Bailly Generating Station 

Advanced Flue Gas 

Desulfurization System 

FINAL 

ENVIRONMENTAL INFORMATION 

VOLUME 

April 1989 

Pure Air 

a jcint venture company 

Mitsubishi Heavy Industries America, Inc. 
TABLE OF CONTENTS 

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 

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2-18 

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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 

3-30 
TABLE OF CONTENTS (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 

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:I: 

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:I: 

:I: 

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:r: 

:I; 

4% 

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4-13 

4-15 

4-15 

4-16 

4-16 

4-17 

4-17 

4-17 

4-17 

4-18 

ii 
TABLE OF CONTENTS (Continued) 

4.6 Energy and Materials Impacts 

4.6.1 Construction 

4.6.2 Operation 

4.7 Impact Summary and 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 

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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 

iii 
LIST OF TABLES 

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 AFGD System 

Versus Conventional FGD Technology 

Capital Cost Savings Features of the 

AFGD System 

Operating Cost Savings Features of the 

AFGD System 

Modified Mercalli Scale 

Freshwater Wetland Classification 

Indicated in Figure 3.3-l 

Wetlands and Deepwater Habitats 

Classification Indicated in Figure 3.3-l 

Summary of Flood Elevations for Lake 

Michigan Near Unincorporated Areas of 

Porter County to Include the Bailly 

Generating Station 

Abundant Bird Species Known to Nest in 

the Indiana Dunes Area 

Fish Species Verified in the Aquatic 

Community of the Bailly Generating 

Station and Its Vicinity 

Benthos Common to 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 

iv 
LIST OF TABLES (Continued) 

Table 

3.5-5: 

4.3-l: 

4.3-2: 

5.1-1: 

5.1-2: 

A-l: 

A-2: 

A-3: 

Nursing Homes and Bed Totals Within 

a 12-Mile Radius of the Bailly 

Generating Station 

Projected Wastewater Composition from 

the AFGD Process 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 

NPDES Permit 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 

V 
LIST OF FIGURES 

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 AFGD System Plot Plan 

Process Flow Schematic 

Sulfur, Gypsum and Limestone Balance: 

AFGD Design Condition 

Chloride Balance: AFGD Design Condition 

Water Use and Gas Temperature: 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 Dune Acres 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 Map of 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 

Vi 
LIST OF APPENDICES 

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 Roe Comments on Draft 

Environmental Impact Volume 

D-l 

E-l 

vii 
1.0 INTRODUCTION 

Pure Air, a joint 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 AFGD system 

will be installed and operated at the Northern Indiana Public 

Service Company's (Northern Indiana) Bailly Generating 

Station located approximately 12 miles northeast of Gary, 

Indiana on the southern shore of Lake Michigan. 

Significant decreases in sulfur dioxide (S02) 

emissions from high sulfur coals are expected to result from 

operation of the AFGD system: guaranteed 90 percent reduction 

during operation, and testing at 95 percent. Operation of 

the system will demonstrate not only a high 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 a single module to 

control emissions from multiple boilers; 

The functionality of a single 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 FGD systems. 

l-1 
E-l 

In addition to these technological features, the 

demonstration project will advance several important and 

highly innovative commercial features that also contribute 

significantly to a greater reduced cost for achieving SO2 

emission 

overview 

1. 

2. 

3. 

4. 

reductions over conventional FGD systems. An - 

of these features follows: 

Pure Air will own and operate the AFGD facility 

during the demonstration period of three years and 

later during commercial operation. This approach 

will result in substantial operational savings 

compared to existing FGD systems. 

Multiple boilers connected to a single 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 95 weight percent CaS04* 

2H20, typically 1.9 weight percent CaC03 and 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 AFGD system. 

The purchase and dry charging of powdered 

limestone, based on preliminary quotes, should 

significantly reduce the capital and operating 

costs of the AFGD system. 

The intent of Pure Air and Northern Indiana to 

enter into a commercial arrangement whereby Pure Air will 

continue to own and operate the AFGD facility at the Bailly 

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

successful completion of the demonstration program, 

constitutes a unique and commercially attractive industrial 

alternative to the utility own/operate scenario. This 

commercial operation will result in a significant reduction 

of interstate SO2 emissions during the 17-year commercial 

period. 

The purpose of this Environmental Information 

Volume (EIV) is to provide to the DOE a data base, analyses 

and impact assessments for the AFGD system. 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 

AFGD system. 

The comments made by the Department of Energy on 

the Draft EIV have been included as Appendix E. Each comment 

has been numbered and the response is referenced in the text 

by notation(s). 

1-3 
2.0 THE PROPOSED ACTION AND ITS ALTERNATIVES 

2.1 THE PROPOSED 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 a 300-acre tract in Porter County, 

Indiana (Figure 2.1-1). When constructed, the AFGD system 

will occupy approximately four acres of land on the station 

site. 

The AFGD system 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 SO2 removal 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 a high 

quality gypsum which may be sold to a wallboard manufacturer 

or other user of high-quality gypsum. 

The AFGD system will be run for a demonstration 

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 AFGD System for an additional 17 years giving 

the system a 20-year life cycle. 

E-4 

E-2 

2-l 
KAGO 

a joint venture company 

ADVANCED FLUE 
2.1.1 Site Description 

The AFGD system and supporting facilities will be 

constructed on a 4-acre tract adjacent to Units 7 and 8 of 

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 an area 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 Dune Acres two miles to the 

east. Lake Michigan is north of the plant site and Bethlehem 

Steel Corporation, south and west. To the 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 

2-3 
ZONE MAP 

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WESTCHESTER TOWNSHIP 1 

PORTER COUNTY, INDIANA 

PREPARED FOR THE PORTER COUNTY PLAN COMMIS8K)N I 

& Pure Air A 

a joint venture company 

ADVANCED FLUE 

OAS DESULFURIZATION 

Westchester Township 

Zone Map 

Figure 2.1-2 
miles northwest; the Illinois-Indiana boundary is about 21 

miles due west; Michigan City, Indiana, and the 

Indiana-Michigan boundary are about 13 and 18 miles 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 6 West 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 own steam 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 a year - 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 7 boiler produces 1,200,OOO 

pounds of steam per hour at a pressure of 2,400 pounds per 

square inch and a temperature of l,OOO" F. Unit 8 produces 

2,600,OOO pounds of steam per hour at a pressure of 3,500 

pounds per square inch and a temperature of l,OOO" F. Each 

boiler supplies a steam turbine generator rotating at 3,600 

RPM and 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. 

2-5 
E-27 

The units have a combined 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 C Hazardous Waste Regulations 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. 

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 a wastewater 

discharge to Lake Michigan. The wastewater initially is 

directed through a series of on-site retention ponds and is 

recycled through the station on an as-needed basis. These 

discharges are regulated under a National Pollutant Discharge 

2-6 
Elimination 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 

AFGD system 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 SO2 emissions can 

be reduced at a cost of approximately 50 percent of the cost 

of currently available FGD systems. This will be 

accomplished by combining wet limestone AFGD technology, 

highly efficient plant operation and maintenance 

capabilities, and potential gypsum sales. 

2.1.2.2 Project Justification 

The AFGD system 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. The AFGD system is expected to remove E-7 

greater than 90 percent of the SO2 from the inlet flue gas. 

As part of the 20-year processing agreement with Northern 

Indiana, Pure Air will guarantee a 90 percent SO2 removal 

2-7 
TABLE 2.1-1: INNOVATIVE FEATURES OF AFGD SYSTEM VERSUS 

CONVENTIONAL FGD TECHNOLOGY 

Advanced Flue Gas 

Desulfurisation 

Innovative Feature 

528 MW absorber module 

20 ft/sec co-current high 

velocity absorber 

Single loop absorber vessel 

to absorb SO 

limestone, 4' 

react with 

a d oxidise 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 

SO2 removal 

Direct injection of 

pulverised limestone from 

offsite supplier 

No spare module 

On-line chemical 

process monitors 

Operation and ownership 

by a chemical company, 

separate from power 

plant operation 

Conventional Flue Gas 

Desulfurization 

Technoloav 

125 MW modules in U.S. 

10 to 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 a wastewater stream 

Produces solid and/or liquid 

waste streams 

Typically 90 percent SO 

removal 2 

On-site limestone pulverisation 

or grinding 

At least one spare module 

No on-line monitors 

Utility owns and operates, 

often with little chemical 

expertise 

2-8 
efficiency for coals with a sulfur 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 a higher 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 FGD system 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 a co-current 

rather than a counter-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 a counter-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 a flue 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 much more practical to retrofit this 

absorber in a restricted space. The co-current tower design 

2-9 
E-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 same direction 

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 10 MW co-current pilot plant FGD scrubber 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 a successful test. On a 

commercial scale, Hoosier Energy in Indiana has installed and 

successfully operated eight 125 MW co-current absorber vessel 

FGD systems at their Merom Station since 1982. The design 

velocity for these vessels was 12 feet per second. 

Worldwide, Mitsubishi Heavy Industries (MHI) has installed 

over 12,000 MW of co-current absorber vessels. The high 

velocity design however, is a recent 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 a 61 

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 ppm dry) react with limestone, and 

oxidise to gypsum. This process differs from others that 

produce a commercial gypsum. In both the United States and 

worldwide, other processes employ a dual-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 SO2 removal 

guarantees and producing a commercial gypsum product. 

Worldwide, the standard process for producing commercial 

2-10 
gypsum requires separate reaction and oxidation unit 

operations. The oxidation step is typically carried out in a 

separate vessel with a lower pH to 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 a capacity of 3.5 x lo6 

cubic feet per hour. MHI supplied the FGD system which 

operates with an inlet SO2 concentration 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 a coal-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 a range 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, SO2 removal 

is also guaranteed at 90 percent by Pure Air. 

D. Air Rotary Sparser 

The proposed project incorporates a unique air 

rotary sparger (ARS) system that combines the function of 

agitation and oxidation. The ARS is a specially 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. One advantage of this design is 

the decrease in air requirements for oxidation to 

approximately 40 to 50 percent of that required by 

conventional air sparging systems. Another advantage is the 

2-11 
E-10 

reduction of equipment required by combining both the 

agitator and air sparging equipment into one design. 

Conventional systems typically require a complex network of 

piping throughout the reaction tank to assure complete 

oxidaton of the absorbed SO2 to gypsum. This unique rotary 

sparging system has been tested by MHI at their Hiroshima 

Technical Institute in Japan at a 50 MW scale test unit. The 

ARS is also being tested at the Hoosier Energy, Merom 

Station. 

E. Wastewater Evaporation System 

The proposed project will demonstrate a process 

step to pump part 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 AFGD design 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 

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

this point, they do not enter the downstream SO2 removal 

equipment and do not affect SO2 removal 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 made possible through the 

development of a proprietary dual-fluid nozzle by MHI. This 

nozzle produces a very 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 

a commercial grade gypsum FGD system supplied by MHI on a 125 

MW oil-fired boiler. The SO2 content of the flue gas is 

approximately 500 ppm with 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 MW level. This wastewater 

evaporation system has never been demonstrated at these 

levels, in the United States or on a coal-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 SO2 removal equipment. The 

sulfur balance using the design coal for the AFGD (4.51 

weight percent sulfur) and 90 percent SO2 removal 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. 

2-13 
E-15 F. Potential for No Solid or Liquid Waste 

E-16 

The proposed AFGD system will demonstrate the 

potential for producing no solid or liquid waste from any 

portion of the process. Most operating FGD processes in the 

United States produce a solid-waste stream consisting of 

scrubber sludge and a mixture of fly ash and limestone which 

is landfilled as a U.S. Environmental Protection Agency, 

E-15 Resource Conservation and Recovery Act exempt or 

non-hazardous waste. The few regenerable FGD processes 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 FGD systems 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 SO2 Removal 

The proposed AFGD system will be designed to 

operate at an SO2 removal efficiency of 90 percent with an 

E-8 inlet flue gas concentration of SO2 of 3,055 ppm dry. In the 

E-13 United States, a 90 percent SO2 removal level is the accepted 

E-15 technology and corresponds to the current limits of the New 

Source Peformance Standards. Although some FGD systems have 

been nominally designed for an SO2 removal 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 SO2 removal 

levels in this range on a low sulfur coal, but again not on a 

2-14 
consistent basis. High SO2 removal designs have recently 

been installed in Germany and are currently coming into 

operation. These designs generally have 95 percent or 

greater SO2 removal, but are typically on a low sulfur coal 

(l-percent level). In Japan, some systems have achieved a 90 

to 95 percent SO2 level, but again on lower sulfur coals. 

Thus, high SO2 removal has never been demonstrated 

consistently in a cost-effective manner either in the United 

States, or on a high sulfur coal. AFGD performance 

guarantees have been described earlier in this section. E-17 

H. Direct Injection of Pulverized Limestone 

The proposed AFGD system 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 a blower for pneumatic conveying 

to the process. 

The conventional United States practice is on-site 

wet ball mill grinding in a closed 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 a 20 to 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 new grass roots plant. On a shorter plant 

life, it makes economic sense to avoid the expensive capital 

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

limestone directly from a supplier. The reduced equipment 

requirement also enhances the ability to retrofit other 

existing plants. 

On a worldwide 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 FGD units. These 

are 370 MW plants using West German brown coal. The earliest 

one started operation in November 1985. The FGD systems were 

designed by MHI to produce a commercial grade gypsum with an 

inlet SO2 concentration of 1,050 ppm dry and an SO2 removal 

efficiency of 95 percent. This innovative feature has never 

been demonstrated in the United States at the 500 to 600 MW 

E-18 level or on a high sulfur coal. Additionally, the proposed 

AFGD system will have an inlet SO2 concentration of 3055 ppm 

dry. 

I. No Spare 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 AFGD system 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 FGD system to the utility. This design 

practice, to include a spare module, is essentially directed 

by the current New Source Performance Standards in effect 

since 1978. Air emissions from the AFGD system and the 

Bailly Station are discussed in Section 4, Consequences 

(Impacts) of the Project and Section 5, Regulatory 

Compliance. 

On a worldwide basis, the common practice is to 

design the FGD system with no spare module. However, United 

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

feature until successfully demonstrated in this country. 

Therefore, Pure Air believes that the demonstration of an 

AFGD system that includes no spare module is an essential 

part of the proposed process. The cost advantages of the 

elimination of a spare module are significant. 

J. Continuous Chemical Process Control Monitors 

The key to the operability and availability of the 

overall AFGD chemical 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 a continuous basis since no continuous 

monitoring devices have been available. Chloride 

concentration is sometimes monitored on a grab sample basis 

for systems that produce a saleable gypsum product. MHI has 

developed a continuous monitoring capability that has been in 

service to a limited degree on recent FGD systems 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 FGD facility. 

K. Own and Operate AFGD System by Chemical Company 

The proposed project is structured so that the AFGD 

system will be designed, constructed, owned, operated, and 

maintained by a company 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 AFGD system operation will be 

totally separated from that of the power plant. 

2-17 
The conventional practice worldwide is for the 

utility to own and operate the FGD system. Since the utility 

is ultimately responsible for all emissions from its power 

plant, it has remained accepted practice for the utility to 

own and operate the FGD system. The advantage of a separate 

operator for the AFGD system is that Air Products and 

Chemicals, Inc. has the technical expertise to operate the 

AFGD system, 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 

FGD system by a separate 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 a savings of approximately 50 percent in capital 

and 50 percent in operating costs over a conventional forced 

oxidation FGD system applied as a retrofit to an existing 

plant. Tables 2.1-2 and 2.1-3 summarize the capital and 

operating cost savings of the proposed AFGD system. 

2.1.3 Engineering Description of the Proposed Action 

2.1.3.1 Description of Project Phases 

The AFGD project will take 81 months 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. 

