Notes from Site Visit at Seminole Electric Cooperative on January 23, 2013

EPA conducted a site visit at Seminole Electric Cooperative , Inc orporation ’s Seminole Generating Station located in Palatka, FL on Wednesday, January 23, 2013 to learn about the operations at the plant , specifically the dry conveyor bottom ash handling retrofit

. These notes describe the information collected during the site visit. Table 2 , located at the end of the se notes
, identifies the site visit participants. A summary of the bottom ash handling conversion and block diagram of the bottom ash system, provided by Seminole during the site visit, are included as Attachment 1 to these notes. Additionally, a wa ter flow diagram provided by Seminole during
the site visit is included as Attachment 2 to these notes.

Plant Overview

• Seminole operates two coal

- fired generating units at the power plant. Construction of the Seminole plant initiated in October 1979

, for approximately $960 million

. Units 1 and 2, which begin operation in January and December 1984, respectively, each have a gross generating capacity of 715 megawatts (MW). Both units are categorized as base load
units. T able 1 contains some general inf ormation for the two generating units

.

Table 1. Seminole Generating Station Units Operation

Unit Fuel Capacity (MW) Fly Ash Bottom Ash FGD NOx Control FGMC

1 Coal: Bituminous Oil: No. 2 Fuel Oil 715 Dry Ash Handling

– Pressure System Dry Ash Handling Wet System SCR, Overfire Air, Low NOx burner None

2 Coal: Bituminous Oil: No. 2 Fuel Oil 715 Dry Ash Handling

– Pressure System Dry Ash Handling Wet System SCR, Overfire Air, Low NOx burner None

• The Seminole plant covers approximately 1,980 acres. After the plant started producing a gypsum product, Seminole sold a portion of the land to Lafarge, a wallboard manufacturing company that purchas es 100 percent of the gypsum product. [ QUESTION
FOR SEMINOLE: C onfirm the year and approximate acreage of the land sold to Lafarge

. ] Seminole employs approximately 250 employees on site.

• The plant draws raw intake water from the St. Johns River . Seminole also discharges its
treated wastewater to the St. Johns River via NPDES

- permitted Outfall D

- 001. A flow diagram for Seminole is provided in Attachment 2 of this memorandum.

• Seminole primarily burn s bituminous coal from the Southern Illinois Basin and has up to 7 2 additional different sources of coal , primarily including Illinois and Kentucky mines. [QUESTION FOR SEMINOLE: Please provide the chloride content of the coal?]Seminole burns No. 2 fuel oil in Units 1 and 2 for startup and supplemental co

- firing for
flame stabilization.

• Seminole is currently considering switch ing to a natural gas fuel source for the plant, due
to its cost effectiveness. [QUESTION FOR SEMINOLE: If you converted, w ould you modify the existing boilers or install new units for the change to natural gas ? If installing new units, would you install co mbined cycle units?]

• Seminole has the following NOx controls installed for both units: SCR, overfire air, and low NOx burners. The SCR catalyst is not replaced or regenerated onsite. Seminole operates its NOx controls year round

.

• The plant operates two cooling towers which each process 5,000 gallons of water per minute (GPM)

.

• Seminole performs chemical cleaning of the boilers every five years

. [QUESTION FOR SEMINOLE: Is this boiler cleaning the fireside of the boiler or the insid e of the boiler tubes?] T he resulting metal cleaning waste is transported by truck and di sposed offsite. Boiler blowdown and air preheater was h are sent to two percolation ponds (north and south) located at the plant. After the water discharges to groundwater, the plant dredges
the solids and disposes of them in the onsite landfill

. [QUESTION FOR SEMINOLE: Is Seminole required to do any groundwater monitoring around the percolation ponds ? ]

• Seminole operates electrostatic precipitators (ESPs) to control fly ash and particulate emissions from the plant. The ESPs remove approximately 99.7 percent of the fly ash
from the flue gas. Seminole generates approximately 250,000 tons of fly ash per year

.

