## STATE OF MISSOURI



# DEPARTMENT OF NATURAL RESOURCES

MISSOURI CLEAN WATER COMMISSION



# MISSOURI STATE OPERATING PERMIT

In compliance with the Missouri Clean Water Law, (Chapter 644 R.S. Mo. as amended, hereinafter, the Law), and the Federal Water Pollution Control Act (Public Law 92-500, 92 nd Congress) as amended,

Permit No. MO-0004847

Owner: Thermal North America

Address: 99 Summer Street, Suite 900, Boston, MA 02110

Continuing Authority: Veolia Energy Kansas City, Inc.

Address: 115 Grand Blvd., Kansas City, MO 64106

Facility Name: Veolia Energy Kansas City, Inc. Facility Address: 115 Grand Blvd., Kansas City, MO 64106

Legal Description: SW 1⁄4 Sec 32 T 50N R 33W Jackson County

UTM Coordinates: X=363403, Y=4330696

Receiving Stream: Missouri River (P)

First Classified Stream and ID: Missouri River (P)(356)

USGS Basin & Sub-watershed No.: 210300101-0301

is authorized to discharge from the facility described herein, in accordance with the effluent limitations and monitoring requi rements
as set forth herein:



### FACILITY DESCRIPTION Outfall #001- Steam and Air Conditioning Supply – SIC #4961 and NAICS #221330 Outfall #001 is non-contact cooling water. The water from the c oolers flows into a series of discharge pipes that combine into an 84” diameter river water return pipe. This pipe travels underground back to the river where it is connected to a weir assembly. The purpose of the weir is to insure that the 84” discharge line stays full of water from the main plant to the weir to insure that there a lways a slight draw on the line. The water from the slag tanks is discharged to the plant sump pump system where it is pumped into the City of Kansas City, Missouri’s combined sanitary sewer system. Design Flow is 153.67 MGD Average Flow: 7.60 MGD

Maximum Flow: 82.00 MGD

This permit authorizes only wastewater di scharges under the Missouri Clean Water Law and the National Pollutant Discharge Elimination System; it does not apply to other regulated areas. This permit may be appealed in accordance with Section 644.051 .6 of

the Law.

September 1, 2012
Effective Date Sara Parker Pauley, Director, Department of Natural Resources

June 30, 2014
Expiration Date John Madras , Director, Water Protection ProgramA. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS PAGE NUMBER 2 of 4

PERMIT NUMBER MO-0004847

The permittee is authorized to discharge from outfall(s) with se rial number(s) as specified in the application for this permit. The final effluent

limitations shall become effective upon issuance and remain in effect until expira tion of the permit. Such discharges shall be controlled, limited and monitored by the permittee as specified below:

OUTFALL NUMBER AND

EFFLUENT PARAMETER(S) UNITS FINAL EFFLUENT LIMITATIONS MONITORING REQUIREMENTS

DAILY

MAXIMUM WEEKLY

AVERAGE MONTHLY

AVERAGE MEASUREMENT SAMPLE FREQUENCY TYPE

Outfall #001

Flow (Effluent)

Stream Flow (Note 1)

Temperature (Stream) (Note 2)

Temperature (Effluent)

Δ Temperature (Note 3)

Temperature Cap (Note 4) cfs

cfs

°F

°F

°F

°F *

*

*

*

5°F

90°F 5°F

90°F once/day 24-hr total

once/day grab

once/day grab

once/day grab

once/day grab

once/day grab

MONITORING REPORTS SHALL BE SUBMITTED MONTHLY ; THE FIRST REPORT IS DUE OCTOBER 28, 2012

. THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.

B. STANDARD CONDITIONS

IN ADDITION TO SPECIFIED CONDITIONS STATED HE REIN, THIS PERMIT IS SUBJECT TO THE ATTACHED PART I STANDARD CONDITIONS DATED October 1, 1980 and August 15, 1994, AND HEREBY INCORPORATED AS THOUGH

FULLY SET FORTH HEREIN.

A. Effluent Limitations and Monitoring Requirements (continued)

* - Monitoring requirement only.

Note 1: Stream flow. Stream flow is the daily flow of the receiving stream – intake flow.

Note 2: Temperature (Intake). It is recommended that if the In take structure does not adequate ly provide a temperature of the receiving stream, then the fac ility should use the r eceiving stream’s ambient temperature.

Note 3: Δ T = [((Q

s /4)T

s + Q

e T

e ) / ((Q

s /4) + Q

e )] - Ts

Where: Q

s /4 = daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. Q

e = effluent’s flow in cfs.

T

s = stream’s temperature (ambient/intake temperature).

T

e = effluent’s temperature.

Δ T = amount in T °F that the facility is causing the receiving str eam’s temperature to rise at the end of the regulatory mixing zone.

Note 4: T cap = [((Q

s /4)T

s + Q

e T

e )) / ((Q

s /4) + Q

e )]

Where: Q

s /4 = daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. Q

e = effluent’s flow in cfs.

T

s = stream’s temperature (ambient/intake temperature).

T

e = effluent’s temperature.

T cap = temperature of the receiving stream at the end of the regulatory mixing zone.Page 3 of 4

Permit No. MO-00048 47

C. SPECIAL CONDITIONS

1. This permit may be reopened and modified, or alternatively revoked and reissued, to: (a) Comply with any applicable effluent standard or limitation issued or approved under Sections 301(b)(2)(C) and (D), 304(b)(2), and 307(a) (2) of the Clean Water Act, if the effluent standard or limitation so issued or approved: (1) contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or (2) controls any pollutant not limited in the permit. (b) Incorporate new or modified effluent limitations or other conditions, if the result of a waste load allocation study, toxi city test or other information indicates changes are nece ssary to assure compliance with Missouri’s Water Quality Standards (c) Incorporate new or modified effluent limitations or other conditions if, as the result of a watershed analysis, a Total Maximum Daily Load (TMDL) limitation is developed fo r the receiving waters which are cu rrently included in Missouri’s list of waters of the state not fully achieving th e state’s water quality standards, also called the 303(d) list.

The permit as modified or reissued under this paragraph shall also contain any other requirements of the Clean Water Act then applicable.

2. All outfalls must be clearly marked in the field.

3. Permittee will cease discharge by connectio n to a facility with an area-wide manage ment plan per 10 CSR 20-6.010(3)(B) within 90 days of notice of its availability.

4. Water Quality Standards (a) Discharges to waters of the state shall not cause a violation of water quality standards rule under 10 CSR 20-7.031, including both specific and general criteria. (b) General Criteria. The following general water quality criteria shall be applicable to all waters of the state at all times including mixing zones. No water contaminant, by itself or in combination with other substances, shall prevent the waters of the state from meeting the following conditions: (1) Waters shall be free from substances in sufficient amounts to cause the formation of putrescent, unsightly or harmful bottom deposits or prevent full maintenance of beneficial uses; (2) Waters shall be free from oil, scum and floating debris in sufficient amounts to be unsightly or prevent full maintenance of beneficial uses; (3) Waters shall be free from substances in sufficient amounts to cause unsightly color or turbidity, offensive odor or prevent full maintenance of beneficial uses; (4) Waters shall be free from substances or conditions in sufficient amounts to result in toxicity to human, animal or aquatic life; (5) There shall be no significant human health h azard from incidental c ontact with the water; (6) There shall be no acute toxicity to livestock or wildlife watering; (7) Waters shall be free from physical, chemical or hydrologic changes that would impair the natural biological community; (8) Waters shall be free from used tires, car bodies, appliances , demolition debris, used vehicles or equipment and solid waste as defined in Missouri's Solid Waste Law, section 260.200, RSMo, except as the use of such materials is specifically permitted pursuant to section 260.200-260.247.

5. Report as no-discharge when a discharge does not occur during the report period.

6. Changes in Discharges of Toxic Substances The permittee shall notify the Director 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 toxic pollutant which is not limited in the permit, if that discharge will ex ceed the highest of the follow ing "notification levels:" (1) One hundred micrograms per liter (100 μg/L); (2) Two hundred micrograms per liter (200 μg/L) for acrolein and acrylonitrile; five hundred micrograms per liter (500 μg/L) for 2,5 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 the pollutant in the permit application; (4) The level established in Part A of the permit by the Director. (b) That they have begun or expect 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.Page 4 of 4

Permit No. MO-00048 47 C. SPECIAL CONDITIONS (cont).

7. It is a violation of the Missouri Clean Water Law to fail to pay fees associated with this permit (644.055 RSMo).

8. The permittee shall comply with any applicable requir ements listed in 10 CSR 20-9, unless the facility has received writt en notification that the Department has approved a modification to the requirements. The monitoring frequencies contained in this permit shall not be construed by the permittee as a modification of the monitoring frequencies listed in 10 CSR 20-9. If a modification of the monitoring frequencies listed in 10 CSR 20 -9 is needed, the permittee shall submit a written request to th e Department for review and, if deemed necessary, approval.