2-18 
TABLE 2.1-2: CAPITAL COST SAVINGS FEATURES OF THE 

AFGD SYSTEM(l) 

AFGD Feature Cost Savinqs 

1. 528 MW Absorber Nodule A single 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 10 feet per 

second for conventional 

spray towers results in an 

absorber area which is 50 

percent of conventional and 

a flat 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 lim Z' stone, 

oxidation to gypsum) in a 

single vessel represents a 

significant savings over 

commercially available 

systems. Other 

conventional designs 

include a two-loop process 

or a separate 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 20 years of 

life or less would benefit 

from this cost saving 

feature. 

2-19 
TABLE 2.1-2: (Continued) 

AFGD Feature 

6. No Spare Module 

Note to Table 2.1-2: 

Cost Savings 

The ability to maintain 

high availability with only 

a single module is also an 

essential part of the cost 

saving features of the 

proposed technology. 

Elimination of a spare 

absorber module represents 

a significant cost saving. 

(1) Capital cost savings for items 3 through 6 are estimated 

to be at least 10 percent over conventional FGD systems. 

Z-20 
TABLE 2.1-3: OPERATING COST SAVINGS FEATURES OF THE 

AFGD SYSTEM(l) 

AFGD Feature 

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 AFGD system. 

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 

a higher 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 10 percent over conventional FGD systems. 

2-21 
- _ ‘. . 

I I I I I I 

. . 

. . 

. . 

. . 
Phase 1: Design and Permittinq 

This initial phase will culminate in the detailed 

design of the AFGD system for the Bailly Station. A program 

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 1 and will last 27 months. Following DOE approval, the 

AFGD equipment 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 a piled foundation. 

Phase 3: Operation, Data Collection, Reportinq and 

Disposition 

Phase 3 will begin'at the completion of Phase 2 and 

will last 36 months. Following DOE approval, the AFGD unit 

will be tested for three years over a range of conditions. 

All data and test results will be compiled into a final 

report that will be made available to DOE. 

2.1.3.2 Description of Process 

The AFGD system will be a blend of new innovative 

process technologies and existing process technologies 

(updated, improved upon and/or scaled upwards from what is 

seen at existing plants). The AFGD system 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 a single scrubbing 

process. 

2-23 
The final design of the AFGD system 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 AFGD design 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 AFGD system. The 

design parameters were established to show the ability of the 

AFGD process to clean flue gas to stringent emission 

standards. Northern Indiana's current coal purchasing 

practices and anticipated future purchasing plans indicate 

that a coal 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 

2-24 
Since the AFGD system design accommodates a coal E-17 

with a greater sulfur content than the range indicated above, 

and a guaranteed 90 percent removal efficiency, the 

likelihood of a successful demonstration with respect to this 

aspect of the project is maximized. 

The location of the overall AFGD system 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 

The AFGD system is divided into four sections: E-52 

Flue Gas Ducting and Fans Section E-60 

A. 

B. Limestone Feed and Handling Section 

C. SO2 Removal Unit Section, and 

D. Gypsum By-Product Handling Section. 

These sections are described below. 

A. Flue Gas Ducting and Fans Section 

The flue gas ducting and fans section directs flue 

gas from the existing Bailly Generating Station electrostatic 

precipitators (ESP) to the AFGD system SO2 removal section. 

Also, this section receives wastewater from the wastewater 

evaporation system (WES) upstream of the ESP. 

B. Limestone Feed and Handlinq Section 

The AFGD system will receive purchased pulverized 

limestone from a limestone supplier. The limestone will be 

2-25 
LAKE MICHIGAN 

N 

I, 

IT 0 cl 0 Figure 2.1-4 E-5 
EL. 40’ NORTH-SOUTH SASE LINE 

ADMIN. 

PRECIPITAmR 

DING 

-3 G&OECIPITArnR 0 

\ ,I I 

\\ 

\\ 

\\ i\ 

\\\ 

: 

I\ 

\\\ 

rr 4,: 

\ I\\ 

Note: New construction is indicated 

by shaded areas on figure. 

N- 

& Pure Air JL 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURIZATION 

Proposed AFGD System 

Plot Plen 

Flgure 2.1-5 E-23 
SO2 REMOVAL UNIT SECTION 

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-60 
ceco3 58.458 Lb/HI 

Permit Emieaion Level: 

6.0 Lb SOzlMMBtu 

(Existing) 

SO, REMOVAL UNIT SECTION 

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 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURIZATION 

Sulfur, Gypsum and 

Limestone Balance: 

AFGD Design Condition 

Figure 2.1-7 E-22, 52 
1 RE;;;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. 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURlZATlON 

Chloride Balance: 

AFGD Design Condition 

Figure 2.1-8 E-22, 52 
SO2 REMOVAL UNIT SECTION 

j RE”s;E”T;oEED 1 

~~0: 34.301 Lb/M 

/ PI l=“Fti 

- 1 I I F!?~ I I\ 

/ \ 

J I---@ 

, Gypsum to landfill or 

wallboard msnutacturt 

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

i m 

TOTAL MAKE-UP 1 THROUGH 5: 361,404 Lb/Hr 
pulverized to 95 percent 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 a pneumatic 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 SO2 removed) to 

achieve 90 percent or higher SO2 removal, and results in 10 E-25 

percent or less of the station's SO2 being emitted to the 

atmosphere, and by-product gypsum purity. 

Hydrated lime will be received by truck, 

pneumatically conveyed to a small silo and added directly to 

the wastewater tank by gravity. The hydrated lime is added 

to the wastewater stream to raise the pH of the wastewater. 

C. SO2 Removal Unit Section 

The flue gas from the flue gas ducting and fans 

section will enter the SO2 removal 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 a gas 

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 SO2 removal 

efficiency. The absorbed SO2 will be partially oxidised by 

the oxygen in the flue gas as it passes through the 

2-32 
E-55 

absorption grids. Complete oxidation will be accomplished in 

a reaction tank by using a newly 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 SO2 from 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 be absorbed into H20, then dissociates 

from H2S03 to H +2 and HSO:. A portion of the HSOZ will be 

oxidized by oxygen in the flue gas and converted to H2S04. 

Calcium carbonate in the slurry will neutralize a portion 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 CaC03 to form CaS04*2H20. 

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

20 percent to 25 percent (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. A two-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 a horizontal run between 

the absorber tank and the eliminator. Collected entrainment 

will be returned to the absorber tank. A washing 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. Gypsum By-Product Handling Section 

In the gypsum by-product handling section two 

absorber bleed pumps will batch transfer the gypsum slurry 

from the SO2 removal unit section into basket centrifuges 

which will reduce it to a dewatered cake containing 8 to 10 

percent moisture by weight. A portion 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 a wallboard 

manufacturer or hauled offsite for landfilling. 

During the 3-year demonstration phase, a portion of 

the filtrate water from the centrifuge operation will be sent 

to the WES for disposal. In the WES, wastewater from the 

2-34 
E-26 

absorber system will be fed to a pH adjustment tank. In the 

tank, wastewater will be neutralized by hydrated lime. 

Impurities in the wastewater such as a chloride 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 pump and pumped to the wastewater evaporators located 

upstream of each ESP in the flue gas ducting and fans 

section. 

Wastewater will then be atomized by a pressure 

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 WES is 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 AFGD system. 

2-35 
A. Feedstocks 

The only reagent feedstocks to the process are 

limestone and hydrated lime; no organics are used. Limestone 

(CaC03) is a naturally 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 AFGD process 

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 

2-36 
E-28 

Ethe specification gypsum amounts and still meet wallboard 

specifications. In some instances this lower-quality gypsum 

can be sold to cement manufacturers. In a worst-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 95 percent of the wallboard produced in 

North America have been introduced to this project. These 

producers have expressed interest in purchasing by-product 

gypsum. The AFGD system 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 a medium-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 a waste 

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 AFGD system to storage 

is fully covered to eliminate fugitive emissions. 

2-37 
Ii 

In the event the main conveyor has mechanical E-31 

problems, an emergency stackout conveyor and building will be 

installed near the AFGD system 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 AFGD system will be directed E-29 

to process drains. These drains will connect to a central 

collection sump where 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 SO2 by the AFGD system. 

2.1.3.4 Project Source Terms 

This section characterizes the source terms of the 

AFGD technology 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: 

2-38 
a. Utilities 

b. Land 

C. Labor 

d. Materials 

e. Transportation 

a. Utilities 

The utilities listed below will be required for 

operation of the proposed AFGD system at the Bailly Station. 

Northern Indiana will provide these utilities to the boundary 

limits of the AFGD facility 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 

Pump Seal Water 175 

Potable Water 70 

Quench Water 5,800 

Continuous 

Continuous 

Intermittent 

Continuous 

Intermittent 

Intermittent 

In addition, approximately 7.6 MW of continuous power will be 

supplied~to the AFGD facility. 

During the construction phase of the AFGD system, 

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 - 70 GPM 

2-39 
As 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 

AFGD facility's day-to-day operation. 

Based on preliminary design estimates of water 

requirements stated above, it is envisaged that process 

water, pump seal 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 AFGD equipment 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. No treatment 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 

AFGD facility. 

The 480-volt construction power will be supplied to 

support construction of the facility and will originate from 

a spare 480-volt breaker located inside the Bailly Station. 

Direct buried cable will be supplied from the breaker to the 

AFGD boundary limits. Subsequent to construction this cable 

2-40 
E-56 

will be abandoned in place. To support the power 

requirements for operation of the AFGD facility, an 

independent feed will emanate from the Bailly Station's 34 kV 

yard. 

Two new transformers 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 AFGD system electric yard. 

Considering that both construction and operating 

power needs emanate from a power generation station, the 

availability and reliability are not compromised for 

continuous service to the AFGD facility. 

b. Land 

The AFGD process is designed to require a minimum 

amount of space, and is thereby applicable for difficult 

retrofit situations. Equipment for the AFGD process requires 

about 75,000 square feet (1.72 acres) of land area; whereas 

all facilities associated with the AFGD system 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. Gypsum dewatering 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 

2-41 
Storaqe 

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 a more restricted access area. 

The limestone feed system and the gypsum dewatering 

system are also located close to the absorber to minimize 

piping lengths. A small 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 AFGD process 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 

2-42 
The 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 SO2 in the flue gas. The limestone is 

added based on a stoichiometric ratio of 1.05 moles CaC03/1.0 

moles SO2 removed, and a limestone composition of 96.5 

percent CaC03 and 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 WES or an 

on-site wastewater pond. The hydrated lime is added to 

neutralize the water stream prior to feeding to the WES. 

Only stable CaC12 will be formed when the pH is adjusted to a 

value of 8.0. The hydrated lime will neutralize the acidic 

components in the wastewater to achieve a neutral or basic 

wastewater pH. 

e. Transportation 

The AFGD process 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 

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

the method of transportation are as follows: 

1. 

2. 

1. 

Raw Materials 

Limestone 

Hydrated Lime 

Quantity 

(Tons/Day) 

760 

0.34 

Method/Frequency 

of Transportation 

38 trucks every day* 

One truck every one 

to two months 

By-Product 

Gypsum 1,358 Continuous conveyor 

belt to nearby gypsum 

transfer building 

* Based on 20 Tons/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 35 to 40 trucks 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 

A number of EHSS aspects could potentially be 

impacted by the AFGD system 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 

2-44 
and other EHSS aspects of the AFGD project. Section 4, 

Consequences (Impacts) of the Project, evaluates the 

potential impacts of the AFGD project on these receptors. 

2-45 
2.2 ALTERNATIVES TO THE PROPOSED ACTION 

This subsection discusses three alternatives to the 

proposed AFGD project: 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 DOE would not 

provide funds to facilitate the demonstration of the unique 

features of the AFGD system. 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 an AFGD system at 

the Northern Indiana Bailly Generating Station to provide a 

demonstration of the effectiveness of a number 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 AFGD systems with reduced solid waste and 

wastewater disposal problems. 

Although the FGD industry has been in existence for 

approximately 20 years, there are no commercially competitive 

2-46 
processes that produce a consistently 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 AFGD system 

unless a unique market situation exists for sales of the 

B2SO4' elemental sulfur or concentrated SO 2 products. 

Since the proposed AFGD system has the potential to 

produce no solid waste, it is environmentally superior to 

other competitive technologies that produce a waste product. 

Nearly all FGD systems in operation in the United States at 

present produce a solid waste. Other competitive 

technologies such as fluidized bed combustion, sorbent 

injection, and spray dryer FGD systems also produce a solid 

waste. On a worldwide basis, only the gypsum-producing FGD 

systems have consistently proven to be capable of reducing 

SO2 emissions while generating no solid wastes. 

Many FGD systems are permitted for wastewater 

discharges. Gypsum-producing FGD systems inherently have a 

wastewater discharge to control the chloride content of the 

gypsum by-product. The proposed AFGD system will demonstrate 

a wastewater evaporating system whereby a part 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 a commercial 

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 SO2 in the flue gas, 

or alternatively 1.05 moles of calcium carbonate per mole of 

SO2 removed for a 95 percent SO2 removal efficiency. For 

2-47 
1, 

comparative purposes, circulating fluidized bed boilers 

typically operate with a calcium/sulfur ratio of 2 for 

approximately 80 percent removal and a calcium/sulfur ratio 

of 3 to 4 for a 90 percent removal. Sorbent injection 

systems, including furnace sorbent injection, economizer 

sorbent injection, and duct sorbent injection typically 

operate with a calcium/sulfur ratio of 2 for a 40 to 60 

percent removal level. Spray dryer FGD systems, which are 

commercially available, typically operate at a calciumfsulfur 

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 FGD systems require 30 to 40 percent more 

limestone for an equivalent SO2 removal. From the standpoint 

of the consumption of a non-renewable resource (limestone), 

the AFGD system 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 AFGD facility to meet envisaged 

emission requirements, when acid rain legislation passes, and 

2) to demonstrate uniqueness in the AFGD system 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 a site for the AFGD demonstration. 

However, none of these was chosen because of the current 

operation of the Northern Indiana generating system. 

2-48 
3.0 EXISTING ENVIRONMENT 

3.1 ATMOSPHERIC RESOURCES 

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 May and 

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 

Thorn technique, the cycle for a tornado striking a point in 

this sector is 635 years. 

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-l 
S 

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 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURlZATlON 

Windrose ‘84 - ‘86 

Dune Acres Data 

Figure 3.1-1 
the 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 Dune Acres substation 

located one mile southeast of the Bailly Station. 

3.1.2 Air Quality 

Air quality is a source of concern in the 

highly-industralised area adjacent to the Bailly Station. 

Recently, IDEM conducted a study to develop a control 

strategy to attain the National Ambient Air Quality Standards 

(NAAQS) for S02. The result of this study indicated that the E-33 

NAAQS for SO2 are 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 AFGD system. 

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 SO2 to 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 SO2 per year. The proximity of other industry also 

contributes to the concentrations of SO2 in 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 now been incorporated into the Porter County SO2 

Monitoring Network. Northern Indiana now operates three SO2 

monitoring sites within the Porter County SO2 monitoring 

network. Meteorological data are collected at two of the 

3-3 
E-34 

three SO2 monitoring sites. The Northern Indiana SO2 

monitoring sites include: 

1) Main Office Site SO2 data collection 

2) Lagoon Site SO2 and meteorological data 

collection 

3) Dune Acres Site SO2 and 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 SO2 and 

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 an opacity limit not to exceed 40 

percent. 

3-4 
3.2 LAND RESOURCES 

3.2.1 Geology 

The Bailly Station is located in a stable 

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 10 and 30 feet. 

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 a consequence of postglacial lake activity. 

The major component of the glacial deposits is a glacial 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 a terminal 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. 

