

a. All reports required by the permit and other information requested by the Commissioner shall be signed and certified by aperson described below or by aduly authorised representative of that person: (1) For acorporation: by aprincipal executive officer of at least the level of vice-president (including aperson who is not avice-president but performs similar policy-making functions for the corporation); (2) For apartnership or sole proprietorship: by ageneral partner or the proprietor. respectively; or (3) For a Federal, State, or local governmental body or anagency or political subdivision thereof: by either aprincipal executive officer or ranking elected official. b. Aperson is aduly authorized representative only if: (1) The authorisation is madein writing by aperson described above.

C-24Page 19of 20 Permit No. IN 0000132
(2) Theauthorisation specifies either an individual or aposition having responsibility for the overall operation of the regulated facility or activity, such as the position of plant manager, operator of awell or awell field, superintendent, or position of equivalent responsibility. (A duly authorised representative maythus beeither anamedindividual or any individual occupying anamedposition.); and (3) The authoritation is submitted to the Commissioner.

c. Certification. Any person signing adocument under this section shall make the following certification: “I certify under penalty of law that I have personally examined and amfamiliar with the information submitted in this document and all attachments and that, based onmyinquiry of those individuals immediately responsible for obtaining the information, I believe that the information is true, accurate, and complete. I amaware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment.” 9. Availability of Reports Except for data determined to be confidential under Water Pollution Control Board Regulation 3.27IAC 12, all reports prepared in accordance with the terms of this permit shall be available for public inspection at the offices of the Indiana Department of Environmental Management and the Regional Administrator. As required by the Clean Water Act, permit applications, permits, and effluent data shall not be considered confidential. 10. Penalties for Falsification of Reports The Indiana Environmental Management Act provides that any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this permit, including monitoring reports or reports of compliance or noncompliance, shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than 6months per violation, or by both.

C-25---- -- -_-_ Permit No. IN 0000132

Part III Other Requirements

Thermal Effluent Reauirements Asa result of approval of the 316(a) demonstration study submitted in September 1976, no thermal effluent limitations are included in this permit. Indiana Water Quality Standards (IWQS) for temperature are waived unless the generating capacity is expanded, or the modeof operation of the existing condensers is changed to allow for additional thermal discharge. Intake Structures The 316(b) demonstration submitted for this plant has been approved. Although it appears that significant numbers of fish are impinged due to the nature of the intake pipe, the Indiana Department of Environmental Management does not believe that asignificant reduction of impingement could be attained by any reasonably practical measures such as the addition of mesh screen over the intake pipe, since NIPSCOhas demonstrated by their letter of September 6, 1983, that this is impractical due to the presence of “dune grass” in the intake which would soon obstruct any small diameter screens. Nofurther submission of information on this subject is required at the time of reissuance of this permit. Chlorine Concentration The total exposure time of TRCresulting from chlorination of the condenser cooling water shall not exceed two hours per day per generating unit.

Intake Screen Wash There shall be no discharge of debris from intake screen washing operations which will settle to form objectionable deposits, which is in amounts sufficient to be unsightly or deleterious, or which will produce colors or odors constituting anuisance. Polychlorinated Biphenyl There shall be no discharge of polychlorinated biphenyl (PCB) compounds such as those commonly used for transformer fluid, in accordance with 40 CFR423.12(b) and 423.13(a). A.

B.

C.

D.

E.

P/Bailly Station Pll

C-26AIR EMISSIONPERMIT(DRAFTOPERATINGPERMIT)



### c-27- OFTICZSTAiRMANAINoLAN DELPiQmENT

OFE?JvImu MPJixsmrr ?.9ow9 OPEPATION

PE.DlIT No?x%erxIndiana Public Sernce Ccxrgany 

### ailif ~enearrn~st+rm at EurnsHa?ncr Chesxt7on. indiana

hasappJ.Ledfor autnorzzauon ~0operate: thewchnic (sM~'r~L) coal fired boiler CUtit $7). rated at 1638un Btu's perhourenergy input. usedtogenerate upto 183megawatts(grosst or‘ d.%CULCity. precipitator. Pe.r!!ti~emrteremssxms areconrrolJ& byannicrzusa~c

conKroLLedbil.er eanisslonsarefsmaustad to theamrsonex through a400foot tall stack k&rig al5.25 foot exit diamxcr *at is sfuzed with utit #a.



### Itisgropsedrto A.sLleai5 permrr l,lndecw a.5326 .rac Amr'e~~2 s&m the folLowing .anrrliti:
1. Thatthedataand infomtim supplied in theappiication shall beconsidered part of this pemit. Priorto=change in theoperationvhichrrayresult in an increase in potential emissions exeeding those specified in 326 IAC 2-1-l. this change rust beapprovedbytheOffice ofAir Kmag6nen.t.t.Thatthepermitteeshallc~ywiththaprovirionsoftheIndianaErmimnrental MenaganentLaw(IC13-7). Air 

### PolLLtinnCouunl~ (ICU-l-1) andthenkspnnuLgatedtherernrler. 3. Ttk3tthf2equiprPntshallt-soperatedand~tai.nedti a!xodance with the ImnLlfm's specifications.