9. Cooling Water Intake. This permit may be reopened and modified, or alternatively revoked and reissued to: incorporate new or modified requirements applicable to existing cooling water intake structur es under Section 316(b) of the Clean Water Act. In the event that, it is necessary for this permit to be reopened and modi fied, or alternativel y revoked and reissued, permittee shall comp ly with any such new or modified requirements or standards appli cable to existing cooling water intake structures under 316(b) of the Clean Water Act. Until such time that the 316(b) Phase II is promulgated, the permittee is required to continue operat e intake structures as indicated in the approved 1980 and subsequent 2007 impingement studies. 10. There shall be no discharge of polychlorinated biphenyl compounds.

11. Any pesticides discharge from any point source shall comply with the requirements of Federal Insecticide, Fungicide and Rodenticide Act, act as amended (7 U.S.C. 136 et.seq.) and the use of such pesticid es shall be in a manner consistent with its

label.

12. Except for any untreated overflow from facilities designed, constructed and operated to treat the volume of material storag e runoff and construction runoff which is associated with a 10-year, 24-hour rainfall event; discharges resulting from material storage runoff and construction runoff sh all comply with the following limitations:

a) Total suspended solids shall not exceed 50 mg/L at any time. b) The pH shall not be less than 6.5 standard units nor greater than 9.0 standard units at any time.

13. The discharge monitoring reports shall contain the re sults of all sampling, not just representative values.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 2 

### Missouri Department of Natural Resources

F ACT 

### S HEET


### F OR THE 

### P URPOSE OF 

### RENEWAL

OF


### MO-0004847

VEOLIA ENERGY KANSAS CITY, INC.

The Federal Water Pollution Control Act ("Clean Water Act" Secti on 402 Public Law 92-500 as amended) established the National Pollution Discharge Elimination System (NPDES) permit program. This program regulates the discharge of pollutants from point

sources into the waters of the United States , and the release of storm water from certain point sources. All such discharges a re unlawful without a permit (Section 301 of the "Clean Water Act"). After a permit is obtained, a discharge not in compliance wi th all permit terms and conditions is unlawful. Missouri State Operatin g Permits (MSOPs) are issued by the Director of the Missouri Department of Natural Resources (Departm ent) under an approved program, operating in accordance with federal and state laws (Federal "Clean Water Act" and "Missouri Clean Water Law" Sectio n 644 as amended). MSOPs are issued for a period of five (5) years unless otherwise specified.

As per [40 CFR Part 124.8(a)] and [10 CSR 20-6.020(1)2.] a Factsheet shall be prepared to give pertinent information regarding the applicable regulations, rationale for the development of effluent limitations and conditions, and the public participation proc ess for the Missouri State Operating Permit (operating permit) listed below.

A Factsheet is not an enforceable part of an operating permit.

This Factsheet is for an Industrial Facility.



### Part I – Facility Information

Facility Type: IND Facility SIC Code(s): 4961

Facility Description:

This permit, originally issued on February 16, 2007, was modified on May 18, 2011 to change the names of the facility, owner, a nd continuing authority. The facility name has changed from Trigen Kansas City Energy – Grand Avenue Station to Veolia Energy Kansas City, Inc. The owner’s name has changed from Trigen Kans as City District Energy Corp. to Thermal North America, and the continuing authority name has changed from Trigen Kansas City Energy Corp. to Veolia Energy Kansas City, Inc. No other portions of this permit has been addressed or modified.

The Veolia Energy Kansas City, Inc. supplies 185 psig steam into a downtown distribution system, which services Truman Medical Center, Cargill Soybean and Biodiesel plant and National Starch Corn plan t with steam demands and the downtown areas’ customers with building heating. The plant also supplies 33° F chilled water into a downtown distribution system, which services the are a’s customers with building cooling.

The facility’s Pump House is comprised of three sections. The fi rst section was built in the early 1900s and is currently aband oned in place. To the east of the 1900 section is th e 1929 addition. The 1929 s ection houses pumps No. 3, 4, 5 and 6. Pumps No. 3, 4 an d 5 are high volume, low pressure pumps capable of pumping 2.7 million gallons/hour. Pump No. 6 is rated at 0.24 million gallons/hr. an d is used when plant flow requirements are lower than pumps 3, 4, and 5’s pumping curves allow. Pumps No. 3, 4 and 5 have suction hoods and take their suction from the suction bays which are 43 feet deep as measured from the floor of the pump house. USGS pl aces the floor of these suction bays at +2.33’ which is above the USGS Station Gage datum of elevation 706.4’ above sea level.

To the east of the 1929 addition are the 1939 addition which hous es pumps No. 1 and 2. No. 2 pump is a high volume, low pressu re pump capable of moving 2.7 million gallons/hr. No. 1 Pump is capable of 1.47 million gallons/hour and is driven by a Variable Frequency Drive which allows us to vary the speed of the pump to vary the pumping volume and pressure. The suction bays for the se pumps are 55’-2” deep. These bays have a 5-foot wooden bulkhead installed at the bottom of the bay. Both the 1929 and 1939 pump house sections have movable screens installed in the river in front of the pump suction bays to keep debris from entering the p ump suctions. These are slow moving, self-cleaning screens that u tilize river water sprays to clean the screens into a trough wher e the

debris is removed.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 3

The pumps move the river water to the Main Plant via two 54-inc h diameter and one 48-inch diameter discharge pipes where the wa ter is used for once through cooling in the Chiller Condensers, Chille r Turbine Oil Coolers, Bearing Cooling Water Heat Exchanger a nd

the House Turbine Generator Oil Cooler. The water is also used to fill the boiler slag collection tanks which seal the bottom o f the boilers from the atmosphere and provide cooling of the slag (m olten bottom ash) that flows from the boilers. The water from the slag tanks is discharged to the plant sump pump system where it is pumped into the City of Kansas City, Missouri’s sanitary sewer sy stem.

The water from the coolers flows into a seri es of discharge pipes that combine into an 84” diameter river water return pipe. Th is pipe travels underground back to the ri ver where it is connected to a we ir assembly. The purpose of the weir is to insure that the 8 4” discharge line stays full of water from the main plant to the weir to insure that there always a slight draw on the line. The w ater that overflows the weir is discharged into the Missouri river downstream and to the east of the Pump House. Veolia Energy Kansas Cit y, Inc.’s central region manager certified that the facility through its process is not adding pollutants to the cooling water pri or to discharge.

The Design Flow is 153.67 MGD. The receiving stream is the Miss ouri River. All storm water runo ff, material storage runoff and construction runoff flows to the Kansas City Combined Sewer Syst em. Kansas City Water Services Department is the downstream landowner. The city of Kansas City does periodic water quality sa mpling and analysis of the storm water runoff, material storag e runoff and construction runoff. The analysis consists of pH and Total Suspended Solids (TSS).

Have any changes occurred at this facility or in the r eceiving water body that eff ects effluent limit derivation? - Yes; (please provide simple description or reference appropriate location in the Fact Sheet.

- No.

Application Date: 07/14/11 Expiration Date: 02/15/12 Last Inspection: 03/02/11 In Compliance ; Non-Compliance

O UTFALL ( S ) T ABLE : O UTFALL #001

O UTFALL D ESIGN F LOW (CFS) T REATMENT L EVEL E FFLUENT TYPE D ISTANCE TO
C LASSIFIED S EGMENT ( MI )

001 238.2 BMP Non-contact cooling water 0.0

Outfall #001- Steam and Air Conditional Supply – SIC #4961 and NAICS #221330 Non-contact cooling water UTM Coordinates: X=363403, Y=4330696 Design Flow is 153.67 MGD Average Flow: 7.60 MGD

Maximum Flow: 82.00 MGD Receiving Stream: Missouri River (P) First Classified Stream and ID: Missouri River (P) (356)

USGS Basin & Sub-watershed No.: 10300101-0301

Receiving Water Body’s Water Quality & Facility Performance History: Missouri River (P) (356) is listed on the 2010 Missouri 303(d) List for bacteria. This facility is not a source of the listed i mpairment.

Comments: Temperature monitoring of intake and effluent (Outfall #001) non-contact cooling water is proposed with limitations being those specified in Missouri Water Quality Standards Criteria [10 CSR 20-7 .031(4)(D)1.] Upon examination of Veolia Energy Kansas City, Inc. five-year discharge monitoring reports (DMR), the facility shows in compliance with Δ T.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 4



### Part II – Operator Certification Requirements

Not Applicable; This facility is not required to have a certified operator.



