EMERGENCY ACTION PLAN...FGD Pond 4 (FGD-4) manages flue gas desulfurization ma terials produced from...

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FGD Pond 4, NID WY02497 EMERGENCY ACTION PLAN FGD Pond 4 National Inventory of Dams ID WY 02497 PacifiCorp Thermal Generation 1407 W North Temple Salt Lake City, Utah 84116 Last Issued: April 2017 DO NOT DUPLICATE

Transcript of EMERGENCY ACTION PLAN...FGD Pond 4 (FGD-4) manages flue gas desulfurization ma terials produced from...

FGD Pond 4, NID WY02497

EMERGENCY ACTION PLAN

FGD Pond 4 National Inventory of Dams ID WY 02497

PacifiCorp Thermal Generation 1407 W North Temple

Salt Lake City, Utah 84116

Last Issued: April 2017

DO NOT DUPLICATE

CERTIFICATION

I hereby certify that this Emergency Action Plan for FGD Pond 4 located at PacifiCorp’s Naughton Power Plant has been prepared in accordance with §257.73(a)(3) – Emergency Action Plan of the Coal Combustion Residuals (CCR) Rule - 40 CFR Parts 257 and 261, “Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals From Electric Utilities; Final Rule published in the Code of Federal Regulations (CFR) on April 17, 2015 with an effective of October 19, 2015.

By:

Date: 04/01/2017

Chad Tomlinson, P.E.

Wyoming P.E.# 15375

Emergency Action Plan – FGD Pond 4 National Inventory of Dam WY02497

Naughton Thermal Power Plant

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TABLE OF CONTENTS

RECORD OF REVISIONS ................................................................................................ II DOCUMENT CONTROL AND PLANHOLDER LIST ..................................................III EMERGENCY ACTION PLAN VERIFICATION ........................................................... V STATEMENT OF PURPOSE .............................................................................................2 SUMMARY OF EAP RESPONSIBILITIES ......................................................................3 PROJECT DESCRIPTION ................................................................................................13

STEP 1 – INCIDENT DETECTION, EVALUATION, AND EMERGENCY LEVEL DETERMINATION ...........................................17

STEP 2 – NOTIFICATION AND COMMUNICATION .....................................19 STEP 3 – EMERGENCY ACTIONS ....................................................................23 STEP 4 – TERMINATION AND FOLLOW-UP ..................................................27

GENERAL RESPONSIBILITIES .....................................................................................29 PACIFICORP RESPONSIBILITIES ....................................................................29 NOTIFICATION AND COMMUNICATION RESPONSIBILITIES ..................30 EVACUATION RESPONSIBILITIES .................................................................30 MONITORING, SECURITY, TERMINATION, AND FOLLOW-UP

RESPONSIBILITIES ................................................................................30 EAP COORDINATOR RESPONSIBILITIES ......................................................30

PREPAREDNESS .............................................................................................................31 SURVEILLANCE AND MONITORING .............................................................31 EVALUATION OF DETECTION AND RESPONSE TIMING ..........................31 ACCESS TO THE SITE ........................................................................................31 RESPONSE DURING PERIODS OF DARKNESS .............................................31 RESPONSE DURING WEEKENDS AND HOLIDAYS .....................................31 RESPONSE DURING ADVERSE WEATHER ...................................................32 ALTERNATIVE SOURCES OF POWER ............................................................32 EMERGENCY SUPPLIES AND INFORMATION .............................................32 STOCKPILING MATERIALS AND EQUIPMENT ............................................34 COORDINATION OF INFORMATION ..............................................................34 TRAINING AND EXERCISE ..............................................................................34 ALTERNATIVE SYSTEMS OF COMMUNICATION .......................................34 PUBLIC AWARENESS AND COMMUNICATION ..........................................34

INUNDATION MAPS ......................................................................................................36 INUNDATION MAP DEVELOPMENT ..............................................................36

REFERENCES ..................................................................................................................38

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RECORD OF REVISIONS

Date of Revision Pages Revised

Emergency Action Plan – FGD Pond 4 National Inventory of Dam WY02497

Naughton Thermal Power Plant

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DOCUMENT CONTROL AND PLANHOLDER LIST

Copy Number Organization and Address Person Receiving a Copy

1 Naughton Power Plant

PO Box 191 Kemmerer, WY 83101

Plant Managing Director

2 Naughton Power Plant

PO Box 191 Kemmerer, WY 83101

Naughton Control Room Operator

3 Naughton Power Plant

PO Box 191 Kemmerer, WY 83101

Operations Training Manager

4 Naughton Power Plant

PO Box 191 Kemmerer, WY 83101

Engineering Manager

6 Naughton Power Plant

PO Box 191 Kemmerer, WY 83101

Emergency Action Plan Coordinator

7

Sweetwater County Emergency Management

731 C Street, Suite 131 Rock Springs, Wyoming 82901

County EMA Coordinator

8

Sweetwater County Combined Communications

Joint Powers Board 5 Shoshone Avenue, Green River,

Wyoming 82935

Executive Director

9 Lincoln County Emergency Management

421 Jefferson St., Suite 401 Afton, Wyoming 83110

Lincoln County Dispatch Office – Kemmerer

10 Lincoln County Sheriff Dispatch

1040 Justice Center Drive Kemmerer, Wyoming 83101

Lincoln County Sheriff’s Office – Kemmerer

11

Wyoming State Engineer's Office, Safety of Dams Program

122 West 25th Street, Herschler Building Cheyenne, Wyoming 82002

Safety of Dams Engineer

12 Wyoming Highway Patrol 6101 N Yellowstone Road

Cheyenne, Wyoming 82009

Southwest Regional Office – Evanston

13 National Weather Service, Riverton Forecast Office Senior Hydrologist

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12744 West US Highway 26 Riverton, Wyoming 82501

14

National Weather Service Colorado Basin Regional Forecast Center 2242 West North Temple, Salt Lake City,

Utah 84116

Lead Forecaster

15 Wyoming Office of Homeland Security

5500 Bishop Boulevard Cheyenne, Wyoming 82009

State Planner

16 Naughton Power Plant

PO Box 191 Kemmerer, WY 83101

Electronic Copy in P8 Database

17 Sims Sheep Company 521 Almy Road 107

Evanston, Wyoming 82930 Sims Residence

18

Westmoreland Kemmerer Mine PO Box 950

6520 Elkol County Rd. 304 Kemmerer, WY 83101

Mine Manager

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Statement of Purpose Tab (Gray)

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STATEMENT OF PURPOSE

This Emergency Action Plan (EAP) has been prepared by PacifiCorp, in accordance with EPA requirements under the Coal Combustion Residual rule (40 CFR 257.73(a),(3)) to provide early warning to people who may be affected by the sudden release of water caused by natural disaster, accident or failure of any component of FGD Pond 4 at the Naughton Thermal Power Plant (Plant). The EAP also seeks to minimize the impact on property caused by emergency events. During an actual emergency, questions regarding the status of the emergency or administration of the EAP should be directed to PacifiCorp's Media Hotline at 800-775-7950. PacifiCorp’s Media Communication Representative will respond to keep the public and media informed of the changing situation. The failure studies underlying this Plan are strictly hypothetical and the procedures presented in this Plan were developed to handle the impact of those “what if” conditions. The Plan does not in any way reflect upon the safety, adequacy, or integrity of any project component. The dam and its appurtenant structures, systems and procedures have been inspected by independent consultants, and their good condition and operation have been certified.

