2016 Land Disturbance SWPP

LAND DISTURBANCE STORM WATER POLLUTION PREVENTION PLAN (SWPPP) Blue Valley Power Station Ash Impoundment Closure 21500 E. Truman Road Independence, Missouri Presented to: City of Independence Power and Light P.O. Box 1019 Independence, Missouri 64051 Presented by: SCS ENGINEERS 7311 West 130th Street, Suite 100 Overland Park, Kansas 66213 (913) 681-0030 February 2016 File No. 27215142.00 Offices Nationwide www.scsengineers.com

Blue Valley Power Station Ash Impoundment Closure

LAND DISTURBANCE STORM WATER POLLUTION PREVENTION PLAN (SWPPP) Blue Valley Power Station – Ash Impoundment Closure 21500 E. Truman Road Independence, Missouri 64056 Prepared for: City of Independence Power and Light P.O. Box 1019 Independence, Missouri 64051

Prepared by: SCS ENGINEERS 7311 West 130th Street, Suite 100 Overland Park, Kansas 66213 (913) 681-0030 February 2016 File No. 27215142.00

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TABLE OF CONTENTS Section

Page

Engineer’s Certification .................................................................................................................................... iv 1.0 Introduction.............................................................................................................................................. 1 1.1 SWPPP Purpose .............................................................................................................. 1 1.2 SWPPP Objectives ......................................................................................................... 1 1.3 SWPPP Revisions ............................................................................................................ 2 2.0 SITE Evaluation, Assessment, & Planning ............................................................................................ 3 2.1 Site Description ............................................................................................................... 3 2.2 Construction Activities ..................................................................................................... 3 2.2.1 Closure Sequence .................................................................................................3 2.2.2 Major Tasks ............................................................................................................4 2.3 Potential Pollutants ......................................................................................................... 4 2.3.1 Erosion and Sediment...........................................................................................4 2.3.2 Chemicals and Oils ...............................................................................................4 2.3.3 Waste .....................................................................................................................5 2.3.4 Dewatering ............................................................................................................5 2.4 Storm Water Drainage Patterns ................................................................................. 5 2.5 404/401 Permit requirements ..................................................................................... 5 2.6 General Land Disturbance Permit REquirements ...................................................... 5 2.7 Personnel .......................................................................................................................... 6 2.7.1 SWPPP Team.........................................................................................................6 2.7.2 SWPPP Certification ............................................................................................7 2.7.3 CCR Contractor .....................................................................................................7 3.0 Erosion and Sediment Control BMPs................................................................................................... 8 3.1 Temporary Best Management Practices..................................................................... 8 3.1.1 Silt Fence ................................................................................................................8 3.1.2 Channels and Ditches ...........................................................................................8 3.1.3 Vegetative Cover or Erosion Matting ...............................................................9 3.1.4 Mulch .......................................................................................................................9 3.1.5 Dust Control............................................................................................................9 3.1.7 Sedimentation Basin .............................................................................................9 3.2 Permanent Best Management Practices ..................................................................... 9 3.3 Other Controls ............................................................................................................... 10 3.3.1 Maintenance of Construction Entrance/Exit and Roads .............................. 10 3.3.2 Stockpiles............................................................................................................. 10 4.0 Good Housekeeping BMPs ................................................................................................................ 11 4.1 Product Specific BMPs ................................................................................................. 11 4.1.1 Hazardous Products ......................................................................................... 12 4.1.3 Fertilizers ............................................................................................................. 12 4.1.2 Petroleum Products and Oils............................................................................ 12 4.2 Spill Control ................................................................................................................... 12

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5.0

6.0

7.0

4.3 Waste Disposal ............................................................................................................. 13 Inspections and Effluent Limitations................................................................................................... 14 5.1 Inspections ...................................................................................................................... 14 5.2 SAMPLING and Effluent Limitations .......................................................................... 14 RecordKeeping and Notifications ..................................................................................................... 16 6.1 Recordkeeping .............................................................................................................. 16 6.2 Notifications ................................................................................................................... 16 Final Site Stabilization ........................................................................................................................ 17

LIST OF FIGURES Figure 1 – Site Location Map Figure 2 – Ash Impoundment Closure Pre-Construction Figure 3 – Ash Impoundment Closure Post-Construction LIST OF APPENDICES Appendix A – General Permit Appendix B – SWPPP Certification Form Appendix C – Inspection and Maintenance Form

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E N G I N E E R ’ S C E R T I F I C AT I O N Certification By means of this certification, the Professional Engineer affirms this Land Disturbance Storm Water Pollution Prevention Plan (SWPPP) has been prepared in accordance with good engineering practice, including consideration of industry standards and applicable regulations.

Procedures for required inspection and documentation have been established and the SWPPP is adequate for the land disturbance activities at the facility described herein. Such certification in no way relieves the owner or operator of the facility of his duty to fully implement the SWPPP.