### Part III – Receiving Stream Information

A PPLICABLE D ESIGNATIONS OF W ATERS OF THE S TATE : As per Missouri’s Effluent Regulations [10 CSR 20-7.015], the waters of the state are divided into seven (7) categories. Each category lists effluent limitations for specific parameters, whic h are presented in each outfall’s Effluent Limitation Table an d further

discussed in the Derivation & Discussion of Limits section. Missouri or Mississippi River [10 CSR 20-7.015(2)]:

10 CSR 20-7.031 Missouri Water Quality Standards, the Department defines the Clean Water Commission water quality objectives in

terms of “water uses to be maintained and the criteria to protect those uses." The receiving stream and/or 1 st classified receiving

stream’s beneficial water uses to be maintained are located in the Receiving Stream Table locat ed below in accordance with [10 CSR 20-7.031(3)].

R ECEIVING S TREAM ( S ) T ABLE :

W ATERBODY N AME C LASS WBID D ESIGNATED U SES * 12-D IGIT HUC

Missouri River (P) 356 IRR, LWW, AQL, SCR, DWS, IND, WBC-B 10300101-0301

* - Irrigation (IRR), Livestock & Wildlife Wate ring (LWW), Protection of Warm Water Aquatic Life and Human Health-Fish Consumptio n (AQL), Cool Water Fishery(CLF), Cold Water Fishery (CDF), Whole Body Contact Re creation (WBC), Secondary Contact Recreation (SCR), Drinking Water Supply (DWS), Industrial (IND), Groundwater (GRW).

R ECEIVING S TREAM ( S ) L OW -F LOW V ALUES : The flows and level of the Missouri River are controlled by the US Army Corps of Engineers and are subject to human interferenc e. The critical low flow values for the Missouri River were calculated by the U.S. EPA, at a 30Q10 of 28,823 cfs in the summer and 17,248 cfs in the winter (applicable to Ammonia); a 7Q10 of 11,674 cfs (applicable to all other parameters). US EPA conducted their study on February 13-14, 2008.

MIXING CONSIDERATIONS THERMAL : Missouri’s Water Quality Standards [10 CSR 20 -7.031(4)(A)1.], specifically state that mi xing considerations for toxics do not a pply to thermal mixing considerations and that thermal mixing considerations are located in [10 CSR 20-7.031(4)(D)6.], which states the rmal mixing considerations are limited to 25% of the cross-sectional area or volume of a river, unless a biological survey performed in response to 316(a) of the Clean Water Act indicate no significan t adverse effect on aquatic life. For the purpose of mixing considerations, the Department typically uses the 25% of the daily flow vs cross-sectional area. For a more detailed determin ation and discussion of thermal mixing, please see Appendix A: Temperature Limit Guidance.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 5



### Part IV – Rationale and Derivation of E ffluent Limitations & Permit Conditions

A LTERNATIVE E VALUATIONS FOR N EW F ACILITIES : As per [10 CSR 20-7.015(4)(A)], discharges to losing streams sh all be permitted only after other alternatives including land application, discharges to a gaining stream and connection to a regional wastewater treatment facility have been evaluated and determined to be unacceptable for envir onmental and/or economic reasons.

Not Applicable; The facility does not discharge to a Losing Stream as defined by [10 CSR 20-2.010(36)] & [10 CSR 20-7.031(1)(N)], or is an exis ting facility.

A NTI

- BACKSLIDING : A provision in the Federal Regulations [CWA §303(d)(4); CWA §402(c); 40 CFR Part 122.44(I)] that requires a reissued permit to be as stringent as the previous permit with some exceptions.

- All limits in this operating permit are at least as protectiv e as those previously establishe d; therefore, backsliding does not apply.

A NTIDEGRADATION : In accordance with Missouri’s Water Qua lity Standard [10 CSR 20-7.031(2)], the De partment is to document by means of Antidegradation Review that the use of a wate r body’s available assimilative capacity is justified. Degradation is justified b y documenting the socio-economic im portance of a discharging activity after dete rmining the necessity of the discharge.

- Renewal no degradation proposed and no further review necessary.

A REA -W IDE W ASTE T REATMENT M ANAGEMENT & C ONTINUING A UTHORITY : As per [10 CSR 20-6.010(3)(B)], ...An applicant may utilize a lower pr eference continuing authority by submitting, as part of the application, a statement waivin g preferential status from each existing higher preference authority, providing the waiver does not conflict with any area-wide management plan approved under section 208 of the Federal Clean Water Act or any other regional sewage service and treatment plan approved for hi gher preference authority by the Department.

B IOSOLIDS & S EWAGE S LUDGE : Biosolids are solid materials resulting from domestic wastewater treatment that meet federal and state criteria for beneficial uses (i.e. fertilizer). Sewage sludge is solids, semi-solids, or liquid re sidue generated during the treatment of domestic sewage in a tr eatment works; including but not limited to, domestic septage; scum or solids removed in primary, secondary, or advanced wastewater treatment process; and a material derived from sewage sludge. Sewage sludge does not include ash generated during the firing o f sewage sludge in a sewage sludge incinerator or grit and screening generated during preliminary treatment of domestic sewage in a treatment works. Additional information regarding biosolid s and sludge is located at the following web address: http://dnr.mo.gov/env/wpp/pub/index.html, items WQ422 through WQ449.

Not applicable; This condition is not applicable to the permittee for this facility.

C OMPLIANCE AND E NFORCEMENT : Enforcement is the action taken by the Water Protection Program (WPP) to bring an entity into compliance with the Missouri Clea n Water Law, its implementing regulations, and/or any terms and conditions of an operating permit. The primary purpose of the enforcement activity in the WPP is to resolve viol ations and return the entity to compliance.

Not Applicable; The permittee/facility is not currently under Water Protection Program enforcement action.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 6

COAL COMBUSTION RESIDUALS (CCR): Coal Combustion Residuals (CCR), often referred to as coal ash, and is currently considered exem pt wastes under an amendment to RCRA, the Resource Conservation and Recovery Act. Coal ash is re sidues from the combustion of coal in power plants and capture d by pollution control technologies, like scrubbers. Potential environmental concerns from coal ash pertain to pollution from impoundment and landfills leaching in to ground water and structural failures of impoundments.

The US EPA is currently proposing the first- ever national rules to ensure the safe disposal and management of coal ash from coa lfired power plants under the nation’s primary law for regulati ng solid waste, the RCRA. The EPA is putting forward two (2) proposals that reflect different approaches to managing the disposal of coal ash and both are to ensure the safe management of coal ash that is disposed in surface imp oundments and/or landfills.

Both options will prov ide for the first time on a national basis that liners and ground water monitoring are in place at new la ndfills handling coal ash and impoundments in order to prevent leaching of contaminants to groundwater and resulting risks to human hea lth. Under the Subtitle C proposal, EPA is adopting measures intende d to phase out the wet handlin g of CCRs and existing surface impoundments; under the Subtitle D proposal, existing impoundment s would require liners, which will create strong incentives to close these impoundments and transition to safer landfills which store coal ash in dry form. Both proposals will ensure stronge r oversight of the structural integrity of impoundments. Additionally, both options will require liners and groundwater monitori ng, and corrective action if there is any contamination detected. For the Subtitle D Option, the corrective action requirements are no t as
extensive.

Veolia Energy Kansas City, Inc. has electrostatic precipitator (ESP). The fly ash and bottom ash (coal combustion residual) is removed from our facility by Underground Services Company (U I-0000010). USC uses the ash for structural stabilization of underground limestone mines.

P RETREATMENT P ROGRAM : The reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of pollutant properti es in wastewater prior to or in lieu of discharging or otherwise intr oducing such pollutants into a Publicly Owned Treatment Works [4 0 CFR Part 403.3(q)].

Pretreatment programs are required at any POTW (or combination of POTW operated by the same authority) and/or municipality with a total design flow greater than 5.0 MGD an d receiving industrial wastes that interfer e with or pass through the treatment work s or are otherwise subject to the pretreatment standa rds. Pretreatment programs can also be required at POTWs/municipals with a design flow less than 5.0 MGD if needed to prevent interf erence with operations or pass through.

Several special conditions pertaining to the permittee’s pretreat ment program may be included in the permit, and are as follows :

 Implementation and enforcement of the program,

 Annual pretreatment report submittal,

 Submittal of list of industrial users,

 Technical evaluation of need to establish local limitations, and

 Submittal of the results of the evaluation

Not Applicable; The permittee, at this time, is not required to have a Pretreatment Program or does not have an approved pretreatment program.

R EASONABLE P OTENTIAL A NALYSIS (RPA): Federal regulation [40 CFR Part 122.44(d)(1)(i)] requires effluent limitations for all pollutants that are or may be discharged at a level that will cause or have the reasonable potential to cause or c ontribute to an in-stream excursion above narrative or numeric wa ter quality standard.

