Document Rg8R10o02LmzqgGM5qg2db9E

COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Purpose: NPDES Compliance Evaluation Inspection Facility: Calumet Energy LLC 11653 South Torrence Avenue Chicago, Illinois 60617 NPDES Permit: IL0075108 Date of Inspection: May 25, 2022 EPA Inspectors: Val Dooling, Environmental Engineer, (312) 886-7167 Ray Cullen, Enforcement Engineer, (312) 885-0538 Facility Representatives: Andrew Thompson; Environmental and Operator [Andrew.Thompson@vistracorp.com] Sam Davies; Environmental Coordinator [Samantha.Davies@vistracorp.com] Report Prepared By: Val Dooling, Environmental Engineer EPA Inspector Signature and Date: VALERIE Digitally signed by VALERIE DOOLING DOOLING Date: 2022.07.25 10:05:52 -05'00' _____________________________________________ Approver Name and Title: Ryan J. Bahr, Section 2 Supervisor, Water Enforcement and Compliance Assurance Branch Approver Signature and Date: Digitally signed by Bahr, Bahr, Ryan Ryan Date: 2022.07.25 ______________1_2_:09_:3_2_-0_5'0_0_' _______________________ TABLE OF CONTENTS I. INTRODUCTION ....................................................................................................................... 1 II. BACKGROUND........................................................................................................................ 1 III. OPENING CONFERENCE...................................................................................................... 1 IV. FACILITY DISCUSSION........................................................................................................ 1 V. SITE VISIT ................................................................................................................................ 3 VI. CLOSING CONFERENCE...................................................................................................... 3 VII. POST INSPECTION:.............................................................................................................. 4 LIST OF APPENDICES Appendix A: Photo Log Appendix B: Aerial Facility Image Appendix C: NPDES Permit IL0075108 Calumet Energy LLC CEI Inspection - May 25, 2022 I. INTRODUCTION The purpose of this report is to describe, evaluate and document Calumet Energy LLC's compliance with the Clean Water Act (CWA) and its National Pollutant Discharge Elimination System (NPDES) permit at its Chicago, Illinois facility. II. BACKGROUND Calumet Energy LLC is a simple cycle, natural gas peaker plant ("facility"). The facility was commissioned new in 2001 and was purchased by its parent corporation, Vistra Corp in 2018. It is a 24-hour facility, but is only staffed from 6am-3pm by four technicians and one manager. As a simple-cycle facility, it does not generate energy through stream and is therefore not subject to 40 Code of Federal Regulations (CFR) 423, Steam Electric Power Generating Point Source Category. In a typical year, the facility is operational for only 50-80 hours; however, the previous year, 2021, was an abnormally busy year and it ran for approximately 300 hours. At the time of the inspection, the last time the facility had run was in November 2021. A regional transmission organization monitors the grid and will inform the facility when it needs to run. At that time, approval must also be granted from the local gas company to access the natural gas from their pipes. It is able to start up in seven minutes. All fuel used comes from pipes and no fuel is stored on site. III. OPENING CONFERENCE On May 25, 2022, Ray Cullen and I (EPA) arrived at Calumet Energy's office at 8:45am. EPA showed credentials to Andrew Thompson. EPA explained that it would take photographs as part of the inspection and requested whether any information was Confidential Business Information (CBI). Mr Thompson stated that nothing discussed in the inspection was CBI. After a brief discussion concerning the reason for the inspection, EPA began to ask Mr. Thompson some questions about the facility. IV. FACILITY DISCUSSION Mr Thompson stated that there are two outfalls which discharge to a retention pond. The pond then