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8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION, A CASE STUDY Topics Black Hills Corporation Overview Post Construction BMPs and Controls Risk Assessment BMP Repair Engineering Design and BMP Selection Soil Sampling and Amendments Construction Phase One Year Later BMP: Best Management Practice 3 4 Based in Rapid City, SD, with corporate offices in Denver, CO, and Papillion, NE Utility operations serve 765,000 utility customers in CO, IA, NE, SD, WY Non-regulated businesses generate wholesale electricity, and produce natural gas, crude oil and coal. Utilities Electric Utilities Gas Utilities Black Hills Power Cheyenne Light* Colorado Electric Colorado Gas Kansas Gas Nebraska Gas Iowa Gas Non-Regulated Energy Power Generation Coal Mining Black Hills Electric Generation Wyodak Resources Oil and Gas Black Hills Exploration and Production Black Hills Corp. Overview
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Page 1: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

8/14/2015

1

AHMP National Conference – 2015

Joe Jenkins, PG, CHMM, CPESC

POWER PLANT STORMWATER

STABILIZATION THROUGH

REVEGETATION, A CASE STUDY

Topics

• Black Hills Corporation Overview

• Post Construction BMPs and Controls

• Risk Assessment

• BMP Repair

• Engineering Design and BMP Selection

• Soil Sampling and Amendments

• Construction Phase

• One Year Later

BMP: Best Management Practice

3

4

• Based in Rapid City, SD, with corporate offices in Denver, CO, and Papillion, NE

• Utility operations serve 765,000 utility customers in CO, IA, NE, SD, WY

• Non-regulated businesses generate wholesale electricity, and produce natural gas, crude oil and coal.

Utilities

Electric Utilities Gas Utilities• Black Hills Power

• Cheyenne Light*

• Colorado Electric

• Colorado Gas

• Kansas Gas

• Nebraska Gas

• Iowa Gas

Non-Regulated Energy

Power Generation Coal Mining

• Black Hills Electric Generation

• Wyodak Resources

Oil and Gas

• Black Hills Exploration and Production

Black Hills Corp. Overview

Page 2: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Pueblo Airport Generating Station (PAGS)January 2012

5

6

W. N. Clark StationCanon City, CO• 48 MW• 255,425 mT CO2e

• 24 employees

PAGS• 380 MW, 29 MW wind• 317,683 mT CO2e

• 14 employees• Replaced 300 MW of

coal-based purchased power

Impact of PAGS on GHG Emissions Reduction

7

37% reduction in GHG Emissions

Page 3: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Location of PAGs in Respect to Arkansas River

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Facility with Respect to Local Topography

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PAGS

Arkansas River

Approx. 3.6 miles

April 2012

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Page 4: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Area Designations

11Go to master slide >

Site of new turbine unit, construction beginning 2016

Pueblo County Stormwater Considerations

12

No stormwater retention allowed by County

Army Corp Non-Jurisdictional WOTUS

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Page 5: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Natural Vegetation in and Around PAGS

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Shortgrass prairie co-dominant with Greasewood shrubland:• Blue Grama• Alkali saction grass• Galetta grass• Sand dropseed• Rabbitbrush• Cholla

Post-Construction BMPs and Controls

15

Engineer’s Design 2010

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Page 6: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

8/14/2015

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Power Block March 2013

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SE Stockpile and Detention Pond Area

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March 2013

West of Powerblock

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Culvert 9, 4 ft. box culvert

Culvert 10, 3 ft. round culvert

Page 7: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Floodplain Analysis Culvert 10

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10 yr

25 yr100 yr

Culvert 10 – 100 yr Flood Level Determination

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100 yr FP

10 yr FP

July 2013 – 2.05” rainfall

Culvert 10 – 100 yr Flood Level Determination

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100 yr FP

September 2013 – 2.86” rainfall

Page 8: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Rain Event July 15, 2014

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Pond Slope Design

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Evaporation Ponds

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Page 9: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Laydown Yard March 2013

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Shale Stockpiles

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RISK ANALYSIS

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Page 10: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Risk Analysis – August 2013

• Review of existing stormwater restoration practices and BMPs

• State of Colorado Stormwater Civil Penalty Matrix

• Determine Base Gravity Penalty

• Account for Duration of Violation (multi-day penalties)

• Apply Aggravating or Mitigating Factors

• Add Economic Benefit

• Multiple Violations

• Ability to Pay

• Multi-Day Penalties

• Conducting Covered Activities without a Stormwater Permit

• Failure to Prepare Stormwater Management Plan (SWMP)

• Deficient Stormwater Management Plan (SWMP)

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Violation Matrix Multi-Day Penalties Example

Day 1 ($1037.50) = $ 1,037.50

+ Days 2-10 ($1037.50) X (9 days) X (50%) = $ 4,668.75

+ Days 11-50 ($1037.50) X (40 days) X (40%) = $16,600.00

+ Days 51-100 ($1037.50) X (50 days) X (30%) = $15,562.50

+ Days 101-200 ($1037.50) X (100 days) X (20%) = $20,750.00

+ Days 201-270 ($1037.50) X (70 days) X (10%) = $ 7,262.50

Multi-Day Base Gravity Penalty = $65,881.25

Applicable to each identified violation:

• Failure to Install, Maintain, or Properly Select BMPs

• Failure to Perform Inspections of Stormwater Management System

• Pollution, Contamination, or Degradation of State Waters

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PAGS at Risk Stormwater Management System

• Permit expanded in phases but no evidence of communication with State on expansions

• Initial permit described access road and plant

• Did not include evaporation ponds or shale stockpiles

• No post-construction version of the SWMP• Inadequate SWMP

− Site description changes not addressed

− Site map not updated

− BMPs not updated

− Final stabilization practices not described

• Examples of Recent Violations• 2011, Timnah Ranch, $90,223 penalty

• 2012, Sumo Development, $100,000 penalty

• 2013, Rock Mt. Materials, $65,000

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Page 11: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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PAGS at Risk for Stormwater Management

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Maintenance and Replacement of Failed BMPs• The potential to discharge sediment-laden water from numerous outfalls around the plant site. Each outfall is a separate violation.

• Stormwater sediment retention basin SE corner of facility

• Multiple locations along both arroyos on each side of the shale pile

• All silt fence at the site

• Partially riprapped channels

• Slopes along the substation

• Unstabilized drainage along access road

• Unstabilized drainage (no controls) along the dirt road west of shale pile

• Unstabilized slopes (no controls) around evaporation ponds

• Unstabilized surfaces (no controls) around evaporation ponds

• Unstabilized surfaces (no controls) around sediment retention basin

• No perimeter control around stockpile northwest of plant

• No perimeter control around stockpile southeast of plant

• No perimeter control around small stockpile by arroyo south of access road

• No or incomplete perimeter control around shale piles

• Sediment tracking on roadways at dirt road access west of shale pile

• Sediment on road east of arroyo where it flows with run off being tracked along roadway above arroyo (potential discharge to state waters)

• Erosion (rills) on shale pile

• Erosion (rills) on evaporation pond slopes

• Erosion (rills) on access road slopes

• Erosion (rills) on south side of substation

• Erosion (rills) on sediment retention basin

• Erosion (rills) on slopes of drainage channels

• Improperly designed sediment retention basin with direct discharge potential off site

• Failed controls in “laydown yard”

• Failed controls on horizontal surfaces in power block area

• Lack of weed control

33

INITIAL REPAIR OF FAILED BMPS

34

Page 12: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Initial Repair of Failed BMPs

35

Initial Repair of Failed BMPs

36

Initial Repair of Failed BMPs

37

Total Cost of repairs $160,000

Page 13: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Initial Repair of Failed BMPs

38

5/13/13 South Powerblock Drainage

Power Block 4, 2014

39

BMP Maintenance 2014

40

Page 14: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

8/14/2015

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Engineering Design and BMP Selection

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• Control Technology and BMP Selection

• Available Technologies• Revegetation‒ Soil sampling

‒ Amend and revegetate

‒ Addition of topsoil

• Rock, riprap, grouted rip rap

• Manufactured drainage

• Retaining walls

• Budgetary Considerations• Previously budgeted expense

• Will raise customer rates

• Rock versus Vegetation• SWOT analysis

• Cost comparison

Engineering Evaluations

42

Soil Sampling

43

South Shale Stockpile (1, 2), Laydown Yard (3)

North Shale Stockpile (1), SE Shale Stockpile (2)

TDS: Total Dissolved Salts; SAR: Sodium Absorption Ratio; CEC Cation Exchange Capacity

Page 15: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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SWOT Analysis• Rock

• Strengths / Opportunities− No watering, not affected by drought

− Potentially low maintenance

− Immediate results

• Weaknesses / Threats− High Cost

− Windblown dust may cover riprap over time

− Potentially high cost to maintain

• Vegetation• Strengths / Opportunities

− Lower cost

• Weaknesses / Threats− Watering required to support growth

− Semi/arid conditions accentuated by drought

− Heavy downpour could impact structures and wash away seeds

− Greater maintenance anticipated due to time to establish seeds

44

Rock versus Vegetation

45

$1,155,223 for vegetation versus $3,178,261 for primarily rock and riprap cover

Final Engineering Design June 2014

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Page 16: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Amendments and Seed Mixture

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Construction Phase

BMP Construction

49

Began 7/15/2014

Page 17: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

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Permanent BMP Installation and Revegetation

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Permanent BMP Installation and Revegetation

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Complete 9/1/2014

June 2015

Go to master slide > 52

Page 18: Power Plant Stormwater Stabilization 2015€¦ · 8/14/2015 1 AHMP National Conference – 2015 Joe Jenkins, PG, CHMM, CPESC POWER PLANT STORMWATER STABILIZATION THROUGH REVEGETATION,

8/14/2015

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Lessons Learned

• Prior to Project Start

• Establish effective communication with all parties before construction begins

• Communicate compliance risk early and effectively

• Critically evaluate engineering design to determine if effectively addresses site conditions

• Establish effective communication with federal, state and local agencies as needed

• During the Project

• Provide ongoing comprehensive oversite to assure compliance is addressed along with construction activities

• Carefully manage records

• Reevaluate compliance as site condition change

• Do it right the first time!

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Contact Information

Joe Jenkins, PG, CHMM, CPESCSr. Environmental Professional

Black Hills Corporation

1515 Wynkoop St, Denver CO 80202

303-566-3446

[email protected]

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