In accordance with [40 CFR Part 122.44(d)( iii)] if the permit writer determines that an y give pollutant has the reasonable pote ntial to cause, or contribute to an in-stream excursion above the WQS, the permit must contain effluent limits for that pollutant.

Not Applicable; A RPA was not conducted for this facility.

CHLORINATION OF OUTFALL #001 Chlorination (Free Available and/or Total Recoverable) as established in 40 CFR 423.12 and 423.13 is not applicable to this fac ility for once through cooling water due to the fact that this fac ility does not chlorinate. Additionally, WET testing as a schedule condition will not be applied to this facility due to the fact that they do not use pesticides for organisms (e.g., zebra mussels) that o bstruct their

intake structure.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 7

R EMOVAL E FFICIENCY : Removal efficiency is a method by which the Federal Regulations define Secondary Treatment and Equivalent to Secondary Treatment, which applies to Biochemical Oxygen Demand 5-day (BOD 5 ) and Total Suspended Solids (TSS) for Publicly Owned Treatment Works (POTWs)/municipals.

Not Applicable; Influent monitoring is not being required to determine percent removal.

S ANITARY S EWER O VERFLOWS (SSO) AND I NFLOW AND I NFILTRATION (I&I): Sanitary Sewer Overflows (SSOs) are defined as an untreated or partially treated sewage release are considered bypassing under state regulation [10 CSR 20-2.010(11)] and should not be confused with the federal definition of bypass. SSO’s have a variety of cau ses including blockages, line breaks, and sewer defects that allow excess storm water and ground water to (1) enter and overload th e collection system, and (2) overload the treatment facility. Additi onally, SSO’s can be also be ca used by lapses in sewer syste m operation and maintenance, inadequate sewer design and construction, power failures, and vandalism. SSOs also include overflow s out of manholes and onto city streets, sidewalks, and other terrestrial locations.

Additionally, Missouri RSMo §644.026.1 mandates that the Department require proper maintenance and operation of treatment facilities and sewer systems and proper disposal of residual waste from all such facilities.

- Not applicable. This facility is not required to develop or implement a program for maintenance and repair of the collectio n system; however, it is a violation of Missouri State Environmental Laws and Regulations to allow untreated wastewater to discha rge to waters of the state.

S CHEDULE OF C OMPLIANCE (SOC): A schedule of remedial measures included in a permit, including an enforceable sequence of interim requirements (actions, opera tions, or milestone events) leading to compliance with the Missouri Cl ean Water Law, its implementing regulations, and/or the terms an d conditions of an operating permit.

Not Applicable; This permit does not contain a SOC.

S TORM W ATER P OLLUTION P REVENTION P LAN (SWPPP):

In accordance with 40 CFR 122.44(k) Best Management Practices (BMPs) to control or abate the discharge of pollutants when: (1)

Authorized under section 304(e) of the Clean Water Act (CWA ) for the control of toxic polluta nts and hazardous substances from ancillary industrial activities: (2) Authorized under section 402( p) of the CWA for the control of storm water discharges; (3) Numeric effluent limitations are infeasible; or (4) the practices are re asonably necessary to achieve effluent limitations and standard s or to carry out the purposes and intent of the CWA.

In accordance with the EPA’s Developing Your Stormwater Pollution Prevention Pl an, A Guide for In dustrial Operators , (Document number EPA 833-B-09-002) [published by the United States Environmental Protection Agency (USEPA) in February 2009], BMPs are measures or practices used to reduce the amount of pollution entering (regarding this operating permit) waters of the state . BMPs may take the form of a process, activity, or physical structure.

Additionally in accordance with the Storm Wa ter Management, a SWPPP is a series of steps and activities to (1) identify sources of pollution or contamination, and (2) select and carry out actions which prevent or control the pollution of storm water discharg es.

Not Applicable; At this time, the permittee is not requ ired to develop and implement a SWPPP.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 8

T EMPERATURE L IMITS C ONSIDERATIONS : The temperature limits contained in this operating pe rmit are based on Missouri’s Temperature Guidance ( see Appendix A ). Missouri’s Water Quality Standards establish Temperature Criteria that provide several forms of protection from the impacts of heat energy on receiving water bodies. The purpose of the Temperature Limit Guidance is to provide an approach to help both permit writers and the public understand Temperature Criteria and ho w they are applied in Missouri State Operating Permits.

This approach assumes that the receiving wa ter consumes 100% of the heat energy bein g discharged. At any time the permittee ha s reason to believe that their facility discharge may exceed thei r permit temperature limits or if the permittee does exceed thei r permit limit, the permittee may determine it necessa ry to take action that may include, but not limited to, seeking a 316(a) Variance, a Mixing Zone Study, or conduct a “Heat Model”.

If action is taken by the permittee that warra nts a modification to this operating permit, then the permittee will need to subm it an application for a permit modification. Submitting an application for permit modification does not guarantee approval of said a ction and does not directly indicate that the result of said action w ill be implemented into an operating permit. A Quality Assuranc e Project Plan (QAPP) must be submitted for an y alternative complia nce approach.

V ARIANCE : As per the Missouri Clean Water Law § 644.061.4, variances shall be granted for such period of time and under such terms and conditions as shall be specified by the commission in its order. The variance may be extended by affirmative action of the

commission. In no event shall the variance be granted for a period of time greater th an is reasonably necessary for complying with the Missouri Clean Water Law §§644.006 to 644.141 or any standard, rule or regulation promulgated pursuant to Missouri Clean Water Law §§644.006 to 644.141.

Not Applicable; This operating permit is not drafted under premises of a petition for variance.

W ASTELOAD A LLOCATIONS (WLA) FOR L IMITS : As per [10 CSR 20-2.010(78)], the amount of pollutant each discharger is allowed by the Department to release into a given stre am after the Department has determined total amount of pollutant that may be discharged into that stream without endangering its w ater quality.

Not Applicable;

Wasteload allocations were not calculated.

WLA M ODELING : There are two general types of effluent limitations, technology-b ased effluent limits (TBELs) and water quality based effluent limits (WQBELs). If TBELs do not provide ad equate protection for the receiving wa ters, then WQBEL must be used.

Not Applicable; A WLA study was either not submitted or determin ed not applicable by Department staff.

W ATER Q UALITY S TANDARDS : Per [10 CSR 20-7.031(3)], General Criteria shall be applicable to all waters of the state at all times including mixing zones. Additionally, [40 CFR 122.44(d)(1)] directs the Department to establish in each NP DES permit to include conditions to achieve w ater quality established under Section 303 of the Clean Water Ac t, including State narrative criteria for water quality.

W HOLE E FFLUENT T OXICITY (W ET ) T EST : A WET test is a quantifiable method of determining if a discharg e from a facility may be causing toxicity to aquatic life by it self, in combination with or through syne rgistic responses when mixed with receiving stream water.

Not Applicable; At this time, the permittee is not required to conduct WET test for this facility. However, if the facility is required to app ly biocides to the intake structure, the permit will need to be modified and a WET test will be required.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 9

40 CFR 122.41( M )

- B YPASSES : The federal Clean Water Act (CWA), Section 402 prohibits wastewat er dischargers from “bypassing ” untreated or partially treated sewage (wastewater) beyond the headworks. A bypass, which incl udes blending, is defined as an intentional diversion of waste streams from any portion of a treatment facility, [40 CFR 122.41( m)(1)(i)]. Additionally, Missouri regulation 10 CSR 20-2.010(1 1) defines a bypass as the diversion of wastewater from any portion of wastewater treatment facility or sewer system to waters of the state. Only under exceptional and specified limitations do the federal regulations allow for a facility to bypass some or all of the flow from its treatment process. Bypasses are prohibited by the CWA unless a permittee can meet all of the criteria listed in 40 CF R 122.41(m)(4)(i)(A), (B), & (C). Any bypasses from this facility are subject to the reporting requ ired in 40 CFR 122.41(l)(6) a nd per Missouri’s Standard Conditions I, Section B, part 2.b. Additionally, Anticipated Bypasses include bypasses from peak flow basi ns or similar devices designed for peak wet weather flows.

- Not Applicable; This facility does not bypass.

303(d) L IST & T OTAL M AXIMUM D AILY L OAD (TMDL): Section 303(d) of the federal Clean Water Act requires that each state identify waters that are not meeting water quality stand ards and for which adequate water pollution controls have not been require d. Water quality standards protect such beneficial uses of wa ter as whole body contact (such as swimming), maintaining fish and other aquatic life, and providing drinking water for people, livest ock and wildlife. The 303(d) list helps state an d federal agencies keep track of waters that are impaired but not addressed by nor mal water pollution control programs.