3-5 
Syrt*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, moduatdy demo 

Aquitw ‘ggg$ Qlmlo-l~cu9bifN. @lllY OhY 

(“7, Glwa-lrclutrtM depdt dlt and litty clay h 

Dolomlt.~; 5andmton.r. Shales 

Source: Northern Indiana Public Service Company, 

‘Final Environmental Statement Related to 

Construction of Bailly Qenerating Station 

Nuclear- 1 ,‘February 1973 

& Pure Air A 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURIZATION 

Site Stratigraphy of 

Porter County, Indiana 

Figure 3.2-l 
izl BEACH AND ASSOCIATED DUNE DEPOSITS 

m LAKE CLAYS AND MUCK 

@J . ..y OUTWASH SANDS AND GRAVELS 

liiiiiil TILL 

LAKE MlCHlCAN BEVERLY SHORES 

Source: Texas Instruments Jnc., ‘1 Q74- 1875 

Annual Report -SaiUy Nuclear I Site ” 

Surficial Geology in Vicinity 

of Bailly Generating Statior 

1 Fisure 3.2-2 
I a, 

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 50 miles of the site. The largest 

occurred in 1938 near the south shore of Lake Michigan and 

had a Modified 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, Maumee loamy 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 a thick 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. 

3-8 
TABLE 3.2-l: MODIFIED MERCALLI SCALE 

I. Not felt except by a few under especially favorable 

circumstances. 

II. Felt only by a few 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 may rock slightly. 

Vibration like passing of truck. Duration estimated. 

IV. During the day felt indoors by many, outdoors by 

few. At night some awakened. Dishes, windows, doors 

distubed, walls make creaking sound. Sensation like heavy 

truck striking building. Automobiles rocked noticeably. 

V. Felt by nearly everyone, many awakened. Some 

dishes, windows, etc., broken; a few instances of cracked 

plaster; unstable objects overturned. Disturbance of trees, 

poles, and other tall objects sometimes noticed. Pendulum 

clocks may stop. 

VI. Felt by all; many frightened and run outdoors. 

Some heavy furniture moved; a few instances of fallen plaster 

or damaged chimneys. Damage slight. 

VII. Everybody runs outdoors. Damage negligible in 

buildings of good-design and construction; slight to moderate 

in well-built ordinary structures; considerable in poorly 

built or badly designed structures; some chimneys broken. 

Noticed by persons driving automobiles. 

3-9 
VIII. Damage slight 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 mud ejected in small amounts. Changes 

in well water. Disturbs persons driving autos. 

IX. Damage considerable 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. Damage total. Waves seen 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 I Site & Pure Air I. 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURIZATION 

I Soil Composition - Bailly 

Generating Station Area 

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

composed of Maumee loamy fine sand. Maumee soils 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 a few 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, Hammond and 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 60 percent of the land in 

Porter County is used for agricultural purposes. The closest 

houses to the Bailly Station are those within the town of 

Dune Acres, 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 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURIZATION 

Land - Use Map 

Figure 3.2-4 
3.3 WATER RESOURCES 

3.3.1 Ground Water 

Ground water at the station area occurs at depths 

from 44 to 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 a depth 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 a total of three 

wells at a distance of two miles. The nearest municipal 

water system is that of Dune Acres. In Dune Acres, three 

wells have been drilled to a depth of about 30 feet, 

approximately 300 feet from the shoreline of Lake Michigan. 

Dune Acres 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 a portion 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 

3-14 
N 

LAKE f#2lGAN 

Site 

k Pure Air .t 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURIZATION 

Wetlands Map of the Bailly 

Generating Station Vicinity 

Fiaure 3.3-l E-36 
TABLE 3.3-l: FRESBWATER WETLAND CLASSIFICATION INDICATED IN 

FIGURE 3.3-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 

3-16 
TABLE 3.3-l: (Continued) 

Class: Forested (FO) 

Subclass: 1. Broad Leaf Deciduous 

5 

Needle Leaf Deciduous 

Broad Leaf Evergreen 

4. Needle Lead Evergreen 

5. Dead 

Class: Open Water 

Subclass: Unknown Bottom 

MODIFYING TERMS (in order to describe more adequately wetland 

and aquatic habitats, water regime, water chemistry, soil or 

special modifiers may be 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 

pH Modifiers 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 

3-17 
TABLE 3.3-2: WETLANDS AND DEEPWATER HABITATS CLASSIFICATION 

INDICATED IN FIGURE 3.3-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 

3-18 
TABLE 3.3-2: (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: Open Water 

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 

3-19 
TABLE 3.3-2: (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 : Rocky S;e”;-o~;W Subclass: 1. 

2. Rubble 

Class: Unconsolidated Shore (US) 

Subclass: 1. 

2. 

Cobble/Gravel 

Sand 

2 

Mud 

Organic 

5. Vegetated 

Class: Open Water 

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 

3-20 
E-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. Some marshy areas to the east and south of the Bailly 

Station empty into Lake Michigan via Dunes Creek in Indiana 

Dunes State Park. However, much of the National Lakeshore is 

within a subwatershed 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 Sag Canal. 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 a highly polluted canal about 200 

feet wide and eight miles long which empties into Lake 

Michigan. The lower end of Burns Ditch is used as a docking 

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 summer and 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 

3-21 
represents 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 a depth of 30 feet. It is a subarea 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 a five-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 maximum density (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 may also 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. 

Maximum current velocities in the upper layer measured at the 

3-22 
LEGEND: 

BA1Ll.Y GENERATINQ STATION 

DIRECTION OF CURRENT 

SUMMER CIRCULATION 

S-SW WINDS 

$ BAlleLY .::::,I3 STATION 

DIRECTION OF CURRENT 

w\NTER CIRCJJCATIO~~ 

W-NW WINDS 

Source: Northern Indiana Public Service Company. ‘Bailly 

Generating Station Nuoiear 1, Final Environmental 

Statement Related to Construction, ’ 1373 

SUMMER CIRCuLATIOh 

N .NE WINDS 

WINTER CIRCULATION 

S-SW WINDS 

I 

& Pure Air 2. 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURIZATION 

Seasonal Currents 

of Lake Michigan 

Figure 3.3-2 
station were 40 cm/s. Seiches occur occasionally at the 

southern end of the lake. 

E-37 

An examination of the Federal Emergency Management E-58 

Agency Flood Insurance Rate Maps and Flood Insurance Studies 

for Porter County, Town of Dune Acres and Town of Burns 

Harbor, indicates that the Bailly Generating Station and 

associated AFGD system 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 map for Dune Acres, Indiana; thus, the AFGD system 

will be constructed 36 feet above the loo-year flood 

elevation. 

"The frequency-elevation data for Lake Michigan was E-58 

(sic) developed in a Great Lakes Flood Level Study prepared 

by the Detroit District Corps of Engineers. The study uses 

the many gages on the Great Lakes which have record lengths 

of 11 to 75 years. 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.) 

3-24 
E-58 TABLE 3.3-3: SUMMARY OF FLOOD ELEVATIONS FOR LAKE MICHIGAN 

NEAR UNINCORPORATED AREAS OF PORTER COUNTY TO 

INCLUDE THE BAILLY GENERATING STATION 

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. 

3-25 
i il, 

3.4 ECOLOGICAL RESOURCES 

The area occupied by and surrounding the Bailly 

Station has a diverse community of terrestrial and aquatic 

life. The dune region along Lake Michigan in Porter County 

is estimated to contain at least 40 to 50 percent 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 own distinguishing characteristics. The 

terrestrial environments provide a beach succession series - 

dunes, swales, bogs and oak forests. Freshwater habitats 

include drainage streams, ponds, bogs, springs and Lake 

Michigan. Appendix A contains 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 and endangered 

species in the Lakeshore. None of the plants, amphibians, E-38 

reptiles, birds .or mammals listed in Appendix A reside on the 

site of the proposed AFGD system or on the Bailly Station. 

The current habitats or migratory patterns of wildlife will E-39 

not be disturbed in any way by the proposed construction of 

the AFGD system. 

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 a number of drainage 

ditches. Burns Ditch is of major importance because it may 

be a source 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 a graphic analysis of the 

vegetation within a S-mile radius of the station. The 

mid-beach supports a few 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 a clump type serving 

to stabilise the sands. These plants and other grasses are 

typical of a beach succession ecosystem. In some areas 

successful changes may be inhibited or halted along Lake 

Michigan by the constant shifting of sands, a feature of the 

normal development of such an ecosystem. 

The dune line (foredune) has both active and 

temporarily stabilized dunes. Many of 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 A 5-MILE RADIUS OF THE BAILLY STATION SITE 

LECiEND 

1 Beachwsa~ 11 Highway FtidS-ot-~~ 

2 Baach 12 Ima c+nmucld 

3 Black Oak 13 ReeltiM 

4 Wooded swamp 14 Qm was 

SMwah 15 Duln 

6 Red Ma~IelLowlmd Hafdwcad~ 16 FYI 

7 canlfrr 17 Bwmlm while oak 

6 Tramml~lm CarIda 16 CQm Fldd 

9 Orchvd 18 CdtIvatad Ftotd 

10 Military Raemwtim 20 MlXbd VvJntti 

Prepared fmn colw Inbared pkebyaphy obtah-led m 

.kma 12. 1874. Fletd backed nd rwlwd &tl, 1676. 

Source: Texas Inetrumenta, Inc.. ‘1974-1975 

Annual Report-Bailly Nuclear I We’ 

& Pure Air .k 

a joint venture company 

ADVANCED FLUE 

QAS DESULFURIZATION 

Vegetation Analysis 

Figure 3.4-l 
pine, 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. On active 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. Oak seedlings, wild cherry, sassafras, 

and witch hazel comprise the understory. The oak forest is 

classified as both immature and mature. The vegetational 

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 a native stand of 

predominantly red maple and white oak. Sassafras trees and 

large black oaks are occasionally found in this forest 

habitat with some 12 additional 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 common in the sand dunes 

of the National Lakeshore. Old field vegetational types are 

3-29 
characteristically 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 a classic picture of a bog 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 a variety 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. A bald eagle, a rare 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 a resident of, or nests in the Lakeshore area 

(Appendix A). The eagle is a migratory bird, and makes its 

3-30 
TABLE 3.4-l: ABUNDANT BIRD SPECIES KNOWN TO NEST IN THE INDIANA 

DUNES AREA 

Common Name 

Pied-billed Grebe 

Great Blue Heron 

Green Heron 

Canada Goose 

Mallard 

Blue-winged Teal 

Turkey Vulture 

Red-tailed Hawk 

Common Bobwhite 

Sora 

Common Gallinule 

American Coot 

Killdeer 

American Woodcock 

Spotted Sandpiper 

Black Tern 

Rock Dove 

Mourning Dove 

Yellow-billed Cuckoo 

Chimney Swift 

Belted Kingfisher 

Common Flicker 

Red-headed Woodpecker 

Downy Woodpecker 

Eastern Kingbird 

Great Crested Flycatcher 

Acadian Flycatcher 

Willow Flycatcher 

Eastern Wood Peewee 

Horned Lark 

Tree Swallow 

Bank Swallow 

Barn Swallow 

Purple Martin 

Blue Jay 

Common Crow 

Tufted Titmouse 

House Wren 

Marsh Wren 

Gray Catbird 

Brown Trasher 

American Robin 

Wood Thrush 

Veer-y 

Cedar Waxwing 

Starling 

Yellow-throated Vireo 

Red-eyed Vireo 

Warbling Vireo 

Blue-winged Warbler 

Yellow Warbler 

Cerulean Warbler 

Ovenbird 

Common Yellowthroat 

American Redstart 

House Sparrow 

Bobolink 

Eastern Meadowlark 

Red-winged Blackbird 

Northern Oriole 

Common Grackle 

Brown-headed Cowbird 

Scarlet Tanager 

Cardinal 

Rose-breasted Grosbeak 

Indigo Bunting 

American Goldfinch 

Rufous-sided Towhee 

Chipping Sparrow 

Field Sparrow 

Swamp Sparrow 

Song Sparrow 

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

Indiana Dunes National Lakeshore, National: 

Lakeshore Research Program Report No. 81101, 1981. 

3-31 
habitat 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 a protected resting and 

feeding area, especially valuable when the lake is turbulent. 

E-38 No threatened or endangered amphibian, reptile, 

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

within the confines of the Bailly Generating Station. Due to 

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 a number 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 

3-32 
vicinity. 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 game fish as yellow 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 game species 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. Some species are highly pollution 

tolerant. Most of the other species of benthic organisms are 

of a type 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 

3-33 
TABLE 3.4-2: FISH SPECIES VERIFIED IN THE AQUATIC COMMUNITY 

OF THE BAILLY GENERATING STATION AND ITS 

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 

Common Name 

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. 

3-34 
i H, 

riprap, a favorite 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, 35 percent copepods, and 19 percent 

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 

3-35 
TABLE 3.4-3: BENTHOS COMMON TO NON-LAEE MICHIGAN AQUATIC 

COMMUNITIES OF THE BAILLY GENERATING STATION 

AND ITS 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 

Common Name 

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 

Pygmy Backswimmers 

Alder Flies 

Toad Bugs 

SOW Bugs 

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. 

3-36 
the 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 a combination of the two factors. 

A large portion of the zooplankton found in the 

thermal plume had large infestations of fungus on their 

bodies. This was especially apparent in Eurytemora affinis 

and Daphnia retrocurva, the two most abundant organisms in 

the thermal plume. These same species 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. A relationship 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 some localized 

inhibition of the phytoplankton population. 

3-37 
After 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 warm water discharge. 

Blue-green algae (Cyanophyta) are especially 

abundant in the warm water. 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 summer and 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 common forms 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 a nuisance 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 SOCIOECONOMIC RESOURCES 

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, Dune Acres, is a private 

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 a population 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 made below the county level, so no 

data are available on migrational trends. The available 

labor force in 1987 was 53,500 with a 7.6 percent 

unemployment rate countywide. Unemployment figures for 

individual communities are not available, so no estimate can 

be made of 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. 

3-39 
TABLE 3.5-l: POPULATION DATA FOR INCORPORATED(l) 

COMMUNITIES WITHIN FIVE MILES OF THE BAILLY 

GENERATING STATION 

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) No census 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 

3-40 
From the 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. A windshield survey of the Lakeshore area 

(January 1989) revealed a moderate 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 as well 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 much of 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. To the south of the 

Indiana Toll Road, the land in Porter, Lake, and LaPorte 

Counties is largely devoted to growing corn and soybeans. 

Approximately 60 percent of the land in Porter County is used 

for agricultural purposes. 

3-41 
TABLE 3.5-2: MAJOR(l) MANUFACTURING ACTIVITY WITHIN A 

5-MILE RADIUS OF THE BAILLY 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. 

3-42 
3.5.3 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 12 borders the site boundary on the 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 on the 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 a relatively high 

density of railroad mainlines and principal highways that 

feed into Chicago from the east and south. The railroad 

3-43 
TABLE 3.5-3: HOSPITALS WITHIN A 12-MILE RADIUS OF THE 

BAILLY GENERATING STATION 

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. 

TABLE 3.5-4: PUBLIC SCHOOL ENROLLMENT FOR COMMUNITIES 

WITHIN A 12-MILE RADIUS OF THE BAILLY 

GENERATING STATION 

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. 

3-44 
TABLE 3.5-5: NURSING HONES AND BED TOTALS WITHIN A 12-MILE 

RADIUS OF THE BAILLY GENERATING STATION 

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. 

3-45 
LAKE MICHIGAN 

Chesterton 

FORMER LAKE BOTTOM 

Source: Indiana Dunes National Park map ,diatributed 

by the National Park Service. 

‘U M’LE 

QRAPHIC SCALE I 

& Pure Air A 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURIZATION 

Major Roadways and 

Recreational Land Use 

Figure 3.5-1 E-3, 42 
lines 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&SB electrified railroad. 

Several principal highways pass within 10 miles of 

the station, including Interstate Highways 80, 90 and 94, 20, 

12 and 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 12 passes directly through 

land that is now part of the National Lakeshore. A study by 

the National,Park Service (NPS) is in progress to determine 

the feasibility of re-designating Highway 12 as a parkway 

according to NPS standards. 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. On the 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 

3-47 
it. 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 Dune Acres and 

Beverly Shores. Pinhook Bog is situated about 12 miles 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 a relatively 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 a unit. 

The Lakeshore was formally established in 1972 and is now 

administered by the National Park Service. 