Emergency Action Plan – FGD Pond 4 National Inventory of Dam WY02497

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SUMMARY OF EAP RESPONSIBILITIES

PacifiCorp’s Responsibilities

• Maintain this EAP and update it annually

• Provide and facilitate training and testing of the EAP

• Detect, verify, and assess emergency conditions

• Send notification of emergency conditions to specifically-identified local authorities, EAP planholders, and agencies shown on the corresponding emergency level notification chart of this EAP

• Terminate the emergency condition in conjunction with local authorities

• Facilitate an after-action evaluation and report

Emergency Management Agency Responsibilities

• Participate in training and testing as appropriate

• Public warning and notification

• Coordinate the evacuation from inundation areas and block access areas

• Establish evacuation routes and road closures

• Provide security for the affected areas during, and after, evacuation

• Establish shelters for evacuated individuals

• Facilitate return of evacuated individuals

• Participate in after-action evaluation

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Notification Flowchart Tab (Gray)

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Level 0 Non Failure Tab (White)

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LEVEL 0: NON-FAILURE CONDITION FGD Pond 4 DAM NOTIFICATION FLOW CHART

SHIFT SUPERVISOR 801-828-4250

PLANT ENGINEERING MANAGER Ryan Witbeck

307-828-4267 (o) 307-871-8730 (c)

PACIFICORP - DAM SAFETY ENGINEERING GROUP

Roger Raeburn, Chief Engineer 503-552-2715 (o) 503-278-1001 (c)

OR Peter Martins, Dam Safety Manager

503-813-6639 (o) 971-804-3244 (c)

1s

2n

PLANT MANAGING DIRECTOR Rodger Holt

307-828-4275 (o) 307-248-3374 (c)

3r

Note: (o) Office (c) Cell

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Level 1 High Flow Tab (Green)

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A Level 1 Emergency Condition has not been identified for FGD Pond 4. The pond has no upstream inputs and therefore is not expected to have high flow conditions.

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Level 2 Potential Hazard Tab (Yellow)

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NOTIFICATION FLOWCHART LEVEL 2: POTENTIALLY HAZARDOUS CONDITION

PACIFICORP GRID OPERATION 503-251-5253

LINCOLN COUNTY EMERGENCY MANAGEMENT 307-877-9835

OR 911

PACIFICORP MEDIA HOTLINE 1-800-775-7950 (24 HRS)

5th

WYOMING HOMELAND SECURITY 307-777-4321

Note: (o) Office (c) Cell

SHIFT SUPERVISOR 801-828-4250

CONTROL ROOM OPERATOR 307-328-4450 24-Hours

307-677-5895 (c)

Mobilize Plant Emergency Response Team (If Needed)

Sound Plant Alarm

PACIFICORP - DAM SAFETY ENGINEERING GROUP

Roger Raeburn, Chief Engineer 503-552-2715 (o) 503-278-1001 (c)

OR

Peter Martins, Dam Safety Manager 503-813-6639 (o) 971-804-3244 (c)

1st

2nd

2nd

1st

3rd

PLANT MANAGING DIRECTOR Rodger Holt

307-828-4275 (o) 307-248-3374 (c)

3rd

4th

NATIONAL WEATHER SERVICE RIVERTON OFFICE

307-857-3869 OR

NATIONAL WEATHER SERVICE COLORADO BASIN RFC

801-824-4377

WYOMING HIGHWAY PATROL Dispatch Center 307-777-4321

WYOMING DEPARTMENT OF TRANSPORTATION

307-777-3987

UINTA COUNTY EMERGENCY MANAGEMENT

307-783-0327 OR 307-783-1000

4th

1st

5th

3rd

2nd

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Level 3 Failure Tab (Red)

Emergency Action Plan – FGD Pond 4 NID WY02497

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NOTIFICATION FLOWCHART LEVEL 3: FAILURE IS IMMINENT OR HAS OCCURRED

SHIFT SUPERVISOR 801-828-4250

1st

5th

2nd

1st

PACIFICORP GRID OPERATION 503-251-5253 3rd 2nd

3rd

4th

WYOMING HOMELAND SECURITY 307-777-4321

4th

1st

5th

3rd

2nd

Note: (o) Office (c) Cell

CONTROL ROOM OPERATOR 307-328-4450 24-Hours

307-677-5895 (c) Mobilize Plant Emergency Response

Team (If Needed)

Sound Plant Alarm

PACIFICORP - DAM SAFETY ENGINEERING GROUP

Roger Raeburn, Chief Engineer 503-552-2715 (o) 503-278-1001 (c)

OR

Peter Martins, Dam Safety Manager 503-813-6639 (o) 971-804-3244 (c)

PLANT MANAGING DIRECTOR Rodger Holt

307-828-4275 (o) 307-248-3374 (c)

LINCOLN COUNTY EMERGENCY MANAGEMENT 307-877-9835

OR 911

PACIFICORP MEDIA HOTLINE 1-800-775-7950 (24 HRS)

NATIONAL WEATHER SERVICE RIVERTON OFFICE

307-857-3869 OR

NATIONAL WEATHER SERVICE COLORADO BASIN RFC

801-824-4377

WYOMING HIGHWAY PATROL Dispatch Center 307-777-4321

WYOMING DEPARTMENT OF TRANSPORTATION

307-777-3987

UINTA COUNTY EMERGENCY MANAGEMENT

307-783-0327 OR 307-783-1000

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General EAP Information Tab (Gray)

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PROJECT DESCRIPTION

General Project Description

The Naughton Power Plant (the Plant) is located approximately 3 miles from the town of Kemmerer, Wyoming as shown in Figure 1. The Plant consists of three coal-fueled units, rated with a net dependable capacity of 156 MW, 201 MW, and 280 MW, respectively. Coal combustion by-products at the Plant include several types of materials including bottom ash, fly ash, and flue gas desulfurization (FGD) materials.

FGD Pond 4 (FGD-4) manages flue gas desulfurization materials produced from coal-fired power generation Units 1, 2, and 3. The flue gas generated at these units passes through scrubbers and is “sprayed with a slurry mixture of soda liquor and other chemicals which capture and pull sulfur dioxide” out of the exhaust gas, producing FGD waste. The FGD waste is then transferred through a pipe from units 1, 2 and 3 to FGD-4. FGD-4 was constructed in 2010 and has an active storage capacity of 1,407 acre-feet with an expected service life of six to seven years and a base elevation greater than or equal to 6815 ft above mean sea level (amsl) (Tetra Tech, 2009; 2010).

FGD-4 was designed and constructed as a homogenous fill embankment with a double-liner, leak detection system, and underlying drainage system. These systems were installed because it was expected that the excavation of FGD-4 would intercept perched groundwater and/or seepage from adjacent, unlined ponds. In addition to minimizing contaminant transport, the drainage system reduces hydrostatic pressure, improving the long term stability of FGD-4. A summary of relevant information regarding FGD-4 is presented in Table 1.