A TMDL is a calculation of the maximum amount of a given pollutant that a body of water can abso rb before its water quality is affected. If a water body is determined to be impaired as lis ted on the 303(d) list, then a watershed management plan will be developed that shall include the TMDL calculation

Applicable; MISSOURI RIVER (P)(356) is listed on the 2010 Missouri 303(d) List for Bacteria. This facility is not noted as a contributor to the impairment.

316(a) T HERMAL V ARIANCE Section 316(a) of the Clean Water Act (CWA) applies to point sour ces with thermal discharges. It authorizes the NPDES permitti ng authority to impose alternative effluent limitations for the cont rol of the thermal component of a discharge in lieu of the eff luent limits that would otherwise be required under section 301 or 306 of the CWA.

Regulations implementing section 316(a) are codified at 40 CFR Part 125, subpart H. These re gulations identify the criteria an d process for determining whether an alternative effluent limitation (i.e., thermal variance from the otherwise applicable efflue nt limit) may be included in a permit and, if so, what that limit should be. This means that before a thermal variance can be granted, 4 0 CFR Parts 125.72 and 125.73 require the permittee to demonstrate that the protection and propagation of the water body’s balanced, indigenous population (BIP) of shellfish, fish, and wildlife is being attained.

The burden of proof is on the permittee to demonstrate that it is eligible to receive an altern ative thermal effluent limit und er section 316(a). This means the pe rmittee must demonstrate to the Missouri Department of Natural Resources that a thermal effluent limi t necessary to meet the requirements of sections 301 or 306, sp ecifically 10 CSR 20-7.031(4)(D)1 and 10 CSR 20-7.031(4)(D)5, is more stringent than necessary to assure the protection and propagation of a BIP in and on the body of water into which the disc harge is

made.

- No Demonstration of 316(a) Variance At this time, the permittee is not operating under a 316(a) Va riance and has not requested a 316(a ) Variance. If during the cy cle of this operating permit the permittee determines that a 316(a) Variance is needed, the permit will contain language indicating th at the permit can be reopened and modified, or alternatively revoked and reissued to: incorporate new or modified requirements applica ble to implementing a Department approved 316(a) Variance.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 10

316(b) COOLING WATER INTAKE STRUCTURE Section 316(b) of the Clean Water Act (CWA) applies to new or existing facilities operating a cooling water intake structure (C WIS). Section 316(b) requires that location, design, construction, and capacity of CWISs reflect the be st technology available (BTA) for minimizing adverse environmental impacts (AEI). Under curren t regulations, existing facilities are subject to section 316(b) conditions that reflect BTA for minimizing AEI on a case-by -case, best professional judgment (BPJ) basis.

The Environmental Protection Agency’s (E PA) Phase II Section 316(b) Existing F acilities Rule was remanded to the EPA in Riverkeeper, Inc, et al. v EPA 475 F.3d 83 (2d Cir. 2007). The Federal Water Pollution Control Act Amendments of 1972 require cooling water intake structures to reflect the best available technology for minimizing adverse environmental impact. Best tech nology available must consider intake design, location, construction, and capacity.



### Part V – Effluent Limits Determination

Effluent limitations derived and established in the below Effluent Limitations Table are based on current operations of the fac ility. Future permit action due to facility modification may contain new operating permit terms and conditions that supersede the term s and conditions, including effluent limitations, of this operating permit

E FFLUENT L IMITATIONS T ABLE : O UTFALL #001

PARAMETER U NIT B ASIS FOR
L IMITS D AILY
M AXIMUM W EEKLY
A VERAGE M ONTHLY
A VERAGE M ODIFIED PREVIOUS PERMIT

LIMITATIONS

O UTFALL #001

FLOW ( EFFLUENT ) CFS 1 * NO *

STREAM FLOW ( NOTE 1) CFS 1 * YES **

TEMPERATURE ( STREAM ) ( NOTE 2) ° F 1,3 * NO *

TEMPERATURE ( EFFLUENT ) ° F 1,3 * NO *

Δ T ( NOTE 3) ° F 1,3 5° F 5°F YES **

TCAP ( NOTE 4) ° F 1,3 90° F 90°F YES **

* - Monitoring requirement only. ** - Parameter not previously estab lished in previous state operating permit.

Basis for Limitations Codes :

1. State or Federal Regulation/Law 7. Antidegradation Policy

2. Water Quality Standard (includes RPA) 8. Water Quality Model

3. Water Quality Based Effluent Limits 9. Best Professional Judgment

4. Lagoon Policy 10. TMDL or Permit in lieu of TMDL

5. Ammonia Policy 11. WET Test Policy

6. Antidegradation Review

O UTFALL #001

– D ERIVATION AND D ISCUSSION OF L IMITS :

 Flow (Effluent). In accordance with [40 CFR Part 122. 44(i)(1)(ii)] the volume of effluent di scharged from each outfall is needed to assure compliance with permitted effluent limitations. If th e permittee is unable to obtain effluent flow, then it is the responsibility of the permittee to inform the Department, which may require the submittal of an operating permit modification.

 Flow (Stream). Daily monitoring only requirement in cfs. It is th e Department’s expectations that the permittee will obtain stream flow data from appropriate and applicable upstream USGS or COE (or both) Gauging Stations. If there is a significant distance from the facility to the nearest gauging station, it may be in the best interest of the permittee to fund a new gaugin g station; however, it is not required. Additionally, the Departme nt will only use gauging station data as a viable source of st ream flow. Meaning that flows (design or actual) from other poin t sources will not be considered (i.e., added to the flow determination).

 Temperature (Effluent). Daily monitoring only requirement in °F. Temper ature (Effluent) is the measured temperature of the discharge and is not the measured difference between the intake temperature and the discharge temperature.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 11

 Temperature (Stream). Daily monitoring only requirement in °F. For most facilities, the intake temperature can be used to determine stream’s temperature. However, in some cases, the ambient stream temperature can be used. The permittee will need to inform the Department that they may use the actual stream’s temperature.

 Temperature Cap (Tcap). In accordance with 10 CSR 20-7 .031(4)(D)5., this facility shall not exceed the monthly temperature criteria established of 90°F. Tcap is calculated as follows:

Tcap = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe)]

Where, Qs/4 = the receiving stream flow in cfs di vided by 4 or the flow represented in the cross-sectional area of the receiving strea m divided by 4 in accordance with [10 CSR 20-7.031(4)(D)6.] Qe= Effluent Flow. Ts = Receiving stream’s ambient temperature. A facility’s intake temperature can be used for this parameter if the facility be lieves that it is representative of the receivi ng stream’s actual temperature. Te = Temperature of the Effluent.

For additional description, please see Appendix B – Temperature Limit Guidance.

 Delta Temperature ( Δ T). The permittee shall not cause the temperature of the receiving stream to change by +/- 5°F, in accordance with [10 CSR 20-7.031(4) (D)1.]. Δ T is calculated as follows:

Δ T = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe)] - Ts

Where, Qs/4 = the receiving stream flow in cfs di vided by 4 or the flow represented in the cross-sectional area of the receiving strea m divided by 4 in accordance with [10 CSR 20-7.031(4)(D)6.] Qe= Effluent Flow. Ts = Receiving stream’s ambient temperature. A facility’s intake temperature can be used for this parameter if the facility believes that it is representative of th e receiving stream’s actual temperature. Te = Temperature of the Effluent.

For additional description, please see Appendix A – Temperature Limit Guidance.



### Part VI: Finding of Affordability

Pursuant to Section 644.145, RSMo., the Department is required to determine whether a permit or decision is affordable and make s a finding of affordability for certain permitting and enforcement deci sions. This requirement applies to discharges from combine d or separate sanitary sewer systems or p ublically-owned treatment works.

Not Applicable; The Department is not required to determine find ings of affordability because the facility is not a combined or separate sanitary sewer system for a publically -owned treatment works.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 12



### Part VII – Administrative Requirements

On the basis of preliminary staff review and the application of applicable standards and regulations, the Department, as admini strative agent for the Missouri Clean Water Commission, proposes to issue a permit(s) subject to certain effluent limitations, schedules , and special conditions contained herein and within the operating permit. The proposed determinations are tentative pending public

comment.

P ERMIT S YNCHRONIZATION The Missouri Department of Natural Resources is transitioning from the traditional methods with which Missouri’s water resource s have been managed to a Watershed Based Management (WBM) appr oach. The WBM approach will manage watersheds on the eightdigit Hydrological Unit Code (HUC 8) scale. As permitting and permit synchroniza tion is a key aspect of successful implementatio n of a Watershed Management Plan (WMP), the same HUC8 groups that will move through the WBM cycle will have their permit expirations and issuances synchronized in th e same fiscal year. The typical five-year term of the permit issuances aligns with the proposed five-year WBM cycle and the two processes will be intimately tied together.