discharges to a ditch wetland area; however, he has only observed the pond discharge one or two times in the last eight years. In the summer months, the pond is covered by algae and typically will dry up. Mr. Thompson did ask EPA as to whether it would be preferable to monitor the pond discharge instead of the current outfall locations which drain to the pond, as the pond is the source of the actual discharge off facility's property. As Mr. Thompson was explaining the outfall system, Sam Davies joined in the inspection by phone and was present for the remaining inspection, excluding the facility walk-through. According to the Calumet Energy NPDES Permit, Outfall 001 is comprised of "Evaporative Cooler Blowdown, Stack, Diffuser and Floor Drains, Bleed Water, and Transformer Pit". Mr. Thompson stated that the evaporative cooldown is non-contact water which does not have any 1 Calumet Energy LLC CEI Inspection - May 25, 2022 chemical additives. This only discharges water when the facility is operating. The stack discharge is rainwater which has been collected in drains. Discharges from diffuser and floor drains are drains located in the turbine and generator enclosure. Floor drains are plugged in case of glycol spills and if water is released to the floor drain, it must be pumped out to the oil water separator. Bleed water is discharged when cleaning turbines and may contain a non-chlorinated cleaning product. The transformer pit drains are plugged in case of an oil spill. After a rain event, staff will visually observe whether an oily sheen appears in the pit, prior to draining. If an oily sheen does appear, then staff will use a vacuum truck to remove the oil. Evaporative cooler blowdown and diffuser and floor drains area all treated by an oil water separator prior to discharging. Discharges are collected in a 1500-gallon tank then are automatically released at Outfall 001. According to the Calumet Energy NPDES Permit, Outfall 002 is comprised of non-contact cooling water, and water from mechanical seal leak off and diesel fire pump building drain. According to Mr. Thompson, the mechanical seal requires a constant flow of water through bearings to maintain seal and there is a constant drip which discharges into Outfall 002 . The diesel fire suppression pump uses water to cool the heat exchanger. It is a backup pump in the event of a power failure and the primary system is not operable. Each week the pumps will be run for 30 minutes. The discharge at Outfall 002 is controlled by Special Condition 3.C, which states that discharge shall not cause the maximum temperature rise above natural temperatures to exceed 2.8 C. Outfall 002 is released to a ditch which flows into the retention pond. During the reporting period ending on January 12, 2022, during winter, there was a temperature exceedance. Mr. Thompson explained this occurred since the ditch water has a low flow and the discharge of cooling water caused a temperature exceedance. The facility installed a system to ensure that during winter months the discharge is cooled to outdoor temperatures prior to discharging to the ditch, to eliminate a repeat of the temperature effluent exceedance. The intake water used is chlorinated city water, and carbon tanks are installed prior to remove any residual chlorine. None of the discharges from either Outfall 001 or 002 are from a wet scrubber, and, in fact, the facility does not have any scrubber system. No chlorinated solvents or degreasers are used at the facility. No hazardous waste is generated. No process water is sent to the city sewer system. No chemicals are used in wastewater treatment. The facility uses a preventative maintenance system to track work orders and schedule maintenance activities. Stormwater inspections, as required by the permit, are assigned through the preventative maintenance system, as are yearly oil water separator filter changes. According to Special Condition 10 of the NPDES Permit, the facility must conduct a visual annual inspection to determine if any facility modification have occurred which change the stormwater