Allen Steam Facility (17)

AN' '
F IL E
NCDENR ,w
Norah Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H Sullins Dee Freeman
Governor Director Secretary
September 30, 2010
Mr. Allen Stowe, Water Management
Duke Energy
Post Office Box 10WEC 13K
Charlotte, North Carolina 28201-1006
Subject: Compliance Sampling Inspection
Allen Steam Station
NPDES Permit No. NC0004979
Gaston County, N.C.
Dear Mr. `Stowe:
Enclosed please find a copy of the Compliance Sampling Inspection Report as well as the
results from the laboratory analyses on the samples collected at different'stage& of the FGD
treatment system at the Allen Steam Station during the inspection of the subject facility. The
samples analyzed were all grab,samples collected during the Compliance Sampling Inspection
performed on June 6, 20,10 by Ms. Donna Hood and Mr. Wes Bell of the Mooresville Regional
�Office.and Ms. Autumn Romanski of the Raleigh Regional Office Please inform the,facility'�s
Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed report.
The Outfall 002 sample results were compliant with the current NPDES permitted effluent
limits. However, exceedances,of Water Quality Standards were reported. Please be advised
that:
1. The following effluent results exceeded Water Quality Standards for Water Supplies:
Antimony (5.6 ug/1),, Total, Dissolved Solids (560 mg/L), Molybdenum (160 ug/1),
Manganese (200 ug/1), and Thallium (0.24 ug/1)
2. The Selenium results exceeded the weekly limit in the previous permit (21 ug/1) as well as
the Water Quality Standard for Class,B waters (5 ug/1).
3. The following results exceeded the Water Quality Action Levels for Class B streams:
Copper (7 ug/1), Silver (0.06 ug/1), Chloride (230 mg/1).
4. The following exceeded Water Quality Standards. Aluminum (87 ug/1)
Sample results for Outfall 002A also had exceedances; however, Outfall 002A was not
discharging on the day of the inspection. Samples were taken from the wetwell influent, directly
across from the overflowpipe. Exceedances are as follows: Silver, Aluminum, Copper, Iron,
Manganese, Molybdenum, Antimony, Selenium, Thallium, and Temperature.

Outfall 002A'is currently permitted for intermittent discharge and is only required to be
sampled after discharging for 30 minutes, the quality of the potential discharge is of concern. No
treatment is, available to the wastewater discharging from 002A and excessive temperatures
(45.3°C/113.5°F) and other constituents could be detrimental to the receiving stream.
While, no in -stream samples were collected, elevated effluent sample results'indicate the
need for further investigation/sampling to ensure Water Quality standards are being met and the
Catawba and South Fork Rivers are being protected.
Should you have ,questions concerning this report, please do not hesitate to contact Ms.
Hood, at [phone].
Sincerely,
Robert B. Krebs
Regional Supervisor
Surface Water Protection
Enclosure:
DH

i T,
Outfall' 002
01711
U 1
U I
Antimony
200
5.6
Selenium
25
5 ('pervious permit: 21)
Total'D►ssolved'Sol►ds
768
500
Molybdenum
200
160
Manganese
300
200`
Thallium
200
0.24
Copper
20
7
Silver
50
0.06
Chloride
240
230
Aluminum
190
87
Outfall 002A
Antimony
200
5.6
Silver
50
0.06
Aluminum
2600
87
Copper
35
7
Iron
5000
1000
Manganese
350
200
Molybdenum
200
160
Selenium
7.8
5
Thallium
200
0.24
Mooresvlllel Regional Office
Location -610 East CenterAve , Suite 301 Mooresville,�NC 28115 one
Phone [phone] Fax [phone] Customer Service 1-877.623-6748 NorthCarolina
Intemet,www ncwaterquahty org -
An Equal Opportunity IAffirmative Action Employer-50WRecycled110% Post Consumer paper �irtura!!�

