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f t E A ~ United States .,....., Environmental Protectior ,. Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) March 12, 2025 Water NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Cleco Power, LLC Dolet Hills Power Station 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield, Louisiana 71052 963 Power Plant Road Mansfield, Louisiana 71052 DeSoto Parish Mr. Sam Wise I Manager - Waste & Water Quality (Office) 318.484.7739 (Mobile) 318.229.5928 samuel.wise@cleco.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110000450155 LA0062600 (AI No. 585) N/A 22111 4911 Personnel participating in inspection: Jack Arias EPA Region-6 ECD-WA Sam Wise Cleco Power LLC Inspector 214-665-8164 Manager - Waste & Water Quality 318-229-5928 EPA Lead Inspector Signature/Date JACK ARIAS Digitally signed by JACK ARIAS Date: 2025.05.08 15:07:05 -05'00' {Jack Arias} Date Supervisor Signature/Date ANTHONY LOSTON Date: 2025.05.08 18:38:15 -05'00' Digitally signed by ANTHONY LOSTON {Anthony Loston} Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Cleco Power, LLC - Dolet Hills Power Station Inspection Wednesday 3/12/2025 PURPOSE OF THE INSPECTION EPA Region 6 inspector, Jack Arias performed an announced inspection of the Cleco Power, LLC- Dolet Hills Power Station on March 12, 2025, at 9:00 AM. I met with the Plant Environmental Manager, Mr. Sam Wise at the opening conference. I presented my credentials to the facility representative, Mr. Sam Wise, and informed him that this was an EPA inspection to determine the facility's compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) water intakes and discharge regulations. The scope of the inspection included a compliance evaluation of the NPDES permit (LA0062600) that includes DMR data and effluent limitations, 316b cooling water intake structures integrity, 316b intake and discharge processes, monitoring/sampling requirements, equipment/pipes maintenance, 316b biomonitoring requirements connected with best management practices and best technology available to minimize impingement mortality and entrainment of aquatic organism, review of stormwater pollution prevention plan (SWPP3) and Spill Prevention Control and Countermeasures (SPCC) plan, record keeping requirements, and facility procedures connected to the permit. Following the opening conference, Mr. Sam Wise and other facility members accompanied us for the entirety of the inspection and gave us a tour of the site in a company vehicle. The closing conference was held with Mr. Sam Wise where I informed him of the results and observations of the inspection. FACILITY DESCRIPTION Cleco Power LLC operates the Dolet Hills Power Station (DHPS) at 963 Power Plant Road in Mansfield, DeSoto Parish, Louisiana. The DHPS is located at 963 Power Plant Road in Mansfield, DeSoto Parish, Louisiana. The geographical coordinates of the front gate are Latitude 32.033096 North and Longitude 93.571006 West. Cleco is currently authorized to discharge various wastewaters and storm water associated with industrial activity under the authority of Louisiana Pollutant Discharge Elimination System (LPDES) permit number LA0062600 issued by the Louisiana Department of Environmental Quality (LDEQ). The DHPS currently operates under LPDES permit number LA0062600 which was issued by the LDEQ with an effective date of March 1, 2020, modified August 1, 2022, and an expiration date specified as five years from the effective date (February 28, 2025). In November 2021, Cleco completed a planned permanent shutdown of the facility. Currently, Cleco has permanently shut down operations at the facility. Generation of process wastewater has ceased and Cleco is in the process of cleaning and dismantling equipment. The DHPS facility submitted a new LPDES permit application that describe shut down and current operations (See Photo Nos. 1 - 13 in Appendix 1). The DHPS was a fossil fuel-fired steam/electric generating facility. Initial startup at the facility was in 1986. Lignite was fired in a boiler to produce steam that was used to power a steam turbine/electric generator producing approximately 650 megawatts. Process wastewater is no longer generated at the facility. Cleco is in the process of closing the impoundments at the site. A Facility Plot Plan shows the buildings, roads, remaining ponds, equipment, and storage containers (See Photo No. 1 in Appendix 2). 