3-48 
Fishing in Lake Michigan is a popular 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 AFGD system 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 a chain of small lakes in the 

Valparaiso area. 

Figure 3.5-l depicts some of the recreational uses 

of land within a 5-mile radius of the Bailly Generating 

Station. 

3-49 
3.6 ENERGY AND MATERIALS RESOURCES 

Northern Indiana currently operates two electric 

generating units at the Bailly Generating Station. The units 

are coal-fired and rated at 528 MW total 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. 

3-50 
3.3 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, Town of 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. 

Town of Dune Acres, 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 Town of Burns Harbor, Indiana Porter 

County. Community-Panel Numbers 180207 0001 B and 

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. 

3-51 
REFERENCES (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. One and 

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. New York, 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 En 2. ironmental Management, Office of Air 

Management, Indianapolis, IN. June 1988 

3-52 
REFERENCES (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 Use of 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 

3-53 

4.0 CONSEQUENCES (IMPACTS) OF THE PROJECT 

4.1 ATMOSPHERIC IMPACTS 

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 a hazard 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 SO2 will be reduced. When the AFGD system 

is not in operation or during an upset condition, combustion 

products will be directed through the existing stack. 

Combustion products will be within 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 may increase 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-l 
E-45 

transferred to a storage silo. Transfer to the AFGD system 

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 AFGD system are in 

the flue gas exiting the scrubber and stack. The existing 

and new emission 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 

The AFGD system will reduce the SO2 emission rate 

by 90 percent from 5.2 lbs/MMBtu to 0.52 lbs/MMBtu. This is 

a significant reduction in SO2 emissions, and results in an 

SO2 emission rate that is well below the New Source 

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. The wet limestone slurry does not react with 

the NO, so that no NOx is removed in the SO2 absorber. 

No additional particulate matter is expected to be 

emitted as a result of the AFGD system. In practice, all FGD 

systems receive some amount of particulate (nominally 0.1 

lb/MMBtu for the Bailly Station) from the electrostatic 

4-2 
I, 

precipitator. Approximately 50 percent of this particulate 

received from the ESP is removed by the AFGD system. The 

AFGD system in turn emits a minor 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 AFGD system. 

4-3 
4.2 LAND-USE IMPACTS 

4.2.1 Construction 

E-47 

Land use impacts during the 24-month construction 

period are projected to be minimal, primarily as a result of 

the industrial nature of the Bailly Station. Additionally, 

the AFGD system 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. 

No quantities of oil will be utilized during 

construction sufficient to cause a spill 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 an occurrence, response would 

be immediate in accordance with the Spill Prevention, Control 

and Countermeasure Plan that will be developed. 

The construction phase will have a minimal 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 a portion 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 

4-4 
left in its natural state to serve as a buffer 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. No historic 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, 10 miles 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 AFGD system operation 

will be taking place on a heavily industralized site. 

Currently Pure Air is facilitating negotiations E-46 

with manufacturers of wallboard to become a supplier of 

gypsum. Successful negotation of a contract would result in 

this by-product being recycled into a useful 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 AFGD system will be slightly higher than 

4-5 
E-31 

that generated by existing operations as a result 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 may have minimal impact on available landfill capacity 

and no impact on water quality. 

Operation of the AFGD system is projected to have 

no impact on existing or proposed historic resources. 

4-6 
4.3 WATER-QUALITY IMPACTS 

4.3.1 Ground Water 

4.3.1.1 Construction 

The construction of the AFGD system 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 an occurrence, response would 

be immediate in accordance with the Spill Prevention, Control 

and Countermeasure Plan that will be developed. 

4.3.1.2 Operation 

The AFGD system will be designed to minimize 

wastewater generation. However, there will be wastewater 

from the sanitary system and some process-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 a membrane liner. The most recent results of ground 

water monitoring have shown no impact on the ground water. 

4-7 
The 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 AFGD system 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 AFGD system may be put to beneficial use or 

disposed in previously mentioned appropriately-permitted 

state facilities. As discussed 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 a silo 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 AFGD system would be 

obtained directly from Lake Michigan. This usage is not 

anticipated to have any effect on the lake, nor to affect 

recreation thereon. No additional outfall or docking 

facilities (permanent or temporary) are planned during 

construction of the AFGD system. 

E-35 A review of the area wetlands (Figure 3.3-l) 

indicates that the AFGD system 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 70 x 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 

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

the Lakeshore area. 

Surface water impacts from the operation of the 

AFGD system will be negligible since the system will be 

designed to comply with existing NPDES permit 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 a contract hauler. 

As discussed above, the ash generated from the AFGD 

system will be placed in a storage 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 WES will be designed to evaporate part of the 

wastewater from the process, and result in lower water 

discharges from the process. Provisions will be made to 

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. The wastewater flow rate at 

normal AFGD system 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 

4-9 
E-26 TABLE 4.3-l: PROJECTED WASTEWATER COMPOSITION FROM THE AFGD 

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++ 

soa 

clF- (total) 

s20; 

Level 

116.8 (total flow) 

5.6 

5.15 

0.45 

7,186 

4,035 

1,293 

23,072 

1,095 

605 

4-10 
system 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. 

4-11 
TABLE 4.3-2: COMPARISON BETWEEN EXISTING AND PROPOSED WASTEWATER 

DISCHARGE TO LAKE MICHIGAN, AND PRELIMINARY WATER 

QUALITY BASED PERMIT LIMITS 

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 

AFGD System 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. 

4-12 
4.4 ECOLOGICAL IMPACTS 

4.4.1 Construction 

Construction activity related to development of the 

AFGD system 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 on wildlife will be that which occurs as a 

result of increased human activities. This impact may be 

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. An erosion 

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 human activity 

associated with operation, it is expected that species 

resident, if any, may leave the area to seek new habitat. 

None of the species known to occur in the area has a 

restricted home range. Overall, there is no detrimental 

effect projected for the species identified in the site 

environs, as a result of human activity during AFGD system 

operation. 

No state or federally listed threatened or 

endangered plant or animal species, or critical habitat for 

4-13 
such species, are present on the Bailly Station or are 

expected to be impacted by the proposed project within the 

site environs (Appendix A). 

Additionally upon completion, the new stack will be 

appropriately marked which should minimise the effects on 

flying species. 

The AFGD system will conform to the requirements of 

the NPDES permit 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. 

4-14 
4.5 SOCIOECONOMIC IMPACTS 

4.5.1 Construction 

An assessment of the relative impact of the 

construction of the AFGD system on population, employment and 

housing in Porter County indicates a benefit 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 a regular 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 a number of workers may come from within Porter 

County and adjacent counties. A permanent 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 AFGD system will not have any 

significant impact on the housing demands in the area. Only 

those employees who live too far from the site to commute, 

and those who will be permanently assigned to the site once 

the AFGD system is operational, will have a need initially 

for temporary and subsequently for permanent housing. This 

will constitute a relatively small percentage of employees 

requiring permanent residence, but will provide a positive 

benefit to the local economy. 

4-15 
4.5.1.1 Transporation 

E-43 

Primary access to the proposed construction site 

will be from Highway 12 and the nearby interstate system. 

The anticipated increase in traffic volumes averaging from 

100 to 150 vehicles per day will easily be accommodated by 

the existing transportation network thereby reducing 

potential impact as a result 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 a significant 

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 

4-16 
I I 

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 new stack. 

4.5.2 Operation 

The impact on population, employment and housing as 

a result of operation of the AFGD system 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 demand on the real estate market. 

4.5.2.1 Transportation 

The addition of from 110 to 120 vehicle-trips on a 

24-hour basis will not impact the existing vehicular network. 

Parking will be easily accommodated on-site on a permanent 

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 AFGD system operating at 

the Bailly Station, a comparable facility (528 MW), would 

produce a sound level of 58 dB(A). The vehicular traffic 

4-17 
projected 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 AFGD system will be 

perceived as visually 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 

a successful and environmentally sound operation. Operation 

of the new stack will produce a visible steam plume 

characteristic of FGD systems. 

4-18 
4.6 ENERGY AND MATERIALS IMPACTS 

4.6.1 Construction 

During the construction phase of the AFGD system 

heavy construction equipment as well 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 AFGD system. 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 AFGD system operation as follows: 

4-19 
Estimated 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 65 percent and the AFGD design coal (4.51 

weight percent sulphur) data in Section 2.1.3.2, while the 

average and emergency estimates are based on the preliminary 

process design. 

Limestone will be used as an absorbent. It is 

inexpensive and widely available: 46 of 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 AFGD system. 

4-20 
4.7 IMPACT SUMMARY AND MITIGATION MEASURES 

4.7.1 Mitigation Measures 

Because the AFGD system will be installed in a 

heavily industrialized area, no significant EHSS impacts 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 a potentially saleable by-product. More 

importantly, however, the successful operation of the system 

will substantially reduce a precursor 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. No open burning will be allowed. Cleared areas 

will be covered with hay to minimise potential wind erosion. 

The AFGD system will reduce SO2 emissions to the 

environment during normal operations, thus enhancing air 

quality. When not 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 beg accommodated 

in the system design. 

4-21 
Bulk 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 on weekends 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 AFGD aystem within a highly 

industrialised area will mitigate any significant impact of 

construction and operation of the AFGD system. 

4.7.1.3 Water-Quality Mitigation 

Prior to actual construction, a soil erosion and 

sedimentation plan will be developed. It will incorporate 

4-22 
I 

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 WES constitutes one of the major alternative 

designs for the AFGD system. Containment of some discharges 

is a significant 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 AFGD system 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 

No mitigation measures are proposed for 

socioeconomic impacts, since no significant impacts are 

projected during construction and operation of the AFGD 

system. The AFGD system is viewed as a benefit to the area's 

socioeconomic setting. 

4-23 
4.7.1.6 Energy and Materials Mitigation 

The generation of electrical power is by nature 

consumptive of natural resources. The production of a useful 

by-product, gypsum, constitutes a mitigation of this overall 

activity from the overview perspective. A large portion of 

the SO2 in the stack gas will be converted to a ,saleable 

product. Finally, the plant will be afforded the option of 

burning a widely available, economical high-sulfur coal, 

while lowering SO2 emissions from their present,levels. 

4.7.2 Monitoring 

Environmental monitoring for the AFGD project 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, a distributed control 

system, and intermittent or periodic sampling. Continuous 

monitoring equipment is expected to include monitors for 

opacity, S02, O2 and slurried chloride, sulfite and carbonate 

concentrations. Other process data (e.g., major anions and 

cations) will be collected on a distributed control system 

with a high sampling frequency such that these data can be 

considered essentially continuous. Finally, some data will 

be collected on a set sampling schedule primarily as part of 

compliance monitoring to meet regulatory agency permit 

conditions. 

4-24 
4.7.2.1 Wastewater Monitoring 

The Bailly Generating Station has a wastewater 

discharge to Lake Michigan. The wastewater initially goes to 

a series of on-site retention ponds and then is recycled by 

the station on an as-needed basis. This discharge is under 

an NPDES permit and covers the main outfall and intake 

discharges (Appendix C). 

The proposed AFGD system will demonstrate the 

potential for reducing liquid waste from any portion of the 

process. If the proposed WES is not used as currently 

planned, then wastewater from the AFGD system will be 

discharged into an on-site pond. Additional wastewater 

discharges resulting from the AFGD system may include 

sanitary wastes and stormwater runoff. These additional 

discharges will be handled by existing facilities. 

No additional wastewater monitoring will be 

required as a result of the AFGD system, since no new outfall 

points are proposed. The current wastewater outfall 

monitoring will be maintained as required by the IDEM, Office 

of Water Management (OWM). The water quality information 

required by the OWM may include chlorides, pH and 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 SO2 and 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 an opacity limit 

not to exceed 40 percent (Appendix C). 

4-25 
Northern Indiana also conducts ambient air 

monitoring as part of the Porter County SO2 Monitoring 

Network. Northern Indiana collects SO2 data from three 

monitoring sites, two of which also collect meteorological 

data. The proposed AFGD system should not introduce any 

additional air pollutants into the Bailly Station area; in 

fact, this system is designed to reduce SO2 emissions by 90 

percent or greater. 

An existing air monitoring network can be used to 

determine the impacts of the AFGD system. Source tests for 

SO2 and particulate8 will be conducted and plume opacity will 

be checked so that all air emissions are within the 

established air permit conditions. A continuous opacity 

monitor will be installed after the electrostatic 

precipitator. 

As part of the AFGD system, continuous chemical 

process control monitors are expected to be installed. These 

instruments will continuously monitor chloride, SO3 and 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 C Hazardous 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 a broker for resale or for 

4-26 
I u 

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 AFGD demonstration phase 

will be processed in a test unit to produce by-product 

gypsum. This representative material will be characterized 

by EP toxicity 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 AFGD system. This new system 

will result in additional noise at the plant and also produce 

(non-hazardous) gypsum. 

A background sound survey will be conducted prior 

to AFGD system construction. Once the system is operational, 

additional sound-level studies can be conducted to verify the 

design basis to mitigate increases in noise levels. 

4-27 
4.0 REFERENCE 

1. Boynton, Robert S. 

and Limestone. Chemistry and Technoloqy 

New York of Lime 

Sons, Inc., 1967. 

, New York: John Wiley & 

4-28 
5.0 REGULATORY COMPLIANCE 

5.1 REGULATIONS AND PERMIT REQUIREMENTS 

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 Law and existing regulations. The air regulations 

governing the existing Bailly Generating Station will also 

govern the proposed AFGD system. The installation of the 

AFGD system is not in response to any regulatory 

requirements. The IDEM, OAM has indicated that the AFGD 

system does not fall under Prevention of Significant 

Deterioration (PSD) regulations. The OAM will require a 

Permit to Construct application. As part of this application 

the OAM will issue a Technical Support Document (TSD). The 

TSD will contain a proposed air emission permit with emission 

limitations and conditions. The IDEM, OAB will also set 

maximum limits on various parameters (S02, particulates, 

opacity) to protect air quality and determine compliance. 

5-1 
Stack 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 Law and 

associated regulations are enforced by IDEM, Office of Water 

Management (OWM). Surface water discharges are authorized by 

these regulations under the NPDES program. 

The existing Bailly Station NPDES permit requires 

that any anticipated facility process modifications that 

result in new, different or increased wastewater discharges 

must be reported. Therefore, a new NPDES permit application 

with some modifications to the current NPDES permit for 

discharge of additional wastewater may be required. The only 

waste stream from the AFGD process is the high-chloride 

wastewater from the gypsum cake washing cycle. The proposed 

AFGD system is designed to evaporate some of 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 

Law and 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 AFGD system are ash and gypsum. Currently 

the Bailly Generating Station's ash is sold to a broker for 

resale, for other uses or for disposal out-of-state. The 

gypsum produced as a by-product will be a stable compound (no 

pre-treatment or stabilization required). It is a saleable 

5-2 
I II 

by-product, and is a suitable 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 AFGD system demonstration phase will be 

processed in a test unit to produce by-product gypsum. This 

representative material will be characterized by EP toxicity 

tests and analyzed for chlorides. Pure Air will conduct the 

testing necessary to receive approval from the IDEM for 

disposing of the gypsum prior to AFGD system start-up. 

5.1.2 Permit Requirements 

Permit requirements for the AFGD system are 

described below based on contact with the appropriate 

regulatory agencies. Relevant excerpts from these contacts 

are included in Appendix D. Permits for the AFGD system 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 a solid 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 a contract hauler for disposal or reuse. 

The station also has an EPA Identification Number as a 

generator of routine power-plant hazardous wastes. It is 

expected that Pure Air will obtain another EPA Identification 

Number for construction and operation of the AFGD system (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: 

5-3 
TABLE 5.1-l: ANTICIPATED PERMITS/APPROVALS AND RESPONSIBLE 

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 

5-4 
Parameter Emission Level 

SO2 

Particulate Matter 

Opacity 

6.0 lbs/MEBtu 

0.22 lbs/MEBtu 

40 percent 

In addition to the above boiler emission 

requirements, the station's fugitive dust emissions shall 

comply with the Indiana Air-Pollution Control Law. 