Table 1 – FGD Pond 4 Relevant Information

NID # Hazard Classification

Crest Elevation

Max. Pond Elevation

Design Freeboard

Pond Capacity

WY02497 Significant 6,870’ AMSL 6,865’ AMSL 5’ 1,367 acre-ft

Areas Potentially Affected by a Dam Failure

Motorists and property downstream of FGD Pond 4 could be affected as a result of embankment failure. The inundation map included in this EAP show the extent of the expected embankment failure flood flow. The only permanent residence or business located flood zone of FGD Pond 4 is the Sims Sheep Company located near the Carter Cutoff Road (County Road 225) (Figure 3). Also located downstream of FGD Pond 4 are several roads (County Roads 304, 305 and 225 (Carter Cutoff Road) and U.S. Route 189) that will likely be inundated with water in the event of a failure at the FGD Pond 4.

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Figure 1: Project Vicinity Map

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Figure 2: FGD Pond 4 overview.

South Ash Pond

South Clear Water Pond

FGD Pond 4 Inflow Channel

FGD Pond 4

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Figure 3: Approximate location of Sims Sheep Company

SIMS SHEEP CO.

FGD Pond 4

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EAP RESPONSE PROCESS

Step 1 – Incident Detection, Evaluation, and Emergency Level Determination

Incident Detection This section describes the detection of a non-failure or emergency condition and provides information to assist PacifiCorp in determining the appropriate emergency level for the condition.

Non-failure or emergency conditions may be detected by the following:

• Observations at or near the dam by PacifiCorp, government personnel (local, state, or federal), visitors to the dam, or the public.

• Evaluation of instrumentation data. • Earthquakes felt or reported in the vicinity of the dam (this is to be differentiated from

ground tremors as a result of blasting at the near by mine). • Forewarning of conditions, which may cause a non-failure condition or emergency

condition at the dam. For example, a severe weather or flash flood forecast Emergency Evaluation After a non-failure or emergency condition is detected or reported, the Shift Supervisor is responsible for classifying the event into one of the following three emergency levels: Level 0: Non-Failure Condition A Level 0 condition is the least severe of any of the conditions and applies when there is an event at the project which does not constitute a higher level response. Some examples of this would be trespassing, theft, broken equipment which would not lead to a higher level response, etc. When a Level 0 condition has been detected, the Shift Supervisor will initiate Level 0 measures and contact all individuals and agencies assigned to them on the Notification Chart in the “Non-Failure” section of this EAP, and advise them of the situation. It will be the Shift Supervisor’s role to use judgment and notify the appropriate agencies as necessary. This includes differentiating between ground tremors resulting from earthquakes as opposed ground tremors resulting from blasting at the nearby mine.

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Level 1: High Flow or Flooding Condition A Level 1 High Flow or Flooding Condition has not been identified for FGD Pond 4. FGD Pond 4 has no upstream inputs and therefore is not expected to have high flow conditions. Level 2: Potentially Hazardous Condition Developing A Level 2 condition exists when there may still be time to correct or modify an observed dam safety condition which could escalate into dam failure if left unattended, but which does not pose immediate danger. If a Level 2 condition is indicated, the Shift Supervisor will activate Level 2 measures by notifying the Control Room Operator. The Shift Supervisor and Control Room Operator will then notify all individuals and agencies assigned to them on the Notification Chart in the “Potential Hazard” section of this EAP, and will tell each of them that “a Level 2 potentially hazardous condition is developing at FGD Pond 4” or “Level 2 of FGD Pond 4 EAP is activated for a potential hazardous condition at the dam.” Level 3: Failure Has Occurred or Is Imminent A Level 3 condition exists when a dam failure has occurred or is imminent (will very soon occur), and there is no time to mitigate the failure. Emergency response to both conditions should be the same since a failure of FGD Pond 4 could occur at any time. When a Level 3 condition exists, the Shift Supervisor will activate this EAP by notifying the Control Room Operator. The Shift Supervisor and the Control Room Operator will then contact all individuals and agencies assigned to them on the Notification Chart in the “FAILURE” section of this EAP, and will tell each of them that “a Level 3 failure of FGD Pond 4 is occurring or will very soon occur” or “Level 3 of the FGD Pond 4 EAP is activated for a dam failure at FGD Pond 4.”

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Step 2 – Notification and Communication

Staff Responsibilities The following people and groups within PacifiCorp share responsibilities for proper operation and emergency response of the dam:

The Plant Managing Director is responsible for routine maintenance and emergency repairs to the dam. The plant’s staff includes civil, mechanical and heavy equipment operating specialties. The PacifiCorp Dam Safety Engineering Group is also available to support the Plant Managing Director on emergency repairs.

The Naughton Operations Manager is based at the project plant, and is responsible for the day-to-day inspections and operations of the facilities. Plant personnel, including seasonal employees, work under the Operations Manager’s direction.

The Plant personnel are based at the Plant, and are responsible for the weekly and monthly inspections and day-to-day operations of the dam and appurtenant structures. Plant personnel work under the Engineering/Environmental Manager’s directions.

The Plant Shift Supervisor is responsible for implementing the EAP. This person is responsible for notifying and coordinating with staff and plan holders during emergencies.

The Plant Safety Department is responsible for the development, review and update of the emergency response programs, including this EAP. This department is responsible for conducting and evaluating functional exercises; executing and evaluating annual EAP drills and test results; training PacifiCorp personnel in emergency response; and providing updated information for EAP issuances and revisions.

The Naughton EAP Coordinator will conduct an investigation and prepare a report for the company documenting each event. A plan responding to the event, required monitoring, and follow-up actions will be developed and carried out according to recommendations made by qualified personnel.

Plant Personnel Responsibilities in the Event of an Emergency All personnel first observing or verifying any emergency situation at the dam are responsible for notifying the Shift Supervisor.

Quick notification allows time to provide early warning to emergency response agencies and to individuals who may be affected by the sudden release of water caused by natural disaster, accident or failure of the dam. Notification Flow Charts After the emergency level has been determined, the people on the notification flowchart for the appropriate emergency level shall be notified immediately. The following “Contact Checklist Form” may be used to record and document the contacts that were made.

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Contact Checklist Form (May be completed by PacifiCorp during the emergency)

Date: _________________

The following contacts must be made immediately after the emergency level is determined (see Step 1 for guidance to determine the appropriate emergency level for a specific situation). The person making the contacts must initial and record the time of the call and who was notified for each contact made. See the “Notification Flowchart” tab for critical contact information. Emergency Level 0 Person Time Contacted Contacted Contacted By __ Naughton Operations Manager _____________ ____________ _____________

__ Dam Safety Engineering Group _____________ ____________ _____________

__ Plant Managing Director _____________ ____________ _____________

Emergency Level 2 Person Time Contacted Contacted Contacted By __ Control Room Operator _____________ ____________ _____________

__ Dam Safety Engineering Group _____________ ____________ _____________

__ Plant Managing Director _____________ ____________ _____________

__ Lincoln County EM _____________ ____________ _____________

__ PacifiCorp Media Hotline _____________ ____________ _____________

__ SIMS Sheep Co. _____________ ____________ _____________

Emergency Level 3 Person Time Contacted Contacted Contacted By __ Control Room Operator _____________ ____________ _____________

__ Lincoln County EM _____________ ____________ _____________

__ PacifiCorp Media Hotline _____________ ____________ _____________

__ Dam Safety Engineering Group _____________ ____________ _____________

__ Plant Managing Director _____________ ____________ _____________

__ SIMS Sheep Co. _____________ ____________ _____________

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Communication Potential Failure – Level 2

The following message may be used to help describe the emergency situation to the Local Emergency Official:

• “This is (Identify yourself; name, position).