(SeePage2)

PendingldentificationNo. 64-07-92-0245 hp3ntmu Date Julv 1. 1992
THIS IS NOT A PERMIT -_-- --___- --w-wC-28Normernmalana+:CIICjervlce i;mcanv

SaillvGenerarmoStanon Burnsnaroor. :noiana &4-,,;.;2.;;J5 hoe ‘> ^. ^ - -.,,_

Zsnamcns‘knnnuec:

-. Yar cursuant :c2.25GC5.2Sec::cn:I*:. cantculammatter emlsslons;omeatmoscnere xm mscotterxail oellmirec:cG.22counasoermillion

### ausST enerqyInca:.
E. T:arcursuanr:3Secxn .::*I-- _,;2j jAC2-:,;;aCT1esi.s~0aerermlneoanware maner emissionsrrcmmlstoiler snailoeccnouceo cursuanr10328iACZ-2. -herirstYes.1 snailbe oerrormeacunngcalenaarvear?990wnnanomerresttoneoerrormeacurmacalenaarvear i562. Ti;eOfficeOT

AirManaaemenr CAM) snailoenorlfieoOT metesroatesInaovance cursuanrwnn325IACZ-2-3.anaresrrecOnssnarlwSIJO~~TEU romeOAMwrrntn~5aavs 0~metest 8. Tinatoursuamto326IACf-:-2! (aH2!.sulfurofox~oaemlsslons rromBelierNOS. 7ana8 snailbeiimneclto6.0IbsJMMBtu. Zotiers7ano8mallbeIireOwlmcoal.Iuel011 or ilaturalqas. 7. TharmeslaflonsnailsamuieanaanaivzemeccaiuseaInEolier NOS. :ana8cnaaallvoasis {Note: AflaIvSIS oaseaonccmaosnesamntesrorweeKenasananollaavswailoeac=eoIaole.! TheacoveanalvslsWIIIinc:uoeallormefoliowlnqonanasounKereo crasoumeaoasis: neai ccnrenr.36sulrur.96asnana%morsrure. ‘gnuant fo325IAC7-:-L cuartenvreoonsOT the30-aavroilingwelgnreaaverageemissionratetin oounosoerrntllion

### amTareacnaav oftheauanersnailbesuommeabvmelastaavormemonrnrollowIngmeena01meouaner. Rea~rdsofmedailyaveragesuifurcontent.neatcontentanasulfurdiqoae_emlssion rate(in

,,poundspermillionBtu)shallberetainedatthestationforthreeyear ‘-2r madeavailableuponrequest. 8. Thatvisibleemissions shallbelimitedto40%opacitypursuantto326IAC5-l. Section 2(a)(l), forattainment areas. 9. ThatoursuanttoSection3(d)of326IAC5-1,aso&al temmray exemonon.isnereov granted10allow.wnennecessary.thefollowmgvisiblestacxemissionsaunngooiler StaRuDsanasnutdowns. (a)Duringboilerstanupsanexemptionfromthe40%opacitylimitisallowedforup to10(ten)six-minuteaverageperiods,oruntil thefluegastemperatureenteringthe electrostatic precipitator reaches250degressF,which everoccursfirst. Intheevent thattheaboveisexceededdue10specialcircumstances (suchasacoldstarluoafteran extendedoutage),NIPSCOshallreportthistotheOAMwithinoneworkingdayofthe occurrence. Thisreportshallalsoincludethetotalaccumulated oenoosofexcess opacityandthereasonwhytheextenaedtimewasnecessary. Duringmese.SUUD periodsallreasonableeffortsshallbemaaetominimhe thenumneranamagnnuaeof theexceedances. (b)Duringboilershutdowns anexemmiorrimm~the 40%opacitylimitisallowedforup1 to10(ten)six-minuteaverageperiods. Duringmesashutdownpehodsallreasonable effortsshallbemaaetominimizethenumberandmagnitudeoftheexceedances.
10.Thatatnotimeshallthecombined rateofheatinputforBoilerNos.7and8exceedatotalof 5.012millionBtu’spernour. c-29-=- - -_ OFFIE OFAIRIN!JIANADEPAr?mmrOFENvImAL -

PFQWSEDOPEFATIONPER+I? Norme.?n Indiana
f Fublrc Se.'xrceCaqmy

SaiLLyGeneraring Statinn

sb a, EurnsHaroor ChesKerton. IndLma
0 hasapplied for au- KlAanto operate: thecycl.onic (?abcdticaL) cad fkezi holler (Unit ta), rated at 3374mAJim mu's perhourenergy input, usedto gellate upto 335megawmts(gross) of wty. Pe?siautemrtererlussaonsareccmrrolledbyan~ StatLC p?zeclatator. cantrolled.boiler -sions areexnausted totheaumsuhere th.m&ha 400fat tallstack having aIL25 foot eXrrrdiiuneter-&K -ti stand with Unit ft7.



### It4pL&

.to;issue:m.p under- of 326IX e 2wid thefallaring: '1" : 1. Thatthedata andinformstion supplied in theapplication shall beconsidered part of this permit. Priortoanychange in theoperationwtkhmyresu.Lt inan increase in potential emissions exceeding thosespecified in 326IAC 2-l-l. this 'ctnnge mst beapprovedbytheOffice of Air Managerrrcnt. 2. Thatthe~permitteeshallcarplywiththep~ofthelndianaEmnrrmIlk?aaLMauag~t-r.au (IC.U-7). Air Pouuricm corrtrol Iaw(ICU-l-11 &:.tbezJlJs arrmr)larrrl.-. 3. nlat-the~

# l

lqipmnt*.be opelx¶ted

and maintained inacmrdance

with the ilvmufm‘s speczfications.

(SeePage2)

PllnrliaQ;T’ ‘.-’ ” No. 64-07-92-0246

.. rate July 1, 1992

THIS IS NOT A PERMIT ---_ -- -.-- - ------

P..?flNonnemmoiana?*ZCIIC 5ervlca ,kmoanv SaillvGenerauno5tanon Zurnsnarccr. :nc:ana &$.i-J;.$2-*~24~

Csnal77ons‘knrmuec:

-. -. natcursuant :c325iACZ-2Sect:on-I::. :amczare maneremrssrons70mea7mospnere xm tmscoziersnsiloe9mires:C222~3uncscermIllion2u.s c7eneraymcu::. 3. Thatoursuanr:oSealon 1Ie!c722-3,AC2.:. xix.5~esis10oerermtneoanrware maner emwlons iromrnlscwer snailDecznauc:e~cur-wan7:c225iACS-2.?e 7irsiieslSnarlbe cenormeaammocaienaarvear7999wnnano7nerlest70seoerrormeoaunnczrenaar vear :EE2. TheOfficeorAirManaoement tOAM)snarloenotifieacrmelestdatesinaovance oursuan7w7n325IAC3-2-S.anates7reconssnarlnesuomtnea70meOAMwttnm45oavs 2r:netes7. 6. Thatoursuant70325IACT-:-2: rai(B. suuir c:oxtaeemlssronsmm SorierNOS.:ano8 snailoetlml7ea706.9ibs;MMEk. ZoliersT2nd8snarloerireawnnczar.:uer017 c: naturalgas. 7. Thar7nesfauonsnarlsamorean0anaivze7neczarusea7nSoiierNOS.:ana8cnaca7rvoasis iNote: Anaivmsoasesoncsmcosire samolesrorweettenasananolhavs wailoeaccaotaote.! Tineaooveanaivsrswailinc:uaeairarmeror~owrno onanasounrrereo orasDumearxsts: nea7 content.96sutfur.96asnana%mols7ure. Pnutsuant 70326IACT-7-3.cuartenvremns or the30day rottingwergnteaaverageemissronrateiin oounasoermrllionSt”7roreacnaav oftheauanersnailbesuommeabymeias7aavofthemonmfoilowmgmeenaOT mectuaner. Pecorasofthedailyaveragesuifurmntem. heatcontentanasuffuraioxiaeemrsstonrate(in poundspermillionBtu)shallberetainedatthestationforthreeyear&m v madeavailableuponrequest. -
8. Thatvisibleemissions shallbelimitedto40%ooacitypursuanrto326IAC5-l. Secrion 2(a)(l). forattainment areas. 9. ThatpursuanttoSection3(d)of326IACS-1.asoeoraftemoorarvexemotion ISnereov grantedtoallow,whennecessary,theiorlowrngvrsiblestacxemtssronsaunngoo7rer startupsandshutdowns. (a)Duringboilerstartupsanexemptlonfromthe40%opacitylimitisallowedforup to10(ten)six-minute averageperiods,oruntilthefluegastemperature enteringthe electrostatic precipitator reaches250degressF,whicheveroccursfirst. Intheevent thattheaboveisexceededduetospecialcircumstances (suchasacoldstartuoaheran extendedoutage),NIPSCOshallreportthistotheOAMwithinoneworxingaavofthe occurrence. Thisreportshallalsoincludethetotalaccumulatea oenoosorexcess opacityandthereasonwhytheextendedtimewasnecessary. Duringmesestamm periodsallreasonableeffortsshallbemadetominimizethenumoeranamagnrmaeof theexceadmces. (b)Duringboilershutdowns anexemptionfromthe40%opacitylimaisailowedforup to10(ten)six-minuteaverageperiods. Duringtheseshutdownperiodsallreasonable effortssnailbemadetominimizethenumberandmagnitudeoftheexceedances.
10.Thatatnotimeshallthecombined rateofheatinputforBoilerNos.7and8exceedatotalof 5.012millionBtu’sperhour. c-31OFECZOFAIRMANA~ INDL4NADEPARlMEWOFENVI~ALMANA(3MENT

PFQFUSED

OPERATION

PE$MIT
NorcM Indiana Public Servxe Cmpany Bailky Generating Starlon at Burns Hador Chesrmon. Imiiana

hasapplied fezaurhoczauan roopexare: theoil fired gasturbine (Unit #lo). rared ar:435milLion Btu's perhourenergy input,usedtog-tee.LemzzitydurPgperzods ofpeakdRnand.~sxxn areexhaustedto theamsp- through a40foor ta.U srask hamnga14foor exitdiamter.



### It.isprqmsed=to~3--*h+~~~

. -c&326IBc-2wktb thefallwing- ." : 1. Thatthedataand information suppLied in theapplication shaLLbe considered part of this pennit. Priorto~change in the0perationwhichmyresuLt inanincreaseinpotentialemissionsexceedingthosespecifiedin326IAC 2-1-l. this .change mst beapprovedbytheOffice ofAir Managmt. 2. matthepennitteeshallcarplyywiththe~oftheJ" mntal Menag-t raw(IC~,x+7). Air pall&&XL- (rzL3-l-1) andthe rol.ee prmulgatd--. 3. Tt!attbe equipmltshrllbeoperatedandmsinteirledin-withthe manufaczturds spacifica tbns. 4. Thatpursuant to 326UC7-1-21(a)(2), gasturbine Unit #lOshall burn ~%-iiF,~garrZll~, .sz!cmk~ti#lfl~tlarre.abalLballaintained andmsdel?wedabletotheoAMupor-request.

Pending.mentizicatiur~No. 64-07-92-0247 Expntum Date JuLv1, 1992
THIS IS NOT A PERMIT ---- -- --- - ------

. mnOFEE OF?JRINDLANADEPARZMENTOFENVIFCWlDCALMANGmDn

Nor&em Indiana Public Semite Ccnpeny Rsiy Generattig Station ar:BurnsHerbor Chesterton, Indiana

hesappl&d for au- toopenite: thefacilitiesassociatedwtththcfuelanddryfl~~ands=coraoe syst-, s

ennngthecDaLfkedboiLzz.

1. Thatthedata end:imfanmtion supplied in ttksapplication shall beconsidered pert of this pezmit. Priorto~ckange in theoprationwhichrmyresult inaninareaseinptat~tielemissione exceeding thosespecified in 326IAC 2-l-1, this ,cbnge mLstbeapprwedbytheOfficeofAirManagment. 2. Thatthepernritteeshall.~lywith,tbe~ofthe~~- mentalMlsugawtLaw (IcJ3-7). AirEolkrt-Lm~~crrrrm, (KU-1-l)andtheruJ.e3. That~tbe~~~~ ..' dinacamkmcewiththe Insnufrn's s-d. 4. Thatfugitive dust tanissinns stdlanply with 326IAC6-4.