Prepared by Patrick M. Goeke, P.E. Project Director SCS Engineers

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1.0

INTRODUCTION

SCS Engineers (SCS) has prepared this Land Disturbance Storm Water Pollution Prevention Plan (SWPPP) for the City of Independence Power and Light (IPL) Blue Valley Power Station (BVPS) in Independence, Missouri. The BVPS has three inactive coal combustion residual (CCR) impoundments (also referred to as ash impoundments or ash ponds) that will undergo closure construction activities. Closure construction activities will impact approximately 50 acres or less of BVPS’s property. The construction activity area at BVPS is referred to as the Facility for the purposes of this SWPPP. The SWPPP has been prepared under the supervision of a Missouri-licensed professional engineer in accordance with the general Missouri State Operating Permit for construction and land disturbance activity (MORA00000). A complete copy of this SWPPP shall be maintained at the IPL office and shall be made available upon request for onsite review. This SWPPP does not modify or supercede the facility’s NPDES SWPPP or any part of the facility’s MO-0115924 permit.

1.1

SWPPP PURPOSE

The purpose of this SWPPP is to identify potential sources of pollution associated with the closure of the ash impoundments that may affect the quality of storm water discharges during the ash impoundment closure activities at the BVPS. The SWPPP describes and outlines the implementation, management, and maintenance of best management practices (BMPs) to reduce the amount of pollutants in storm water discharges associated with the ash impoundment closure activities.

A general Missouri State Operating Permit for construction and land disturbance activity (MORA00000) will be obtained in addition to this SWPPP. A general Missouri State Operating Permit for construction and land disturbance is required if one or more acres of land is disturbed.

A copy of the general permit is included in Appendix A and applicable pages will be replaced following issuance to BVPS.

1.2

SWPPP OBJECTIVES

The ash impoundment closure activities at the BVPS facility will require earthwork activities on approximately 50 acres or less. BMPs will be implemented to minimize erosion and the conveyance of sediment from the facility construction area during rain events. Applicable BMPs and a timeline for their implementation are described in this SWPPP. Approximately 40 acres of the 50 acre Facility consists of the ash impoundments. Storm water collected in the ash impoundments currently do not discharge with the Facility’s storm water, instead the storm water is discharged through Outfall 002, which goes to the Little Blue Valley Sewer District (LBVSD). However, once closure activities are completed, all three of the impoundments will have the ability to discharge storm water to the existing onsite storm water drainage system leaving through Outfall #004 (see Section 2.1). IPL will file for a permit modification following completion of the closure activities.

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1.3

SWPPP REVISIONS

The SWPPP will be revised and updated as appropriate during the duration of the construction activities. IPL will amend the SWPPP at a minimum when the: • Design, operation, or maintenance of BMPs is changed; • Design of the construction project is changed in a way that could significantly affect the quality of storm water discharges; • SWPPP Coordinator inspections indicate deficiencies in the SWPPP or any BMP; • MDNR notifies IPL in writing of deficiencies in the SWPPP; • SWPPP is found to be ineffective in minimizing or controlling erosion and sedimentation; • Settleable Solids from a storm water outfall exceed 2.5 milliliters per liter (ml/L); and • MDNR determines violations of water quality standards may occur or have occurred.

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2 . 0 S I T E E VA L U AT I O N , A S S E S S M E N T, & P L A N N I N G 2.1 SITE DESCRIPTION The BVPS is owned and operated by the City of Independence, Missouri. Three inactive coal ash impoundments are present on the BVPS and occupy approximately 40 acres of the site.

These fly ash impoundments include; the North Fly Ash Pond (17 acres) the South Fly Ash Pond (15 acres), and the Bottom Ash Pond (9 acres). The North Fly Ash Pond and South Fly Ash Pond were taken out of service in 2008 and 1991, respectively. The Bottom Ash Pond ceased accepting Coal Combustion Residuals (CCR) prior to October 14, 2015. The three ponds are inactive and located north of the power plant. The general location of the site is identified in Figure 1. The general site layout of the ash impoundment area including site topography is included as Figure 2.

As described in site specific current Missouri Site Operating Permit number MO-0115924, five outfall locations are identified for this site. These outfall locations include: •

Outfall #001, discharging storm water drainage from Area 1 (southwest portion of the site);

•

Outfall #002, not included in the site specific storm water permit since it is discharged to the Little Blue Valley Sewer District LBVSD for treatment;

•

Outfall #003, discharging storm water drainage from Area 3 (southeast portion of the site);

•

Outfall #004, discharging storm water drainage from Area 4 (northern half of site, discharges east perimeter); and

•

Outfall #005, discharging storm water drainage from Area 5 (southern portion of site).

Outfall #002 and #004 is the only outfall that could reasonably be impacted by the construction activities and the location of outfalls #002 and #004 are shown on Figure 2.

2.2 CONSTRUCTION ACTIVITIES 2.2.1

Closure Sequence

Approximately 40 acres or less of land are anticipated to be disturbed during the inactive ash impoundment closure construction activities. Construction activities are anticipated to begin in May 2016 and finish in August 2018.

Closure will involve grading of the ash within the impoundment and construction of final cover on the impoundments. Closure construction plans detail the type of fill and final cover decisions for the impoundments. The fill will be graded to promote surface water drainage from the top of the final cover, via sheet flow, toward the existing drainage system. The southern portion of the

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Bottom Ash Pond will involve clean closure with the removal of CCR to create an area for a new sedimentation basin for the power plant.

