600 North 18* Street & Alabama Power Post Ofice Box 2641 Birmingham, Alabama 35291 a March 26, 2019 IND. MUN BRANCH Overnight Mail - Receipt Requested Mr. Theo Pinson Alabama Department of Environmental Management 1400 Coliseum Boulevard Montgomery, AL 36110 Re: Upset of March 23, 2019 Gorgas Steam Plant NPDES Permit No. AL0002909 Dear Mr, Pinson: On March 23, 2019, at approximately 4:15pm, the Plant Gorgas #3 Switchyard fire protection system lost primary air pressure and the backup air compressor failed to operate. The loss in air pressure caused the switchyard fire protection system to open, spraying water throughout the switchyard which flowed into a nearby stormwater drainage system and discharged into Bakers Creek. In addition to using water to suppress fires, the switchyard fire protection system utilizes a chemical additive, F500 Multi-Purpose Encapsulator Agent, to quickly extinguish electrical fires. ‘The additive is mixed into the fire protection system at a ratio of approximately 1 gallon of additive per 30 gallons of water. Using this ratio, plant personnel estimate approximately 650 — 700 gallons of additive and 22,000 — 23,500 gallons of fire water were released throughout the switchyard during this event. The quantity of water/additive mixture that may have entered Bakers Creek could not be quantified. Within approximately 6 minutes from the start of the event, plant personnel were able to regain air pressure and control of the system. Subsequently, plant personnel initiated cleanup utilizing vacuum trucks to remove standing water from the switchyard and associated yard drains. Additionally, the primary and backup air pressure systems have been inspected and are fully ‘operational.Mr. Theo Pinson Page Two March 26, 2019 Brad Dutton reported this condition to you at approximately 8:05am on Sunday, March 24, 2019. Based on the fact that this was an exceptional incident in which there was an unintentional and temporary noncompliance with technology based permit discharge limitations because of factors beyond the reasonable control of the permittee, and was not caused by operational error, improperly designed treatment facilities, inadequate facilities, lack of preventative maintenance, or careless or improper operation, per Part II.C.2 and part III.H.43 of the NPDES permit, this incident is and should be considered an upset. Should you have any questions, please contact Brad Dutton at (205) 257-2237. VL wy, Mike Godfrey, Mane MWg Environmental Compliance Sheep IBD