• We have an emergency condition at the FGD Pond 4, located at the Naughton Thermal Power Plant, about 3 miles southwest of Kemmerer, Wyoming.

• We have activated the Emergency Action Plan for this dam and are determining this to be a Potential Failure condition.

• We are implementing predetermined actions to respond to a rapidly developing situation that could result in dam failure.

• Please prepare to evacuate the areas shown on the inundation map in your copy of the Emergency Action Plan.

• We will advise you when the situation is resolved or if the situation gets worse.

• I can be contacted at the following phone number . If you cannot reach me, please call the following alternative phone number .”

Imminent Failure – Level 3 The following message may be used to help describe the emergency situation to emergency management personnel:

• “This is an emergency. This is (Identify yourself; name, position).

• FGD Pond 4, located at the Naughton Thermal Power Plant about 3 miles southwest of Kemmerer, Wyoming, is failing. The downstream area must be evacuated immediately. Repeat, the FGD Pond 4 is failing; evacuate the areas shown on the inundation map in your copy of the Emergency Action Plan.

• We have activated the Emergency Action Plan for this dam and are determining this to be an Imminent Failure condition.

• I can be contacted at the following phone number . If you cannot reach me, please call the following alternative phone number .”

• The next status report will be provided in approximately ________ minutes.”

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The following pre-scripted message may be used as a guide for emergency management authorities to communicate the status of the emergency with the public:

• Attention: This is an emergency message from the ________. Listen carefully. Your life may depend on immediate action.

• FGD Pond 4, located at the Naughton Thermal Power Plant about 3 miles southwest of Kemmerer, Wyoming, is failing. Repeat. FGD Pond 4, located at the Naughton Thermal Power Plant, about 3 miles southwest of Kemmerer, Wyoming, is failing.

• If you are in or near this area, proceed immediately to higher ground away from the valley. Do not travel on _____. You cannot outrun or drive away from the flood wave. Proceed immediately to higher ground away from the valley.

• Repeat message.

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Step 3 – Emergency Actions After the Shift Supervisor determines the emergency level, the following actions may be taken. The Shift Supervisor may contact PacifiCorp’s Dam Safety Engineering Group for technical consultation. The Shift Supervisor may record the available information, observations, and actions taken on the “Event Log Form,” included after the table below. The time of changing conditions should be noted on the form and the situation documented with photographs and video, if possible. The information in the table below provides recommended actions to be taken based on the given condition. These actions may be performed directly by plant staff or by a contractor or consultant retained by PacifiCorp.

Description of Condition

Action to be Taken

FLOODING

Reservoir level reaches elevation 6,865 ft and is rising at a rate of greater than one foot per hour.

Assess cause of increased reservoir stage, especially during fair weather conditions. Perform additional tasks as directed by Dam Safety Engineer. Make notifications if condition worsens such that downstream flooding is imminent.

SEEPAGE

Localized new seepage or boil(s) observed along downstream

slope / toe of earthen embankment with

muddy discharge and increasing but

controllable discharge of water.

Measure and record feature dimensions, flow rate, and relative location to existing surface features. Take photos if possible. Document location on a site plan and in inspection report. Place a ring of sand bags with a weir at the top towards the natural drainage path to monitor flow rate. If boil becomes too large to sand bag, place a blanket filter over the area using non-woven filter fabric and pea gravel. Attempt to contain flow in such a manner (without performing any excavations) that flow rates can be measured. Stockpile gravel and sand fill for later use, if necessary.

Inspect the dam and collect piezometer, water level, and seepage flow data daily unless otherwise instructed by Dam Safety Engineer. Record any changes of conditions. Carefully observe dam for signs of depressions, seepage, sinkholes, cracking, or movement. Contact a geotechnical engineer and provide all collected information.

Maintain continuous monitoring of feature. Record measured flow rate and any changes of condition, including presence or absence of muddy discharge. Review information collected by field inspection and provide additional instructions / actions as required. Recommend remedial seepage control and stability measures. Make notifications if condition worsens such that failure is imminent

EMBANKMENT DEFORMATION

SINKHOLES: Small depression observed on the

embankment or within 50 feet of the

embankment toe that is less than 5 feet deep

Measure and record feature dimensions and relative location to existing surface features. Take photos if possible. Document location on a site plan and in inspection report. Restrict traffic on dam crest to essential emergency operations only. Rope off sinkhole with sufficient distance to feature to prevent Contact a geotechnical engineer and provide all collected information.

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Description of Condition

Action to be Taken

and 30 feet wide or which is increasing

with time.

Backfill the depression with relatively clean earth fill (free of organic materials) generally even with surrounding grade and slightly mounded (6 to 12 inches higher) in the center in order to shed storm water away from the depression. Stockpile additional fill. Inspect the dam; collect piezometer and water level data daily unless otherwise instructed by Dam Safety Engineer; and record any changes of condition. Carefully observe dam for signs of depressions, seepage, sinkholes, cracking or movement. Review information collected by field inspectors and provide additional instructions / actions as required. Consider remedial construction such as grouting. Make notifications if conditions worsen such that failure is imminent.

CRACKS: New longitudinal

(along the embankment) or

transverse (across the embankment) cracks more than 6 inches deep or more than 3

inches wide or increasing with time.

New cracks on or near the embankment crest associated with slope

movement

Measure and record feature dimensions and relative location to existing surface features. Take photos if possible. Document location on a site plan and in inspection report. Restrict traffic on dam crest to essential emergency operations only. Contact a geotechnical engineer and provide all collected information. Place a buttress against base of slope immediately below surface feature and extending beyond visible feature limits (parallel to the embankment). Stockpile additional fill. Place sand bags as necessary around crack area to divert storm water runoff from flowing into crack(s). Inspect the dam; collect piezometer and water level data twice daily unless otherwise instructed by Dam Safety Engineer; and record any changes of condition. Carefully observe dam for signs of depressions, seepage, sinkholes, cracking or movement. Review information collected by field inspectors and provide additional instructions / actions as required. Consider survey monitoring of crack and embankment. Make notifications if conditions worsen such that failure is imminent.

EMBANKMENT DEFORMATION (continued)

SLIDES / EROSION: Deep slide / erosion (greater than 2 feet deep scarp) on the

embankment that may also extend beyond the

embankment toe but does not encroach onto the embankment crest

and appears stable with time.

Measure and record feature dimensions, approximate flow rate, and relative location to existing surface features. Take photos if possible. Document location on a site plan and in inspection report. Restrict traffic on dam crest to essential emergency operations only. Contact a geotechnical engineer and provide all collected information. Re-establish embankment fill slope. Place a buttress against base of slope at the slide location that extends beyond the furthest downstream limits (perpendicular to the embankment) and extending beyond visible feature limits at either end (parallel to the embankment). Place sand bags as necessary around slide area to divert any storm water runoff from flowing into slide(s). Inspect the dam; collect piezometer and water level data daily unless otherwise instructed by Dam Safety Engineer; and record any changes of condition. Carefully observe dam for signs of depressions, seepage, sinkholes, cracking or movement. Review information collected by field inspectors and provide additional instructions / actions as required. Consider survey monitoring. Make notifications if conditions worsen such that failure is imminent.

SABOTAGE AND MISCELLANEOUS OTHER ISSUES

FGD Pond 4, NID WY02497 Page 25 – April 2017

Description of Condition

Action to be Taken

Criminal action with significant damage to

embankment or structures where

significant repairs are required and the

integrity of the facility is compromised – condition appears stable with time.