pretreatment. According to Mr. Thompson, such modifications have not occurred. The facility uses TekLab to collect its flow, pH and temperature samples on the first Friday of each month. During the reporting period ending July 31, 2021, there was a chlorine exceedance listed on the Discharge Monitoring Report (DMR) at Outfall 001. According to Mr. Thompson, the prior day the 1500-gallon tank was manually discharged to the pond and not enough water was present to collect an adequate sample. The lab collected a smaller sample then used a calculation to adjust the result which increased the chlorine 10x and resulted in the effluent exceedance. A note was submitted with the DMR form to the Illinois Environment Protection Agency stating the cause of 2 Calumet Energy LLC CEI Inspection - May 25, 2022 the exceedance. According to Mr. Thompson, the reason that the tank was manually discharged was due to a small problem with the automatic pump, which was since repaired. V. SITE VISIT At 9:46 am, EPA and Mr. Thompson began to walk the facility premises starting at Outfall 002 and its wastestreams then moving to Outfall 001 wastestreams and finally ending at Outfall 001 and the retention pond. At Outfall 002 (Photo 1), EPA observed a discharge flowing into the drainage ditch which flows towards the retention pond. Mr. Thompson showed EPA the new addition which is used in the winter to cool the discharge to ambient temperatures. Inside the diesel pump building, Mr Thompson showed EPA the two wastewater streams (Photo 3), the diesel pump and the mechanical seal, which make up the discharge to Outfall 002. After the wastestreams connect, the wastestream is processed through a carbon filter prior and then dechlorinated (Photo 4). EPA and Mr. Thompson viewed the four floor drains in each turbine and generator and observed that they were currently plugged (Photo 6). The facility has two identical turbines and generators. EPA noted the access hatch to the oil water separator (Photo 7), and Mr. Thompson stated that there are two pumps, one active and one backup, from the oil water separator which feed Outfall 001. EPA observed a ditch designed to remove stormwater from between the turbines (Photo 9). Mr. Thompson explained that this ditch runs along the outside of the property and transfers the stormwater to a wetland area offsite. At the transformer pit, EPA noted there was sitting water (Photo11-12). Mr. Thompson stated that this was rainwater and the pit is plugged until a visual observation can be done to ensure that an oily sheen is not present on the water. After the visual inspection, the drains will be opened and the water will flow to Outfall 001. EPA and Mr. Thompson walked to Outfall 001. There is an underground 1500 gallon storage tank with an automatic pump which was not flowing at the time of inspection. Mr. Thompson manually turned on the pump, so EPA could view the discharge into the retention pond (Photo 13-14). EPA then walked around the pond (Photo 15) and observed the pathway that the pond discharges to off property (Photo 17). The pond was not discharging at the time of inspection. Mr. Thompson explained that the pond discharged to a wetlands area just offsite, prior to the railroad tracks. EPA observed algae on the pond and Mr. Thompson explained that at the time of the inspection the pond is approximately 18 inches deep; however, in the summer the pond mostly dries up. The facility tour ended at 10:40 am. VI. CLOSING CONFERENCE EPA requested the following documents: laboratory analysis and chain of custody for the last three years; documentation of annual stormwater visual inspections for the last three years; maintenance on the oil water separator; NPDES permit application and Safety Data Sheets (SDS) 3 Calumet Energy LLC CEI Inspection - May 25, 2022 for any chemicals used onsite. Sam Davies agreed to email documents within a week. During the inspection, EPA did not note any preliminary areas of concern. EPA concluded the inspection and thanked the representatives of Calumet Energy LLC, then EPA left the facility at 10:47 am. VII. POST INSPECTION On June 2, 2022, Sam Davies emailed the agreed upon documents. 