United States Environmental Protecbon Agency
Forth Approved
EPA Washington, D C 20460
OMB No 2040-0057
Water Corn p fiance Ins ectlon Re p off
Approval, expires 8-31-98
Section'A National Data System Coding (I e, PCS)
Transaction Code NPDES yr/mo%day Inspection Type Inspector Fac Type
1 1 N1 2 151 31 NC00049.9 111 121 10/06/08 117 18' SI 19I SI 20I
L-
Remarks
211 111II I I I I I I I I I I I I I I I I I IIIc I I I I IIl1`IIII I.II_I IU6
Inspection WorIc0ays Facility Seif-Monitoring Evaluation Rating B1 Q,4 -------------=—Reserved-=----
67 I 5.0 169 701 41 7,11 iI 721 N( 73 74 751 I I I I I I 1 80
--�
Section B Facility-Data
Name and1ocation of Facility Inspected (Forindustnal Users,dischargmg to,POTW, also include
Entry Time/Date
Permit�EHective Date
POTW,name and'INPDES,permit Number)
09.95 AM 10/06/08
09/08/01
Plant Allen Steam Station
Exit Time/Date
Permit Expiration Date
NCSR 2525
Belmont NC 28012
03:30 PM 10/06/08`
10/05/31
'Name(s) of Onsite,Representative(s)fritles(s)/Phone and,Fax Number(s)
Other Facility Data
Donald Lynn Scruggs/ORC/704-829-2923/
Name, Address of Responsible OfficialMtle/Phone and,Fax Number
Contacted
Jimmie Allen,Stowe,526 S Chruch St Charlotte NC
No
28201'1002//704-382-4309/7043829840
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Permit ® Flow Measurement f Operations & Maintenance 0 Records/Reports
Self-Monitonng"Program Sludge Handling Disposal 0 Facility Site Review M,Effluent/Receiving Waters
Laboratory
Section D Summa ,of Finding/Comments Attach additional sheets of narrative,and checklists as,necessa
(See attachment summary)
Name(s),and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Wesley N Be MRO WQ//709-663-16991xt 2192/
n
Donna Ho MRO WQ//704-663-1699 Ext 2193/ 41
Si nature of Management Q PjRe w Agency/Office/Phone and Fax,Numbers Date
C,
I'
..a. MRO WQ//709-663-1699 Ext 2204/
Marcia Allocco
EPA Form 3560-31(Rev 9-94) Previous editions°are obsolete
Page # 1

Permit: NC0004979 Owner -Facility Plant Allen Steam Station
Inspection Date 06/08/2010 Inspection Type Compliance Sampling
Permit Yes No NA NE
(If the present permit expires in 6 months or less) Has the permittee submitted a new application? ■ n n n
Is the,facility as described imthe permit? ® n n n
# Are there any special conditions for the permit? n ■ fn n
Js access to the plant site restricted,to the general public? ® n Q n
Is the Inspector granted'access to all areas for inspections ®n Q n
Comment The facility Is currently classified°as a PC -1 The facility operates a
biological WWTP as well as extensive physical/chemical treatment This Information
has been submitted to Technical Assistance and Certification Unit ,(TACO) who will
re-evaluate the current classification
Operations & Maintenance Yes No NA NE
Is the,plant generally clean with acceptable housekeeping? ■ n n n
Does the facility analyze process control parameters, for ex MLSS, ,MCRT, Settleable Solids, pH, DO, Sludge ■ n n C1
Judge,, and other that are applicable?
Comment Although Duke supplies the ORC for the facllby, the FGD WWTP is
currently operated by a contract operator, Siemens Water Technologies
Record Keeping Yes No NA NE-
Are,records kept and maintained as required by thespwmit? ® n n n
Is all required information readily available, complete and current? ® n n n
Are all records maintained for 3�years (lab reg required 5,years)?
■ n n n
Are analytical results consistent with data,reported on DMRs?
■, n n n
n n M n
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of Individual performing the, sampling
Results,of analysisland calibration
Dates of analysis
Name of person performing analyses
Transported COCs
n
Are DMRs complete do,they;include all permit parameters?
n ■ n n
Has the facility submitted,its annual compliance report to users and DWW
n n ■ n
(If the facility is = or,> 5 MGD permitted flow) Do they operate'24/7 with a certified operator on each shift?
■ n n n
Is the ORC visitation log available and current,
■ n n n
Is the ORC certified'at grade equal to or higher than the facility classification?
■ n n In
Page # 3

Permit. NC0004979 Owner -Facility Plant Allen Steam Station
Inspection Date: 06/08/2010 Inspection Type Compliance Sampling
Lagoons
Yes No NA NE
Is the lagoon free of, -short circuiting?
■ O ,D 0
Comment
Flow Measurement - Effluent
Yes No NA NE
# Is flowmeter used for reporting*?
n 'n ■ n
Is flow meter calibrated annually
0,000,
Is the flow meter operational?
■ 0 n n
(If units are,separated) Does,the chart recorder match the flow meter?
_n n ■, 0'
Comment Effluent flow Is measured by pump logs and staff gauge
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
■ n n n
Is sample collected below all treatment units?
■ n n n
Is proper volume collected
nnn ■� -
Is the tubing,clean?
■ n Cl ❑
# Is proper temperature set°for sample storage (kept,at less than or equal,to 6 &degrees Celsius)?
■ ❑ n' n
,Is the facility sampling performed as required by,the permit (frequency,, sampling type representative)?
■, n n n
Comment The facility was sampled on the day of the�lnspectlon Please see the
attached sample result sheets for all sample results
Effluent Pipe
Yes .No NA NE
Is°right of way,to the outfall properly maintained?
■ n n n
Are the receiving water free of foam other than trace amounts and other debris?
■ n n ,Q
If effluent (diffuser,pipes are required) are they�operatng, properly?
00 �■ n
Comment
Page 9 5