• Seminole currently has no plans to install flue gas mercury control (FGMC) technologies at the plant. Seminole is already meeting current air r equirements

. Ash Handling Operations

Fly Ash Handling

• Seminole operates dry pressure fly ash handling system s on both units. The dry fly ash handling system s were installed on Units 1 and 2 as part of the original plant design (i.e.,

t he systems were not retrofits )

.

• Each unit has 16 fly ash hoppers. Fly ash is collected from the ESP into the 16 hoppers
and pneu matically conveyed from Units 1 and 2 to two dry fly ash handling storage silos. The two silos are equipped to accept dry fly ash from either Unit 1 or Unit 2. The two flyash silos have the capabilities to moisture condition the fly ash or unload the ash completely dry.

• The transferred fly ash in the two storage silos is used to stabilize the other materials
transferred to the onsite landfill , which is primarily sludge from the FGD wastewater treatment system

. Th e fly ash is mixed with the wastewater tr eatment sludge , using a pugmill unloader, and piled onto a pad near the landfill

. The fly ash is fed to the pugmill using a screw conveyor. Trucks transport the fly ash and sludge mixture from the pad to the landfill.

• Prior to 2000, before sellable gypsum was produced onsite, Seminole was able to sell 100 percent of the fly ash. However, with the production of sellable gypsum, Seminole must

use all of the f ly ash to stabilize the FGD sludge prior to disposal. Seminole’s fly ash has a low enough loss on ignition (LOI) to be market ed

.

• Because the plant uses oil for startup fuel, the LOI of the fly ash is higher during startup.

Bottom Ash

• In 2012, Seminole completed conver s i on of the bottom ash wet sluicing systems on each unit to completely dry bottom ash conveyor systems. Seminole installed Clyde Bergemann Power Group’s (CBPG) DRYCONTM systems on Units 1 and 2 at the plant.
The retrofit of the Unit 2 bottom ash handling system wa s completed in April 2012, and Unit 1 was completed in November 2012. Seminole installed the first DRYCONTM systems (or similar type of dry conveying system) in the United States since the 1980’s. An older version of the dry conveyance system, designed by Magaldi, was installed in the United States at the Crystal River Plant. The combined total cost to convert both units at Seminole was approximately $25 million , including enginee ring, equipment, installation, removal, and other activities

.

• The bottom ash handling conversion took four years from conception through completion. Seminole considered a conversion from the wet sluicing system based on an economic analysis completed in 2007. Seminole chose to retrofit their wet bottom ash sluicing system because it was labor intensive, energy intensive, and vendors were starting to phase out required replacement parts.

• Prior to the conversion, Seminole was wet sluicing bottom ash and e conomizer ash to
four dewatering bins for solids removal. The overflow water from the dewatering bins was recycled back to the bottom ash handling system or sent to a wastewater treatment system, including pH adjustment and settling, prior to discharge to St. Johns River. The wet bottom ash handling system used 26 pumps per unit and generated 300 GPM ofbottom ash sluice. The wet system required an operator to maintain the bottom ash wet sluicing system (i.e., fixing valves and leaks) at all times. Addition ally, sluice water was previously pumped approximately 150 feet to the economizer ash hoppers to collect economizer ash prior to being combined with the bottom ash sluice sent to dewatering bins, all resulting in high operation and maintenance costs.

• Semi nole did not have any problems meeting Florida water quality limitations or discharge permit limitations for the bottom ash sluice; therefore, the plant did not convert the systems due to water quality issues. The plant ultimately decided to convert to the dry handling system because of the benefits result ing from an economic analysis completed
in 2007 , which included less maintenance and labor, safety benefits

, and energy savings.