The AFGD system will require obtaining new Permits 

to Construct and Operate from the IDEM, OAM. 

Wastewater discharges from the Bailly Generating 

Station are authorized under the NPDES program administered 

by the IDEM, OWM. The NPDES permit 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 a visible film or 

sheen on the receiving waters. 

The existing NPDES permit requires that any 

anticipated facility process modifications that result in 

new, different or increased wastewater discharges must be 

reported. Thus, a new NPDES permit application may be 

submitted to the IDEM, OWM for either the combined Bailly 

Generating Station and AFGD system 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 FAA will provide approvals for the AFGD 

system's new stack and operation of construction cranes. 

5-5 
TABLE 5.1-2: EXISTING BAILLY GENERATING STATION NPDES 

PERMIT EFFLUENT LIMITATIONS 

Discharge Point 

or Outfall Parameter 

OOl-Main Outfall Flow 

Temperature 

002-Intake Deicing Total Residual 

Chlorine 

Within Station Discharges 

lOO-Miscellaneous 

Low Volume 

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 

5-6 
5.2 ANTICIPATED PERMITS/APPROVALS 

As indicated previously, the AFGD system 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 AFGD system 

will require various construction releases from the state and 

Porter County. The anticipated permits/approvals for the 

AFGD system are shown in Table 5.1-1 and described below. 

5.2.1 Air Emission Permits/Approvals 

Discussions with the IDEM, DAM indicate 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 same parameters that are in the existing station 

Operating Permit (i.e., S02, particulate matter, opacity). 

The air emission limits will be based on modeling 

the new stack's physical parameters. Once the AFGD system is 

in operation, source testing will be conducted to determine 

actual stack emissions. An Operating 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 

The AFGD system 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., 

5-7 
E-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 AFGD system site these hazardous waste 

activities will be under an EPA Identification Number. 

Similar wastes, if any, generated during operation also will 

be disposed under this Identification Number. 

AFGD system operational wastes or by-products will 

consist primarily of coal ash and gypsum. These wastes may 

be removed from the site by a contract hauler for disposal or 

sale for other uses. Under these circumstances the contract 

hauler may be responsible for obtaining any necessary 

permits/approvals, in particular if the wastes or by-products 

are taken out of Indiana. However, the AFGD system project 

may be 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 

The AFGD system 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 AFGD system wastewater discharges. If the additional 

wastewater discharges from the AFGD system are viewed by the 

IDEM, OWM as having a significant impact on the existing 

wastewater discharge system, or there are additional point 

discharges, a new NPDES permit will be required. 

If a new NPDES permit is required, the IDEM, OWM 

has indicated that parameters similar to those in the Bailly 

5-8 
Station'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. 

A federal approval from the FAA will be obtained 

for construction of the new AFGD system stack (Notice of 

Proposed Construction or Alteration). This approval also 

involves obtaining approval for the cranes to be used during 

construction of the AFGD system. 

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 

DFB will require that the AFGD project 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. Once the review is complete, 

building permits will be issued such as a foundation release, 

construction design release and fire suppression system 

approval. 

The state of Indiana does not have a Coastal Zone 

Management Act Plan. However, projects along the lake may be 

subject to environmental review by the IDEM if 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 a waterway the 

project will be subject to review by the Department of 

Natural Resources (DNR) Water Division. Since the AFGD 

system project will neither impact the flood plain, nor be 

built on the lakeshore, and wetlands are not present, Pure 

Air does not anticipate involvement of the DNR. 

The only anticipated local approval for the AFGD 

project will be issued by the Porter County Plan Commission. 

This will involve issuance of an Improvement Location Permit 

and Certificate of Occupancy. This approval involves 

submitting a site plan for the project and information 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 AND THEIR QUALIFICATIONS 

6.1 AIR PRODUCTS AND CHEMICALS, INC. 

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

Dr. Kuns, a Chemical and Environmental Engineer, is 

the Manager of Environmental Engineering Design for Air 

Products and Chemicals, Inc. Process System Group. He has 

over 20 years of industrial experience in chemical and 

refinery technology, process engineering, and environmental 

assessment, control and permitting. He has contributed to 

the published literature in the areas of environmental 

control and water and wastewater treatment, and is a 

recipient of the Harrison Prescott Eddy Medal from the Water 

Pollution Control Federation. 

6.2 ENVIROPLAN, INC. 

Hacue, Obaidul, B.S., M.S. 

Mr. Haque, a Chemical Engineer, served as a Project 

Engineer for preparation of the Environmental Information 

Volume. He has extensive experience in environmental studies 

estimating air pollution emissions for different chemical, 

petroleum, and manufacturing plants. He is also experienced 

in community exposure, risk assessment, and air quality 

modeling for various industrial clients. 

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

Mr. Huston served as Project Manager for 

preparation of the Environmental Information Volume (EIV). 

He has over 20 years experience in environmental assessment 

6-l 
and reporting in support of capital development varying from 

$250,000 to over $1 billion. These activities include 

nuclear-fueled power plants, petrochemical plants and synfuel 

facility development under DOE auspices. Mr. Huston is a 

Certified Consulting Meteorologist (296). 

Kowalskv, Laura, B.A. 

Ms. Kowalsky, Project Investigator for the EIV, 

writes marketing brochures and proposals, and has written, 

edited and produced many of Enviroplan's publications, 

proposals and reports. She has been a journalist and 

technical editor/writer specialising in environmental 

subjects. 

Lackaye, Robert W., B.S. 

Mr. Lackaye served as Project Scientist in the 

preparation of the Environmental Information Volume. He has 

extensive experience conducting air pollutant sampling and 

analysis projects. His project experience has included 

source testing utilising EPA Methods, fugitive emission 

studies, ambient air monitoring and industrial hygiene 

studies for various pollutants. Mr. Lackaye has conducted 

air sampling projects to determine compliance with Federal, 

state and local air pollution regulations, and also to assess 

environmental quality. 

Simpson, Estelle B., B.S. 

Ms. Simpson, a Chemical Engineer, is a Project 

Engineer for preparation of the EIV. She has extensive 

experience in environmental studies of hazardous emissions 

from industrial facilities. These studies include 

comprehensive emission studies, community exposure, 

accidental releases, and risk assessment. She is also 

6-2 
involved in air-quality modeling of hazardous pollutants for 

various chemical clients. 

6.3 NORTHERN INDIANA PUBLIC SERVICE CO. 

Ross, John M., B.A., M.B.A. 

Mr. Ross is the Superintendent of Environmental 

Planning in Northern Indiana's Environmental Programs 

Department. He acted as Northern Indiana's project 

coordinator for the preparation of the EIV. During the past 

11 year8, Mr. Ross has held various environmental positions 

at Northern Indiana to include ambient air monitoring system 

design and operation, estimation of air pollution emissions, 

performance and review of EPA source tests; application and 

operation of continuous emissions monitors. Mr. Ross has 

also been involved in the analysis of environmental 

regulation and policy to the extent that it impacts on 

Northern Indiana operations. 

6.4 PURE AIR 

Bolinsky, Francis T., B.S. 

Mr. Bolinsky, a Chemical Engineer, is the Senior 

Project Manager for Pure Air. He has over 18 years of 

experience in industrial plants and has been extensively 

involved in permitting in many states. 

6.5 STEARNS-ROGER DIVISION OF UNITED ENGINEERS & 

CONSTRUCTORS INC. 

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

Dr. Dennis, an Environmental Engineer, coordinated 

the overall development of the Environmental Information 

6-3 
Volume. He has over 19 years experience with environmental 

studies and over 12 years experience with permitting 

industrial projects. These projects have included coal, 

copper, uranium and precious metal mines; natural gas 

processing facilities; coal liquefaction and pyrolization; 

underground coal gasification and potash solution mining; 

uranium processing from phosphoric acid; coal-fired 

generating facilities; crude oil pipelines; low density 

polyethylene plant; oil shale processing: CO2 enhanced oil 

recovery: coastal spaceport facility, and an ammonium 

perchlorate plant. 

Brown, Gary D., B.S. 

Mr. Brown, a Chemical Engineer, served as a Process 

Engineer for preparation of the EIV. He has extensive 

experience in technical feasibility and economic studies of 

SO2 control processes for the Electric Power Research 

Institute (EPRI) and private utilities. Mr. Brown is a 

Registered Professional Engineer in Colorado (Registration 

No. 20713) and is a process engineer in the Power Division of 

Stearns-Roger. 

Ireland, Paul A., B.S. 

Mr. Ireland was responsible for several 

project/process related sections of the EIV. He has 20 years 

experience in the flue gas desulfurization (FGD) industry, 

has served as lead process engineer for two major FGD 

projects (600 MW and 1,000 MW) and has traveled throughout 

the U.S., Japan and Europe visiting FGD installations. 

6-4 
APPENDIX A 

INFORMATION LETTER FROM INDIANA 

DEPARTMENT OF NATURAL RESOURCES 

AND 

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) 

A-l 
E-59 

INDIANA DEPARTMENT OF NATURAL 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 

59 Main Street 

West Orange, NJ 07052 

Dear Ms. Xowalsky: 

In response to your request of March 30, 1989, I will address each 

question individually. 

Migratory patterns and nesting information on the bald eagle in 

relation to the Bailly Site: 

E-40 

Historically, bald eagles (Haliaeetus leucocephalus) nested 

along the shore of Lake Michigan in Indiana. In 1898, Amos 

Butler reported that bald eagles "bred quite commonly" in Lake 

County and there were numerous reports of nesting near the 

lakeshore. In recent years, however, we have seen no indication 

of nesting along the lakeshore. Certainly, based on your 

description of the Bailly Site, no bald eagles nest within it. 

However, eagles are often seen in the area. Bald eagles have 

been reported annually since 1978 in the area and are most often 

seen near the lakeshore. These birds are not local nesters. 

Any federally 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, and rare wildlife in the state. We are unaware of 

the existence of any federally or state endangered, threatened, 

or rare species within the boundaries of the Bailly Generating 

Station. Given the site description as per our phone 

conversation, there doesn't appear to be suitable habitat. 

Does transient migration of land vertebrates occur in the area: E-39 

Because of the site's proximity to Lake Michigan and the Indiana 

Dunes National Lakeshore, it is probable that land vertebrates 

travel into or across the site. However, no data are available 

to confirm that species do or do not use the site in their 

normal movements. 

“EQUAL OPPORTUNITY EMPLOYER” 
Page 2 

Information on the migratory patterns of birds in the National 

Lakeshore: 

The Department of Natural Resources has no compiled information 

on the migratory patterns of birds in the Lakeshore area. This 

information may be found in "Birds of the Indiana Dunes." by 

Kenneth J. Brock published by the 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 Lake Michigan into the Dunes 

area at the toe of the lake. During spring flights, migrating 

hawks are concentrated in a belt 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 seen flying along the beaches. 

Please contact me if I can be of further assistance. 

sincerely, 

[f ,,.($& ,$ &Ji.,( 

Michelle L. Martin 

Indiana Natural Heritage Program 

cc: Scott Johnson, Division of Fish and Wildlife 

Noel Pavlovic, Indiana Dunes National Lakeshore 

A-3 
u 

TABLE A-l: ENDANGERED, THREATENED AND RARE PLANTS FOUND IN 

THE INDIANA DUNES NATIONAL LAKESHORE, PORTER 

COUNTY (STATE OF INDIANA LIST1 

Key: E = Endangered T = Threatened R = Rare 

SPECIES NAME SPECIES COMMONAME 

Actaea Rubra Red Baneberry 

Amelanchier Humilis Running Serviceberry 

Andromeda Glaucophylla Bog Rosemary 

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 

Carex Aurea 

Carex Chordorrhixa 

Carex Debilis Var 

Rudgei 

Carex Eburnea 

Carex Flava 

Carex Folliculata 

Carex Garberi 

Carex Leptonervia 

Carex Limosa 

Carex Pedunculata 

Carex Seorsa 

Carex Woodii 

Caralpa Speciosa 

Chimaphila Umbellata 

Var Cisatlantica 

Chrysosplenium 

Americanum 

Cirsium Pitcheri 

Coeloglossum Viride 

Var Virescens 

Cornus Canadensis 

Cornus Rugosa 

Stiff Sandwort 

Slim-Spike Three-Awn Grass 

Seabeach Needlegrass 

Forked Aster 

Rush Aster 

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 

Ebony Sedge 

Yellow Sedge 

Long Sedge 

Elk Sedge 

Finely-Nerved Sedge 

Mud Sedge 

Longstalk Sedge 

Weak Stellate Sedge 

Pretty Sedge 

Northern Catalpa 

Common Wintergreen 

American Golden-Saxifrage 

Dune Thistle 

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 
TABLE A-l: (Continued) 

SPECIES NAME 

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 

Melampyrum Lineare 

Milium Effusum 

Myosotis Laxa 

Myriophyllum 

Verticillatum 

Nemopanthus Mucronatus 

Oenothera Perennis 

Oryzopsis Asperifolia 

Prysopsis Racemosa 

Panax Trifolius 

Panicum Boreale 

Panicum Leibergii 

Panicum Verrucosum 

Pinus Banksiana 

Platanthera Ciliaris 

Platanthera Clavellata 

Platanthera Flava 

Var Herbiola 

Platanthera Hyperborea 

Platanthera Psycodes 

SPECIES COMMONAME STATUS 

Small White Lady's-Slipper R 

Bush Honeysuckle 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 

Downy Gentian 

Bicknell Northern Crane' 

Sand-Heather 

Large Whorled Pogonia 

Brown-Fruited Rush 

Ground Juniper 

Smooth Veiny Pea 

Cattail Gay-Feather 

Globe-Fruited 

False-Loosestrife 

Running Pine 

Northern Bog Clubmoss 

Tree Clubmoss 

Deep-Root Clubmoss 

Green Adder'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 Green Woodland Orchis R 

Northern Rein-Orchid R 

Leafy Northern Green Orchis T 

Small Purple-Fringe Orchis R 

A-5 
TABLE A-l: (Continued) 

SPECIES NAME SPECIES COMMONAME 

Poa Alsodes Grove Meadow Grass 

Poa Paludigena Bog Bluegrass 

Pogonia Ophioglossoides Rose Pogonia 

Polygala Paucifolia Gay-Wing Milkwort 

Polygonella Articulata Eastern Jointweed 

Polygonum Opelousanum Smartweed 

Var Adenocalyx 

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 

Var Americana 

Rhus Trilobata Var Beach Sumac 

Arenaria 

Rhynchospora Globularis Globe Beaked-Rush 

Var Recognita 

Rhynchospora Tall Beaked-Rush 

Macrostachya 

Ribes Hirtellum Smooth Gooseberry 

Rubus Odoratus 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 Ledge Spike-Moss 

Solidago Deamii Deam Goldenrod 

Solidago Spathulata Sticky Goldenrod 

Var Gillmanii 

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 

Woodwardia Areolata 

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 
TABLE A-2: ENDANGERED, THREATENED AND RARE ANIMALS FOUND 

IN THE INDIANA DUNES NATIONAL LAKESHORE, PORTER 

COUNTY (STATE OF INDIANA LIST1 

Key: E = Endangered T = Threatened SC = Special 

WL = Watch List 00 = Status Under Review 

SPECIES NAME 

Amphibians 

Ambystoma Laterale 

Hemidactylium Scutatum 

Pseudacris Triseriata 

Rana Pipiens 

Reptiles 

Clemmys Guttata 

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 

SPECIES COMMONAME 

Blue-Spotted Salamander 

Four-Toed Salamander 

Striped Chorus Frog 

Northern Leopard Frog 

Spotted Turtle 

Blanding's Turtle 

Western Smooth Green Snake 

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 

Canada Warbler 

Hooded Warbler 

Franklin's Ground Squirrel 

Concern 

STATUS 

SC 

T 

SC 

SC 

T 

SC 

T 

00 

T 

SC 

WL 

E 

% 

00 

SC 

E 

SC 

E 

E 

E 

A-7 
TABLE A-2: (Continued) 

SPECIES NAME 

Insects 

SPECIES COMMON 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 
TABLE A-3: 1989 FEDERALLY THREATENED AND ENDANGERED 

FLORA AND FAUNA FOUND IN THE INDIANA DUNES 

NATIONAL LAKESHORE 

Key: E = Endangered T = Threatened 

SPECIES NAME COMMONAME 

Cirsium Pitcheri Dune Thistle 

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 Dunes National Lakeshore; National Park 

Service - Resource Management Division. Personal 

communication: January 1989. 