Once the fill is placed and graded, the final cover will be constructed on the fill. The fill will be seeded with a short root vegetation for stabilization. A short root vegetation will help minimize disturbance of the newly placed final cover on the ponds.

Once the majority of the grading is completed within an ash impoundment, the water remaining or collected in the impoundments will be pumped to frac tanks for temporary storage or pumped to be discharged through Outfall #002 for treatment at the LBVSD. Storm water that has contacted ash will not be discharged from the site. Once the water is pumped, as needed, from the ash ponds, the embankments will be lowered to allow storm water to sheet flow from the cover of the impoundments.

2.2.2

Major Tasks

Ash impoundment closure at the facility will proceed in generally the following manner: • • • • • • • •

Place silt fencing; Level and rough grade area; Stabilize disturbed areas; Stockpile topsoil; Construct final cover; Grade and compact the filled area within the berms; Lower, grade, and compact the berms; and Seed the final cover and disturbed areas.

2.3 POTENTIAL POLLUTANTS 2.3.1

Erosion and Sediment

Erosion and sediment will be the primary pollutant of concern for the closure construction activities. The potential sources of sediment to storm water runoff at the site include ash and soil grading, filling, and vehicle tracking (both across and on/off the site). This source of pollution to storm water discharge at the site is likely to occur within areas that have been disturbed by construction and vehicle travel around the construction area.

2.3.2

Chemicals and Oils

Chemical and oil constituents are potential site pollutants and may include leaks or spills of gasoline, diesel, hydraulic oil, antifreeze or coolant, and sanitary toilet fluids. Source areas across the site to storm water discharge include any equipment usage and storage areas, contaminant or equipment staging areas, and locations where sanitary toilets are placed.

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2.3.3

Waste

Potential waste sources may be generated from construction materials, personnel on site, and trash storage areas/bins. These areas for waste placement (such as roll-offs, bins, etc) will be specifically designated and maintained to prevent unnecessary storm water exposure or blowing litter (such as lids on bins).

2.3.4

Dewatering

Dewatering activities will occur in conjunction with the ash impoundment closure. Primary dewatering will occur in the ash impoundments. Water generated from these activities, where water was in contact with ash, will not be discharged except to the LBVSD or frac tanks.

Water from dewatering activities, where water did not come in contact with ash, may be discharged to existing ditches as long as suspended solids and other parameters do not exceed the BVPS’ existing NPDES permit limits.

2.4 STORM WATER DRAINAGE PATTERNS A drainage ditch runs through the site and exits the property on the east side of the site near the northeast corner of the South Fly Ash Pond into an unnamed tributary that runs into the Little Blue Valley River. The confluence of the unnamed tributary and the Little Blue Valley River is approximately 6 miles north/northeast of the northeast corner of the facility property.

Implementation of BMPs is required to minimize the impact of storm water runoff from the area during construction activities. Currently runoff collected within the ash impoundments on-site is collected and pumped into the wastewater treatment lines as part of a currently existing pretreatment permit for the site. The current construction planning for the site involves lowering and grading the bermed edges of the impoundments as one of the final steps. As such, no additional water from the current impoundment area is expected as runoff on-site until the caps have been placed on the impoundments and the existing berms are breached to allow surface runoff from the capped areas to flow to Outfall #004. Water running into the impoundments during construction will continue to be pumped to the LBVSD discharge point.

2.5 404/401 PERMIT REQUIREMENTS A 404 Permit and a 401 Permit are not required for this facility as the discharge of dredged or fill material into the waters of the United States is not planned during construction activities at the site.

2.6 GENERAL LAND DISTURBANCE PERMIT REQUIREMENTS This SWPPP is written to help insure the design, installation and maintenance of effective erosion controls and sediment controls to minimize the discharge of pollutants as required by the general permit. The following requirements have been addressed through this SWPPP document and site construction activity plans and are summarized below.

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Ash, clay, and topsoil will be used during construction. Sediment discharge will be prevented through the existing berms and later by the installation of temporary and permanent BMPs as discussed in this SWPPP. Ash is a fine, loose material and precaution will be taken to prevent excessive erosion and dust by installing silt fences as needed within the construction area and wetting the ash. Topsoil is also a loose material and will not be heavily compacted, so areas with topsoil will be seeded as soon as possible and surrounded by silt fence to prevent excess erosion.

Clay is compact and will not erode as easily as ash or soil. However, where clay is left exposed outside a berm, silt fence will be placed downgradient as a precaution.

The site is well vegetated and has natural buffers. The vegetation and buffers will be maintained as much as possible throughout the construction activity. Vegetation on the berms will be maintained until the regrading of the berms begins. By doing this, the amount of exposed soil during construction activity will be minimized. As soon as possible following regrading, the exposed surface will be seeded again.

Storm water volume and discharge are controlled though the maintenance of the bermed ash impoundment areas with sedimentation ponds inside throughout the duration of the project.

Maintaining the berms will prevent loose soil or ash within the construction area from being discharged elsewhere on site. In addition, silt fence will be placed around the outer edge of the construction area. As the ash is graded, water velocity will not be affected as the slopes are generally planned have a one percent grade. Water velocity within the channels and ditches will be controlled through the use of check dams.