The immediate goals of the permit sy nchronization include the following:

 The administrative and technical streamlining of Water Protecti on Program and Regional Office activities such as permitting, inspections, and water quality monitoring.

 Providing the basis for future watershed permitting.

 Beginning to further examine Missouri’s water resources on a watershed basis.

This permit will expire on June 30, 2014 in order to meet the permit synchronization goals.

P UBLIC N OTICE : The Department shall give public notice that a draft permit has been prepared and its issuance is pending. Additionally, publi c notice will be issued if a public hearing is to be held because of a significant degree of interest in and water quality concerns rela ted to a draft permit. No public notice is required when a request for a permit modification or termination is denied; however, the requester and permittee must be notified of the denial in writing.

The Department must issue public notice of a pending operating permit or of a new or reissued statewide general permit. The pu blic comment period is the length of time not less than 30 days following the date of the public notice which interested persons may submit written comments about the proposed permit.

For persons wanting to submit comments regarding this proposed operating permit, then please refer to the Public Notice page lo cated at the front of this draft operating permit. The Public Notice page gives direction on how and where to submit appropriate com ments.

- The Public Notice period for this operating permit is tentatively scheduled to begin in June 2012.

D ATE OF F ACT S HEET : 11 M AY 2012

C OMPLETED B Y :

JOY JOHNSON, E NVIRONMENTAL S PECIALIST III

NPDES P ERMITS U NIT
W ATER P ROTECTION P ROGRAM (573) 751-6982 joy.johnson@dnr.mo.govVeolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 13



### A PPENDIX A 

### : T EMPERATURE LIMIT 

### G UIDANCE 

# Temperature Limits Derivation:
General & Limited Warm-Water

Fisheries Stream Method

Introduction Missouri’s Water Quality Standards (WQS) establish Temperature Criteria that pr ovide several forms of protection from the impacts of heat energy on receiving water bodies. The purpose of this derivation document is to provide a simplistic approach to help both permit writers and the public understand the Missouri WQS’ s Temperature Criteria and how they are applied in Missouri State Operating Permits.

Missouri’s WQS Temperature Criteria [10 CSR 20-7.031(4)(D )] establish two (2) main areas of compliance for general and limited warm-water fisheries. The first compliance requireme nt deals with the rise of temperature in a receiving water body (stream), and the second compliance requirement deals with the overall stream’s temperat ure not to exceed. Both compliance requirements are to be established at the end of the regulatory mixing zone (if applicable – depending on stream classification). These two (2) compliance requirem ents are located in Missouri WQ S [10 CSR 20-7.031(4)(D)1. & 5.].

Missouri WQS Temperature Criteria [10 CSR 20-7.031(4)(D)1.] contains both co mpliance requirements for all streams. However, the overall stream’s temperature not to exceed in th is specific regulation does not cover the Mississippi River. Missouri WQS Temperature Criteria for the Mississippi Rive r is established in [10 CSR 20-7.031(4)(D)5 .], which also

establishes a Percent Deviation Allowance to the Missis sippi River and a maximum temperature not to exceed.

In addition to establishing temperature limits in an operating permit, Missouri’s WQS Temperature Criteria also establish Mixing Zone regulations contain in [ 10 CSR 20-7.031(4)(D)6.]. In comparis on to Missouri’s WQS Toxic Mixing Considerations that use low-flow considerations (i.e, 1Q10, 7Q10, & 30Q10), the Missouri WQS Temperature regulations require the Missouri Department of Natural Resources (Depar tment) to establish a Thermal Mixing Zone limited to either
25% of the cross-sect ional area or 25% volume of a river.

This approach assumes that the receiving water cons umes 100% of the heat energy being discharged.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 14

T ABLE OF C ONTENTS :

A. Compliance with Δ T°F -------------------------------------------------------------------------------------------------------------------P AGE 3

B. Compliance with 90°F Temperature Criteria--- ----------------------------------------------------------------------------------P AGE 4

C. Compliance with Mississippi River Monthly Temperature Criteria

------------ ------------ ------------ ------------ -------Page 5

D. Establishing in an Operating Permit for a 90°F Facility ----------------------------------------------------------------------Page 8

E. Establishing in an Operating Permit for a Mississippi River Facility ----------------------------------------------------Page 9Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 15

A. C OMPLIANCE D ETERMINATION WITH Δ T°F

Missouri WQS Temperature Criteria [10 CSR 20-7.031(4)(D)1.] establis hes that point sources discharging to streams in Missouri shall not raise or lower the temper ature of the receiving stream by 5°F. Be cause this is a WQS, this criteria can be applied at the end of the regulatory Mixing Zone. In the deter mination of compliance with the temperature criteria of

Δ T, several factors/conditions need to be obtained (i.e., inta ke temperature, stream flow, effluent flow, & effluent temperature). Without placing requireme nts in an operating permit for these addi tional parameters, the Department would not be able to determine if compliance with Δ T is being met.

The following calculation determines compliance with the +/- 5°F.

Δ T = [((Q
s /4)T
s + Q
e T
e ) / ((Q
s /4) + Q
e )] - T
s

Where:
Q
s /4: is the daily receiving stream’s mixing zone fl ow in cfs minus the Intake flow in cfs.
Q
e : is the effluent’s flow in cfs.

T
s : is the stream’s temperature (ambient/intake temperature).

T
e : is the effluent’s temperature.

Δ T: is the amount in T°F that the facility is causing the receiv ing stream’s temperature to rise at the end of the regulatory mixing zone.

If the Δ T is greater than 5°F, then the facility is in non-compliance.

The term Q
s will be established in operating permits as Ambient Stream Flow in the unit of cfs. It is the Department’s expectation that the permittee will obtained the Q
s data from appropriate and applic able the nearest upstream USGS or Corp. or Engineers (or both) Gauging Stations.

If there is a significant distance from the facility to the neare st upstream gauging station, it may be in the best interest of the permittee to fund a new gauging station; however, it is not required. Additionally, the Department will only use gauging station data as a viable source of re ceiving stream flow. Meaning that flows (design or actual) from other point sources may not be considered (i.e., added) to the flow determination.

If there is a near-by gauging station downstre am of the facility, then the permittee can use this data but must subtract their daily effluent discharge from the receiving stream flow.

The term Q
e will be established in the operating permit as Flow and reported in the unit cfs. It is recommended that effluent flow be used; however, Intake flow can be used for this determination.

The term T
s will be established in the operating permit as Temper ature (Stream) and reported in the unit °F. For most facilities, the intake temper ature can be used to determine T
s . However, in some cases, ambient stream temperature can be used. The permittee only need inform the Department that they may or may not use ambient stream temperature. Remember, that we are discussing compliance with the receiv ing stream’s temperature and not their intake structure’s water temperature.

The term T
e will be established in the operating permit as Temperatur e (Effluent) and reported in the unit °F. This is not a measurement of the change in temperature from the intake to the effluent, but as it sounds – the temperature of the

effluent.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 16

B. C OMPLIANCE D ETERMINATION WITH 90 °F (T EMPERATURE C AP ):

Missouri WQS Temperature Criteria [10 CS R 20-7.031(4)(D)1.] also establishes that point sources discharging to streams (other than the Mississippi River) shall not cause or contribute to the receiving stre am in excess of 90°F. In order to determine compliance with the T cap , the same equation used for Δ T compliance, with some modification, is used.

The following equation determines compliance with Temperature Cap Criteria of 90°F.

T cap = [((Q
s /4)T
s + Q
e T
e )) / ((Q
s /4) + Q
e )]

Where:
Q
s /4: is the daily receiving stream’s mixing zone fl ow in cfs minus the Intake flow in cfs.
Q
e : is the effluent’s flow in cfs.

T
s : is the stream’s temperature (ambient/intake temperature).

T
e : is the effluent’s temperature.

T cap : is the temperature of the receiving stream at the end of the regulatory mixing zone.

If the T cap is greater than 90°F, then the facility is in non-compliance.

The term Q
s will be established in operating permits as Ambient Stream Flow in the unit of cfs. It is the expectation of the Department that the permittee will obtained the Q
s data from appropriate and applic able the nearest upstream USGS or Corp. or Engineers (or both) Gauging Stations.

If there is a significant distance from the facility to the neare st upstream gauging station, it may be in the best interest of the permittee to fund a new gauging station; however, it is not required. Additionally, the Department will only use gauging station data as a viable source of re ceiving stream flow. Meaning that flows (design or actual) from other point sources may not be considered (i.e., added) to the flow determination.

If there is a near-by gauging station downstre am of the facility, then the permittee can use this data but must subtract their daily effluent discharge from the receiving stream flow.