Contact law enforcement authorities and restrict all access (except emergency responders) to dam. Restrict traffic on dam crest to essential emergency operations only. Assess extent of damage and visually inspect entire dam for additional less obvious damages. Based on inspection results, confirm if extent of damages to various components of the dam warrants revised emergency level and additional notifications. Perform additional tasks as directed by the Dam Safety Engineer or designee. Make notifications if conditions worsen.

FGD Pond 4, NID WY02497 Page 26 – April 2017

Event Log Form (May be completed by PacifiCorp during the emergency)

When and how was the event detected? _____________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Weather conditions: _____________________________________________________________ General description of the emergency situation: _______________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Emergency level determination: ______________ ____ Made by: ________________________

Actions and Event Progression Date

Time

Action/Event Progression

Taken By

REPORT PREPARED BY: ___________________________________ DATE: _______________

FGD Pond 4, NID WY02497 Page 27 – April 2017

Step 4 – Termination and Follow-up Whenever the EAP has been activated, an emergency level has been declared, all EAP actions have been completed, and the emergency is over, the EAP operations must eventually be terminated and follow-up procedures completed. Termination Responsibilities

After consultation with PacifiCorp’s Dam Safety Group, the Plant Emergency Response Team and any affected outside agencies, the Shift Supervisor or designee will terminate each emergency under this EAP together. It is then the responsibility of each person to notify the same group of contacts that he or she notified during the original event notification process to inform those people that the event has been terminated. Prior to termination of a Level 2 or Level 3 emergency event that has not caused actual dam failure, a PacifiCorp Dam Safety Engineer will inspect the dam to determine whether any damage has occurred that could potentially result in progression to Level 3 condition. If it is determined that conditions do not pose a threat to people or property, the Plant will advise the Local Emergency Official of the situation at the dam. Termination of the emergency is the decision of the Local Emergency Official or Incident Command. EAP Activation Follow-up Responsibilities

The Plant Engineering Group will prepare a report for PacifiCorp Management documenting the event and all actions taken. The following “Dam Safety Emergency Situation Report” may be used by PacifiCorp personnel to document the emergency event and all actions taken.

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Dam Safety Emergency Situation Report (May be completed by PacifiCorp following the termination of the emergency)

Date: ____________________________________________ Time:________________________ Weather Conditions: _____________________________________________________________ General Description of Emergency Situation: _________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Area(s) of Dam Affected: _________________________________________________________ ______________________________________________________________________________ Extent of Dam Damage: __________________________________________________________ ______________________________________________________________________________ Possible Cause(s): _______________________________________________________________ Effect on Dam’s Operation: _______________________________________________________ Initial Reservoir Elevation: __________________________ Time:________________________ Maximum Reservoir Elevation: ______________________ Time:________________________ Final Reservoir Elevation: __________________________ Time:________________________ Description of area flooded downstream/damages/injuries/loss of life: ______________________ ______________________________________________________________________________ Other Data and Comments: ________________________________________________________ ______________________________________________________________________________ Observer’s name and telephone number: _____________________________________________ Report Prepared by: ________________________________ Date: _ ____________________

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GENERAL RESPONSIBILITIES

PacifiCorp Responsibilities Monitoring Changing Conditions In the event that an incident is developing and/or could occur, the EAP Coordinator or designee will remain on-site to visually monitor the dam condition as long as it is safe to do so. Until conditions change, this monitoring shall be periodically reported to the Shift Supervisor. A Liaison will be assigned to planholder agencies following any EAP activation so that updates can be provided.

Notification of Emergency Conditions Plant personnel have been trained to identify unusual and/or emergency conditions as part of their routine duties, and to initiate notifications and actions as appropriate. At the first possible opportunity after identifying an emergency condition, plant personnel will inform the Shift Supervisor, who will initiate emergency operating procedures.

If the Emergency Action Plan is activated, the Shift Supervisor will contact the Control Room Operator. The Control Room Operator will then initiate on-site emergency response. The Shift Supervisor will then initiate the emergency-appropriate notification of the planholders, local, state, and federal agencies listed on the Notification Charts in Tab 1 of this EAP.

Security during Emergency Conditions In emergency situations, the embankment will be secured by installing barricades and manning them at all access points. Only PacifiCorp employees and approved individuals (emergency response teams and law enforcement personnel) will have access to those areas. Plant personnel will continue monitoring the dam and appurtenant structures until PacifiCorp engineers or approved consultants have completed their inspections, determined current safety status and flooding potential, and provided a plan to address any contingency.

High Flow Procedures A high flow emergency condition is not applicable for FGD Pond 4.

Emergency Action Plan – FGD Pond 4 NID WY02497

Naughton Thermal Power Plant

FGD Pond 4 EAP, NID WY02497 Page 30 – April 2017

Notification and Communication Responsibilities According to statutory obligations under their charters, local governmental authorities have the responsibility to plan warning and evacuation procedures for their local areas. When PacifiCorp has verified that conditions exist which meet the emergency classifications of this EAP, PacifiCorp is responsible for notifying the specifically-identified local authorities and EAP planholders shown on the corresponding emergency level notification chart of this EAP.

Evacuation Responsibilities Once PacifiCorp has notified the appropriate local authorities, it is the responsibility of those authorities to carry out the warning and evacuation procedures they have planned for their local areas.

Monitoring, Security, Termination, and Follow-Up Responsibilities The Plant Engineering Group will prepare a report for PacifiCorp Management documenting the event and all actions taken. A plan responding to the event, required monitoring, and follow-up actions will be developed and carried out according to recommendations made by qualified personnel.

EAP Coordinator Responsibilities The EAP Coordinator is responsible for the development, implementation, review and update of all emergency response programs, including this EAP. This person is responsible for evaluating annual EAP drills and test results; training PacifiCorp personnel in emergency response; and providing updated information for EAP issuances and revisions. The EAP Coordinator is located in the Naughton Plant and can be contacted as indicated below with any questions concerning this EAP.

Emergency Action Plan – FGD Pond 4 NID WY02497

Naughton Thermal Power Plant

FGD Pond 4 EAP, NID WY02497 Page 31 – April 2017

PREPAREDNESS

Surveillance and Monitoring FGD Pond 4 is visually observed on a weekly basis by Plant personnel with formal inspections of FGD Pond 4 by Plant personnel completed annually and after non-routine events such as earthquakes or significant rainfall events. PacifiCorp Dam Safety Engineering personnel may perform periodic inspection of the dam. In addition, the State of Wyoming’s dam safety engineer may conduct inspections. During periods of known or expected high inflows, Plant personnel may be assigned to specially observe the dam or other project facilities for signs of developing dam safety issues. Plant personnel utilize vehicles equipped with two-way mobile radios, portable hand-held radios, and cellular telephones to notify the Shift Supervisor of current conditions.

Evaluation of Detection and Response Timing Plant personnel perform onsite evaluation of the conditions of the dam. If a significant event has occurred, additional resources can be requested from PacifiCorp’s Dam Safety Group to the site to inspect the dam for damage. Qualified personnel (PacifiCorp engineers and/or consultants) will evaluate the conditions and provide recommendations for short-term actions.

Access to the Site Access to FGD Pond 4 is either by foot or can be accessed via a gravel road off of the paved access road, County Road 302. FGD Pond 4 is accessible by the public. There are no physical barriers preventing public access to the pond. The Kemmerer Municipal Airport is located about 4 miles southwest of the Plant and dam.