2.7 PERSONNEL IPL is the responsible entity for the ash impoundment closure construction activities at the BVPS. IPL will be responsible for choosing a SWPPP Coordinator for the duration of the closure activities. IPL and the CCR closure contractor will implement the requirements of this SWPPP prior to, during, and after construction activities.

2.7.1

SWPPP Team

The SWPPP Coordinator is responsible for ensuring the implementation and maintenance of the BMPs associated with construction. The SWPPP Coordinator is a person familiar with the facility structures, topography, and construction operations. The SWPPP Coordinator may employ a team of additional personnel to provide assistance with the SWPPP program. The SWPPP assistant will be a representative with the construction contractor •

SWPPP Coordinator – Mr. Leon Daggett, IPL Director (Phone: 816-325-7500)

•

SWPPP Assistants – to be determined, will likely be representatives of IPL, the Oversight Engineer, and the CCR General Contractor

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2.7.2

SWPPP Certification

Prior to initiation of construction activities, the SWPPP Coordinator and designated personnel will review this SWPPP and document their review on the SWPPP Certification Form presented in Appendix B. 2.7.3

CCR Contractor

The CCR Contractor working on site will be required to review this SWPPP, acknowledge the SWPPP contents, and implement the BMPs described in this SWPPP. The CCR Contractor working on site will also be required to finalize selection and placement of temporary and permanent BMPs prior to beginning work at the site.

Finalized placement of the planned temporary and permanent BMPs will be recorded on construction plans for the site. Modifications to the type of BMPs and or location of the BMPs selected for the construction activities will be included as a revision to this SWPPP.

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3.0 EROSION AND SEDIMENT CONTROL BMPS A series of temporary and permanent BMPs will be implemented to control storm water runoff associated with the BVPS ash impoundments closure. The temporary BMPs will be implemented prior to and during facility construction; permanent BMPs will be instituted per the CCR Contractor’s plans as the facility is completed. The CCR Contractor will be responsible for the decision of temporary BMP placement throughout the construction area. The CCR Contractor will also be responsible for the maintenance of the BMPs throughout the construction activities. Additional BMPs or variations on the BMPs listed in the SWPPP may be used with the approval of the SWPPP Coordinator or designee in order to help maintain storm water quality.

All temporary and permanent BMPs will be installed and be compliant with American Public Works Association (APWA) BMP storm water management guidelines.

3.1 TEMPORARY BEST MANAGEMENT PRACTICES The BVPS will employ temporary BMPs before, during, and after during construction activities.

The temporary BMPs will include placement of silt fencing, as well as potentially using temporary diversion berms to minimize the impact of storm water runoff during ash impoundment closure activities. A temporary sedimentation basin could be used within the ash impoundments prior to embankment lowering. Silt fencing will be placed along the low-lying boundaries of the construction area to control sediment and minimize the effects of storm water runoff.

When an area is disturbed and activities have been temporarily halted for at least 14 days, interim stabilization will be initiated immediately and completed within 7 days in that location.

Installed BMPs will be suited to the area disturbed, taking into account the number of acres exposed and the steepness of slopes.

3.1.1

Silt Fence

As facility construction continues, silt fencing will be placed downslope of the final grade to intercept storm water runoff. Silt fencing will also be placed around stockpiles where applicable.

Fencing location details will be finalized and presented on a construction drawing by the CCR Contractor after the bid process is complete.

If a significant amount of sediment begins to accumulate behind the silt fencing, the sediment will be removed promptly. The filter fabric will be inspected for rips and replaced as necessary.

3.1.2

Channels and Ditches

Other channels and ditches at the site will be inspected and maintained as described above.

Inspections should include all storm drain inlets located onsite where construction activities may impact. Inlet protection via silt fences or check dams will be monitored to verify sediment is not entering storm drains and collected sediment is removed.

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As shown on Figures 2 and 3, instream stabilization measures will take place in order to prevent the migration of soil or other contaminants from leaving the site. These measures include check dams and filter socks, which may be placed as considered appropriate by the CCR Contractor in areas of concern along, within, and up-gradient of the receiving ditch or channel on site.

3.1.3

Vegetative Cover or Erosion Matting

Well-established vegetative cover currently exists in areas surrounding the facility. Should vegetation outside the construction area be damaged by work activities, the damaged area will be covered with erosion control matting or seeded with a quick-growing suitable vegetative cover.

3.1.4

Mulch

Mulch may be placed in an area as a soil or erosion by the CCR Contractor as an option to assist with moisture conservation and reduction of erosion during seed germination and vegetation establishment. Mulching will be monitored to verify soil erosion is minimized until seeds have germinated and 70% of the ground surface is vegetated.

3.1.5

Dust Control

Potential sources of dust include gravel placement, road construction, soil placement and movement, and ash placement. When dust is visible outside of the construction site, use dust control measures as necessary to control exposed soil from becoming airborne by wind or by vehicle movement. Dust control measures may include wetting the dust covered area or using an erosion control-type blanket. Dust control can also be achieved by installing surface stabilization measures immediately after completing land grading.