• Seminole looked at all available bottom ash handling systems for the planned conversion. These systems included complete recycle, mechanical drag systems, dry conveying systems, and pneumatic systems. Based on the economic analysis, Seminole determined
tha t the DRYCONTM installation would result in a lower horsepower requirement for bottom ash handling equipment, a reduced parasitic load (40 MW per unit), reduced labor and maintenance costs, reduced operator exposure to the system

, and thermal efficiency
ben efits . Seminole did not pursue the mechanical drag system due to concerns with drag chain breakage and replacement. [QUESTION FOR SEMINOLE: P lease provide an estimate of the reduced thermal energy losses realized after installing the DRYCONTM system

. ]

• The new DRYCONTM system does not use any water, requires less power, parts, and system

- operator interaction.

• In the DRYCONTM system, the bottom ash from each unit drops into one of three bottom ash hoppers. Each hopper has three pressure gates equipped wit h jaw crushers, which are manually operated to break apart large agglomerations of bottom ash slag to ensure that they are the right size to be cooled and conveyed. The crushers break the bottom ash up to roughly 8 inch pieces. Because of the new hopper de sign and internal temperature, Seminole worked with the contractors to install cameras within the hoppers so operators can observe the operation of the crushers, and any potential issues with boiler slag, prior to sending bottom ash through the rest of the conveyance system. Additionally, the contractors worked with Seminole to install poke holes along the hopper walls to break up or redirect any large pieces of bottom ash potentially causing issues prior to sending to the primary conveyor.

• The three crush ers at the bottom of each hopper have gates; therefore, Seminole can isolate the bottom ash if there are any issues downstream with a conveyor or any part ofthe bottom ash handling system. At full load, the hoppers (with a 4,600 cubic feet capacity) can h old up to four days worth of bottom ash.

• From the crushers, the 8 inch bottom ash pieces fall onto the primary conveyor underneath the boiler. The primary conveyor is fully sealed to the combustion chamber. Negative pressure inside the bottom of the boile r pulls air into the system to cool the bottom ash. The idea is that the incoming air will re

- burn the bottom ash and reduce the unburned carbon level, increasing thermal efficiency.

• The primary conveyor runs horizontally underneath the boiler prior to i nclining up to the primary crusher. The conveyor belt is a chain of linked conveyor pans. The conveyor pans can be removed and replaced separately as necessary, rather than replacing the
entire chain.

• A similar conveyor belt is in place approximately 150 feet above the bottom of the boiler underneath the six economizer hoppers (for each unit). The economizer collecting conveyor dumps the economizer ash into a double dump isolation valve and onto another conveyor. From the second economizer ash conveyor, th e economizer ash is dumped on to the primary conveyor (carrying the bottom ash) prior to the conveyor incline to the primary crusher.

• Bottom ash and economizer ash are conveyed up an incline and dumped into the primary crusher. The primary crusher is actu ally two crushers with a diverter valve by the mouth of the primary conveyor. Seminole built in this redundancy in the event that one crusher requires maintenance. The primary crusher reduces the size of the bottom ash and economizer ash pieces to approxim ately 3 inches. An air inlet is also located at the top of the primary conveyor to pull in extra air to the system for cooling the bottom ash. See Attachment 1 for a diagram of the bottom ash handling system.

• From the primary crusher, 3 inch pieces of bot tom ash and economizer ash fall onto a secondary conveyor. The secondary conveyor inclines to the secondary crusher (built with the same redundancy as the primary crusher). The secondary crusher reduces the size of the bottom ash and economizer ash to appr oximately 3/4 inch pieces. The bottom ash and economizer ash are then deposited into the bottom ash silo.

• The primary and secondary conveyors carry the bottom ash approximately 150 feet from the units to the bottom ash silo. Each unit has an identical conveyor and silo system. The inclines are built into the conveyors to deposit the ash into the silo and to pr ovide enough
time for the bottom ash to cool during the trip from the bottom of the boiler to the silo.• The storage capacity of each bottom ash silo is 20,000 cubic feet, which can store approximately 7 to 9 days of bottom ash and economizer ash. Blowers are installed at the bottom of each silo to ensure that the bottom ash isn’t settling at the bottom of the silos. Ash is unloaded from the silos approximately twice a week. The bottom ash can be unloaded completely dry or moisture conditioned. [QUESTION F OR SEMINOLE: Please provide the moisture content of dry bottom ash.]