The term Q
e will be established in the operating permit as Flow and reported in the unit cfs. It is recommended that effluent flow be used; however, Intake flow can be used for this determination.

The term T
s will be established in the operating permit as Temper ature (Stream) and reported in the unit °F. For most facilities, the intake temper ature can be used to determine T
s . However, in some cases, ambient stream temperature can be used. The permittee only need inform the Department that they may or may not use ambient stream temperature. Remember, that we are discussing compliance with the receivi ng stream’s temperature and not their intake structure.

The term T
e will be established in the operating permit as Temperatur e (Effluent) and reported in the unit °F. This is not a measurement of the change in temperature from the intake to t he effluent, but as it is – the temperature of the effluent.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 17

C. C OMPLIANCE D ETERMINATION WITH M ISSISSIPPI R IVER T EMPERATURE C AP C RITERIA :

Missouri WQS Temperature Criteria [ 10 CSR 20-7.031(4)(D)5.] es tablishes that point sources discharging to the Mississippi River shall not cause or contribute to the receivin g stream in excess of a Mont hly Temperature Criteria. The methodology for the determination of compliance is similar to the T cap for 90°F established above. However, the fundamental difference is the Monthly Temperature not to be e xceeded. Thus, the criteria is established per calendar month and per Mississippi River Zone, as follows:

Month A & B C

°F °C °F °C January 45 7 2/9 50 10 February 45 7 2/9 50 10

March 57 13 8/9 60 15 5/9 April 68 20 70 21 1/9 May 78 25 5/9 80 26 6/9

June 86 30 87 30 5/9 July 88 31 1/9 89 31 6/9 August 88 31 1/9 89 31 6/9 September 86 30 87 30 5/9

October 75 23 8/9 78 25 5/9

November 65 18 3/9 70 21 1/9

December 52 11 1/9 57 13 8/9

Zone A = Zone 1A: Des Moines River to Lock and Dam No. 25.

Zone B = Zone 1B: Lock and Dam No. 25 to Lock and Dam No. 26.

Zone C = Zone 2: Lock and Dam No. 26 to the Missouri-Arkansas state line.

In addition to the Monthly T cap , [10 CSR 20-7.031(4)(D)5.] establishes a Pe rcent Deviation Allowance. The Percent Deviation Allowance provides a specific amount of time (in hours) that a faci lity can be out-of-compliance with their Monthly T cap . Finally, [10 CSR 20-7.031(4)( D)5.] establishes a Maximum T cap (T
max ) that is never to be exceeded. The

T
max = T cap + 3°F. Meaning that if a facility lo cated in Zone C is disc harging their cooling wate r during the month of January, their T cap would be 50°F and their T
max would be 53°F as long as they had time available for deviation from their

T cap.

The following equation determines compliance with Monthly T cap.

T cap = [((Q
s /4)T
s + Q
e T
e )) / ((Q
s /4) + Q
e )]

Where:
Q
s /4: is the daily receiving stream’s mixing zone fl ow in cfs minus the Intake flow in cfs.
Q
e : is the effluent’s flow in cfs.

T
s : is the stream’s temperature (ambient/intake temperature).

T
e : is the effluent’s temperature.

T
max : is the temperature of the receiving stream at the end of the regulatory mixing zone.

If the T cap is greater than the Monthly Temperature Criteria, t hen the facility may or may not be in non-compliance with Missouri’s Water Quality Standards, Temperature Criteria due to Percent Deviation Allowance. Please see below:

If the T cap is greater than the monthly limit but is below the T
max ; and there is time available in their applicable Percent Deviation Allowance, then the permittee is in compliance.

If the T cap is greater than the monthly limit but is below the T
max ; but there is NO time available in their applicable Percent Deviation Allowance, then the permittee is in non-compliance.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 18

C. C OMPLIANCE D ETERMINATION WITH M ISSISSIPPI R IVER T EMPERATURE C AP C RITERIA ( CONTINUED ):

If the T cap is greater than the monthly limit and above the T
max ; then the facility is in non-compliance.

The following equation determines compliance with Monthly T
max.

T
max = [((Q
s /4)T
s + Q
e T
e )) / ((Q
s /4) + Q
e )]

Where:
Q
s /4: is the daily receiving stream’s mixing zone fl ow in cfs minus the Intake flow in cfs.
Q
e : is the effluent’s flow in cfs.

T
s : is the stream’s temperature (ambient/intake temperature).

T
e : is the effluent’s temperature.

T
max : is the temperature of the receiving stream at the end of the regulatory mixing zone.

If the T
max is greater than the Monthly Temperature Criteria, then the facility is in non-compliance and the “clock is ticking” with regards to Percent Deviation Allowance time.

The term Q
s will be established in operating permits as Ambient Stream Flow in the unit of cfs. It is the expectation of the Department that the permittee will obtained the Q
s data from appropriate and applic able the nearest upstream USGS or Corp. or Engineers (or both) Gauging Stations.

If there is a significant distance from the facility to the neare st upstream gauging station, it may be in the best interest of the permittee to fund a new gauging station; however, it is not required. Additionally, the Department will only use gauging station data as a viable source of receiving stream flow . Meaning that assumptions (e.g., other point sources) will

not be considered as an added flow determination.

If there is a near-by gauging station downstre am of the facility, then the permittee can use this data but must subtract their daily effluent discharge from the receiving stream flow.

The term Q
e will be established in the operating permit as Flow and reported in the unit cfs. It is recommended that effluent flow be used; however, Intake flow can be used for this determination.

The term T
s will be established in the operating permit as Temper ature (Stream) and reported in the unit °F. For most facilities, the intake temper ature can be used to determine T
s . However, in some cases, ambient stream temperature can be used. The permittee only need inform the Department that they may or may not use ambient stream temperature. Remember, that we are discussing compliance with the receivi ng stream’s temperature and not their intake structure.

The term T
e will be established in the operating permit as Temperatur e (Effluent) and reported in the unit °F. This is not a measurement of the change in temperature from the intake to t he effluent, but as it is – the temperature of the effluent.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 19

Percent Deviation Allowance The site-specific criteria for the Mississippi River allows the permittee to exceed t heir applicable criteria either 1% of the year for Zone 1A and 2; and 5% of the year for Zone 1B . It has been determined that this percent exceedances allowance should be tracked in hours for a calendar year.

Zone 1A and 2 = 1% = [(365)(24) (0.01)] = 87.6 hours = 88 hours Zone 2A = 5% = [(365)(24)(0.05)] = 438 hours.

Tracking of time used for Percent Deviation Allowance, can be captured and tracked via a permit Special Condition or actual effluent limit (if available in MoCWIS). If the permittee’s T cap exceeds the Monthly Temperature Criteria but is below

the T
max and there is available time in the Percent Deviation Allow ance, then the facility is in compliance. However, if the facility exceeds their T cap and does not have any time remaining on their Pe rcent Deviation Allowance, then the facility is in non-compliance. Finally , if a facility exceeds T cap & T
max , they are in non-compliance and the Percent Deviation Allowance “clock” is running during the time of the excursion.

For every episode that the permittee uses their available time , the operating permit shall requir e that the permittee submit the time with their DMR that they exceeded their T cap. This is very important to put this into the permit because it has implications for tracking and data entry in MoCWIS.

The below is an example of Percent Deviation in an Operating Permit. This does not indicate that this is the only language to use, but the language should be very near and try to capture the same.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 20

D. E STABLISHING IN AN O PERATING P ERMIT FOR A 90°F FACILITY :

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS PAGE NUMBER 2 of 8

PERMIT NUMBER MO-xxxxxxx

The permittee is authorized to discharge from outfall(s) with se rial number(s) as specified in the application for this permit. The final effluent

limitations shall become effective upon issuance and remain in effect until expira tion of the permit. Such discharges shall be controlled, limited and monitored by the permittee as specified below:

OUTFALL NUMBER AND

EFFLUENT PARAMETER(S) UNITS FINAL EFFLUENT LIMITATIONS MONITORING REQUIREMENTS

DAILY

MAXIMUM WEEKLY

AVERAGE MONTHLY

AVERAGE MEASUREMENT SAMPLE FREQUENCY TYPE

Outfall #001

Flow (Effluent)

Stream Flow (Note 1)

Temperature (Stream) (Note 2)

Temperature (Effluent)

Δ T (Note 3)

T

ca p (Note 4) cfs

cfs

°F

°F

°F

°F *

*

*

*

5°F

90°F 5°F

90°F once/day grab

once/day grab

once/day grab

once/day grab

once/day grab

once/day grab

A. Effluent Limitations and Monitoring Requirements (continued)

* - Monitoring requirement only.

Note 1: Stream flow. Stream flow is the daily flow of the receiving stream – intake flow.