PeIdinge. 64-m-92-0248

. -Date July 1. 1992
THIS IS NOT A PERMIT ---.-- ---- ------

c-33APPENDIXD IH

DOCUMENTATION

OFAGENCYCONTACTS During the week of January 2, 1989, AFGDproject team members met with the Indiana regulatory agencies which have been identified as having jurisdiction over the project. Relevant excerpts from the meeting notes for these contacts are contained in this Appendix.

The project team members that met with the agencies were:

o Air Products and Chemicals, Inc.

o Enviroplan, Inc. o Northern Indiana Public Service Company o Stearns-Roger Division of United Engineers &Constructors Inc.
The agencies contacted were as follows:

0 Indiana Department of Fire Prevention and Building Safety o Office of Water Management (IDEM) o Office of Solid and Hazardous Waste Management (IDEM) o Office of Air Management (IDEM) 0 Porter County Plan Commission

D-liH

DATE: January 4, 1989
SUBJECT: Indiana Department of Fire Prevention and

Building Safety (DFB) Permit Requirements
LOCATION: Indiana Department of Fire Prevention and

Building Safety Offices 1099 N. Meridian Street/Suite 900 Indianapolis, IN
RELEVANTEXCERPT:

The DFBindicated that they process all building permit applications for anumber of groups including the State Fire Marshall and the Bureau of Elevator Safety. The DFB conducts aplan review for life and safety features of the project. The DFBdoes not really get into astructural review, although structural design maybe scrutinised as it relates to the life and safety review.

Indiana currently follows the 1985 UBCwith the Indiana amendments which basically replaces the first three UBCchapters. After April, 1989 the 1988 UBCwill be used. Indiana also follows the NECand NFPA. The DFBfollows the General Administrative Rules (GAR)which specifies howthey operate. Chapter 5UBCrequirements should be closely reviewed and followed. All codes generally have Indiana amendments. The DFBcommented that as of l/3/89, Indiana follows the BOCAPlumbing Code. Also, the 1988 UBCMechanical Code is nowfollowed.

If the project's design has a major change from the appropriate codes, avariance has to be filed. The variance will then be evaluated the first week of each month by the 15-member Building Commission.

D-2The DFBsaid that handicapped parking is not

required until there are more than 50 parking spaces. However, if there is handicapped parking within about 300 feet of astructure, the DFBwill probably accept this. Handicapped parking requirements are based on the appropriate ANSI code.
The DFBsaid that their plan review considers occupancy vs. building sizes (square footage and number of stories), fire-proofing, construction type, exiting (including staircase enclosures) and fire protection. Although the latter is covered by aseparate application. The DFBsaid that local contractors at one time had difficulties with the sprinkler system requirements. However, they are now knowledgeable about these requirements.

The Bailly Station is in Seismic Zone 1according to the UBC, although the southern part of Indiana is in Zone 2.

The DFBwill accept partial filings for different structures. However, after filing the building foundation permit for astructure the applicant has 30days according to the GASto file everything else (plumbing, electrical, etc.). Oftentimes the DFBwill allow 45days, then send out a 15-day notice to complete the filing. After 60days an application has to be refiled. If partial filings are used (partial program 1, subsequent submissions must be listed on the building permit application form.

Asix-digit filing number will be assigned to submittals and this should be referred to in any correspondence. Oncethe number is known, it could be placed on drawings (title block) or specifications. Applications will be received initially by the DFBcounter and then routed to the plan reviewer. Typical applications are processed in

D-3II

10to 15working days. If the project has not heard from the DFBwithin three weeks, the project should call the DFB.

Abuilding permit application consists of the appropriate form, filing fee and design information. The first submittal should also include aproject description and aplot plan. Subsequent submittals require only aplot plan especially for each newbuilding.

The filing fees include: $100 partial filing fee; $50 building/foundation filing fee for two-day approval or $15 fee for afoundation review for a four-hour turnaround. The foundation review includes an examination of footing width, insulation, cross ties and anchor bolts. Oncethe application is approved, the DFBwill assess aconstruction fee indicated in the fee schedule. If Porter County does not have a building inspector, an additional 50percent will be added to the fee for the state to dothe inspections.

Any size drawings are acceptable, although 23x 36 inch would be good. Thespecifications and drawings must be AFC. Anything stamped "preliminary" will be rejected. Specifications and drawings must be stamped and signed (, the seal) by an Indiana PE(architect or engineer). It help to include the date of signing and expiration date seal. The original mylar should be stamped and copies submitted to the DFB. under would of the

If there are design changes after the DFBissues its approval, an addendum has to be submitted for approval. If.ite the changes are madeduring construction, the DFBcan exped its approval.

If during the DFB's review of the design information, more than 10unacceptable features (conditions 

### 1 are found, the DFBputs the review on hold. These conditions



### D-4must be resolved by resubmitting the plans before the review

will continue. The DFBsaid that this is more of aproblem with non-resident engineering firms. For example, the Indiana code allows for afour-hour fire wall being equivalent to 60 feet of yard space (yard space allowable). But this only can be used on one side of abuilding one time. Non-residents are usually not aware of this aspect of the code.

Once the DFBissues its approval, the approved plans and release placard must be maintained on-site. Following approval, the project needs to makearrangements to have inspections. These are done by the state or a local inspector. The inspections include one by the Bureau of Elevator Safety and other inspections of foundations, structural rough in, and afinal inspection. However, the inspectors can drop by unannounced. If there is aproblem the inspectors cannot stop construction, they will refer the problem to the state attorney general whowill stop construction. Following the final inspection, certificates of occupancy are issued either by the state or local jurisdiction.
The DFBsaid that in some areas of the state as of 4/l/08, the appropriate jurisdiction needed to provide (1) a city or county ordinance stating that the state building code will be followed, and (2) evidence of the number of people and the names of people whowill do inspections. If the local municipalities do not provide this information, the state is responsible for construction inspections. The municipalities do the inspections if they have provided the indicated information. The DFBprovided a list indicating that Porter County currently does not have abuilding inspector.