ANALYTICAL RESULTS SHEET
NAME OF FACILITY Allen Steam:Statlon
Sample Dates) 06/08/2010
WWTP
Grab- X
Composite
NPDES Permit No
NC0004979
Sample1ocation Outfall 002
BOD5, mg/1
<20
County Gaston
Mo -Molybdenum, ug/1
200*
COD Low, m I
<20
Na -Sodium, mg%I
6"7
Chloride, mwJl
240
Ni -Nickel, ugti
12
Fluoride, mg/1
<4 0*
Pb-Lead,`u I
<10
Sulfate, m
85
Sb -Antimony, ug/1
200*
TDS-Total Dissolved Solids, mg/1
768
Se-Selemum, u9/1
25`0
NH,=N, mo
034
Sn-Tin, ug/I
200*
TKN, mg/1
050
Tl -Thallium, ug/1
200*
NO2 + NOs„m
0'64
Ti-Titamum, ug/1
<10
P Total, mgtl
012
V -Vanadium, ug/I
<25
Ag -Silver, ugn
5,V
Zn -Zinc, ug/1
31
Al -Aluminum, u 1
190
TOC, mg/l
<2 0
—
As -Arsenic- u
25
TSS„mg/l
<120
B -Boron, ug/I
5500
PH, su
64
Ba=Banum, ug/1
110
Temperature, °G
285
Be -Beryllium, u I
<5 0
Ca -Calcium', rd ' b
130----------------
Cd-Cadmium, ug/I
<2 0
Co -Cobalt, u
<50
Cr -Chromium Total, ug/I
<10
Cu -Copper, ug/I
'20*
Fe -Iron, upli
150
H =Mercu „u l
<0 2
K -Potassium, m l
3 1
Li -Lithium, ug/1
<25
Mg -Magnesium, m I
29
Mn -Manganese, ug/I
3.00
* denotes,an elevated PQL due to,matrix spike interference and/or sample,dilution

ANALYTICAL RESULTS SHEET
NAIME OF FACILITY„' Allen Steam Station WWTP
Sample Date(s) 06/08/2010
Grab X
Composite
NPDES-Permit No
NC0004979
Sample Location Outfall' 002A
County Gaston
BOD5, mg/l
Mo -Molybdenum, ug/I
200*
COD Low, m /I
<20
Na -Sodium, mg/l
64
Chlonde,,,m I
9�6
Ni -Nickel, ug/I
12
Fluoride, mg/l
<0 4*
Pb -Lead, u 1
<10
Sulfate, m I
37
Sb-Antimony,,ug/l
200*
TDS-Total Dissolved�Solids, mg/1
82
Se -Selenium, ug/I
78
N143 -N, mg/l
045
Sn-Tin, ug/1'
200*
TKN, mg/l
082
TI -Thallium, ug/l
200*
NO, + NO3, mg/l
028
Ti -Titanium, ug/l
480
P Total, m
0'12
V -Vanadium, ug/I
42
Ag -Silver, ug/l
50*
Zn -Zinc, ug/1
34
Al -Aluminum, ug/ -1
'2600
TOC, mg/I
23
As -Arsenic, ug/I
12
Conductivity, umhos/cm
211
B -Boron, u
160
PH,.su
4,8
Ba -Barium, ug/l
220
Temperature, °C
453
Be -Beryllium, ug/I
<5 0
Dissolved Oxygen, mg/l
28
Ca -Calcium, ug/l
1 I
Cd -Cadmium, ug/l
<2 0
Co-Cobalt,.0 1
<50
Cr -Chromium Total, ug/l
<10
Cu -Copper, ug/1-
35
Fe-Iron„u 1
5000
H -Mercu „u
<0 2
K-Potassium„m l
31
Li -Lithium, ug/l
<25.
M -Ma esium, m I
3.5
Mn -Manganese, ug/l
350
Es an elevated PQL due to matrix spike interference and/or sample dilution