4 Calumet Energy LLC CEI Inspection - May 25, 2022 Appendix A: Inspection Photo Log Calumet Energy LLC EPA Inspection May 25, 2022 All photos taken by Ray Cullen, Enforcement Engineer, U.S. EPA Camera: RICOH WG-3 1: CALU0267 Description: Outfall 002 flowing into ditch. Camera Direction: Southeast Date/Time: May 25, 2022 - 9:51am A1 Calumet Energy LLC CEI Inspection - May 25, 2022 2: CALU0268 Description: Outfall 002 entering ditch, showing dowstream through culvert under roadway which leads to retention pond. Camera Direction: West Date/Time: May 25, 2022 - 9:52am A2 Calumet Energy LLC CEI Inspection - May 25, 2022 3: CALU0269 Description: Diesel flow in larger pipe and mechanical seal drip combining prior to Outfall 002. Camera Direction: North Date/Time: May 25, 2022 - 9:57am A3 Calumet Energy LLC CEI Inspection - May 25, 2022 4: CALU0270 Description: Carbon tank for dechlorination prior to Outfall 002. Camera Direction: Northwest Date/Time: May 25, 2022 - 9:59am A4 Calumet Energy LLC CEI Inspection - May 25, 2022 5: CALU0271 Description: Closed valve exaust pipe leading from turbine. Camera Direction: East Date/Time: May 25, 2022 - 10:10am A5 Calumet Energy LLC CEI Inspection - May 25, 2022 6: CALU0272 Description: One of four floor drains in turbine building. Camera Direction: Northeast Date/Time: May 25, 2022 - 10:14am A6 Calumet Energy LLC CEI Inspection - May 25, 2022 7: CALU0273 Description: Oil water separator which feeds Outfall 001. Camera Direction: Southwest Date/Time: May 25, 2022 - 10:16am A7 Calumet Energy LLC CEI Inspection - May 25, 2022 8: CALU0274 Description: Empty tote outside of turbine building. Camera Direction: South Date/Time: May 25, 2022 - 10:17am A8 Calumet Energy LLC CEI Inspection - May 25, 2022 9: CALU0275 Description: Stormwater ditch between turbine buildings. Camera Direction: South Date/Time: May 25, 2022 - 10:20am A9 Calumet Energy LLC CEI Inspection - May 25, 2022 10: CALU0276 Description: Stormwater ditch between turbines. Camera Direction: North Date/Time: May 25, 2022 - 10:20am A10 Calumet Energy LLC CEI Inspection - May 25, 2022 11: CALU0277 Description: Transformer pit with standing rainwater. Camera Direction: West Date/Time: May 25, 2022 - 10:21am A11 Calumet Energy LLC CEI Inspection - May 25, 2022 12: CALU0278 Description: Same as photo 11. Camera Direction: West Date/Time: May 25, 2022 - 10:22am A12 Calumet Energy LLC CEI Inspection - May 25, 2022 13: CALU0279 Description: Outfall 001, with pump manually turned on. Retention pond in the background. Camera Direction: West Date/Time: May 25, 2022 - 10:27am A13 Calumet Energy LLC CEI Inspection - May 25, 2022 14: CALU0280 Description: Outfall 001, no flow. Camera Direction: West Date/Time: May 25, 2022 - 10:30am A14 Calumet Energy LLC CEI Inspection - May 25, 2022 15: CALU0281 Description: Retention pond at Outfall 001. Camera Direction: West Date/Time: May 25, 2022 - 10:32am A15 Calumet Energy LLC CEI Inspection - May 25, 2022 16: CALU0282 Description: Algae at retention pond at merger point of Outfall 002 ditch. Camera Direction: North Date/Time: May 25, 2022 - 10:35am A16 Calumet Energy LLC CEI Inspection - May 25, 2022 17: CALU0283 Description: Culvert at retention pond where water is discharged off property. Camera Direction: East Date/Time: May 25, 2022 - 10:37am A17 Calumet Energy LLC CEI Inspection - May 25, 2022 Appendix B: Aerial Image Note: Aerial image from Google Earth obtained July 20, 2022. Image does not represent conditions observed and is only to be used as a reference. B-1 Calumet Energy LLC CEI Inspection - May 25, 2022 Appendix C: NPDES Permit IL0075108 C-1 Calumet Energy LLC CEI Inspection - May 25, 2022 C-2 Calumet Energy LLC CEI Inspection - May 25, 2022 C-3 Calumet Energy LLC CEI Inspection - May 25, 2022 C-4 Calumet Energy LLC CEI Inspection - May 25, 2022 C-5 Calumet Energy LLC CEI Inspection - May 25, 2022 C-6 Calumet Energy LLC CEI Inspection - May 25, 2022 C-7 Calumet Energy LLC CEI Inspection - May 25, 2022 C-8 Calumet Energy LLC CEI Inspection - May 25, 2022 C-9