FOUR CORNERS POWER PLANT CLOSURE PLAN (b) UPPER RETENTION SUMP FC_ClosPlan_011_

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FOUR CORNERS POWER PLANT CLOSURE PLAN 257.102(b) UPPER RETENTION SUMP FC_ClosPlan_011_20161017 Closure Plan Contents 257.102(b)(1) The owner or operator of a CCR unit must prepare a written closure plan that describes the steps necessary to close the CCR unit at any point during the active life of the CCR unit consistent with recognized and generally accepted good engineering practices. The written closure plan must include, at a minimum, the information specified in paragraphs (b)(1)(i) through (vi) of this section. SITE INFORMATION Site Name / Address Owner Name / Address CCR Unit Location Reason for Initiating Closure Final Cover Type Closure Method CLOSURE PLAN DESCRIPTION (b)(1)(i) A narrative description of how the CCR unit will be closed in accordance with this section. Four Corners Power Plant / 691 CR-6100, Fruitland, NM 85416 Arizona Public Service / 400 North 5 th Street, Phoenix, AZ 85004 Upper Retention Sump 36 41 14 N, 108 28 37.8 W Replacement with a tank. N/A Clean Closure and replacement with a tank. The Upper Retention Sump is an approximately 1- acre, unlined surge pond associated with operation of the flue gas desulfurization (FGD) systems for treatment of flue gas from Units 4 and 5. The Upper Retention Sump will be clean-closed by excavating the coal combustion residuals (CCR) and the existing soil cement operations layer. A concrete tank will be constructed in place of the Upper Retention Sump to comply with the Rule. Figure 1 shows a plan view of the Upper Retention Sump. Closure, CCR removal, and tank construction operations will involve: 1) Dewatering, 2) Temporarily diverting the current flows from the Upper Retention Sump to the Lined Ash Impoundment, 3) Removing the CCR sediments from the Upper Retention Sump and placing them 1

in the Dry Fly Ash Disposal Area, 4) Removing the existing soil cement operations layer for tank subgrade preparation, and 5) Construction of a new reinforced concrete tank. (b)(1)(ii) If closure of the CCR unit will be accomplished through removal of CCR from the CCR unit, a description of the procedures to remove the CCR and decontaminate the CCR unit in accordance with paragraph (c) of this section. (b)(1)(iii) If closure of the CCR unit will be accomplished by leaving CCR in place, a description of the final cover system, designed in accordance with paragraph (d) of this section, and the methods and procedures to be used to install the final cover. The closure plan must also discuss how the final cover system will achieve the performance standards specified in paragraph (d) of this section. (c) CCR removal and decontamination of the CCR unit are complete when constituent concentrations throughout the CCR unit and any areas affected by releases from the CCR unit have been removed and groundwater monitoring concentrations do not exceed the groundwater protection standard established pursuant to In accordance with 257.102(b)(3), this initial written closure plan will be amended to provide additional details after the final engineering design for the clean closure and concrete tank system is completed. The initial version of the closure plan reflects the information and planning available at the time of issuance. Applicable. The Upper Retention Sump will be with 257.102(c) and replacing the facility with a reinforced concrete tank. CCR removal operations will consist of dewatering the existing Upper Retention Sump and removing CCR deposits using conventional excavators and loaders. The CCR material and other construction debris will be removed and transported to the Dry Fly Ash Disposal Area. Not applicable. The Upper Retention Sump will be with 257.102(c) and replacing the facility with a reinforced concrete tank. The Upper Retention Sump will be dewatered and existing CCR will be removed. The existing soil cement operations layer at the base of the pond will serve as the boundary for identification of the extent of CCR wastes. The Upper Retention Sump groundwater monitoring well network will be monitored until groundwater concentrations do 2

257.95(h) for constituents listed in appendix IV to this part. INVENTORY AND AREA ESTIMATES (b)(1)(iv) An estimate of the maximum inventory of CCR ever on-site over the active life of the CCR unit. (b)(1)(v) An estimate of the largest area of the CCR unit ever requiring a final cover as required by paragraph (d) of this section at any time during the CCR unit s active life. not exceed groundwater protection standards for any constituents listed in appendix IV to Part 257. 1.07 acre-feet Not applicable. The Upper Retention Sump will be with 257.102(c). A reinforced concrete tank will be constructed in place of the Upper Retention Sump. CLOSURE SCHEDULE (b)(1)(vi) A schedule for completing all activities necessary to satisfy the closure criteria in this section, including an estimate of the year in which all closure activities for the CCR unit will be completed. The schedule should provide sufficient information to describe the sequential steps/milestones that will be taken to close the CCR unit, and the estimated timeframes to complete each step or phase of CCR unit closure. If closure timeframe is anticipated to exceed the timeframes specified in paragraph 257.102(f)(1) of this section, the written closure plan must include the site-specific information, factors and considerations that would support any time extension sought under paragraph 257.102(f)(2). The milestone and the associated timeframes are initial estimates. Some of the activities associated with the milestones will overlap. Amendments to the milestones and timeframes will be made as more information becomes available. Initial Written Closure Plan Completed By October 17, 2016 Permits and Approvals from Agencies July 2017 Closure Activities Initiated August 2017 Complete Dewatering October 2017 Estimated Completion of Closure Activities April 2018 3

Certification Statement 40 CFR 257.102(b)(4) Initial Written Closure Plan for a CCR Surface Impoundment CCR Unit: Arizona Public Service; Four Corners Power Plant; Upper Retention Sump I, Alexander W. Gourlay, being a Registered Professional Engineer in good standing in the State of New Mexico, do hereby certify, to the best of my knowledge, information, and belief, that the information contained in this certification has been prepared in accordance with the accepted practice of engineering. I certify, for the above-referenced CCR Unit, that the information contained in the initial written closure plan dated October 17, 2016 meets the requirements of 40 CFR 257.102. Alexander W. Gourlay, P.E Printed Name August 30, 2016 Date

SDU JBH AWG CLEAN CLOSED AND REPLACED WITH CONCRETE TANK UPPER RETENTION SUMP LEASE BOUNDARY Four Corners Power Plant Arizona Public Service Four Corners Power Plant, Fruitland, NM 60492608 Date: 2016-07-15 Four Corners Power Plant Upper Retention Sump Closure Figure: 1