3.1.7

Sedimentation Basin

The facility does not have adequate room downstream of the ash impoundments to construct a sedimentation basin for each drainage area larger than 10 acres. However, since the current ash impoundments were designed to retain water, the ash ponds will act as the sedimentation basins prior to lowering the embankments in designated areas. The water collected in the ash impoundments will be pumped to Outfall #002 for treatment at the LBVSD. Once the embankments of the ash impoundments are lowered as part of the closure construction activities, the storm water will no longer be retained in a sedimentation basin, which will be capped.

3.2 PERMANENT BEST MANAGEMENT PRACTICES Permanent BMPs will be implemented immediately following the construction activities as part of the facility’s separate site SWPPP. The planned location of permanent BMPs is shown on Figure 3. Permanent BMPS include permanent seeding or hydroseeding and bioswales/buffers.

Vegetative cover and the buffers should be installed and maintained per the CCR Contractor’s specifications. Damaged vegetative cover or buffer areas should be reseeded as soon as reasonably possible.

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A new sedimentation basin is planned for installation during the process of clean closure for the southern area indicated in the Bottom Ash Pond. The basin will remain permanently in place following the termination of construction activities to act as a plant water collection area for the site.

Disturbed areas not paved will be reclaimed (e.g., final grading and seeding) upon completion of construction to minimize erosion and sediment transport. These areas will be maintained and inspected as part of the separate site SWPPP.

3.3 OTHER CONTROLS 3.3.1

Maintenance of Construction Entrance/Exit and Roads

A stabilized entrance to the construction area and roads throughout will be utilized to reduce the amount of sediment leaving the site by vehicular traffic. Construction areas experiencing vehicle traffic will be maintained using methods such as wetting, gravel placement and grading to fill significant ruts, or additional gravel placement in order to mitigate dust or mud-tracking throughout and off-site.

The paved street adjacent to the site entrance will be swept as needed to remove excess mud, dirt or rock tracked from the site. Dump trucks hauling material from the construction site will be covered with tarpaulins.

3.3.2

Stockpiles

Stockpiles may be used for soil and aggregates brought on site for construction activities. They may also be used for temporary storage of road gravel. Stockpiles will be placed in an area designated by the SWPPP coordinator or his designee. Care will be taken to prevent sediment or erosion from leaving the site due to the stockpiles. If needed, stockpiles will be tarped or vegetated to reduce erosion or sedimentation potential.

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4.0 GOOD HOUSEKEEPING BMPS The following practices are general construction-related housekeeping BMPs and will be implemented throughout the construction project. Soil and erosion housekeeping BMPs are addressed within Section 3.0. These Good Housekeeping BMPs will apply to all materials and products stored on site.

•

Pickup of waste materials will be regularly scheduled.

•

Efforts will be made to store on site only the amount of the product required to complete the project.

•

Materials stored on site will be organized in an orderly manner and, if possible, stored under a roof or other enclosure.

•

Products will be kept in their original containers with the manufacturer’s label or will otherwise be clearly labeled. If the container is not resealable, an appropriate container will be used and clearly labeled as to the container’s contents.

•

Equipment will be inspected, repaired, and working properly through the implementation of an effective preventative maintenance program.

•

Routine inspections will be conducted to check for leaks or conditions that could lead to discharges of oils, fuels, vegetative material, or chemicals to storm water.

•

Vehicles will be washed as appropriate in order to prevent the tracking of soil off-site.

•

A person will remain at the point of material transfer to minimize the potential for spillage.

•

Adequate spill response equipment and supplies will be available at all materials transfer locations. Appropriate personnel will be adequately trained to respond to spill situations.

•

Adequate space will be provided to facilitate material transfer and easy access (e.g. fueling heavy equipment).

•

When possible, materials and stockpiles will be stored away from direct traffic routes to prevent accidents.

4.1 PRODUCT SPECIFIC BMPS In addition to the above Good Housekeeping BMPs, certain products require the implementation of special measures, as described in the following subsections.

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4.1.1

Hazardous Products

In the event hazardous materials are used on site, the following practices will be implemented to reduce the risk of spills associated with hazardous materials (e.g. cleaning solvents).

•

Safety data sheets (SDSs) will be kept on site in the construction trailer.

•

Any surplus product will be disposed as recommended by the manufacturer or as required

by Missouri Hazardous Waste Laws and Regulations.

4.1.3

Fertilizers

Fertilizers will be applied in the minimum amounts recommended by the fertilizer manufacturer and the project specifications. Fertilizer containers may or may not be stored on site. If stored on site, storage will be in a covered area protected from storm water run-on and run-off. The contents of any partially used bags of fertilizer will be transferred to a sealable plastic bin to avoid spills.

4.1.2

Petroleum Products and Oils

Various fuels and oils may be present on site during construction activities, with products stored in product-appropriate, water-tight containers. When vehicle fueling occurs onsite, the fueling activity should occur in an area provided with appropriate spill control measures whenever possible. Appropriate spill control measures include berming around stored vehicles or equipment and utilization of drip pans under vehicles while fueling or when stored. All equipment fluids generated from vehicle and equipment maintenance activities (when allowed) will be disposed of into designated drums or other suitable containers stored in areas with secondary containment.

All vehicles and equipment will be inspected on each day of use and daily maintenance will take place as necessary. Leaks will be repaired immediately, or the problem vehicle(s) or equipment will be removed from the project site. Spills will be cleaned immediately and disposed of.