A-9 
I I 

APPENDIX B 

ARCHAEOLOGICAL AND HISTORICAL SURVEYS 

AND 

INFORMATION LETTER FROM INDIANA 

DEPARTMENT OF NATURAL RESOURCES 

B-l 
I 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 AFGD system. 

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 10 miles from the Bailly Station. 

B-2 
INDIANA DEPARTMENT OF NATURAL 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, New Jersey 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. 

We appreciate the opportunity to be of service. 

Very truly yours, 

te Historic Preservation Officer 

PRR:SBG:vk 

B-3 

“EQUAL OPPORTUNITY EMPLOYER” 
APPENDIX C 

BAILLY GENERATINGSTATION WAIVER FROM 

GROUND WATER MONITORING REQUIREMENTS, AND PERMITS 

FOR WASTEWATER DISCHARGES AND AIR EMISSIONS 

C-l 
I I 

WAIVER FROM GROUND WATER 

MONITORING REQUIREMENTS 

c-2 
A 

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 am set forth uodcr 40 CFR Part 265. 

Subpart P (320 IAC O-6). The sampling for orgmics in your vaste stream 

is still recommended by staff l o U.S. EPA has indicated the possibillry 

of requiring facilities vho have been granted aa exemptloo fra the 

ground water monitoring requirements or a delisting of vastes to prove 

organlcs arm not 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 l c AC 317/b)]-6676. 

C. Pi&ad 

Technical Secretaq 

Footnote A: Neither the Bailly Generating Station or the 

proposed AFGD system operations will result in discharges 

of organic materials as a wastestream. 

c-3 
I I 

WASTEWATER DISCHARGE (NPDES) PERMIT 

c-4 
I 

DESCRIPTION OF EXISTING 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 may be 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-5 
Lake Michigan 

0 im 

Coal 

Power Plant 

Sewage Treatment 

Plant 201 Wastewater 

, Treatment 

0’ 

1 Ash Ponds 

h Pure Air A 

a joint venture company 

ADVANCED FLUE 

GAS DESULFURIZATION 

Existing Permitted 

Discharge Locations 

Figure c-1 E-53, 66 
iJage I of 20 

Permit No. IN 0000132 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

AUTHORIZATION TO DISCHARGE UNDER THE 

NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM 

In compliance with the provisions of the Federal Water Pollution Control 

Act, as amended (33 U.S.C. 1251 et seq., the "Act"), and the Indiana 

Environmental Management Act, as amended (IC 13-71, 

NORTHERN INDIANA PUBLIC SERVICE COMPANY 

BAILLY GENERATING STATION 

is authorized to discharge from a coal fired power plant which Is located at 

246 Bailly Station Road. Chesterton, Indiana, to receiving waters named Lake 

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 180 days 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-7 
Permit No. IN 0000132 

TREATMENT FACILITY CLASSIFICATION 

The discharger has a Class C industrial wastewater treatment plant, 

classified in accordance with 327 IAC S-12, Classification of Water and 

Wastewater Treatment Plants. 

PART I 

A. EFFLUE?IT LIMITATIONS AND MONITORING REQUIREMENTS 

1. During the period beginning on the 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+ 

Durstfon Of 

mlorlnatfon+ 

chlorfnotfon 

Frequency+ 

Report Report MO 

-- -- 

-- _- 

_- _- 

_- __ 

_- em 

Report Report mg/l 

_- 0.2 q g/l 

_- _- 

-- -- 

*Flow may be 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) may not 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 a visible film or sheen on the 

receiving waters. 

C. Samples taken in compliance with the monitoring requirements 

above shall be taken at a point representative of the discharge 

but prior to entry into Lake Michigan. 

C-8 
II 

Page 3 of 20 

Permit No. IN 0000132 

2. During the period beginning on the effective date of this permit and 

lasting until the expiration date, the permittee is authorfred to 

discharge from Outfall 100 - Miscellaneous Low Volume Bypass. Such 

discharge shall be limited and monitored 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 h Grease -- 

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 pH shall nor be less than 6.0 nor greater than 9.0. The pH 

shall be monitored as follows: by a daily grab sample, during 

discharge. 

The discharge shall not cause excessive foam in the receiving 

waters. The discharge shall be essentially free of floating 

and settleable solids. 

The discharge shall not contain oil or other substances in 

amounts sufficient to create a visible film or sheen on the 

receiving waters. 

Samples taken in compliance with the monitoring requirements 

above shall be taken at a point representative of the discharge 

but prior to mixing with other wastewaters. 

c-9 
Permit 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 Daf ly 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 a weekly 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 a visible film or sheen on the 

receiving waters. 

d. Samples taken in compliance with the monitoring requirements 

above shall be taken at a point representative of the discharge 

but prior to mixing with other wastewaters. 

c-10 
/age 5 of 20 

Permit No. IN OOOC132 

Parameter 

FlOW 

T. Iron 

r. copper 

4. 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 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 and monitoring 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. The volume 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 CPR 423.12(b)(S) as a metal 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 a point representative of the discharge 

but prior to mixing with other wastestreams. 

c-11 
Permit go. IN 0000132 

5. 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 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"m units 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. 

400 100 ml Weekly Crab 

2.0 w/l 2 x Weekly Grab 

*Fetal coliform and chlorine limitations apply only from April 1 

through October 31 annually. Sampling is not required, and 

chlorination should not be practiced November 1 through March 31. 

a. Samples taken in compliance with the monitoring requirements 

above shall be taken at a point representative of the discharge 

but prior to mixing other wastewaters. 

c-12 
r’age 7 of 20 

Permit No. IN 0000132 

6. During the period beginning on the 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 and monitored 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 _- __ 2 x Monthly 24-m. lota, 

-- __ 30 100 mgil 2 X !lonthly 2L-Hr. wmp 

-- -_ 15 20 mgJ1 2 X .%nChly Crab 

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH 

shall be monitored as follows: by a grab sample twice monthly. 

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 a visible film or sheen on the 

receiving waters. 

d. Samples taken in compliance with the monitoring requirements 

above shall be taken at a point representative of the discharge 

but prior to mixing with other wastewaters, except for pg. 

which may be sampled after mixing with the main discharge. For 

TSS and oil 6 grease, the representative location may be from 

the boiler drum rather than at end-of-pipe. 

c-13 
Z-ilBle 0 “1 L?I 

Permit No. IS 0000132 

7. During the period beginning on the 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 or Conccn~ratian Honitoring Requirements 

Monthly Dai 1y ?lonthly Daily xeasuremenc sample 

AvcraKe Y~Ximm - units Average Msximm Units Fl-.eqMnCV LYFC 

Report Report 3GD __ -- WeeklP ZL-Hr. lotal 

*Flow is to be estimated based on precipitation. All parameters are 

to be monitored weekly during periods of discharge of coal pile 

runoff to the ground absorption area. 

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH 

shall be monitored as follows: by a weekly grab sample, during 

periods of discharge. 

b. The discharge shall not contain oil or other substances in 

amounts sufficient to create a visible film or sheen on the 

receiving waters. 

c. Samples taken in compliance with the monitoring requirements 

above shall be taken at a point representative of the discharge 

but prior to entry into the ground absorption area. 

c-14 
Page 9 of 20 

Permit No. IN 0000132 

B. MONITORING AND REPORTING 

1. Representative Sampling 

Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge. 

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 be postmarked 

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 a substantial period of time during which there 

will be no discharge from an authorised outfall, then the permittee 

may submit a written request to the Indiana Department of 

Environmental Management for relief from reporting requirements. 

The Commissioner may then suspend reporting requirements without 

public notice or opportunity for public hearing. 

The Regional Administrator may request 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 by weight during a calendar 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 by veight 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 made during a 

calendar month. Daily determinations of concentration 

made using a composite sample shall be the concentration 

of the composite sample. When grab 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-15 
rage IV 01 LU 

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 a 24-hour 

period and which 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 may be 

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 and Wastewater 

16th Edition, 1985, American Public Health Association, 

Washington, D.C. 20005. 

(2) A.S.T.M. Standards, Part 23, Water: Atmospheric Analysis 

1972 American Society for Testing and Materials, 

Philadelphia, PA 19103. 

(3) Methods for Chemical Analysis of Water and Wastes 

June 1974, Revised, March 1983, Environmental Protection 

Agency, Water Quality Office, Analytical Quality Control 

Laboratory, 1014 Broadway, 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- 16 
LJage 11 of 20 

Permit No. IN 0000132 

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

b. The dates the analyses were performed; 

c. The person(s) who performed 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. REOPENING CLAUSE 

1. 

2. 

When the U.S. EPA and the State of Indiana finalfze a policy 

regarding the implementation of 40 CFR 122.26, which addresses 

stormwater discharges, this permit may be modified, after public 

notice and opportunity for hearing, to incorporate revised 

limitations for the control of such discharges. 

This permit may be 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 

PART II 

STANDARD CONDITIONS FOR NPDES PERMITS 

FOR INDUSTRIAL FACILITIES 

SECTION A. GENERAL CONDITIONS 

1. Duty to Comply 

The permittee shall comply with all conditions of this permit. Any permit 

noncompliance constitutes a violation 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 who violates 

a permit condition implementing sections 301, 302, 306, 307, 318, or 405 of 

the Clean Water Act is subject to a civil penalty not to exceed S25.000 per 

day of such violation. Any person who willfully or negligently violates 

permit conditions implementing sections 301, 302, 306, 307, or 308 of the 

Clean Water Act is subject to a fine of not less than $2,500 nor more than 

525,000 per day of violation, or by imprisonment for not more than 1 year or 

both. If the conviction is for a violation committed after a first conviction 

of such person under this provision, punishment shall be a fine 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 

The permittee 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 may be 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. A change in any condition that requires either a temporary or 

permanent reduction or elimination of the authorized discharge. 

C-18 
1 I I H 

Page 13 of 20 

Permit No. IS 0000132 

The filing of (I) a request by the permittee for a permit modification, 

revocation and reissuance, or termination, or (ii) a notificaclon of planned 

changes or anticipated noncompliance does not stay any permit condition. 

5. Dutv to Provide Information 

The permittee shall furnish to the Commissioner, within a reasonable time, any 

information which the Commissioner may request to determine whether cause 

exists for modifying, revoking and reissuing, or terminating this permit or to 

determine compliance with this permit. The permittee shall also furnish to 

the Commissioner, upon request, copies of records required to be kept by this 

permit. 

6. Duty to Reapply 

If the permittee wishes to continue an activity regulated by this permit after 

the expiration date of this permit, rhe permittee must apply for and obtain a 

new permit. The application should be submitted at least 180 days before the 

expiration date of this permit. The Commissioner may grant permission to 

submit an application less than 180 days 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 

name of the permittee and incorporate such other requirements as may be 

necessary under the Clean Water Act. 

8. Toxic Pollutants 

Notwithstanding Paragraph A-4, above, if a toxic 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 be modified or revoked and 

reissued to conform to the toxic effluent standard or prohibition. 

The permittee shall comply with effluent standards or prohibitions established 

under section 307(a) of the Clean Water Act for toxic pollutants injurious to 

human health 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 

When cyanide 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-19 
rage ,‘I or ‘U 

Permit No. IN 0000132 

10. Ooerator Certification 

The permittee shall have the waste treatment facilities under the direct 

supervision of an operator 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 311 of 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 may be 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 eo and 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 a valid construction permit issued by the Indiana 

Department of Environmental Management pursuant to 327 IAC 3-2. 

c-20 
i’age 15 of 20 

Permit No. IN 0000132 

SECTION B. MANAGEMENT REQUIREMENTS 

1. Proper Operation and Maintenance 

The permittee 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 and which 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 a waste stream from 

any portion of a treatment facility normally utilired for 

treatment of the waste stream. 

(2) “Severe property damage” means substantial physical damage to 

property, damage to the treatment facilities which would cause 

them to become inoperable, or substantial and permanent loss of 

natural resources which can reasonably be expected to occur in 

the absence of a bypass. Severe property damage does 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 no feasible 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 an unanticipated bypass to the 

Commissioner within 24 hours of becoming aware of the bypass 

(if this information is provided orally, a written submission 

must be provided vithin five days). Where the permittee knows 

or should have known in advance of the need for a bypass, this 

prior notification shall be submitted for approval to the 

Commissioner, if possible, at least ten days before the date of 

the bypass. 

C. An anticipated bypass which meets the three criteria of Paragraph b 

of this subsection may be allowed under conditions determined to be 

necessary by the Commissioner to minimise any adverse effects. 

c-21 
rage lb or i!o 

Permit No. IN 0000132 

3. i’pset Conditions 

a. Definition: “Upset” means an exceptional incident in which there is 

unintentional and temporary noncompliance with technology-based 

permit effluent limitations because of factors beyond the reasonable 

control of the permittee. An upset does not include noncompliance 

to the extent caused by operational error, improperly designed 

treatuznt facilities, inadequate treatment facilities, lack of 

preventive maintenance, or careless or improper operation. 

b. (Effect of an upset) An upset 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 a demonstration of upset) A permittee who 

wishes to establish the affirmative defense of upset shall 

demonstrate, through properly signed, contemporaneous operating logs 

or other relevant evidence, that: 

(1) An upset occurred and 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. 

SECTION C. REPORTING REQUIREMENTS 

1. Planned Changes in Facility or Discharge 

Any anticipated facility expansions, production increases, or process 

modifications which will result in new, different, or increased discharges of 

pollutants must be reported by submission of a new XPDES application 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 may be modified to revise existing pollutant 

limitations and/or to specify and limit any pollutants not previously limited. 

c-22 
r 

Page 17 of 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 14 days 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 on the 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 a maximum daily discharge limitation for any of the 

pollutants listed by the Commissioner in the permit to be reported 

within 24 hours: and 

c. Any noncompliance which may pose a significant danger to human 

health or the environment. 

A written submission shall also be provided within 5 days of the time the 

permittee becomes aware of the circumstances. The written submission shall 

contain a description 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 may waive the written report on a case-by-case 

basis if the oral report has been received within 24 hours. 

5. Other Noncompliance 

The permittee shall report any instance of noncompliance not reported under 

Paragraph 3 or 4 of this Section at the time the pertinent Discharge 

Monitoring Report is submitted. The report shall contain the information 

specified in Paragraph 4 of this Section. 

6. Other Information 

Where the permittee becomes aware that he failed to submit any relevant facts 

or submitted incorrect information in a permit 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 

The permittee 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) One hundred micrograms per liter (100 ug/l); 

(2) Two hundred 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 maximum concentration 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 a person 

described below or by a duly authorised representative of that 

person: 

(1) For a corporation: by a principal executive officer of at 

least the level of vice-president (including a person who is 

not a vice-president but performs similar policy-making 

functions for the corporation); 

(2) For a partnership or sole proprietorship: by a general partner 

or the proprietor. respectively; or 

(3) For a Federal, State, or local governmental body or an agency 

or political subdivision thereof: by either a principal 

executive officer or ranking elected official. 

b. A person is a duly authorized representative only if: 

(1) The authorisation is made in writing by a person described 

above. 