D-5DATE: January 4, 1989

SUBJECT: Office of Water Management (OWM)(IDEM) Permit

Requirements
LOCATION: Office of Water Management

Chesapeake Building 105 South Meridian St. Indianapolis, IN
RELEVANTEXCERPT:

The potential wastewater streams were discussed. The OWMindicated that it would prefer that stormwater runoff, sanitary wastes, and potentially WESwastewater be directed to the on-site ponds. If this is done the OWM would like a letter with information on the discharges to the ponds (type, frequency, quantity, quality). The OWM said that it would probably approve these discharges without additional monitoring requirements. The current Northern Indiana NPDES permit requires that any change in Bailly Station wastewater discharges be reported to the OWM by letter.
The OWMsaid that the project should make sure that the existing wastewater treatment plants can handle the proposed wastewater flows. This is particularly true for sanitary wastes.

After submitting the letter with the wastewater information, it will take the OWM two to three weeks to review it. Anapproval will probably be issued by letter then, if everything is okay, without any monitoring requirement. If everything is not okay, additional information maybe required or possibly the existing NPDESpermit mayhave to be modified.

D-6The existing NPDESpermit would also have to be

modified if separate or newoutfall points (other than the existing ponds) are proposed. This would possibly require submittal of an EPAapproved form (e.g., EPAForm 2D) and supporting documentation. Regulations require that this information be submitted 

### 180days prior to discharging. During this period, the OWM will review the information and have a 30-day public comment period on adraft NPDESpermit. The permit would probably include some discharge monitoring requirements.
If the WESis not used as currently planned and is discharged offsite, the OWNwill require wastewater quality information. This would probably include chlorides, pHand TSS.
In the meeting the OWMsaid that most Indiana streams are classified as suitable for general use and aquatic life.

D-7I I

DATE:
SUBJECT: January 4, 1989

Office of Solid and Hazardous Waste Management (OSHWM)(IDEM) Permit Requirements
LOCATION: Office of Solid and Hazardous Waste Management

Chesapeake Building 105 South Meridian St. Indianapolis, IN
RELEVANTEXCERPT:

Ash from the Bailly Station is currently sold to a fly ash marketing firm which'landfills it in Illinois or sells it for other uses. Prior to sale of the ash, it is stored in asilo. TheAFGDsystem ash also will be sold for other uses or landfilled. The OSHWM said that if the ash is disposed in Indiana, the project can send a letter to OSHWM saying that there is coal ash for disposal. The OSHWM will then probably send a letter back saying that the coal ash is asolid waste and can be landfilled. However, the OSHWM said that it would like to see EPtoxicity test information and analyses for the parameters included in the secondary ground water standards. The OSHWM

cannot require this by law. The latter includes chlorides which the OSHWN indicated interest. If the analyses are acceptable according to the regulations, they can be landfilled as asolid waste. If the analyses show aproblem, the ash will be called aspecial waste or hazardous waste by the state and will have to be handled appropriately. The OSHWM said that if analytical data is not provided to them, even if they classify the ash as asolid waste, the landfill mayrequire analytical data.

The OSHWM

will initially consider the gypsum as a special waste resulting from industrial pollution control.

D-8Because it will have only about 8to 10percent moisture, as

explained by Stearns-Roger and Northern Indiana, the gypsum is not considered afree liquid. Thus, the gypsum could probably be disposed in aspecial waste landfill similar to the Wheeler landfill. Special waste landfills must meet ground water monitoring requirements and the operators must be in good standing with the OSHWN.

In order to confirm the appropriate disposal of the gypsum the OSHWN

wants a letter describing the gypsum and the proposed landfill where it will be disposed. Twoor three sites maybe proposed if the waste volume justifies more than one site. The gypsum waste should be characterised by the EP toxicity test (one sample) and analysis for chlorides. This will allow the OSHWN to determine if the gypsum is indeed a special waste. The OSHWM said that the project should check with them prior to doing any analyses to confirm sampling techniques (basically follow SW-846) and the appropriate analyses.
The project cannot dispose of gypsum until an evaluation has been madeby the OSHWM. However, the OSHWM might possibly issue ago-day approval for disposing the gypsum prior to AFGDsystem startup if test data from existing facilities can be provided. The data also maybe provided from bench tests. Once the AFGDsystem is operating the OSHWM would then require that the appropriate analyses be made. Even if the project analyzes the gypsum a landfill maydo analyses on its own.

Anoption besides using an existing landfill is to create the project's ownrestricted waste site for disposing ash and/or gypsum. If the project permits a new landfill the OSHWM will require EPtoxicity information and other tests for secondary drinking water standards. The analyses would then be evaluated according to the restricted waste site

D-9t III

classification where Type I is basically ahazardous waste site and Type II through IV take different categories of non-hazardous wastes. The analyses would have to be based on three samples. Before collecting samples and doing the analyses, everything should be approved by the OSRWM.

For an evaluation of disposing waste in an existing landfill, the OSRWM requires about a 30-day review time. If the project permits a landfill to existing standards, the evaluation time would be about 6to 12months. Currently the OSRWM issues one-year approvals for waste disposal with some retesting in advance of the one-year expiration date. The OSRWM is looking at starting to issue five-year permits with repeat analyses.

The OSRWM

said that coal ash is sometimes disposed in mines with Department of Natural Resources (DNR) approval, not OSRWM

approval. The OSRWM said that they were not sure if the gypsum could be disposed in mines. The OSRWM would have to evaluate this disposal option, possibly in consultation with DNR.

D-10Iw

DATE: January 5, 1989
SUBJECT: Office of Air Management (OAM) (IDEM)

Permit Requirements
LOCATION: Office of Air Management

Chesapeake Building 105 South Meridian St. Indianapolis, IN
RELEVANTEXCERPT:

It was agreed that the installation of the scrubber is not in response to any regulatory requirement. Also, the OAMindicated that the pollution control device does not fall under PSDregulations.