• Bottom ash unloaded into an open top dump truck is moisture conditioned and unloaded with a pugmill, using intake water, for dust control. Seminole does not measure the
moisture content of the bottom ash unloaded from the pugmill, but rather, wets the
bottom ash based on the look and feel of the moisture conditioned bottom ash from the pugmill. [QUESTION FOR SEMINOLE: Please provide an estimate of the moisture
content of the moisture cond itioned bottom ash.] Bottom ash unloaded into closed, vacuum trucks is unloaded completely dry using a telescopic chute with a bin vent pulling vacuum off the truck to eliminate fugitive dust. Currently, all bottom ash is unloaded using the pugmill unloade r. The moisture conditioned bottom ash is sold to a concrete manufacturing company. The dry telescopic unloader was installed for future

contracts.

• The pugmill unloader and telescopic chute can unload bottom ash at a rate of 275 tons per
hour.

• The bottom ash from the wet sluicing system had an LOI of 8 to 9. With the new system, particularly from the re

- burning of the bottom ash, the LOI is approximately 1 to 2.

• Seminole hired an outside engineering firm to help prepare the request for proposal for the bottom ash conversion. Additionally, this outside engineering firm was responsible for overseeing the onsite contractors and construction of the system.

• The goal of the dry bottom ash system design was to build the systems with enough capacity in the design (e.g., overdesign the system) to account for emergency situations. Seminole worked with the contractor to incorporate enough capacity into the speed of the

conv eyors to handle different bottom ash loads from the hopper. The DRYCONTM system is designed to handle 10 tons per hour (tph) (the actual bottom ash production rate is 8 tph); however, the conveyor can actually handle up to 40 tph of bottom ash, not
because of the size of the equipment, but because of the speed of the conveyors. Having the variable conveyor speed allows the plant to handle different amounts of bottom ash, which is helpful during start up s and shutdown s because it moves the bottom ash out quic kly. Additionally, if the DRYCONTM system had a maintenance issue, the plant would hold the bottom ash in the hoppers (up to four days storage time when the unitruns at full capacity) and then quickly be able to move the bottom ash running the conveyor at a higher speed. Incorporating this design “redundancy” did not increase the
cost of the retrofit significantly , because the system’s ability to handle additional ash is not in the size of the conveyor belt, rather the speed of the conveyor.

• Similarly, th e plant designed the economizer ash conveyors for the same redundancy. The units produce approximately 1

- 2 tons of economizer ash per hour and the conveyor can handle up to 7 tons of economizer ash per hour.

• The conveyors run constantly at approximately 25 percent of the maximum design speed for the system.

• As part of the request for proposal, Seminole included the specific number of outage days that would be allotted for the conversion (30 days). The retrofit for each unit was successfully completed wi thin the 30 day planned outage, with all necessary preparation done leading up to the outage. For both units the contractor actually completed the conversion within 21 days. After the conversion was complete, the contractors tested the system for three to four days prior to start up. Seminole did not have any notable start up issues, excluding warranty issues with the contractors and learning curves with pressure ratings and temperature settings. Seminole had more issues with the installation of the
first s ystem (on Unit 2) compared to the second installation (on Unit 1).

• Seminole has not had any forced outages because of the DRYCONTM system since its
installation in 2012.

• The installation of the DRYCONTM system was facilitated by vertical space already
avai lable underneath the boiler. The contractors did not have to excavate any space for the removal of the wet sluicing system or installation of the DRYCONTM system. The removal of the wet bottom ash hopper created more maintenance space around the
boilers. Ad ditionally, the area around the boiler is cleaner and safer, as it was previously
covered with water.