C-24 
Page 19 of 20 

Permit No. IN 0000132 

(2) The authorisation specifies either an individual or a position 

having responsibility for the overall operation of the 

regulated facility or activity, such as the position of plant 

manager, operator of a well or a well field, superintendent, or 

position of equivalent responsibility. (A duly authorised 

representative may thus be either a named individual or any 

individual occupying a named position.); and 

(3) The authoritation is submitted to the Commissioner. 

c. Certification. Any person signing a document under this section 

shall make the following certification: 

“I certify under penalty of law that I have personally examined 

and am familiar with the information submitted in this document 

and all attachments and that, based on my inquiry of those 

individuals immediately responsible for obtaining the 

information, I believe that the information is true, accurate, 

and complete. I am aware 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 3.27 IAC 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 6 months per 

violation, or by both. 

C-25 
---- -- -_ -_ 

Permit No. IN 0000132 

Part III 

Other Requirements 

Thermal Effluent Reauirements 

As a 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 mode of 

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 a significant reduction of impingement 

could be attained by any reasonably practical measures such as the 

addition of mesh screen over the intake pipe, since NIPSCO has 

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. 

No further submission of information on this subject is required at the 

time of reissuance of this permit. 

Chlorine Concentration 

The total exposure time of TRC resulting 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 a nuisance. 

Polychlorinated Biphenyl 

There shall be no discharge of polychlorinated biphenyl (PCB) compounds 

such as those commonly used for transformer fluid, in accordance with 

40 CFR 423.12(b) and 423.13(a). 

A. 

B. 

C. 

D. 

E. 

P/Bailly Station Pll 

C-26 
AIR EMISSION PERMIT (DRAFT OPERATING PERMIT) 

c-27 
- 

OFTICZ ST AiR MANAINoLAN DELPiQmENT OF E?JvImu MPJixsmrr 

?.9ow9 OPEPATION PE.DlIT 

No?x%erx Indiana Public Sernce Ccxrgany 

ailif ~enearrn~ st+rm 

at Eurns Ha?ncr 

Chesxt7on. indiana 

has appJ.Led for autnorzzauon ~0 operate: 

the wchnic (sM~'r~L) coal fired boiler CUtit $7). rated at 1638 un 

Btu's per hour energy input. used to generate up to 183 megawatts (grosst or‘ 

d.%CULCity. 

precipitator. 

Pe.r!!ti~emrteremssxms are conrrolJ& byannicrzusa~c 

conKroLLed bil.er eanisslons are fsmaustad to the amrsonex 

through a 400 foot tall stack k&rig a l5.25 foot exit diamxcr *at is sfuzed 

with utit #a. 

It is gropsedrto A.sLle ai5 permrr l,lndecw a.5326 .rac Amr'e~~2 s&m 

the folLowing .anrrliti: 

1. That thedataand infomtim supplied in the appiication shall be considered 

part of this pemit. Priorto=change in the operationvhichrrayresult 

in an increase in potential emissions exeeding those specified in 326 IAC 

2-1-l. this change rust be approved by the Office of Air Kmag6nen.t. 

t.Thatthepermitteeshallc~ywiththaprovirionsoftheIndianaErmimnrental Menaganent Law (IC 13-7). Air PolLLtinn Couunl~ (IC U-l-1) 

andthenkspnnuLgatedtherernrler. 

3. Ttk3tthf2equiprPntshallt-soperatedand~tai.nedti a!xodance with the 

ImnLlfm's specifications. 

(See Page 2) 

PendingldentificationNo. 64-07-92-0245 

hp3ntmu Date Julv 1. 1992 

THIS IS NOT A PERMIT -_-- --___- --w-wC-28 
Normern malana +:CIIC jervlce i;mcanv 

Saillv Generarmo Stanon 

Burns naroor. :noiana 

&4-,,;.;2.;;J5 

hoe ‘> ^. ^ 

- -.,,_ 

Zsnamcns ‘knnnuec: 

-. Yar cursuant :c 2.25 GC 5.2 Sec::cn : I*:. cantculammatter emlsslons ;o me atmoscnere 

xm ms cotter xail oe llmirec :c G.22 c ounas oer million aus ST enerqy Inca:. 

E. T:ar cursuanr :3 Secxn .: :*I -- _, ;2j jAC 2- :, ;;a CT 1esi.s ~0 aerermlne oanware maner 

emissions rrcm mls toiler snail oe ccnouceo cursuanr 10 328 iAC Z-2. -he rirst Yes.1 snail be 

oerrormea cunng calenaar vear ? 990 wnn anomer rest to ne oerrormea curma calenaar vear 

i 562. Ti;e Office OT Air Manaaemenr CAM) snail oe norlfieo OT me tesr oates In aovance 

cursuanr wnn 325 IAC Z-2-3. ana resr recOns snarl w SIJO~~TEU ro me OAM wrrntn ~5 aavs 

0~ me test 

8. Tinat oursuam to 326 IAC f-:-2! (aH2!. sulfur ofox~oa emlsslons rrom Belier NOS. 7 ana 8 

snail be iimnecl to 6.0 IbsJMMBtu. Zotiers 7 ano 8 mall be IireO wlm coal. Iuel 011 or 

ilatural qas. 

7. Thar me slaflon snail samuie ana anaivze me ccai usea In Eolier NOS. : ana 8 cn a aallv oasis 

{Note: AflaIvSIS oasea on ccmaosne samntes ror weeKenas ana nollaavs wail oe ac=eoIaole.! 

The acove analvsls WIII inc:uoe all or me foliowlnq on an as ounKereo cr as oumea oasis: neai 

ccnrenr. 36 sulrur. 96 asn ana % morsrure. ‘gnuant fo 325 IAC 7-:-L cuartenv reoons OT 

the 30-aav roiling welgnrea average emission rate tin oounos oer rntllion am Tar eacn aav 

of the auaner snail be suommea bv me last aav or me monrn rollowIng me ena 01 me ouaner. 

Rea~rds of me daily average suifur content. neat content ana sulfur diqoae_emlssion rate (in 

,, pounds per million Btu) shall be retained at the station for three year 

‘-2r made available upon request. 

8. That visible emissions shall be limited to 40% opacity pursuant to 326 IAC 5-l. Section 

2(a)(l), for attainment areas. 

9. That oursuant to Section 3(d) of 326 IAC 5-1, a so&al temmray exemonon.is nereov 

granted 10 allow. wnen necessary. the followmg visible stacx emissions aunng ooiler 

StaRuDs ana snutdowns. 

(a) During boiler stanups an exemption from the 40% opacity limit is allowed for up 

to 10 (ten) six-minute average periods, oruntil the flue gas temperature entering the 

electrostatic precipitator reaches 250 degress F,which ever occurs first. In the event 

that the above is exceeded due 10 special circumstances (such as a cold starluo after an 

extended outage), NIPSCO shall report this to the OAM within one working day of the 

occurrence. This report shall also include the total accumulated oenoos of excess 

opacity and the reason why the extenaed time was necessary. During mese .SUUD 

periods all reasonable efforts shall be maae to minimhe the numner ana magnnuae of 

the exceedances. 

(b) During boiler shutdowns an exemmiorrimm~the 40% opacity limit is allowed for up 1 

to 10 (ten) six-minute average periods. During mesa shutdown pehods all reasonable 

efforts shall be maae to minimize the number and magnitude of the exceedances. 

10. That at no time shall the combined rate of heat input for Boiler Nos. 7 and 8 exceed a total of 

5.012 million Btu’s per nour. 

c-29 
-=- - -_ 

OFFIE OFAIRIN!JIANA DEPAr?mmr OF ENvImAL - 

PFQWSEDOPEFATIONPER+I? 

Norme.?n Indiana 

f 

Fublrc Se.'xrce Caqmy 

SaiLLy Generaring Statinn 

sb 

a, Eurns Haroor 

ChesKerton. IndLma 

0 

has applied for au- KlAan to operate: 

the cycl.onic (?abcdticaL) cad fkezi holler (Unit ta), rated at 3374 mAJim 

mu's per hour energy input, used to gellate up to 335 megawmts (gross) of 

wty. Pe?siautemrtererlussaonsareccmrrolledbyan~ StatLC 

p?zeclatator. cantrolled.boiler -sions are exnausted to the aumsuhere 

th.m&ha 400 fat tallstack having a IL25 foot eXrrr diiuneter-&K -ti stand 

with Unit ft7. 

It4pL& . to;issue:m.p under- of 326 IX e 2 wid 

thefallaring: '1" : 

1. That the data and informstion supplied in the application shall be considered 

part of this permit. Priortoanychange in the operationwtkhmyresu.Lt 

inan increase in potential emissions exceeding those specified in 326 IAC 

2-l-l. this 'ctnnge mst be approved by the Office of Air Managerrrcnt. 

2. Thatthe~permitteeshallcarplywiththep~ofthelndianaEmnrrmIlk?aaLMauag~t-r.au (IC.U-7). Air Pouuricm corrtrol Iaw (IC U-l-11 

&:.tbezJlJs arrmr)larrrl.-. 

3. nlat-the~ l lqipmnt*.be opelx¶ted and maintained in acmrdance with the ilvmufm‘s speczfications. 

(See Page 2) 

PllnrliaQ;T’ ‘.-’ ” No. 64-07-92-0246 

. . rate July 1, 1992 

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

P..?fl 
Nonnem moiana ?*ZCIIC 5ervlca ,kmoanv 

Saillv Generauno 5tanon 

Zurns narccr. :nc:ana 

&$.i-J;.$2-*~24~ 

Csnal77ons ‘knrmuec: 

-. 

-. nat cursuant :c 325 iAC Z-2 Sect:on - I::. :amczare maner emrssrons 70 me a7mospnere 

xm tms cozier snsil oe 9mires :C 222 ~3uncs cer mIllion 2u.s c7 eneray mcu::. 

3. That oursuanr :o Sealon 1 Ie! c7 22-3 ,AC 2.:. xix.5 ~esis 10 oerermtne oanrware maner 

emwlons irom rnls cwer snail De cznauc:e~ cur-wan7 :c 225 iAC S-2. ?e 7irsi iesl Snarl be 

cenormea ammo caienaar vear 7 999 wnn ano7ner lest 70 se oerrormeo aunnc zrenaar vear 

: EE2. The Office or Air Manaoement tOAM) snarl oe notifiea cr me lest dates in aovance 

oursuan7 w7n 325 IAC 3-2-S. ana tes7 recons snarl ne suomtnea 70 me OAM wttnm 45 oavs 

2r:ne tes7. 

6. That oursuant 70 325 IAC T-:-2: rai(B. suuir c:oxtae emlssrons mm Sorier NOS. : ano 8 

snail oe tlml7ea 70 6.9 ibs;MMEk. Zoliers T 2nd 8 snarl oe rirea wnn czar. :uer 017 c: 

natural gas. 

7. Thar 7ne sfauon snarl samore an0 anaivze 7ne czar usea 7n Soiier NOS. : ana 8 cn a ca7rv oasis 

iNote: Anaivms oases on csmcosire samoles ror weettenas ana nolhavs wail oe accaotaote.! 

Tine aoove anaivsrs wail inc:uae air ar me ror~owrno on an as ounrrereo or as Dumea rxsts: nea7 

content. 96 sutfur. 96 asn ana % mols7ure. Pnutsuant 70 326 IAC T-7 -3. cuartenv remns or 

the 30day rotting wergntea average emissron rate iin oounas oer mrllion St”7 ror eacn aav 

of the auaner snail be suommea by me ias7 aav of the monm foilowmg me ena OT me ctuaner. 

Pecoras of the daily average suifur mntem. heat content ana suffur aioxiae emrsston rate (in 

pounds per million Btu) shall be retained at the station for three year&m 

v made available upon request. 

- 

8. That visible emissions shall be limited to 40% ooacity pursuanr to 326 IAC 5-l. Secrion 

2(a)(l). for attainment areas. 

9. That pursuant to Section 3(d) of 326 IAC S-1. a soeoraf temoorarv exemotion IS nereov 

granted to allow, when necessary, the iorlowrng vrsible stacx emtssrons aunng oo7rer 

startups and shutdowns. 

(a) During boiler startups an exemptlon from the 40% opacity limit is allowed for up 

to 10 (ten) six-minute average periods, or until the flue gas temperature entering the 

electrostatic precipitator reaches 250 degress F, which ever occurs first. In the event 

that the above is exceeded due to special circumstances (such as a cold startuo aher an 

extended outage), NIPSCO shall report this to the OAM within one worxing aav of the 

occurrence. This report shall also include the total accumulatea oenoos or excess 

opacity and the reason why the extended time was necessary. During mese stamm 

periods all reasonable efforts shall be made to minimize the numoer ana magnrmae of 

the exceadmces. 

(b) During boiler shutdowns an exemption from the 40% opacity lima is ailowed for up 

to 10 (ten) six-minute average periods. During these shutdown periods all reasonable 

efforts snail be made to minimize the number and magnitude of the exceedances. 

10. That at no time shall the combined rate of heat input for Boiler Nos. 7 and 8 exceed a total of 

5.012 million Btu’s per hour. 

c-31 
OFECZ OFAIRMANA~ 

INDL4NADEPARlMEWOFENVI~ALMANA(3MENT 

PFQFUSED OPERATION PE$MIT 

NorcM Indiana Public Servxe Cmpany 

Bailky Generating Starlon 

at Burns Hador 

Chesrmon. Imiiana 

has applied fez aurhoczauan ro opexare: 

the oil fired gas turbine (Unit #lo). rared ar: 435 milLion Btu's per hour energy 

input,usedtog-tee.LemzzitydurPgperzods ofpeakdRnand.~sxxn 

are exhausted to the amsp- through a 40 foor ta.U srask hamng a 14 foor 

exitdiamter. 

It.isprqmsed=to~3--*h+~~~ . -c&326IBc-2wktb 

thefallwing- ." : 

1. Thatthedataand information suppLied in the application shaLLbe considered 

part of this pennit. Priorto~change in the 0perationwhichmyresuLt 

inanincreaseinpotentialemissionsexceedingthosespecifiedin326IAC 

2-1-l. this .change mst be approved by the Office of Air Managmt. 

2. matthepennitteeshallcarplyywiththe~oftheJ" 

mntal Menag-t raw (IC~,x+7). Air pall&&XL- (rzL3-l-1) 

and the rol.ee prmulgatd--. 

3. Tt!attbe equipmltshrllbeoperatedandmsinteirledin-withthe 

manufaczturds spacifica tbns. 

4. That pursuant to 326 UC 7-1-21(a)(2), gas turbine Unit #lO shall burn 

~%-iiF,~garrZll~, .sz!cmk~ti#lfl~tlarre.abalLballaintained 

andmsdel?wedabletotheoAMupor-request. 

Pending.mentizicatiur~No. 64-07-92-0247 

Expntum Date JuLv 1, 1992 

THIS IS NOT A PERMIT ---- -- --- - ------ 

. mn 
OFEE OF?JRINDLANADEPARZMENTOFENVIFCWlDCALMANGmDn 

Nor&em Indiana Public Semite Ccnpeny 

Rsiy Generattig Station 

ar: Burns Herbor 

Chesterton, Indiana 

hes appl&d for au- to openite: 

thefacilitiesassociatedwtththcfuelanddryfl~~ands=coraoe 

syst-, s ennngthecDaLfkedboiLzz. 

1. That the data end :imfanmtion supplied in ttks application shall be considered 

pert of this pezmit. Priorto~ckange in theoprationwhichrmyresult 

inaninareaseinptat~tielemissione exceeding thosespecified in 326 IAC 

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. That fugitive dust tanissinns stdlanply with 326 IAC 6-4. 

PeIdinge. 64-m-92-0248 

. -Date July 1. 1992 

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

c-33 
APPENDIX D 

I H 

DOCUMENTATION OF AGENCY CONTACTS 

During the week of January 2, 1989, AFGD project 

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-l 
i H 

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 

RELEVANT EXCERPT: 

The DFB indicated that they process all building 

permit applications for a number of groups including the State 

Fire Marshall and the Bureau of Elevator Safety. The DFB 

conducts a plan review for life and safety features of the 

project. The DFB does not really get into a structural 

review, although structural design may be scrutinised as it 

relates to the life and safety review. 