2 Cleco Power, LLC - Dolet Hills Power Station Inspection Wednesday 3/12/2025 Section II - OBSERVATIONS Ceased Operations: DHPS has ceased operations and is being decommissioned. Cleco has operated and continues to operate the facility to avoid all potential and real environmental impacts to the maximum extent reasonably possible. At the time of the inspection, I did not observe any adverse environmental impacts, and I do not expect anticipated adverse environmental impacts because of the ceased and decommissioned operations at the facility. Cooling Water Intake Structure (CWIS) Requirements: While Cleco maintains an intake structure at the DHPS, water is no longer used for cooling purposes. As such, the CWIS requirements of the Clean Water Act (CWA), Section 316b no longer apply. Cleco is requesting the removal of CWIS requirements (See Photo Nos. 1 - 13 in Appendix 1). Description of Outfalls: Ceased and Decommissioned Outfalls: As the ceasing and decommissioning of the operations at the facility has advanced, the explanation of the effluent discharged from each outfall has changed. Because Outfalls 002, 003, 004, 005, 006, 007, and 011 no longer exist, Cleco is requesting the removal of these outfalls from the permit. Outfall 012, discharges of hydrostatic wastewater, is no longer required. The discharge collection pond preceding Outfall 001, the lignite pile runoff basin, the limestone runoff pond, and the surge basins have been clean closed and backfilled (See Photo Nos. 1 - 4 in Appendix 1). Active Outfalls: Cleco is requesting the following outfall descriptions in the 2025 renewal permit: Outfall 001 - the intermittent discharge storm water runoff and miscellaneous wastewater, including but not limited to, fire system test waters, eyewash station and safety shower water, vehicle wash water, and general facility wash water. Outfall 009 - the intermittent discharge of pond makeup water Outfall 010 - the intermittent discharge of the fly ash/FGD landfill settling pond, including storm water runoff and leachate from the fly/ash/FGD landfill, and miscellaneous wastewater including, but not limited to, fire system test waters, eyewash station and safety shower water, and general facility wash water (See Photo Nos. 5 - 13 in Appendix 1 and Photo No. 2 in Appendix 2). Biomonitoring: As the discharges from Outfall 001 now consist of only industrial storm water and miscellaneous wastewater, Cleco is requesting that biomonitoring requirements are removed from Outfall 001. Effluent Limitation Guidelines: Cooling tower blowdown, low volume wastewater, and metal cleaning wastewater are no longer generated at the facility or discharged via Outfall 001. Cleco is requesting the removal of effluent limitations for total residual chlorine (TRC), total chromium, and total zinc. 3 Cleco Power, LLC - Dolet Hills Power Station Inspection Wednesday 3/12/2025 Temperature Requirements: Cooling tower blowdown is no longer generated at the facility or discharged via Outfall 001. Cleco requests the removal of temperature limits at Outfall 001. Total Phosphorus: Phosphorus is related to cooling tower additives for scaling control. Cooling tower blowdowns are no longer generated at the DHPS, and therefore there are no chemical storage at the site. Cleco is requesting the removal of the effluent limitation for total phosphorus. Wastewater Collection, Treatment, and Discharge: Outfalls 002, 004, 005, 006, and 007 do not exist. Outfalls 001 and 010 have the potential to discharge vehicle wash water and facility washdown water in addition to industrial storm water. Outfall 001 discharges via pipe to the Red River (Subsegment No. 100101). Final Outfall 010 discharges to Mundy Bayou (Subsegment No. 100606). Outfall 009 discharges to Sawmill Creek (Subsegment No. 100606) (See Photo No. 2 in Appendix 2). Landfill: The landfill was previously used for the disposal of non-combustible byproducts of lignite combustion, fly ash and scrubber sludge. Currently the waste also includes bottom sediments that were removed from on-site settling ponds. The landfill produces a leachate as a resulted of rainwater that percolates through the landfill storm system. The landfill has a liner that separates waste material and subsequent leachate from groundwater. The landfill does not have an apparent leachate collection system, but it does have a pipe underwater that collects leachate from within the landfill and drains to the fly ash landfill settling pond. Storm water from the landfill's active cells drains via gravity to a collection sump and then are transferred to the surface impoundment prior to discharge from Outfall 010 to Mundy Bayou (See Photo Nos. 8 - 9 in Appendix 1 and Photo No. 2 in Appendix 2). Projects to Protect Environment: All waste materials are handled and properly disposed of in accordance with applicable regulations. Alternative projects are not deemed necessary or appropriate since this is an existing facility, and no measurable adverse environmental impacts are anticipated. Facility will meet applicable environmental, industry, and company standards. If wastewater and storm water discharge standards and limitations are modified, appropriate environmental controls and mitigating measures would be designed and implemented as necessary to achieve the revised standards and limitations. Section III - AREAS OF CONCERN There were no areas of concern observed during the inspection. Section IV - FOLLOW UP EPA will provide a copy of the inspection report and hold follow-up meetings relevant to discuss inspection report results, observations, and follow-up conversations connected to the progress of ceasing and decommissioning of operations and final approval of the 2025 renewal permit. 