Note 2: Temperature (Intake). It is recommended that if the In take structure does not adequate ly provide a temperature of the receiving stream, then the fac ility should use the r eceiving stream’s ambient temperature.

Note 3: Δ T = [((Q

s /4)T

s + Q

e T

e ) / ((Q

s /4) + Q

e )] - Ts

Where: Q

s /4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. Q

e : is the effluent’s flow in cfs.

T

s : is the stream’s temperature (ambient/intake temperature).

T

e : is the effluent’s temperature.

Δ T: is the amount in T°F that the facility is causing the receiving stream’s temperature to rise at the end of the regulatory mi xing zone.

Note 4: T cap = [((Q
s /4)T
s + Q
e T
e )) / ((Q
s /4) + Q
e )]

Where: Q

s /4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. Q

e : is the effluent’s flow in cfs.

T

s : is the stream’s temperature (ambient/intake temperature).

T

e : is the effluent’s temperature.

T cap : is the temperature of the r eceiving stream at the end of the regulatory mixing zone.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 21

E. E STABLISHING IN AN O PERATING P ERMIT FOR A M ISSISSIPPI R IVER F ACILITY :

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS PAGE NUMBER 2 of 8

PERMIT NUMBER MO-xxxxxxx

The permittee is authorized to discharge from outfall(s) with se rial number(s) as specified in the application for this permit. The final effluent

limitations shall become effective upon issuance and remain in effect until expira tion of the permit. Such discharges shall be controlled, limited and monitored by the permittee as specified below:

OUTFALL NUMBER AND

EFFLUENT PARAMETER(S) UNITS FINAL EFFLUENT LIMITATIONS MONITORING REQUIREMENTS

DAILY

MAXIMUM WEEKLY

AVERAGE MONTHLY

AVERAGE MEASUREMENT SAMPLE FREQUENCY TYPE

Outfall #001

Flow (Effluent)

Flow (Stream) (Note 1)

Temperature (Stream) (Note 2)

Temperature (Effluent)

Δ T (Note 3)

T cap (Note 4) ( assumes zone c ) January February

March

April May

June July August September

October

November

December

T

max (Note 4) ( assumes zone c ) January February

March

April May

June July August September

October

November

December cfs

cfs

°F

°F

°F

°F

°F *

*

*

*

5°F

50

50

60

70

80

87

89

89

87

78

70

57

53

53

63

73

83

90

92

92

90

81

73

60 5°F

50

50

60

70

80

87

89

89

87

78

70

57

53

53

63

73

83

90

92

92

90

81

73

60 once/day grab

once/day grab

once/day grab

once/day grab

once/day grab

once/day grab

once/day grabVeolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 22

A. Effluent Limitations and Monitoring Requirements (continued)

* - Monitoring requirement only.

Note 1: Stream flow. Stream flow is the daily flow of the receiving stream – intake flow.

Note 2: Temperature (Stream). It is recommended that if the In take structure does not adequately provide a temperature of the receiving stream, then the fac ility should use the r eceiving stream’s ambient temperature.

Note 3: Δ T = [((Q

s /4)T

s + Q

e T

e ) / ((Q

s /4) + Q

e )] - Ts

Where: Q

s /4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. Q

e : is the effluent’s flow in cfs.

T

s : is the stream’s temperature (ambient/intake temperature).

T

e : is the effluent’s temperature.

Δ T: is the amount in T°F that the facility is causing the receiving stream’s temperature to rise at the end of the regulatory mi xing zone.

Note 4: Temperature Cap is the temperature of the receiving stream at the end of the regulatory mixing zone (if applicable). I t is designated with [T cap ] in the equation below.

T cap = [((Q

s /4)T

s + Q

e T

e ) / ((Q

s /4) + Q

e ))]

Where: Q

s /4 = Daily receiving stream’s flow divided by 4 (Mixing Consideration) in cfs minus the Intake flow in cfs.

T

s = Daily receiving stream’s temperature. This can be the actual ambient temperatur e of the receiving stream or the intake water temperature (both in °F). Q

e = Daily effluent flow or intake flow.

T

e = Daily effluent temperature in °F.

(a) If the T cap calculated temperature value is less than the specific month’s Daily Maximum or Monthly Average T cap , the permittee is to report the calculated temperature value as T cap and report a “No Discharge” for T

max. (b) If the T cap calculated result is greater than the specific month’s Daily Maximum and/or Monthly Average T cap limit, but is

below the T

max and there is time available in Percent Deviation Allowance ( see Note 6 ); then the permittee is to report in

accordance with Note 5 below. (c) If the Tcap calculated result is greater than the sp ecific month’s Daily Maximum and/or Monthly Average T cap limit but is

below the T

max , but there is no time available in Percent Deviation Allowance ( see Note 6 ); then the permittee is to report the calculated temperature value as T cap and report a “No Discharge” for T

max . (d) If the T cap calculated result is greater than the specific month’s Daily Maximum and/or Monthly Average T cap and T

max ; then the permittee is to report in accordance with Note 5

. (a)

Note 5: Temperature Maximum is the maximum that a facility can in crease the temperature of the receiving stream by at the end o f the regulatory mixing zone (if applicable. It is designated with the [T

max ] in the equation below and is the T cap monthly limit plus three (+3°F).

T

max = [((Q

s /4)T

s + Q

e T

e ) / ((Q

s /4) + Q

e ))]

Where: Q

s /4 = Daily receiving stream’s flow divided by 4 (Mixing Consideration) in cfs minus the Intake flow in cfs.

T

s = Daily receiving stream’s temperature. This can be the actua l ambient temperature of the receiving stream or the intake wate r temperature (both in °F). Q

e = Daily effluent flow or intake flow.

T

e = Daily effluent temperature in °F.

(a) If the T cap calculated result is greater than the specific month’s Daily Maximum and/or Monthly Average T cap limit, but is

below the T

max and there is time available in Percent Deviation Allowance ( see Note 6 ); then the permittee is to report the calculated temperature value as T

max and report a “No Discharge” for T cap. (b) If the T cap calculated result is greater than the specific month’s Daily Maximum and/or Monthly Average T cap and T

max ; then the permittee is to report the cal culated temperature value as T

max and report a “No Discharge” for T cap.Veolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 23

Note 6 – Missouri’s Water Quality Standards allows permittees to exceed their applicable criteria for 1% of the year in Zone 2A (or C) in the Mississippi River. Percent Deviation Allowan ce shall be tracked in hours per year (please see Special Condition 7 – Percent

Deviation Allowance ).

7. Percent Deviation Allowance Site-specific temperature criteria for the thermal discharges to the Mississippi River allow the permittee to exceed their appl icable temperature criteria for 1% of the year for Zone 1A and 2. This facility discharges to Zone 2 of the Mississippi River. There fore, the permittee is authorized to exceed their Temperature Cap effl uent limitation for 88 hours in on e (1) calendar year. However

, the permittee is not authorized to exceed their Temperature Max limitation at any time. (a) The permittee shall document the time in hours to the neares t minute that their calculated temperature values exceeded a specific month’s Daily Maximum T cap effluent limit. This time is to be subtracted from 88 hours to the nearest minute. (b) The permittee shall submit an annual report on January 28 th of each year that includes the number of hours that the facility exceeded their Temperature Cap effl uent limits for each month during the previous calendar year. (c) If the permittee exceeds their maximum allowed Percent Deviatio n Allowance of 88 hours prior to the end of the calendar year, then the permittee shall submit a Maximum Percent Devi ation Exceeded Report to the Southeast Regional Office within 15 days of notice. (d) Percent Deviation Allowance is not applicable to the permit parameter of Temperature Maximum.

ATTACHMENT 1 VEOLIA ENERGY KANSAS CITY, INC MAPVeolia Energy Kansas City, MO

MO-0004847 Fact Sheet, Page 24

ATTACHMENT 2



### GRAND AVENUE STATION WATER BALANCE

MO

‐ 0004847

INTAKE: 29,300,000 GPD

DISCHARGE TO OUTFALL 001

29,296,000 GPD

8,000 GPD

12,000 GPD 12,000 GPD

48,000 GPD 40,000 GPD

691,000 GPD 48,000 GPD

557,000 GPD STEAM DIST. & EVAP LOSSES

643,000 GPD 86,000 GPD

109,000 GPD 109,000 GPD

14,000 GPD 14,000 GPD

MAY 2012 MISSOURI RIVER 41, 000 CFS MIN. DURING NAVIGATION SEASON

CONDENSER

COOLING,

MISC.

COOLING &

HYDROVACTO

SLAG TANKS

PUMP

SEALS

WATER

SOFTENERS

BOILERS 1A, 6, 7 & 8

GENERAL

SERVICES

SANITARY

KANSAS CITY

SEWERS 309,000 GPD CITY WATER

862,000 GPD