Indiana currently follows the 1985 UBC with the 

Indiana amendments which basically replaces the first three 

UBC chapters. After April, 1989 the 1988 UBC will be used. 

Indiana also follows the NEC and NFPA. The DFB follows the 

General Administrative Rules (GAR) which specifies how they 

operate. Chapter 5 UBC requirements should be closely 

reviewed and followed. All codes generally have Indiana 

amendments. The DFB commented that as of l/3/89, Indiana 

follows the BOCA Plumbing Code. Also, the 1988 UBC Mechanical 

Code is now followed. 

If the project's design has a major change from the 

appropriate codes, a variance has to be filed. The variance 

will then be evaluated the first week of each month by the 

15-member Building Commission. 

D-2 
The DFB said 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 a structure, the DFB will probably accept this. 

Handicapped parking requirements are based on the appropriate 

ANSI code. 

The DFB said 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 a separate application. The DFB said 

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 1 according to 

the UBC, although the southern part of Indiana is in Zone 2. 

The DFB will accept partial filings for different 

structures. However, after filing the building foundation 

permit for a structure the applicant has 30 days according to 

the GAS to file everything else (plumbing, electrical, etc.). 

Oftentimes the DFB will allow 45 days, then send out a 15-day 

notice to complete the filing. After 60 days 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. 

A six-digit filing number will be assigned to 

submittals and this should be referred to in any 

correspondence. Once the number is known, it could be placed 

on drawings (title block) or specifications. Applications 

will be received initially by the DFB counter and then routed 

to the plan reviewer. Typical applications are processed in 

D-3 
I I 

10 to 15 working days. If the project has not heard from the 

DFB within three weeks, the project should call the DFB. 

A building permit application consists of the 

appropriate form, filing fee and design information. The 

first submittal should also include a project description and 

a plot plan. Subsequent submittals require only a plot plan 

especially for each new building. 

The filing fees include: $100 partial filing fee; 

$50 building/foundation filing fee for two-day approval or $15 

fee for a foundation review for a four-hour turnaround. The 

foundation review includes an examination of footing width, 

insulation, cross ties and anchor bolts. Once the application 

is approved, the DFB will assess a construction fee indicated 

in the fee schedule. If Porter County does not have a 

building inspector, an additional 50 percent will be added to 

the fee for the state to do the inspections. 

Any size drawings are acceptable, although 23 x 36 

inch would be good. The specifications 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 DFB issues its 

approval, an addendum has to be submitted for approval. If 

the changes are made during construction, the DFB can exped .i te 

its approval. 

If during the DFB's review of the design 

information, more than 10 unacceptable features (conditions 1 

are found, the DFB puts the review on hold. These conditions 

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

will continue. The DFB said that this is more of a problem 

with non-resident engineering firms. For example, the Indiana 

code allows for a four-hour fire wall being equivalent to 60 

feet of yard space (yard space allowable). But this only can 

be used on one side of a building one time. Non-residents are 

usually not aware of this aspect of the code. 

Once the DFB issues its approval, the approved plans 

and release placard must be maintained on-site. Following 

approval, the project needs to make arrangements 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 a final inspection. However, the 

inspectors can drop by unannounced. If there is a problem the 

inspectors cannot stop construction, they will refer the 

problem to the state attorney general who will stop 

construction. Following the final inspection, certificates of 

occupancy are issued either by the state or local 

jurisdiction. 

The DFB said 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 who will 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 DFB provided a list indicating that Porter 

County currently does not have a building inspector. 

D-5 
DATE: 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 

RELEVANT EXCERPT: 

The potential wastewater streams were discussed. 

The OWM indicated that it would prefer that stormwater runoff, 

sanitary wastes, and potentially WES wastewater 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 OWM said 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. An approval will probably be issued by letter then, if 

everything is okay, without any monitoring requirement. If 

everything is not okay, additional information may be required 

or possibly the existing NPDES permit may have to be modified. 

D-6 
The existing NPDES permit would also have to be 

modified if separate or new outfall points (other than the 

existing ponds) are proposed. This would possibly require 

submittal of an EPA approved form (e.g., EPA Form 2D) and 

supporting documentation. Regulations require that this 

information be submitted 180 days prior to discharging. 

During this period, the OWM will review the information and 

have a 30-day public comment period on a draft NPDES permit. 

The permit would probably include some discharge monitoring 

requirements. 

If the WES is not used as currently planned and is 

discharged offsite, the OWN will require wastewater quality 

information. This would probably include chlorides, pH and 

TSS. 

In the meeting the OWM said that most Indiana 

streams are classified as suitable for general use and aquatic 

life. 

D-7 
I 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 

RELEVANT EXCERPT: 

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 

a silo. The AFGD system 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 a solid waste 

and can be landfilled. However, the OSHWM said that it would 

like to see EP toxicity 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 a solid waste. If the analyses show a problem, 

the ash will be called a special 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 a solid waste, the landfill 

may require analytical data. 

The OSHWM will initially consider the gypsum as a 

special waste resulting from industrial pollution control. 

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

explained by Stearns-Roger and Northern Indiana, the gypsum is 

not considered a free liquid. Thus, the gypsum could probably 

be disposed in a special 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. Two or three 

sites may be 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 made by the OSHWM. However, the OSHWM 

might possibly issue a go-day approval for disposing the 

gypsum prior to AFGD system startup if test data from existing 

facilities can be provided. The data also may be provided 

from bench tests. Once the AFGD system is operating the OSHWM 

would then require that the appropriate analyses be made. 

Even if the project analyzes the gypsum a landfill may do 

analyses on its own. 

An option besides using an existing landfill is to 

create the project's own restricted waste site for disposing 

ash and/or gypsum. If the project permits a new landfill the 

OSHWM will require EP toxicity information and other tests for 

secondary drinking water standards. The analyses would then 

be evaluated according to the restricted waste site 

D-9 
t I II 

classification where Type I is basically a hazardous 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 6 to 12 months. 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-10 
I w 

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 

RELEVANT EXCERPT: 

It was agreed that the installation of the scrubber 

is not in response to any regulatory requirement. Also, the 

OAM indicated that the pollution control device does not fall 

under PSD regulations. 

Ash will 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 OAM said that for known technologies sometimes 

they can merely process a registration based on information 

provided in a letter. However, for the AFGD system which 

involves an unknown technology, they want a Permit to 

Construct (PTC) Application. The PTC canbe applied for by 

either the owner of the system or the operator (either 

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

project participants need to propose who will hold the PTC 

and who is responsible for various emissions on-site and 

discuss this with the OAR. The OAR said that Northern 

Indiana probably will be held responsible for non-AFGD system 

emission control (e.g. fugitive dust). The PTC is required 

so that the OAR can set maximum limits on various parameters 

to protect air quality and to determine compliance. Probably 

emission limits will be placed on the same parameters that 

are in the existing air permit (SO2, TSP, opacity, etc). The 

OAR did not believe that NOx would be monitored or would be a 

problem. The OAR thought the TSP might be a problem, 

although Northern Indiana and Stearns-Roger indicated that 

the AFGD system was not supposed to impact TSP. 

The PTC application 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 AFGD system. The latter should be 

supported by modeling using methods approved by the OAR. 

The PTC application requires a $100 filing fee, 

plus expenses for the OAR's air quality.review. The total 

review time from the time the PTC application is deemed 

complete is four to five months. This includes one month for 

OAR modeling activities and a 30-day public comment period. 

The latter may result in a public hearing if the OAR deems it 

appropriate based on the comments received (reasonable 

technical basis). This then requires a Zl-day notice period, 

time to set the hearing and finalize a report. Project 

participants may be able to avoid a public hearing by working 

with the organisations who make comments to resolve relevant 

issues.' 

D-12 
I I I II 

As part of the public notice, the OAM will issue a 

Technical Support Document (TSD). The TSD will contain a 

proposed permit with emission limitations and conditions. 

One condition might be having an opacity monitor following 

the ESP. 

The OAM will 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 OAM will issue a renewal 

permit to begin covering the commercial operation period. 

The renewal permit will be based on an evaluation of emission 

information. 

D-13 

I II 

APPENDIX E 

U.S. DEPARTMENT OF ENERGY, 

AND BURNS AND ROE COMMENTS 

ON DRAFT ENVIRONMENTAL IMPACT VOLUME 

E-l 
Department of Energy 

Pittsburgh Energy Technology Center 

P.O. Box 10940 

Pittsburgh, Pennsylvania 15236-0940 

March 14, 1989 

Mr. Frank Bolinsky 

Pure Air 

Two Windsor Plaza 

2 Windsor Drive, Suite 303 

Allentown, PA 18195 

SUBJECT: Draft Environmental Information Volume 

Dear Mr. Bolinsky: 

RECEf VED 

MAR ,I 7 1989 

PURE AIR 

Enclosed are three sets of comments on Pure Ah% Draft Environmental 

Information Volume (EIV). The comments were prepared by: 

1. Winston Williams, Burns and Roe 

2. Tom Ruppel, DOE/PETC 

3. Tom Sarkus, DOE/PETC 

*After you review these comments, we will hold a meeting to discuss both the 

comments and your anticipated response. The meeting will be held on Tuesday, 

March 22, 1989, at Burns and Roe’s home office In Oradell, NJ. It will last from 

9:00 a.m. until approximately 11:OO a.m. Please bring Ste,ve Dennis and Spenser 

Huston along. 

Based upon our milestone schedule, your second (and hopefully final) draft EIV is 

due by April 17, 1989. We will begin working on the Environmental Assessment as 

soon as the EIV is finalized. Therefore, you are encouraged to submit your revised 

EIV as soon as possible. 

Sincerely, 

Enclosures 

cc: w/enclosures 

E. Evans, CT-IO 

R. Rogus, AD-21 

T. Ruppel, CT-10 

T. Sarkus, CT-10 

Thomas A. Sarkus 

Project Manager 

Office of Clean Coal Technology 

E-2 
E-l. l-2(4) 

E-2. 2-l(2) 

E-3. 2-2(-) 

E-4. 2-l(2) 

E-5. 2-3(l) 

E-6. 2-6(6) 

E-7. 2-7(l) 

E-8. 2-lO(3) 

/ I II, 

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 a statement 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, l g. 

Steel plants etc. 

State the t of sulfur in tho US coals that will be 

used or can be used in this AFGD system. 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 AFGD rystem. Figure 2.1-5 is 

a detailed 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 SO2 removal. 

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 WES for 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 SO2 removal?. 

There is need for clarification of the statement 

'no solid waste from the proceasl. What is the 

clareification of the flyash Srom the 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 a constant baeio?. Should 

a more coneervatlve estimate of the efficiency be 

2 

E-9. 

E-10. 

E-11. 

E-12. 

E-13. 

E-14. 

E-15. 

EJ6. 

E-17. 

Z-11(1) 

2-11(l) 

2-ll(3) 

Z-110) 

2-12(3) 

2-12(3) 

2-13(l) 

2-13(l) 

2-13(2) 

E-4 
E-18 * Z-15(1) 

E-19. 2-15(2) 

E-20. 2-16(4) 

E-21. 2-23(l) 

E-22. 2-24( ) 

E-23. 2-25 

E-24. 2-26(l) 

I i U 

EIV Review - Pure Air 

Draft 01 - Mar 3, a9 

made at 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 be regulated by the 

NPDES air 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 how will 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?. 

Show on the figure how this wastewater to the WCS 

mentioned in 2-33 (4) enters the SO2 remova 1 

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 AFGD system that is 

proposed. 

Give the actual feed rates for limestone and SO 

and then state the molhr ratio. This im needed ii’ y 

a layman reading the report, and will help 

clarify the issue. 

3 

E-5 
E-25. 

~-26. 

~-27. 

E-?a. 

E- 29. 

E- 30. 

E- 31. 

E- 32. 

E- 33. 

E- 34. 

2-26(l) 

2-28 (2) 

2-30(l) 

2-30(2) 

2-30(3) 

2-30 

2-34( ) 

2-37 

3-3(2) 

3-4 (1) 

mm. _.~ 

Draft 01 - Mar 3, 89 

It will be Wsful if an analysis of the flue gas 

entering the APGD system 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 NIPSCO power plant is being 

BITI f ttad 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 NPDES permit 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?. 

A note 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 

E-6 
E-35. 

E-36. 

E-37. 

E- 38. 

E- 39. 

E- 40. 

E- 41. 

E- 42. 

E- 43. 

E- 44. 

E- 45. 

3-15( ) 

3-21(l) 

3-22(4) 

3-25(l) 

3-31 

3-43 

2) 

3) 

3-43(3) 

3-50 

4-l(1) 

4-l(2) 

4-l(3) 

EIV Review - Pure Air 

Draft 01 - Mar 3, 69 

reports. 

Attach a map of 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 NIPSCO and 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. 

Why will 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 AFGD system 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 P acharged to Lake Uichlgan, where 

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. 

E-8 
I I 

3-6-89 

TC Ruppe1 

COMMENTS ON PURE AIR DRAFT EIV 

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 S Roe Services Corp., and these review comments, 

we expect 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 S health. 

E-52 

E-53 

E-54 

E-55 

E-56 

E-57 

E-58 

E-59 

E-60 

E-61 

E-62 

P. 2-24. Fig. 2.1-4, Show mass balances, including coal input and 

stream compositions (e.g., SO2, CO2 of stack gases ), before and 

after action. The table 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 be displayed prominently. 

P. 2-6, Include wastewater discharge to Lake Michigan in a ‘before 

action’ flow diagram. Is the wastewater the noncontact cooling 

water? See also 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 TYPICAL NEPA PROCESS TIHE SCHEDULE distributed 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, The Attainment 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 

and Wildlife Service, as appropriate. concerning its agreement with 

the statements on P. 3-25 should appear as an appendix. 

P. 4-4. The alternative gypsum disposal information is important and 

should appear on the 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 a permit in an appendix. 

E-9 
E-63 P. 5-4, The status of the several permits should be included, i.e., 

“Obtained” or targeted date for obtaining. The ANTICIPATED 

PERMITS/APPROVALS Section 5.2 (p. 5-7) is good, but anticipated 

dates for obtaining permits should be given somewhere. 

E-64 App. A, A copy of the letter from the Advisory Council on Historic 

Preservation should in included. 

E-65 App. B is 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 NPDES Permit Table 5.1-2 is good, but 

flows should appear somewhere. 

We would appreciate your ruing a slightly wider looseleaf binder for 

the second and probably final draft. 

E-10 
E-67 

E-68 

E-69 

E-70 

E-71 

COMMENTS ON PURE AIR’S DRAFT ENVIRONMENTAL INFORMATION VOLUME 

T. Sarkus, 3113189 

1. 

2. 

3. 

4. 

5. 

Page 2-5, Last Paragraph. It is noted that Bailly units 7 and 8 have a A 

combined capacity of 528 MW. Yet the draft air permits shown in Appendix B 

show a combined capacity of 518 MW. Please explain. 

Page 2-22. An ultimate coal analysis is shown. I assume that it is an’average 

analysis for coal consumed at the Bailly station, which is good. Can you also 

show the approximate range for each coal characteristic, e.g. S 2.5 to 8.5? 

Page 3-5. Capitalize names of geologic periods such as Silurian. Change 

dolomite limestone to dolomitic limestone. 

Page 4-3. It is mentioned that the green belt will not be affected by this 

project. For the unfamiliar reader, please describe the green belt. 

Page 5-3. In the first paragraph, it is noted that typical coal and limestone B 

samples will be processed in a test unit, in order to assess the by-product 

gypsum. Where is the test unit located, and when will these tests occur? 

Footnotes 

A. The Bailly Station Units 7 and 8 have a permitted combined 

capacity of 528 MW. The Indiana OAM has been notified of 

the typographical error in the permit. 

B. This question has not been addressed in the EIV since DOE 

indicated in a meeting on March 22, 1989 that a verbal 

response would prove satisfactory. 

E-11