4 Cleco Power, LLC - Dolet Hills Power Station Inspection Wednesday 3/12/2025 Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 13 photos taken 03/11/2025 Appendix 2 - Map Log - 2 photos taken 03/11/2025 5 Cleco Power, LLC - Dolet Hills Power Station Inspection Wednesday 3/12/2025 Appendix 1 Photograph Log and Significant Photo Locations UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110095.JPG 03/12/2025 32.033831, -93.571877 N WGS-84 09:00 AM Jack Arias This image shows the entrance and the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110097.JPG 03/12/2025 32.031256, -93.571771 S WGS-84 9:40 AM Jack Arias This image shows ponds and surge basins closed and backfilled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110099.JPG 03/12/2025 32.029963, -93.571709 S WGS-84 10:00 AM Jack Arias This image shows ponds and surge basins closed and backfilled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110102.JPG 03/12/2025 32.029963, -93.571709 S WGS-84 10:10 AM Jack Arias This image shows ponds and surge basins closed and backfilled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110103.JPG 03/12/2025 32.020670, -93.566704 SE WGS-84 11:02 AM Jack Arias This image shows the prior to discharge from collection/settling pond and Outfall 010 to Mundy Bayou. surface impoundment UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110106.JPG 03/12/2025 32.020670, -93.566704 SE WGS-84 11:04 AM Jack Arias This image shows the collection/settling pond and surface impoundment prior to discharge from Outfall 010 to Mundy Bayou. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110108.JPG 03/12/2025 32.020961, -93.567076 SE WGS-84 11:05 AM Jack Arias This image shows the discharge area connected to the collection/settling pond prior to discharge from Outfall 010 to Mundy Bayou. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110109.JPG 03/12/2025 32.018235, -93.568349 SE WGS-84 11:15 AM Jack Arias This image shows the fly ash landfill settling pond. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110111.JPG 03/12/2025 32.156593 -93.543281 SE WGS-84 11:20 AM Jack Arias This image shows the landfill collection sump. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110112.JPG 03/12/2025 32.032480, -93.562151 SW WGS-84 11:20 AM Jack Arias This image shows the secondary ash pond. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield I County: DeSoto Parish I State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3110112.JPG 03/12/2025 32.031995, -93.590232 SW WGS-84 12:11 PM Jack Arias This image shows the makeup water pond connected to Toledo bend reservoir. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield I County: DeSoto Parish I State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3120131.JPG 03/12/2025 31.892745, -93.897852 SW WGS-84 01:17 PM Jack Arias This image shows the intake structure and pumps at Toledo Bend Reservoir. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield County: DeSoto Parish State: Louisiana Photograph File Name: Date of Photograph: Latitude & Longitude: Orientation: Map Datum: Time of Photo: Photographer: Description: P3120130.JPG 03/12/2025 31.892745, -93.897852 SW WGS-84 01:16 PM Jack Arias This image shows the intake structure and screens at Toledo Bend Reservoir. Cleco Power, LLC - Dolet Hills Power Station Inspection Wednesday 3/12/2025 Appendix 2 Map Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) Mansfield I County: DeSoto Parish I State: Louisiana N t ! J J c.......- ~-'"' I ----- -_ .. -.. _ . . . .. , . _ , . . r r - - , .. ~ - - I. . . . . . _ . _ . _ , . ,,.11-1 __ ..._,,,__, ---- - ----------- ...._.,_ =--==::==-=..,cmm---- Facility Plot Pl.ii.n and ,IHorm W 11t r Dnal n 119 M ilp L.=,.~:r...'te= PROVIDENCE 2 County: DeSoto Parish Photo No. 2 963 Power Plant Road, Mansfield, Louisiana 71052 (32.033096, -93.571006) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log State: Louisiana I--- Le ach.Jite AyasWFGO Land1il Ri.nol'f --Flyash/FGD Landfi ll .... """"'1aneou w-~ Toledo Bend Reservoir Nomully No Aow Sawmil Oeet Makeup 6 .5 W...,Pond S1DrmWater 0.887 Miscellaneous Wasiewatet- .e I o.aa1 i,.'.)1'13!lt,,\( {Ci!) % ~ .t ~1\/VJRO~"''o Mansfield I--- 1 1 1 I ln1ermitte:nt Intermittent Intermittent lntenTittent 1 I J.luody Bayou In~ lntenrirtem Ilrrte:rmittent Iln~ent Ilnterrrittent Le!le n d ~~, Notes @ S\IVPPPOutfall 1. AD flow ra tes .are in rrillion gallons per dly (MOO). 2. Due to lhe internvnen t ~ of cischarges arw;I the use of reteniion ponds, a ftcM, balanoe can not be estmated. l. o.ntals 013. 0 14. D15. 016. 0 11. 01a 0 1g. 020. Jind 021 are pem"itted LnC1er MSGP. R @d Rive,- Water/Wastew ater Flow Ba lance Diagram LPDES Permit Renewal Application Mansfteld, DeSoto Parish, Louisiana -- Cleco Power, LLC Odet Hils Power Station PROVIDENCE c"',"-".".",o' , .m. WM ___,., .._. ....... 002.337 D1J1w'lngNumb 002-337-8003 IW11l'll OV10,'2S 02/1CY.:!S 3 -