Response During Periods of Darkness Plant personnel are present at the Plant seven days a week, 24 hours per day, and can provide emergency support and verify an emergency at FGD Pond 4 during "hours of darkness” normally within minutes. Temporary portable lights are available from the Plant if needed.

Response During Weekends and Holidays Plant personnel are present at the Plant seven days a week, 24 hours per day, and can provide emergency support and verify an emergency at the dam during weekends and holidays within minutes. PacifiCorp’s Dam Safety Group is typically available Monday through Friday, but can generally be contacted on weekends and holidays by telephone.

Emergency Action Plan – FGD Pond 4 NID WY02497

Naughton Thermal Power Plant

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Response During Adverse Weather The dam is visited daily by Plant personnel, and therefore, access to FGD Pond 4 and responding to an emergency needs to remains possible during periods of adverse weather.

Alternative Sources of Power There are no permanent sources of power at FGD Pond 4.

Emergency Supplies and Information Emergency equipment and supplies required for non-dam related emergencies (such as first aid kits, fire extinguishers, contingency plans, oil spill booms, etc.) are located throughout the Plant and are described in the Plant’s Emergency Procedures Manual. External contractors (civil, mechanical, electrical, etc.) that have equipment and materials needed to respond to a request from PacifiCorp to provide services in the case of a dam emergency are listed in the Emergency Vendor List. The listed contractors have been selected due to their experience. In addition, each of these contractors maintains a current contractual relationship with PacifiCorp so that most administrative details have been pre-arranged. The contractors are familiar with local logistics including worker lodging and transportation to assure that an emergency workforce is available locally. The Plant Senior Staff is preauthorized to use the services of any of the listed contractors in the case of a dam safety emergency or failure.

Emergency Action Plan – FGD Pond 4 NID WY01547

Naughton Thermal Power Plant

FGD Pond 4 EAP, NID WY02497 Page 33 – April 2017

Emergency Vendor List

Commodity/Service Supplier Contract # PGr Buyer Name Expiration Contact Name Title Contact # Mine Water Transportation BTI 460000378 923 Doug Jensen 12/31/2021 Roger King Vice President 307-877-2239

Civil Construction Services -Ut, Wy Flare Construction 4600003126 960 Mark Speight 3/31/2017 Chris Boyer Account Manager 435-336-2888 Civil Construction Services - Ut, Wy, Id Newman Construction Inc. 4600003132 960 Mark Speight 3/31/2017 Stuart Davis Account Manager 801-254-3524

Civil Construction Services - Ut, Wy Spindler Construction Corp. 4600003133 960 Mark Speight 3/31/2017 Gary Stevens Account Manager 435-753-0722 Civil Construction Services - Ut, Wy, Id Whitaker Construction 4600003135 960 Mark Speight 3/31/2017 Judd Hamson Account Manager 435-723-2921

Geotechnical Engineering (All Locations) Geoengineers Inc. 4600002830 601 Joe Kanell 4/30/2018 Lisa Berntsen Account Manager 360-265-1336 Geotechnical Engineering (All Locations) Geotechnical Resources Inc. 4600002831 601 Joe Kanell 4/30/2018 Scott Schlechter Account Manager 503-641-3478 Geotechnical Engineering (Ut, Wy, Id, Mt) Gerhart Cole Inc.orporated 4600002865 601 Joe Kanell 4/30/2018 Ryan Cole Account Manager 801-849-0055 Geotechnical Engineering (All Locations) Shannon & Wilson Inc. 4600002826 601 Joe Kanell 4/30/2018 Gary Peterson Account Manager 503-210-4751 Geotechnical Engineering (Ut, Wy, Id, Mt) Terracon Consultants Inc. 4600002827 601 Joe Kanell 4/30/2018 Rick Chesnut Account Manager 801-545-8500

Spill Response And Cleanup Services - Wyoming And Utah

Enviro Care Inc. 4600003760 982 Jeff Palmer 5/30/2019 John Hart Account Manager 801-299-1900 800-820-9058 (24 hr)

FGD Pond 4 EAP, NID WY02497 Page 34 – April 2017

Stockpiling Materials and Equipment Tools and equipment to complete minor to moderate repairs are available locally at the Plant. These include loaders, dozers, a trackhoe, and dump trucks. Some materials for the emergency use or repair of the dam and appurtenant structures are also available on-site. Sand, rock, and gravel are stockpiled on the south end of the Plant.

Coordination of Information During periods of known or expected high inflows, Plant personnel may be assigned to specially observe the dam or other project facilities for signs of developing dam safety issues.

Training and Exercise On an annual basis, PacifiCorp personnel will exercise this EAP by responding to an unscheduled, simulated emergency at the project. The purpose of this exercise is to check the readiness of personnel and the effectiveness of the EAP, including identification of any corrections that need to be made to the EAP. The Plant Safety Department will administer the simulated emergency exercise of the EAP. At the end of the exercise, training will be given to operation personnel to correct any deficiencies identified during the simulation. An annual EAP exercise report will be prepared and kept on file that includes the executed scenario, project actions and field observations taken during the exercise, evaluator recommendations, training and follow-up items. The report will be available to planholders upon request.

Alternative Systems of Communication The primary communications system used at the Plant and dam site are landline telephones, radios, and cellular telephones. The Plant’s radio system is designed with redundant systems and power backups for emergency situations. Plant personnel dispatched to the dam utilize vehicles equipped with two-way radios operating under FCC licenses. These radios can communicate with control stations within the plant, and other mobile or portable radios around the plant, via fixed base stations which are located at the Plant. The radio system is connected to a remote node controller which controls other base stations. This connectivity also allows the radio system to be monitored for proper operation and alarm reporting. In addition, Plant personnel carry cellular telephones.

Public Awareness and Communication The emergency response agencies that the Shift Supervisor contacts will subsequently determine whether heightened awareness is sufficient for their constituents’ safety, or whether initiating the courses of action they have developed for early evacuation of certain areas is warranted.

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Inundation Maps Tab (Gray)

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INUNDATION MAPS

Inundation Map Development The inundation maps presented in this EAP were developed as part of the Hazard Potential Classification Assessment conducted for FGD Pond 4[4] and represent the hypothetical worst case scenario involving a rainy day breach of FGD Pond 4. The inundation maps represent the maximum water level anticipated to result from a flood wave occurring following a failure of FGD Pond 4. The maximum flood level will not occur simultaneously at all locations of inundation area shown on the maps. Plate 1 demonstrates the overall extent of flooding due to a breach of FGD Pond 4. The numbers on the map correlate with areas in which the hypothetical flood wave will significantly flood a road or structure (the Sims Sheep Co. buildings in this case). Table 2 contains the hypothetical maximum depth of flood waves and flood wave arrival time at each of the 7 locations indicated on Plate 1. Plate 2 is a close-up inundation map of the Sims Sheep Company property and includes hypothetical flood wave depths at several key structures. Since the study was hypothetical, the wave travel times and other data used to create the model may not be exact. The areas of flooding shown on the maps are therefore approximate, and should be used only as guidelines for establishing evacuation zones. Actual areas inundated will depend on actual failure conditions, and may differ from the areas shown on the maps.