• Seminole removed all equipment from the wet sluicing system, including the four dewatering bins and overflow tank , from the site. The majority of the metal was given to the contractor to sell as scrap metal. Seminole saved motors and valves that could be reused throughout the plant. The only pieces of equipment that Seminole kept are the
unloaders underneath the silo where the dewatering bins would dispense the dewatered bottom ash into dump trucks.• Seminole has 5 operators per shift at the power plant . These operators are responsible for all the operations at the plant, including the bottom ash handling system. Th e new system requires significantly less operator interface and is considered to be safer than the old system. At this point, Seminole can quantify the savings on electrical power, maintenance, and operation; h owever, an analysis on improved boiler efficie ncy has not been completed. [QUESTION FOR SEMINOLE: Please provide data on the specific cost savings experienced from converting from the wet sluicing system.]

• The main concern for wear and tear on the system is the affect of the hot bottom ash on the sys tem. The temperature in the bottom of the boiler is 300 oC . Because the conveyors

move so slowly , the fatigue on the equipment is not significant and is not really a

concern.

• Seminole estimates that conveyor plates and other pieces of equipment on the system would need to be replaced every 30 years; however, the entire system would not need to be replaced.

FG D System

• Seminole operates two wet FGD systems, which service Units 1 and 2. Both systems are limestone forced oxidation systems that achieve 92% sulfur dioxide efficiency. Seminole uses 1,000 tons of limestone per day in their FGD systems.

• Seminole does not monitor solids concentrations within the scrubber. However, Seminole operates the scrubber at chloride levels between 8,000

- 12,000 ppm. When the FGD systems were originally installed, the plant did not have a purge stream and had chlorides concentrations ranging from 40,000 to 80,000 ppm. The high chlorides level was corroding the equipment so the plant installed the purge water treatment system to allow the plant to discharge the FGD wastewater from the system

.

• The design maximum chlorides level is 20,000 ppm. Seminole sends blowdown to the wastewater treatment system constantly at a rate of 850 GPM. [QUESTION FOR SEMINOLE: Please confirm that the plan blows down continuously at a rate of 850 GPM?]

• Seminole add s dibasic acid to the scrubbers to improve the sulfur dioxide removal efficiency.

• Seminole uses the following sources of water as makeup to the FGD system as FGD reagent preparation, absorber makeup, or mist eliminator wash water:o Recycled s crubber purg e ;

o Gypsum washwater;

o Landfill leachate;

o Uncapped landfill runoff water;

o Condensate polisher regeneration wastewater;

o Filter backwash water; and

o Service water from St. Johns River.

• FGD slurry blowdown is transferred from each scrubber to the scrubber thickeners (one for each unit) at a rate of 850 GPM. Polymer is added to the thickeners to lubricate the gypsum to facilitate settling.

• The overflow from the thickeners (i.e., FGD scrubber purge) is sent to the supernatant tank (overflow tank) . Some of the water from the supernatant tank is transferred back to the scrubber and some is transferred to the Purgewater Treatment System. Additionally, Seminole has the option to send some of the water to the onsite pond system, depending on system operations. [QUESTION FOR SEMINOLE: Please provide the total flow from the supernatant tank to the treatment system, recycled back to the scrubber, and to the pond system.]

• The underflow from the thickeners is directed to a surge tank once the unprocessed gypsum is thickened to 55 percent solids

. From the surge tank, the underflow it is sent to the vacuum belt filters, which were installed in 2008, for dewatering. Seminole installed
the vacuum bel t filters to replace rotary drum filters; however, the rotary drum filters can still be used in backup situations. Additionally, the plant installed hydrocyclones in 2012 as backups for the thickeners. The plant only uses the hydrocy cl ones if the thickener s are down for maintenance.

• The plant washes the gypsum with service water from St. Johns River as it is applied to
the vacuum belt filter. The filtrate from the vacuum belt filters and the wash water are
transferred back to the thickeners or to the onsi te pond system.

• Seminole sells 100 percent of the produced gypsum to Lafarge. Since 2005, Seminole estimates that approximately 500,000 to 600,000 tons of gypsum is produced every year.