Ashwill continue to be stored in an on-site silo. Limestone also probably will be stored in an on-site silo. Current plans are to purchase pulverised limestone instead of having extensive on-site crushing facilities.

During the demonstration period various sulfur content containing coals will be evaluated. Some coal will always be maintained on-site that meets existing permit conditions for emissions.

The OAMsaid that for known technologies sometimes they can merely process aregistration based on information provided in a letter. However, for the AFGDsystem which involves an unknown technology, they want a Permit to Construct (PTC) Application. The PTCcanbe applied for by either the owner of the system or the operator (either

D-11Northern Indiana or Pure Air can hold the permit). The

project participants need to propose whowill hold the PTC and who is responsible for various emissions on-site and discuss this with the OAR. The OARsaid that Northern Indiana probably will be held responsible for non-AFGD system emission control (e.g. fugitive dust). The PTCis required so that the OARcan set maximum limits onvarious parameters to protect air quality and to determine compliance. Probably emission limits will be placed on the sameparameters that are in the existing air permit (SO2, TSP, opacity, etc). The OARdid not believe that NOxwould be monitored or would be a problem. The OARthought the TSPmight be aproblem, although Northern Indiana and Stearns-Roger indicated that the AFGDsystem was not supposed to impact TSP.

The PTCapplication should include information on the process, stack parameters (including assurance that the stack has an adequate height), and proposed emission limits for operation of the AFGDsystem. The latter should be supported by modeling using methods approved by the OAR.

The PTCapplication requires a$100 filing fee, plus expenses for the OAR's air quality.review. The total review time from the time the PTCapplication is deemed complete is four to five months. This includes one month for OARmodeling activities and a 30-day public comment period. The latter may result in apublic hearing if the OARdeems it appropriate based on the comments received (reasonable technical basis). This then requires aZl-day notice period, time to set the hearing and finalize a report. Project participants maybe able to avoid apublic hearing by working with the organisations whomakecomments to resolve relevant issues.'

D-12I I III

As part of the public notice, the OAMwill issue a Technical Support Document (TSD). The TSDwill contain a proposed permit with emission limitations and conditions. Onecondition might be having anopacity monitor following the ESP.
The OAMwill require source testing following construction and issue a Permit to Operate (PTO) to cover the three-year demonstration period. Typically PTO's cover four years. Following this period the OAMwill issue arenewal permit to begin covering the commercial operation period. The renewal permit will be based on an evaluation of emission information.

D-13III

APPENDIXE
U.S. DEPARTMENT

OFENERGY, ANDBURNSANDROECOMMENTS ONDRAFTENVIRONMENTALIMPACTVOLUME

E-l

### Department ofEnergy Pittsburgh EnergyTechnologyCenter

P.O.Box10940 Pittsburgh, Pennsylvania 15236-0940

March14,1989

Mr.FrankBolinsky PureAir TwoWindsorPlaza 2WindsorDrive,Suite303 Allentown,PA 18195 SUBJECT:Draft EnvironmentalInformationVolume DearMr.Bolinsky: 

## RECEf VED MAR ,I71989 

## PUREAIR

Enclosedare three sets of comments on Pure Ah% Draft Environmental InformationVolume(EIV).Thecommentswerepreparedby:

1.WinstonWilliams,BurnsandRoe 2.TomRuppel,DOE/PETC 3.TomSarkus,DOE/PETC *After youreviewthesecomments,wewill holdameetingtodiscussboththe commentsandyouranticipated response.Themeetingwill beheldonTuesday, March22,1989,atBurnsandRoe’shomeoffice InOradell,NJ. Itwilllastfrom 9:00a.m.until approximately 11:OO a.m. PleasebringSte,veDennisandSpenser Hustonalong. Baseduponourmilestoneschedule,yoursecond(andhopefullyfinal)draft EIVis duebyApril 17,1989.WewillbeginworkingontheEnvironmentalAssessmentas soonastheEIVisfinalized. Therefore,youareencouragedtosubmityourrevised EIVassoonaspossible. Sincerely,

Enclosures
cc:w/enclosures E.Evans,CT-IO R.Rogus,AD-21 T.Ruppel,CT-10 T.Sarkus,CT-10 ThomasA.Sarkus ProjectManager OfficeofCleanCoalTechnology

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E-8. 2-lO(3) / III, EIV Review - rure ALT Draft 01 - Mar 3, 89 geview of Envir~tion V~l,unl0

Pure Air Eroiect fit Technm

L’ntll e firm contract ia in force, this gypsum should be treated as a waste byproduct. rt Will help readers if astatement on the purity of this compound is given - eg. t purity. ‘1,.

. the potential 

### for avoiding

......‘I should be changed to U.

..the potential for reducing

...“, since solid vaste and liquid wastes are produced, see page 2-30. The scale of the map included is not shown. Include other industrial 

### complexes of interest within the environs of the NIPSCO’e site, lg. Steel plants etc. State the t of sulfur in tho UScoals that will be used or can be used in this AFGDsystem. Page 2- 22 suggested that the coal of Indiana hasCtnsu:;y: content of 4.515 ultimate analysis. sulfur content be used throughout the write up of the Environmental Assemnent?. Include a map

### of the entire property, shoving the locations of the existing plant etructures, and the proposed locations 

### of the structures to be conetructed for the AFGDrystem. Figure 2.1-5 is adetailed version of this map. Tha current NPDES dor8 not cover the wastes described on page 2-30. A permit will have to be applied for, for the disposal of: (a) Solid wastes - gypsum, salts (b) Liquid (process water) high in Chlorides. There is 

### a need for information, or a statenant about the probability of 8uccess with the retrofit, in achieving 902 SO2removal. what is the inlet concentration 