Table 2: Maximum Flood Wave Height at 7 Locations Indicated on Figure 2 (Above) MAP ID Number

Road Name Maximum Potential Flood Wave Height (Feet above ground surface)

Estimated Arrival time of Flood Wave* (Hours after

Breach)

1 County Road 304 25 5

2 U.S. Route 189 25 6

3 U.S. Route 189 12 9

4 County Road 305 7 13

5 U.S. Route 189 21 26

6 U.S. Route 189 10 34

7 Carter Cutoff Road (County Road 225)

26 46

*Arrival time is based on depth of water reaching 0.1 feet

FGD Pond 4 EAP, NID WY02497 Page 37 – April 2017

Plate 1: Inundation map showing extent of potential flooding due to a rainy day failure of FGD Pond 4, with red numbers designating locations of maximum flood wave height (See

Table 2 for flood wave height)

1

2 3

4

5

6

7

Carter Cutoff Road (County Road 225)

Sims Sheep Co.

County Road 305

County Road 304

U.S. Route 189

FGD Pond 4 EAP, NID WY02497 Page 38 – April 2017

Plate 2: Detail of inundation map showing potential flood wave levels at key infrastructure

locations on the Sims Sheep Co. property.

REFERENCES

[1] URS Corporation, 2015 Coal Combustion Residuals Annual Inspection, FGD Pond 4,

2015.

[2] Water and Environmental Technologies, 2014 Ground Water Monitoring Report, PacifiCorp – Naughton Power Plant, 2015.

[3] MWH Global, Naughton FGD Pond 4 Hazard History of Construction, PacifiCorp – Naughton Power Plant, 2016.

[4] MWH Global, Naughton FGD Pond 4 Hazard Potential Classification Assessment, PacifiCorp – Naughton Power Plant, 2016.

15’ below water surface

3’ below water surface

FGD Pond 4 EAP, Naughton Power Plant, Wyoming Page − 1 – April 2017

Part II Tab (White)

FGD Pond 4 EAP, Naughton Power Plant, Wyoming Page − 2 – April 2017

EMERGENCY ACTION PLAN

Part II: Appendices

FGD Pond 4 National Inventory of Dams ID WY 02497

Naughton Power Plant

PacifiCorp Thermal Generation

1407 W North Temple Salt Lake City, Utah 84116

DO NOT DUPLICATE

Issued: A p r i l 2 0 1 7

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FGD Pond 4 EAP, Naughton Power Plant, Wyoming Page − 1 – April 2017

TABLE OF CONTENTS APPENDIX A: INVESTIGATION AND ANALYSIS OF DAMBREAK FLOODS ...............................2 APPENDIX B: PLANS FOR REVIEWING, REVISING, AND DISTRIBUTING THE EAP ..................6 APPENDIX C: PLANS FOR POSTING THE NOTIFICATION FLOWCHARTS .................................8 APPENDIX D: FORMS AND LOG SHEETS .............................................................................10 APPENDIX E: SITE SPECIFIC CONCERNS .............................................................................11 APPENDIX F: DOCUMENTATION .........................................................................................13

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Appendix A: INVESTIGATION AND ANALYSIS OF DAMBREAK FLOODS

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INVESTIGATION AND ANALYSIS OF DAMBREAK FLOODS

Breach Parameters Map Development

The dam breach analysis scenario considered for this project consists of a failure of FGD Pond 4 storing water at maximum crest elevation (6,870 ft amsl). This is a conservative estimate that was chosen as a worst case scenario in order to maximize public safety. The dam breach analysis was developed as part of the Hazard Potential Classification in fulfillment of §257.73 (A)(2) of the Environmental Protection Agency Code of Federal Regulation, the process of breach flow estimation and inundation modeling is provided below.

Breach Flow Calculations

The Fread method was used for calculating the peak flows from an overtopping dam breach. The method is outlined by the WSDOE (2007) and was developed for small embankment dams. The calculations utilize a breach formation factor to calculate the volume of eroded material, breach geometry, and time for breach development. This method is suitable for dams with a breach formation factor (BFF) of 100 acre-ft2 or greater, making it suitable for this analysis given the FGD Pond 4 BFF of 77,750 acre-ft2 (where the BFF is the product of the storage volume and height of breach).

The breach flows calculated using the Washington State Dam Safety Guidelines are based on the following equation:

𝑄𝑄𝑝𝑝𝑝𝑝𝑝𝑝𝑝𝑝 = 3.1 𝑊𝑊 𝐻𝐻1.5 �𝐴𝐴

𝐴𝐴 + 𝜏𝜏√𝐻𝐻 �3 𝑓𝑓𝑓𝑓3

𝑠𝑠𝑠𝑠𝑠𝑠

Where:

Qpeak = Dam breach peak discharge (cfs)

W = Average breach width (ft)

H = Initial Height of Water (ft) over the base elevation of breach

τ = elapsed time for breach development (min)

A = 23.4Sa/W (acres), where Sa is the surface area of the FGD Pond 4

The breach formation time is calculated as follows:

𝜏𝜏 = 0.036 𝑉𝑉𝑚𝑚0.36

Where:

𝜏𝜏 = The breach formation time (hours)

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𝑉𝑉𝑚𝑚 = The volume of material eroded during the breach (yds3)

The peak flow was assumed to coincide with the breach formation time. The results of this analysis were used as input to the inundation modeling.

Inundation Modeling

The peak flow developed from the previous analysis was modeled as a 2-D, unsteady flow using the U.S. Army Corp of Engineers River Analysis System (HEC-RAS). Model parameters and boundary conditions are described below.

Topographic Data:

Site topography data for the areas near the ponds,

Stage-Area-Storage data as developed by WET (2015), and

1/3 arc-second resolution raster files obtained from the National Elevation Dataset developed by the United States Geological Survey to investigate downstream impacts. The root mean square error of the 1/3 arc-second map is 1.55 m (5.09 ft) overall and 2.22 m (7.28 ft) for shrub/scrub land use types, which dominate the area (Gesch et al., 2014).

Grid Spacing:

The two dimensional model was evaluated using 50’ x 50’ grid spacing. Finer grid spacing was evaluated but had no discernable changes to the resulting inundations area.

Land Use / Land Cover:

Land use designation was evaluated using the National Land Cover Database (NLCD) produced by the Multi-Resolution Land Characteristics Consortium (Homer et al., 2011). The land use raster map was assigned Manning’s roughness values using the trimmed mean classifications developed by Bent et al. (2013) as shown below in Table A-1. The region is predominately classified as shrub/scrub.

TABLE A-1 – ASSIGNED MANNING’S ROUGHNESS PER NLCD ASSIGNED LAND COVER CLASS

NLCD Land Cover Class NLCD Index Number Assigned Manning’s n Barren Land Rock/Sand/Clay 31 0.033 Developed, Low Intensity 22 0.046 Developed, Medium Intensity 23 0.053 Developed, Open Space 21 0.027 Emergent Herbaceous Wetlands 95 0.089

Emergency Action Plan – FGD Pond 4, Naughton Power Plant PacifiCorp Thermal Operations

FGD Pond 4, Naughton Power Plant, Wyoming Page − 5 – April 2017

NLCD Land Cover Class NLCD Index Number Assigned Manning’s n Grassland/Herbaceous 71 0.037 Pasture/Hay 81 0.039 Shrub/Scrub 52 0.054 Woody Wetlands 90 0.089

Boundary Conditions:

1. The upstream boundary condition is the assumed breach flow hydrograph. The hydrograph shape is not determined in Washington State guidelines; therefore, MWH assumed a triangular hydrograph shape as shown below (Figure A-1). The area below the hydrograph is equal to the total volume of water above the dam breach and the time to peak and peak flow are maintained calculated using the WSDOE methods described previously.