4.2 SPILL CONTROL Personnel will be trained in the proper management of spill control measures and good housekeeping and materials management practices as discussed in the previous sections of this plan.

The following practices will be followed for spill prevention and cleanup: •

Manufacturer’s recommended methods for spill cleanup will be clearly posted and site personnel will be informed of the procedures, the location of Safety Data Sheets (SDSs), and the location and proper use of cleanup supplies.

•

Materials and equipment necessary for spill cleanup will be kept in a designated area on site. Equipment and materials will include, but not be limited to, brooms, dust pans,

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mops, rags, gloves, goggles, kitty litter, shovels, sand or sawdust, and plastic and metal trash containers specifically for this purpose.

•

All spills will be cleaned up immediately after discovery.

•

The spill area will be kept well-ventilated, ignition sources turned off, and personnel will wear appropriate protective clothing to prevent injury from contact with a hazardous substance.

•

Spills of toxic or hazardous material will be reported to BVPS.

•

If a spill occurs, the contractor will celan up the spill to BVPS requirements.

The SWPPP Coordinator and SWPPP Assistant will designate appropriate personnel to receive spill prevention and cleanup training. These individuals will each become responsible for a particular phase of prevention and cleanup. The names of responsible spill personnel will be posted in the construction trailer onsite.

Onsite contractors and temporary facility personnel should also be informed of the facility operations, SPCC plan criteria (if applicable), and any other requirements which may affect storm water management practices.

4.3 WASTE DISPOSAL Waste materials will be collected and stored in a covered roll-off. All trash and construction debris from the site will be deposited in the roll-off. The roll-off will be emptied as necessary and the trash will be hauled to an appropriate waste disposal facility. Roll-offs will be covered and lined to prevent storm water contact when the roll-off is not in use and to prevent impacted water from running into or out of the roll-off.

Hazardous materials will be disposed in the manner appropriate to the material, as specified by Missouri regulation or recommended by the manufacturer.

Sanitary waste will be collected from the portable toilets as needed by a local licensed sanitary waste management contractor.

All personnel will be instructed regarding the correct procedure for waste disposal. Notices stating these practices will be posted in the construction trailer and the SWPPP Coordinator and SWPPP assistant will be responsible for implementing these procedures.

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5 . 0 I N S P E C T I O N S A N D E F F L U E N T L I M I T AT I O N S 5.1 INSPECTIONS All major events related to storm water control should be recorded on inspection sheets. Major events include dates of construction or temporary cessation of activities, dates of storm events, and the initiation of erosion control measures.

All structures used for temporary erosion and runoff control will be inspected weekly and within 48 hours following a storm event (or 72 hours if the storm event ceases on a non-work day) with a rainfall amount greater than one-half (1/2) inch. The inspections will be conducted by the Contractor or a member of the Contractor’s SWPPP team. These inspections, in general, will verify the structures are still in good condition and that the sediment is not freely passing through. The storm water outfall impacted by construction activities (Outfall 004) will be inspected for evidence of erosion deposition. When practicable the receiving stream will also be inspected 50 feet downstream of the outfall.

All areas that have been finally stabilized must be inspected at a frequency of at least once per month.

A maintenance inspection report form will be completed after each inspection. Any structural or maintenance issues will be noted in the inspection report and corrected within one week (7 days) of the inspection. If the corrections cannot be made within the one week the reason for the any delays must be explained and documented (with pictures). This documentation must be included and retained along with the regular inspection report. A copy of the inspection report form to be completed by the Contractor’s SWPPP Coordinator is provided in Appendix D. Completed forms will be kept with the SWPPP for a period of three years following from the date of the letter of termination.

If temporary BMPs do not provide effective storm water and sediment control during construction, additional BMPs will be implemented.

5.2 SAMPLING AND EFFLUENT LIMITATIONS Sampling and reporting may be required by the MDNR as a result of illegal discharges, compliance issues, complaint investigations, or other evidence of contamination from activities at the site. If this action is taken, the MDNR will specify the sampling requirements.

The general permit specifies that effluent limitation for Settleable Solids from a storm water outfall may not exceed 2.5 ml/L per Standard Method 2540 F, except immediately following the local 2-year, 24-hour storm event. Additionally, the parameters listed in the benchmark table below must be met as part of the current NPDES permit in place for the site.

21500 E. Truman Road Independence, Missouri

14

SWPPP

Blue Valley Power Station Ash Impoundment Closure

Benchmark Table Parameter Chemical Oxygen Demands Total Suspended Solids pH - Units Oil and Grease

Benchmark 60 mg/L 50 mg/L 6.5-9.0 Standard Units 10 mg/L

All final control measures (BMPs, controls, practices, etc.) must, when utilized, meet the effluent limits as stated above. The control measures will be implemented from the commencement of the construction activities until final stabilization is complete.

21500 E. Truman Road Independence, Missouri

15

SWPPP

Blue Valley Power Station Ash Impoundment Closure

6 . 0 R E C O R D K E E P I N G A N D N O T I F I C AT I O N S 6.1 RECORDKEEPING BVSP staff will retain copies of the SWPPP, the general land disturbance permit and all amendments for the site, results of any monitoring and analysis and all site inspections records.