### of SO2 in the AFGD system that is proposed by Pure Air, to 1

E-3-irait Oi'- Mar 3, 69
achieve the 90%removal efficiency?. Specify 

### (or estimate) the probability 

### of achieving 901 eificiency with a coal fired power plant, as opposed to industrial coke fired boiler which has been referenced in the XIV. Provide more details of the quality and quantity of the flyaeh produced, and how compare these values with the current production of flyash, is. the delta value. Details is given about recycling part of the process water into the WESfor evaporation. What is the fate of the other parts of the waetewator produced by the gypsum dewatering operation. Specify the quantity that is produced, and the percentage of that wastevater that is recycled. Will the chloride in tho vastevater produced by the gypsum operation affect 

### the AFGD system when pumped back to the flue gas upstream of the system?. If PO, what will the impact on the SO2 removal efficiency be?. What is the concentration 

### of SO d in the flue gas entering the AFGD system, an hov does this compare with that of Kainan Station in Japan that is referenced?. Will scaling the AFGD system upwards from the Xainan Station in Japan affect the efficiency of the SO2removal?. There is need for clarification of the statement 'no solid waste from the proceasl. What is the clareification of the flyash Sromthe WES?. What is the need for permit #64-00-92-0249?. The emphasis on reduced liquid wastes should be stressed rather than no liquid wastes. Given that US coals have high sulfur content, what guarantees 

### exist that the SO2 removal efficiency 

### of 908 vi11 be achieved in this project?. If 902 removal efficiency is achieved, can it be maintained on aconstant baeio?. Should a more coneervatlve estimate of the efficiency be

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madeat this stage of the demonstration period?. What is the concentration of 802 In tha inlet flue gas, and how does this compare with the concentration and removal efficiency of the West Germ6n Veba Kraftwerkc Ruhr AG’s plants?. If there sre failures with the module, and given no spare module, will there be excursions of SO2 emissions to the ambient air. If 80, what amounts will be emitted, and will that beregulated by the NPDESair permit?. Who is responsible for SO d excursions, if any, Pure Air or the Northern In iana Power Plant? What flsxibilities exist for using coal with a sulfur content higher than 4.52 (ultimate analysis), and howwill this affect the removal of so2 produced?. This is important, given the fact thst all prior testings were for coal with lower sulfur content. The figure on page 2-24 shows wastewater leaving the eystem after the thickener. What is the quantity (flow rate) and hov is it disposed off?. Showon the figure how this wastewater to the WCS mentioned in 2-33 (4) enters the SO2 remova1 system. It may be helpful if mass balance diagrams are provided. Process flow schematic diagrams with mans balance information should be provided for the following at the very least: (a) Sulfur and SO2 (b) Water (c) Fly ash Cd)Gypsum (8) Thermal energy Indicate on the figure that shaded portion represents the retrofit 

### of the AFGDsystem that is proposed. Give the actual feed rates for limestone and SO and then state the 

### molhr ratio. This im needed y ii’ a layman reading the report, and will help clarify the issue.

3

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3-4 (1) mm. _.~ Draft 01 - Mar 3, 89
It will be Wsful if an analysis of the flue gas entering the APGDsystem is obtained or estimated. Maybe, the procese schematic 

### for mass balance for S02 will provide this information. It will be useful to let the public know that only IO* 

### of the SO produced by the NIPSCOpower plant is being BITI fttad through the stack. Portion 

### of thQ filtrate is sent 

### to the waetawater ponds for disposal. What is the chemical composition of this vater, and is it regulated under tho NPDESpermit for waste water?. Will this water meet the criteria 

### of the permit?. What is the basis for stating that all the wacte are not considered to be hazardous?. Provide data to support this. 

### Where will the gypsum be landfilled?. what company will accept this gypsum, and what quantity will be accepted and vhat time 

### frame?. Will there be a build-up 

### of this material, at 

### or around the site?. What ir 

### the quality of this 

### procens water?. If not used in the process (recycled), how will it be dimpoeed off?. Will it change or impact the SO2 removal process?. Anote on noise/nuisance level8 of vehicles (about 80 truck 

### per day) and the impact on the neiqhborhood should be inserted after para 3. No land allocation is made for gypsum storage prior to disposal, 

### or for flyash rtorage prior to disposal. What impact will these have on the land/water reseurces in the area, considering that the flyash vi11 contain salts of a higher concentration than currently handled?. Noise levels should be addressed Give the'reference of the IDEn study, and extract details ebout this study for inclusion in the appendix. Reference the soelected governmental agencies" and include extracted data, if poesible, from their

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4-l(3) EIV Review - Pure Air Draft 01 - Mar 3, 69 reports. Attach a mapof the .property boundary, indicating any wetland that is within the property boundary, and any immediately edjecent to the plant site. This should be in addition to Figure 3.3-l. The places mentioned in para 1 and 2 should be indicated in a map of adequate acalo, for clarity. Is 40 cm/s equivalent to 1 mph, or is it an approximation? Get documentary evidence to prove the absence of protected or endangered wildlife within the property boundary. The Wildlife and Conservation Society of the araa should be able to provide this document. Get confirmation about the transient migration of land vertebrates in 

### the area. Again, the Wildlife and Conservation Society of the area should be able to provide this detail. The sighting of a bald eagle should be documented stating by whom, when and where?. Get confirmation from the Wildlifm and Conservation Society that the bald eagle dome not nest within the plant area. The figure raferenced on page 3-43 para 3, is it 3.2-4 or 3.2-2? Figure 3.5-l has to bo enlarged to show the details, and the area of NIPSCOand the coastline clearly marked out. The inclusion of @I

...water will be sprayed on the 

### roads otc, 

### where and when neoeasary, to reduce fugitive dust during constructionl' will help alleviate fears of dust. Noise levels should also be addressed at this stage. Whywill the NO,at ground level be increased with thia AFGD system7 Please clarify and state reacton for this. Give an estimate of the fugitive eaissions from

E-7-- ___ Draft 01 - Mar 3, 89 transport of crushed llneatone. Will this emission meet with the requirements of the State of Federal regulations for fugitive dust?. E-46. 4-4(l) Clarify what impact the disposal of gypsum Will

huve on land use of the area. Will it affect water quality around the site?. E-47. Q-S(l) Include a note on the treatment and cleanup of oil

spills if they occur on site during construction. E-48. 4-5(2) A permit may be required for the process water

which is high in chlorides. E-49. 4-4(2) Details about the landfill uard will be helpful.