FGD Wastewater Treatment

• The FGD wastewater treatment system (i.e., Purgewater Treatment System) treats the FGD scrubber purge from the supernatant tank

. T he Purgewater Treatment System was originally designed for remove the selenium present in the FGD wastewater. The FGD scrubber purge is sent to one of two batch reactors that operate in parallel. Each batchreactor holds 24,000 gallons of wastewater. As one batch reactor is treated, the other batch reactor is filling with process wastewater from the supernatant tank at 300 GPM.

• As each reactor fills, agitators operate a t high speed. Lime slurry is added to the batch reactor to raise the pH to 8.5 S.U. The plant also adds ferrous chloride to the reactors while the tank is filling. After the reactor is full, the agitators are switched to low speed.

• Seminole sends samples of the influent to the batch reactors to a lab oratory to measure selenium concentrations using atomic absorption. Selenium concentrations at the influent to the batch reactor can range from between 180 ppb to 400 ppb. The treatment system
reduces the selenium levels in the wastewater to 20 ppb and less. Historically, Seminole
has observe d 98 percent selenium removal. [QUESTION FOR SEMINOLE: Please confirm the 98 percent selenium removal.]

• The effluent from the batch reactors is pumped to the clarifier (an old backup thickener). [QUESTION FOR SEMINOLE: Please provide the flow rate from the batch reactors to the clarifier.] Polymer is added to the wastewater flow as it is pumped from the batch
reactors to the clarifier. The retention time in the clarifier is approximately four days.

• The underflow from the clarifier is sent to the fly ash silos to mix with fly ash prior to disposal in the onsite landfill. Alternatively, the plant has two filter presses to dewater the sludge prior to dispo sal in the landfill. [QUESTION FOR SEMINOLE: How often do you dewater the FGD sludge with the filter presses? Why do you use the fly ash to stabilize the FDG solids instead of selling the fly ash and dewatering the FGD solids in the filter presses ? ]

• The o verflow from the clarifier is gravity fed to sand filters

. Filter backwash from the
sand filters is transferred back to scrubber. T he treated water is then mixed w ith treated
domestic wastewater , coal pile runoff, deminer alizer regeneration water, and cooling tower blowdown, treated with sulfuric acid to lower the pH to 7 S.U.

, and then discharged directly to St. Johns River via final outfall D

- 001. Prior to converting the bottom ash handling system, Seminole diluted the FGD wastewater discharge wi th
bottom ash sluice water. Since the conversion to the dry bottom ash system , Seminole has
needed to pull in additional process wastewater for dilution. Therefore, the conversion to the dry bottom ash system did not reduce the amount of intake water requi red by the plant.

• Seminole is currently operating under a consent order to address multiple permit violations for elevated mercury levels coming from the Purgewater Treatment System

. Seminole’s NPDES permit limitation for mercury is 90 ng/L.• Seminole has observed mercury concentrations up to 150 ng/L

- 160 ng/L being discharged to St. Johns River. Seminole usually measures mercury discharge
concentrations at internal outfall I

- 006 (directly from the Purgewater Treatment System) ranging from 400 ng/L to 500 ng/L. These concentrations are diluted ten times when mixed with the cooling tower blowdown and other wastewaters prior to final discharge to St. Johns River. Seminole has observed some mercury concentrations at outfall I

- 006 ranging from 1,00 0 ng/L to 2,000 ng/L.

• Seminole recently installed a new layer of catalyst in each of the SCR systems. Since this installation, Seminole observed large mercury concentration spikes and had two permit
exceedances in two months. Seminole believes that the SC R catalyst is the cause of the high mercury discharges.

• Currently, Seminole has an interim mass

- based permit limit of 2.65 lbs/year for mercury. As part of the consent order, Seminole needs to complete studies to get back into compliance with the mercury permit limitation. As part of the studies, Seminole is evaluating the following:

o S crubber operation ;

o Additional treatment steps;

o Scrubber ORP effects;

o Iron cycling ; and [QUESTION FOR SEMINOLE: Please provide some information on iron cycling ? What type of negative effects could iron cycling have on the gypsum ? ]

o A dding inorganic or organic sulfides to the treatment system

.