The records will be maintained in an accessible location and retained for a period of at least three years following the date of the Letter of Termination.

A copy of the SWPPP will be provided to the contractors and employees responsible for installation, operation, or maintenance of any temporary or permanent BMP. The contractors or responsible employees will have a copy of the SWPPP with them while working at the site.

6.2 NOTIFICATIONS BVPS will be responsible for contractor notifications and posting a public notification at the site.

BVPS will be responsible for notifying each contractor or other relevant site employee planned to perform work onsite during the ash impoundment closure activities. Notification includes what action or precautions will be taken while on-site to minimize the potential for erosion or damage to a BMP. A copy of the public notification sign described by MDNR will be posted at the main entrance to the site. The public notification sign will be visible from the public road providing access to the site’s main entrance. An alternate location is acceptable provided the public can see it and the alternate location is noted in this SWPPP. The public notification will remain posted until the permit has been terminated.

21500 E. Truman Road Independence, Missouri

16

SWPPP

Blue Valley Power Station Ash Impoundment Closure

7.0 F I N A L S I T E S T A B I L I Z AT I O N The permit will be terminated when the final site is stabilized. Stabilization is considered achieved when perennial vegetation or pavement cover all areas that have been disturbed. Any vegetated areas will be covered by at least 70 percent plant density over 100 percent of the site.

When stabilization is achieved, BVPS will terminate the permit by notifying the MDNR.

21500 E. Truman Road Independence, Missouri

17

SWPPP

Figures

INDEPENDENCE POWER AND LIGHT BLUE VALLEY POWER STATION W GH I H AY 78

400

SCALE

0 400 FEET

BLUE VALLEY POWER STATION

INDEPENDENCE POWER & LIGHT

APPROXIMATE WORK AREA FOR CONSTRUCTION ACTIVITIES AND LAND DISTURBANCE SWPPP

7311 W. 130th St, Ste. 100 Overland Park, Kansas 66213 PH. (913) 681-0030 FAX. (913) 681-0012

BOTTOM ASH IMPOUNDMENT

SCS ENGINEERS

LAND DISTURBANCE SWPPP

SITE LOCATION MAP

SOUTH FLY ASH IMPOUNDMENT

1

21500 E. TRUMAN RD, INDEPENDENCE, MISSOURI

S. POWELL RD.

N:\City of Independence\Independence Power & Light\Projects\27215142.00 - Ash Pond Closure Design\AutoCAD\SWPPP D1 - Site Location.dwg Feb 19, 2016 - 11:06am Layout Name: 11x17 By: 3789rdt

LE

LITT

BLU EP

NORTH ASH IMPOUNDMENT KW Y

NOTE: AERIAL FROM GOOGLE EARTH IMAGERY DATED MARCH 30, 2015.

E. TRUMAN RD. 800

3

NOTES: APPROXIMATE ASH IMPOUNDMENT BOUNDARY FENCE (APPROXIMATE) EXISTING ROAD RAILROAD TRACKS OVERHEAD ELECTRIC (APPROXIMATE)

STORM WATER CULVERT

POWER / LIGHT POLE EXISTING FLOW ARROW (SEE NOTE 4) FUTURE FLOW ARROW (SEE NOTE 5) SILT FENCING

AERIAL IMAGE FROM SHAFER, KLINE, & WARREN, INC. DATED JULY 2015.

2.

ASH IMPOUNDMENT BOUNDARIES, FENCING, EXISTING ROADS, RAILROAD TRACKS, STRUCTURES, AND UTILITIES ARE APPROXIMATE.

3.

UTILITY LOCATIONS WILL BE VERIFIED BY CONTRACTOR PRIOR TO CONSTRUCTION.

4.

FLOW ARROWS REPRESENT APPROXIMATE EXISTING FLOW.

5.

FLOW ARROWS REPRESENT APPROXIMATE FUTURE FLOW, ONCE ASH IMPOUNDMENT EMBANKMENTS ARE LOWERED. STORM WATER FROM THESE AREAS WILL NO LONGER GO TO OUTFALL #002.

6.

SILT FENCING WILL ALSO BE INSTALLED AROUND SOIL, AGGREGATE, AND OTHER MATERIAL STOCKPILES AND STORAGE AREAS. LOCATIONS TO BE DETERMINED.

IN-STREAM RUNOFF CONTROL (SUCH AS CHECK DAMS)

SILT FENCE

NORTH FLY ASH IMPOUNDMENT

STORM WATER CONTROLS FOR INITIAL CONSTRUCTION PHASE

CHECK DAMS, FILTER SOCKS, OR OTHER INSTREAM STABILIZATION (TYP.)

SILT FENCE

SEDIMENT POND AREAS DURING 1ST PHASE OF CONSTRUCTION

SOUTH FLY ASH IMPOUNDMENT

100 SCALE

0

100

BLUE VALLEY POWER STATION

COAL YARD

21500 E. TRUMAN RD, INDEPENDENCE, MISSOURI

BOTTOM ASH IMPOUNDMENT

7311 W. 130th St, Ste. 100 Overland Park, Kansas 66213 PH. (913) 681-0030 FAX. (913) 681-0012

SILT FENCE

INDEPENDENCE POWER & LIGHT

SEDIMENT BASIN AREAS DURING 1ST PHASE OF CONSTRUCTION

SCS AQUATERRA

N:\City of Independence\Independence Power & Light\Projects\27215142.00 - Ash Pond Closure Design\AutoCAD\SWPPP D2 - Initial Const SW Controls.dwg Feb 19, 2016 - 11:13am Layout Name: 2 Initial Const By: 3789rdt

1.