Its design and size are important. E-50. 4-6(6) Specify these waste materials and the quantity of

each material. Specify or provide more details of the 'appropriate containers' that will be used to ininimize potential contamination of surface water. E-51. 4-6( 1 The flowrate 

### of the wastewater to the pond is

116.8 9pm. Indicate what t of the waetewater from the AFGDsystem is diverted to the panda. The chloride content of the wastewater la high at 23,072 mg/L. A ermit will be required for this if it ie to be d acharged to Lake Uichlgan, where

P the regulated daily maximum concentration of chlorides is 20 mg/L. The regulated amount of fluorides is 1.0 mg/L at Lake Michigan, and 9iven the process water with a concentration of F‘ of 1095 mg/L, then provisions murt be made for adequate mixing to comply with re9ulations. It may be useful to get the current analysis of the water in Lake Michigan around the plant, and model the discharge of this wastewater, to determine the changes in chloride accumulation that may result.

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3-6-89 TCRuppe1 COMMENTS

ONPUREAIR DRAFTEIV The Draft EIV appears to be in good format and the content appears to be fairly complete. Following the thorough review by PETC’s contractor, Burns SRoeServices Corp., and these review comments, weexpect that the second draft should be sufflclent to have BRSC write an Environmental Assessment NEPA document for review by DOE Assistant Secretary for Environment, Safety Shealth.
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E-62 P. 2-24. Fig. 2.1-4, Showmassbalances, including coal input and stream compositions (e.g., SO2, CO2 of stack gases ), before and after action. Thetable on P. 4-2 should be incorporated also into the flow diagrams. This is the kind of information that we are looking for and it should bedisplayed prominently. P. 2-6, Include wastewater discharge to Lake Michigan in a ‘before action’ flow diagram. Is the wastewater the noncontact cooling water? Seealso P. 4-4, below, P. 2-21, Fig. 2.1-3. It is expected that Environmental Issues will continue to at least September 1989 And net end in February 1989 as shown (see TYPICALNEPAPROCESS TIHESCHEDULEdistributed by PETC), P. 2-27, Minor point, balance 2H* in last equation. P. 2-34, The difference in land needed, between 1.72 acres and 4 acres on P. 2-3, should be discussed. P. 3-3, TheAttainment vs. Nonattalnment status of Porter County for the Criteria Pollutants should be addressed. P. 3-24, The FEHA/FIRM floodplain and wetlands maps should be included as an appendix, possibly as an insert in the inside back cover. P. 3-25, Concerning fauna and flora ecological resources, letters from the appropriate Indiana environmental agency or the U.S. Fish andWildlife Service, asappropriate. concerning its agreement with the statements on P. 3-25 should appear as an appendix. P.4-4. Thealternative gypsumdisposal information is important and should appear onthe flow diagram too. P. 4-5, me Indiana Department of Environmental Management’s approval for walvlng ground water monitoring should appear in an appendix, P. 4-6, First line, “appropriately approved facllltles” should be deflned, especially by a copy of apermit in an appendix. E-9E-63 P. 5-4, The status of the several permits should be included, i.e.,

“Obtained” or targeted date for obtaining. The ANTICIPATED PERMITS/APPROVALSSection 5.2 (p. 5-7) is good, but anticipated dates for obtaining permits should be given somewhere. E-64 App. A, Acopy of the letter from the Advisory Council on Historic Preservation should in included. E-65 App. Bis in general good. (No response required. ) E-66 App. B, The outfalls cited. e.g., 001, 002, 100, 111 should be

identified in the flow diagram on Fig. 2.1-4 (p. 2-24) or on a separate flow diagram, preferably in conjunction with the site plan Fig. 2.1-5. p. 2-25. The NPDESPermit Table 5.1-2 is good, but flows should appear somewhere. Wewould appreciate your ruing aslightly wider looseleaf binder for the second and probably final draft.

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E-71 COMMENTSONPUREAIR’SDRAFTENVIRONMENTALINFORMATIONVOLUME T.Sarkus,3113189
1.

2.

3.
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5. Page2-5,Last Paragraph. It isnotedthat Baillyunits 7and8havea A combinedcapacityof528MW.YetthedraftairpermitsshowninAppendixB showacombinedcapacityof518MW.Pleaseexplain. Page2-22.Anultimatecoalanalysisisshown.Iassumethatitisan’average analysisforcoalconsumedattheBaillystation,whichisgood.Canyoualso showtheapproximaterangeforeachcoalcharacteristic,e.g.S2.5to8.5? Page3-5. Capitalize namesofgeologicperiodssuchasSilurian. Change dolomitelimestonetodolomiticlimestone. Page4-3. Itismentionedthatthegreenbeltwillnotbeaffected bythis project. Fortheunfamiliarreader,pleasedescribethegreenbelt. Page5-3. Inthefirst paragraph,itisnotedthattypicalcoalandlimestone B sampleswillbeprocessedinatestunit,inordertoassesstheby-product gypsum.Whereisthetestunitlocated,andwhenwillthesetestsoccur?

Footnotes A. The Bailly Station Units 7 and 8have apermitted combined capacity of 528 MW. The Indiana OAMhas been notified of the typographical error in the permit. B. This question has not been addressed in the EIV since DOE indicated in ameeting on March 22, 1989 that averbal response would prove satisfactory.

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