Notes from Site Visit at Duke Energy’s Gibson Generating Station on February 2 4 , 2009

EPA conducted a site visit at Duke Energy ’s Gibson Generating Station (Gibson) located in
Gibson County , IN on Tuesday

, February 2 4 , 2009 to learn about the operations at the plant

, specifically the deepwell injection of FGD wastewater and planned conversions to dry fly ash handling

. Table 2 , located at the end of th ese notes , identifies the site visi t participants. The presentation that the Gibson personnel gave during the site visit is provided as Attachment 1 to
th ese notes

.

These notes describe the information collected during the site visit and the pre

- site visit phone call, which was held on Fe bruary 1 3 , 2009.

Plant Overview

**•** Gibson operates five coal

- fired generating units at the plant

. The table below contains some general information on the current operation of each steam electric generating unit. [ QUESTION FOR GIBSON: Please confirm if ESP is cold or hot side.]

Table 1. Gibson Generating Station Unit Operations

Unit Installation
Date Gross Capacity (MW) Particulate Control NOx Control SO 2 Control

1 5/3/1976 670 ESP (cold

- side) Selective catalytic reduction (SCR) Wet flue gas
desulfurization (FGD)

2 4/16/1975 670 ESP (cold

- side) SCR Wet FGD

3 3/28/1978 670 ESP (cold

- side) SCR Wet FGD

4 3/27/1979 670 ESP (cold

- side) SCR Wet FGD

5 10/1/1982 670 ESP (cold

- side) SCR Wet FGD

**•** Gibson burns about 29,000 tons of coal per day. The majority of their coal is Illinois Basin coal, with sulfur concentrations ranging from 1.5 to 5 lbs
SO 2 /MMBTU, but more typically 4.5 to 5.0 SO 2 /MMBTU

. The c hlorine content
of the coal ranges from 0.2 to 0.25 % by weight.

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**•** Gibson is a zero discharge plant and, therefore, does not have a NPDES permit. The Gibson plant transfers all the water to its unlined manmade cooling lake, which covers 3,000 acres and is generally 10 to 12 feet deep . The cooling lake also acts as the service water for the plant. If the plant needs additional service water, the plant pulls water from the Wabash River into the cooling lake, but the cooling lake does not discharge to the Wabash River. [CBI information has been removed from this section.]Page 2

FGD Systems

**•** Gibson stated that they use service water (i.e., cooling lake water) for limestone slurry make up, mist eliminator wash water, gypsum washing (Units 1, 2, and 3 only), and make

- up water to the FGD.

**•** Gibson stated that they can use a blend of service water and reclaim water for gypsum washing, limestone slurry make

- up, and make

- up to the FGD, but they try to use as much service water as possible for the mist eliminator wash. [CBI information has been removed from this section.]

Units 1, 2, and 3 FGD Systems

**•** The Units 1, 2, and 3 FGD systems are all single tower, limestone forced oxidation scrubbers. The FGDs were installed at the following times:

**•** Unit 1

– Fall 2007;

**•** Unit 2

– Spring 2007; and

**•** Unit 3

– Winter 2006.

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Unit 4 FGD System

**•** The Unit 4 FGD system is a dual tower, limestone inhibited oxidation FGD scrubber. Gibson adds emulsified sulfur to the scrubber to prevent the oxidation of calcium sulfite to gypsum.

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Unit 5 FGD System

**•** The Unit 5 FGD system is a horizontal flow, limestone forced oxidation FGD system. Gibson stated that the FGD was originally designed for inhibited oxidation, but it was recently converted to increase sulfur dioxide removals. [ QUESTION FOR G IBSON: Please provide date of conversion.] [CBI information has been removed from this section.]

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**•** Gibson stated that fixating gypsum is the same as fixating calcium sulfite.

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FGD Solids Disposal

**•** Gibson stated that Units 1, 2, and 3 have a shared gypsum stacker, but Units 4 and
5 each have their own FGD solids stacker. Gibson collects the soli ds from the stacker pads and trucks it to the on

- site landfill. The gypsum solids from Units 1, 2, and 3 and the pozzolanic materials from Units 4 and 5 are commingled within
the landfill.

FGD W astewater Treatment and Disposal

FGD Wastewater Treatment

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FGD Wastewater Disposal

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**•** Gibson currently has three nonhazardous injection wells on site. The wells are approximately 12,000 feet deep and cased to 5,200 feet. The ground level footprint is 150’ x 150’. The surface casing goes to 500 feet.

**•** Well 1 currently has a test injection permit. Gibson began inject ing some amount of wastewater down Well 1 in June/July 2007

, [CBI information has been removed from this section.]

**•** Gibson stated that Wells 2 and 3 are almost complete.

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**•** Gibson stated that their contractors have been monitoring TSS, pH, chlorides, calcium, magnesium, and sulfate to determine whether the wastewater is safe to be deep well injected.

Ash Handling

**•** Gibson is planning to convert Units 1

- 3 to dry fly ash handling. They currently expect conversion to begin in Fall 2011 and to be complete by Spring 2012. Construction on all units is expected to simultaneous with scheduled outages. [CBI information has been removed from this s ection.]

**•** Gibson does not expect much change in equipment for the conversion. Currently the vacuum pulls ash out of the hoppers, mixes with water, and transfers to the pond. For dry handling, they will still use the trunk line, but will add piping from
the trunk to the filter separation tank. The ash in the separator tank from Unit 3
will be blown to Units 1 and 2 transfer bins. Ash from Units 1 and 2 will drop directly into the transfer bins.

**•** All bottom ash handling is wet. [CBI information has been remov ed from this section.]

Ash Ponds

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**•** Gibson’s ash pond previously used in the 1980s was closed in 2005

.Page 5

**•** Following conversion to dry fly ash handling, Gibson plans to transfer bottom ash sluice water only to the North Ash Pond.

On

- Site Landfill s

**•** Gibson operates two on

- site landfills: South Landfill and the Fixated Scrubber Sludge (FSS) Landfill.

**•** Gibson ’s South Landfill includes 377 permitted acres. Thirteen acres are currently open. The landfill leachate collects in a separate pond (South Basin)

, which discharges directly to the cooling po nd.

**•** The FSS Landfill, named in 1982, accepts all solids generated at the plant. Fixated materials generated from Units 4 and 5 are stored alongside ash and other solids. Gibson does not segregate the wastes in the landfill. Leachate from this landfill
flo ws into North Basin, and ultimately to the cooling pond.Page 6

Table 2 . Site Visit Attendees

Name Organization (Representing) Telephone E

- mail

Becky Sparks Gibson Station

– Environmental
Coordinator 812

- 386

- 4146 [need address]

Mick Harpenau Gibson

– Engineering [need number] [need address]

Tom McClellan Gibson

– Engineering [need number] [need address]

Debbie Nispel Duke Energy [need number] Debbie.nispel@duke

- energy.com

Robert Wylie Duke Energy 704

- 382

- 4669 rrwylie@duke

- energy.com

Mike Judd Duke Energy [need number] [need address]

Howard Lewis Duke Energy [need number] [need address]

Jim Meiers Duke Energy 317

- 838

- 1955 Jim.meiers@duke

- energy.com

Rick Cleveland Duke Energy 812

- 386

- 4146 [need address]

Donna Hill UWAG 205

- 257

- 5234 dbhill@southernco.com

Keith Condra Indiana DEM [need number] [need address]

Ron Jordan EPA/Office of Water 202

- 566

- 1003 jordan.ronald@epa.gov

Deb Bartram ERG (Contractor to EPA) 703

- 633

- 1669 deborah.bartram@erg.com