LAND DISTURBANCE SWPPP

LEGEND:

200 FEET

FOR SITE ORIENTATION ONLY

2

3

NOTES:

SILT FENCING

3.

UTILITY LOCATIONS WILL BE VERIFIED BY CONTRACTOR PRIOR TO CONSTRUCTION.

4.

FLOW ARROWS REPRESENT APPROXIMATE EXISTING FLOW.

5.

FLOW ARROWS REPRESENT APPROXIMATE FUTURE FLOW, ONCE ASH IMPOUNDMENT EMBANKMENTS ARE LOWERED. STORM WATER FROM THESE AREAS WILL NO LONGER GO TO OUTFALL #002.

6.

SILT FENCING WILL ALSO BE INSTALLED AROUND SOIL, AGGREGATE, AND OTHER MATERIAL STOCKPILES AND STORAGE AREAS. LOCATIONS TO BE DETERMINED.

IN-STREAM RUNOFF CONTROL (SUCH AS CHECK DAMS)

STORM WATER CONTROLS FOR FINAL CONSTRUCTION PHASE

FINAL CONSTRUCTION PHASE CHECK DAMS, FILTER SOCKS, OR OTHER IN-STREAM RUNOFF CONTROL (TYP.)

BOTTOM ASH IMPOUNDMENT

COAL YARD

SCS AQUATERRA

N:\City of Independence\Independence Power & Light\Projects\27215142.00 - Ash Pond Closure Design\AutoCAD\SWPPP D3 - Final Const SW Controls.dwg Feb 19, 2016 - 11:17am Layout Name: 3 Post Const By: 3789rdt

AREA TO BE CAPPED BEFORE EMBANKMENT REMOVED

100 SCALE

0

100

LAND DISTURBANCE SWPPP

POWER / LIGHT POLE EXISTING FLOW ARROW (SEE NOTE 4) FUTURE FLOW ARROW (SEE NOTE 5)

BLUE VALLEY POWER STATION

STORM WATER CULVERT

ASH IMPOUNDMENT BOUNDARIES, FENCING, EXISTING ROADS, RAILROAD TRACKS, STRUCTURES, AND UTILITIES ARE APPROXIMATE.

21500 E. TRUMAN RD, INDEPENDENCE, MISSOURI

EXISTING ROAD RAILROAD TRACKS OVERHEAD ELECTRIC (APPROXIMATE)

AERIAL IMAGE FROM SHAFER, KLINE, & WARREN, INC. DATED JULY 2015.

2.

INDEPENDENCE POWER & LIGHT

APPROXIMATE ASH IMPOUNDMENT BOUNDARY FENCE (APPROXIMATE)

1.

7311 W. 130th St, Ste. 100 Overland Park, Kansas 66213 PH. (913) 681-0030 FAX. (913) 681-0012

LEGEND:

200 FEET

FOR SITE ORIENTATION ONLY

3

3

APPENDIX A General Permit

APPENDIX B SWPPP Certification Form

SWPPP CERTIFICATION FORM Storm Water Pollution Prevention Plan Blue Valley Power Station – Ash Impoundment Closure City of Independence Power and Light Independence, Missouri

I certify that I have personally examined and am familiar with the information presented in this Storm Water Pollution Prevention Plan (SWPPP). I will accordingly implement the storm water Best Management Practices (BMPs) identified in the SWPPP. I will perform required inspections and maintenance of the BMPs as required by the SWPPP and directed by the designated SWPPP Coordinator.

Signature

Date

Name (Print)

Signature

Date

Name (Print)

Signature

Date

Name (Print)

Signature

Name (Print)

27215142.00/SWPPP – Signature Form

Date

APPENDIX C Inspection and Maintenance Form

INSPECTION AND MAINTENANCE FORM Storm Water Pollution Prevention Plan Blue Valley Power Station – Ash Impoundment Closure City of Independence Power and Light Independence, Missouri

Inspector: __________________________________ Signature: __________________________________ Inspection Type:

Location

Date: _______________

____ Weekly Check ____ After-Rainfall Check (rainfall amount: _______ inches) Properly Secured?

Erosion, Leaks or Sediment?

Corrective Action Necessary? (describe)

Date of Action

Site Entrance Silt Fence Storage Areas Equipment Grassy Areas Outfalls

Summary of Maintenance Requirements (include location and required maintenance) _________________________________________________________________________ _________________________________________________________________________ _________________________________________________________________________ _________________________________________________________________________ _________________________________________________________________________ Additional Comments (including any changes to materials, storage, or site layout.) _________________________________________________________________________ _________________________________________________________________________ _________________________________________________________________________ _________________________________________________________________________ _______________________________________________________________________

27215142.00/SWPPP – Inspection Form