2. Outflow Hydrograph – set as channel flowing at normal depth with 0.1% slope as recommended by HEC-RAS.

Figure A-1: Breach Hydrograph for failure of FGD Pond 4 at Maximum Water Surface Elevation

The results of the HEC-RAS model were overlain onto an aerial image, showing the extent of the inundation.

Emergency Action Plan – FGD Pond 4, Naughton Power Plant PacifiCorp Thermal Operations

FGD Pond 4 EAP

Page − 5 – Issued April 2017

References

Bent, R.W., Brelsford, C.M., Tasseff, B.A., and D.B. Visarraga. 2013. Hydropolis Dam Failure: Impact Assessment. 12th International Benchmark Workshop on Numerical Analysis of Dams. August 23, 2013.

Gesch, D.B., Oimoen, M.J., and Evans, G.A., 2014, Accuracy assessment of the U.S. Geological

Survey National Elevation Dataset, and comparison with other large-area elevation datasets—SRTM and ASTER: U.S. Geological Survey Open-File Report 2014–1008, 10 p., http://dx.doi.org/10.3133/ofr20141008.

Homer, C.G., Dewitz, J.A., Yang, L., Jin, S., Danielson, P., Xian, G., Coulston, J., Herold, N.D.,

Wickham, J.D., and Megown, K., 2015, Completion of the 2011 National Land Cover Database for the conterminous United States-Representing a decade of land cover change information. Photogrammetric Engineering and Remote Sensing, v. 81, no. 5, p. 345-354

Washington State Department of Ecology (WSDOE). 2007. Dam Safety Guidelines – Technical Note 1 Dam Break Inundation and Downstream Hazard Classification. Water Resources Program. Dam Safety Office. October 2007.

Water and Environmental Technologies (WET). 2015. Naughton Power Plant CCR Pond

Bathymetric Surveys. Part of the Naughton Power Plant IDF Control Plan. File No. MC-HH01-PERCM61.DWG. 11/25/15.

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Appendix B: Plans for Reviewing, Revising, and Distributing the EAP

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PLANS FOR REVIEWING, REVISING, AND DISTRIBUTING THE EAP

Issuance and Revision Versions

This EAP is re-issued every five years, and revised annually. An issuance is a complete re-make of the EAP. Each annual revision contains all updates and changes made to the EAP during the preceding year. Each issuance or revision packet completely replaces the previous year’s EAP contents.

After replacing the previous EAP in the existing binder, the new issuance or revision should be reviewed with others who may be using it in emergency situations. Following the review, the Acknowledgement of Receipt form should be filled in and returned to PacifiCorp as soon as possible via eMail, FAX or U.S. Mail. The transmittal letter should be placed behind the gray divider page titled, “Correspondence”.

If critical changes occur during the year prior to the next issuance or revision, changed pages will be provided when necessary. A new binder will be sent upon request.

Monitoring Acknowledgements of Receipts, Comments and Responses

An Acknowledgement of Receipt form is sent with each EAP issuance or revision, and contains our request that it be returned to us. The Emergency Action Plan Coordinator monitors the return of Plan Holder acknowledgements of receipt, and responds to any comments or concerns. The acknowledgements, comments and responses are kept on file at PacifiCorp.

Emergency Action Plan – FGD Pond 4, Naughton Power Plant PacifiCorp Thermal Operations

FGD Pond 4 EAP

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Appendix C: Plans for Posting the Notification Flowcharts

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FGD Pond 4 EAP

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PLANS FOR POSTING THE NOTIFICATION FLOWCHARTS

PacifiCorp’s EAPs are controlled documents. Part One of each EAP contains the information that EAP planholders agree is most useful to them in an emergency situation, and includes a description of our three emergency levels, the project’s inundation maps and estimated time-of-arrival charts, and our notification flowcharts, along with a project vicinity picture and brief description of project facilities. Part Two adds detailed information for use by project personnel.

EAP Issuance and Revisions Letters

In addition to the copies of two-part EAPs kept at the project locations listed in the “Current EAP Planholder and Volume Location List” in Part One of this EAP, a number of laminated notification flowcharts have been distributed and posted in the following locations for ready access in an emergency situation:

Chart Set No. Distributed to: Location: 1800 Plant Managing Director Plant Control Room 1801 Plant Managing Director Naughton Emergency Action Center 1806 Plant Managing Director Naughton Shift Supervisor Office

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FGD Pond 4 EAP

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Appendix D: Forms and Log Sheets

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FGD Pond 4 EAP

Page − 11 – Issued April 2017

Appendix E: Site Specific Concerns

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FGD Pond 4 EAP

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SITE SPECIFIC CONCERNS

Earthquakes

When Earthquakes Are Felt by Plant Personnel:

• An employee shall immediately notify CONTROL ROOM OPERATOR and then follow the prescribed procedures in the Earthquake Section of the facility’s Emergency Procedures Manual.

• Control Room Operator will notify the Managing Director and the Dam Safety Manager. • The Naughton EAP Coordinator will attempt to contact the U.S. Geological Survey at 303-

273-8680 to confirm an earthquake if he/she has not been notified regarding an earthquake in the area of the project.

• The Naughton EAP Coordinator will contact the Chief Dam Safety Engineer. Note: The adjacent coal mine conducts routine blasting as part of their mining operation. The ground tremors as result of the blasting will have to be differentiated by the plant form an actual earthquake. When Earthquakes Are 5.0 Magnitude and Above within 50 Miles of Site:

• Control Room Operator will receive an alarm indicating that a major earthquake has occurred near one of our projects along with information about the project location and contact information.

• Control Room Operator will notify the Naughton EAP Coordinator. • The Naughton EAP Coordinator will contact the Chief Dam Safety Engineer. • Additionally, the University of Utah Seismology Station may notify Control Room

Operator by telephone to report the epicenter and magnitude of the earthquake. These University of Utah notifications apply only for certain facilities and are verified by a seismologist prior to notification.

Inspections and Actions

When a safe work environment exists, plant personnel will conduct a thorough inspection and report the results to the Chief Dam Safety Engineer, Naughton EAP Coordinator. The Chief Dam Safety Engineer will then determine and direct any required follow-up measures.

Site personnel and CONTROL ROOM OPERATOR operators are allowed discretion on whether or not to activate the EAP or take other emergency measures following earthquakes or at any other time if conditions lead them to believe that dam structural integrity might be compromised.

Emergency Action Plan – FGD Pond 4, Naughton Power Plant PacifiCorp Thermal Operations

FGD Pond 4 EAP

Page − 13 – Issued April 2017

Appendix F: Documentation

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Emergency Action Plan – FGD Pond 4, Naughton Power Plant PacifiCorp Thermal Operations

FGD Pond 4 EAP

Page − 14 – Issued April 2017

DOCUMENTATION

PacifiCorp’s EAPs are controlled documents. Part One of each EAP contains the information that EAP planholders agree is most useful to them in an emergency situation, and includes a description of our three emergency levels, the project’s inundation maps and estimated time-of-arrival charts, and our notification flowcharts, along with a project vicinity picture and brief description of project facilities. Part Two adds detailed information for the use of project personnel.