• Seminole evaluated the possibility of adding organosulfides to the Purgewater Treatment System and determined that additional reaction tanks and a clarifier would be required for system operation, costing approximately $5 million. Additionally, Seminole de termined that adding large amounts of organosulfide to the system decreased the effluent mercury concentrations by 50 percent

. [ QUESTION FOR SEMINOLE: Do you have any sampling results for dissolved mercury in the system? Was the 50 percent reduction in

mer cury concentrations based on bench scale testing, pilot scale testing, theoretical calculations, or another basis? ]

• Seminole expects that the addition of dibasic acid in the scrubber is increasing selenium concentrations in the scrubber purge water; howev er, Seminole does not believe this has an effect on mercury concentrations in the scrubber purge water

.• Seminole conducted a study to evaluate the possibility of installing the GE Advanced Biological Metals Remov al System (ABMet®) to treat selenium and cyanide. According to the study, t he system did not decrease the cyanide or selenium concentrations in the effluent from the system.

• Seminole also evaluated the possibility of installing a zero liquid discharge (ZLD) system, in comb ination with the proposal of a new coal

- fired unit at the plant. Although Seminole is not moving forward with the new unit, the evaluation of the ZLD system showed high capital, O&M, and landfilling costs for the system. Seminole estimates that
it would li kely cost approximately $100 million just to landfill the solids from the ZLD system.

Landfill and Leachate Collection

• Seminole operates one onsite, lined landfill (FGD Landfill). Seminole is planning to expand the landfill in 2022.

• The FGD landfill was brought online in 1984 and now covers approximately 118 acres. The landfill receives and stores boiler slag, bottom ash, fly ash, calcium sulfate (gypsum), calcium sulfite, pozzolanic material, plant sump solids, cooling tower basin sl udge, and solids from the domestic wastewater treatment. The expansion of the landfill will provide Seminole with 8 to 10 more years of storage space.

• The landfill is lined with a double liner. Additionally, Seminole installed a French drain along three s ides of the landfill to collect leachate , runoff, and groundwater . All of the
collected leachate is transferred to the onsite pond system (EPF Pond Treatment System) and either transferred to the FGD scrubber system or transferred to the Purgewater
Treatme nt System prior to being discharged to St. Johns River.

Ponds

• Seminole has five stormwater ponds, two coal pile runoff ponds, two percolation ponds, and six process wastewater ponds.

• The process wastewater ponds (EPF Pond Treatment System) store FGD scr ubber purge, gypsum wash water, storm water, filter process water, and leachate. All six of the process wastewater ponds are lined. Seminole does not discharge the overflow from the EPF Pond Treatment System directly to surface water, instead the overflow is either sent to the Purgewater Treatment System and ultimately discharged to St. Johns River or used as
FGD absorber make

- up water.

• The two percolation ponds receive boiler blowdown and air heater wastewater.Table 2 . Site Visit Attendees

Name Organization (Representing) Telephone E

- mail

John Lopez SECI

– SGS Palatka 386

- 328

- 9255 x2178 jlopez@seminole

- electric.com

Robert Yarbrough SECI

– Environmental 813

- 739

- 1228 ryarbrough@seminole

- electric.com

Justin Gostnell SECI

– Environmental 813

- 739

- 1375 jgostnell@seminole

- electric.com

Donna Hill Southern Company 205

- 257

- 5234 dbhill@southernco.com

Tom Wess SECI

– HQ 813

- 739

- 1206 twess@seminole

- electric.com

Kevin Misamore SECI

– SGS 386

- 328

- 9255 x2254 kmisamore@seminole

- electric.com

Ron Jordan EPA 202

- 566

- 1003 jordan.ronald@epa.gov

Jezebele Alicea EPA 202

- 566

- 1755 alicea.jezebele@epa.gov

Daisy Wang ERG 703

- 633

- 1692 daisy.wang@erg.com

Elizabeth Sabol ERG 610

- 344

- 0829 elizabeth.sabol@erg.com