ANALYTICAL RESULTS SHEET
NAME OF FACILITY Allen Steam Station WWTP
Sample'Date(s) 06/08/2010
Grab X
Composite
NPDES Permit,No
NC0004979
Sample Location FGD Influent
County- Gaston,
BOD5, mg/1
29
Mo -Molybdenum, ug/l
1000*
COD Low, mg/1
83
Na -Sodium. mg/1
34
Chloride, mgtl
5300
Ni-Nickel„u 1
250
Fluoride, mg/I
<100*
Pb -Lead, ug1I
150
Sulfate, m
1000
Sb -Antimony, ug/I
1000*
TDS=Total Dissolved Solids, mg/1
23.500
Se -Selenium, ug/1
2300
NH3-N, mg/1
14
Sn-Tin, ug/l
1000*
TKN, m
1$
TI -Thallium, ug/l
1000*
NO, + NO3, m l
26
Ti -Titanium, ug/l
2500
P 'Total, m l
43
V -Vanadium, ug/I
200
Ag -Silver, ug/1
100*
Zn -Zinc, ug/l
320
Al -Aluminum, u I
72;000
As -Arsenic, ug/1
21.0
B -Boron, ug/l
100,000
Ba=Barium, ug/l
1,400
_
Be -Beryllium, u
11
Ca -Calcium, u
3,600
Cd -Cadmium, u I
47
Co -Cobalt, u
100
Cc -Chromium Total, ug/1
180
Cu Copper, u 1
230
Fe -Iron, u
80;000
H =Meicu , , u 1
055
K-Potassium,,m l
36
Temperature, °C
Li=Lithium, u&1l u `
190
M -Ma nesiurn, mg/1
640
--
Mn-Manganese, ug/1
5600
*denotes�an elevated PQL due to matrix spike interference and/orsam le dilution

ANALYTICAL RESULTS SHEET
NAME OF FACILITY Allen Steam Station WWTP
Sample Date(s) 06/08/2010
Grab X
Composite
NPDES Permit No
NC0004079
Sample Location Clarifier Effluent/Bioreactor Influent
County Gaston
BODS, m 1
<,2, 0
Mo -Molybdenum, ug/1
200*'
COD Low, m I
100
Na -Sodium, mg/1
33
Chloride, mg/1
5600
Ni -Nickel, ug/1
<10
Fluoride, mg/1
<100*
Pb -Lead, ug/1
<10
Sulfate, mg/1
1,100
Sb -Antimony, ug/1
200*
TDS-Total,Dissolved Solids„m l
23,400
Se -Selenium, ug/1
140
NH3-N, mg/I
17
Sn-Tin,,ug/1
200*
TKN, m
I8
Tl-Thallium,-ug/l
200*
NO + NO3, m I
28
Ti -Titanium, ug/1
100*
P Total, m l
003
V-anadium, ug/1
<25
A-Stiver, ug/1
50*
Zn -Zinc, ug/I
<10
AI-Alumirium, ug/1
<50
-
As -Antimony, ug/1
28
B -Boron, u "1
110,000
Ba -Barium, u I
460
Be -Beryllium, u
<5 0 _
Ca -Calcium, ug/1
3,200
Cd -Cadmium, ug/1
5 0*
Co -Cobalt, ug/1
<50
Cr -Chromium Total, ug/1
20
Cu -Copper, u
20*
Fe -Iron, ug/1
72
Hg -Mercury, u l
<0 2
K -Potassium, m I
15
Li -Lithium, u I
84
Mg -Magnesium, m
620
Mn -Manganese, ug/1
800
* denotes,an elevated PQL due to,matrlkspike interference and/or sample dilution'

ANALYTICAL RESULTS SHEET
NAME OF FACILITY Allen Steam Station WW,TP
Sample Date(s) 06/08/2610
Grab X
NPDES'Permit No
County Gaston
Composite
NC0004979
Sample Location FGD Effluent
BOD5, m I
< 2 0
Mo -Molybdenum, ug/I
200*
COD Low, m I
23
Na -Sodium, mg/I
24
Chloride, m ,l
3500
Ni -Nickel, u l
<10
Fluoride, m I
<100*
Pb -Lead, ug/1
<10
Sulfate, m /I
740
Sb -Antimony, ug/I
200*
TDS-Total'Dissolved Solids, m
13,500
Se -Selenium, ug/I
50*'
NH3-N, m I
16
Sn-Tm, ug/1
200*
TKN, mg/1
16
Tl -thallium, ug/I
200*
NO2 + NO3, Mg/1
0 10
Ti -Titanium, ug/l
100*
P Total;�m
0'17,
V -vanadium, ug/I
<25
X -Silver, u 1
50*
Zn -Zinc, ug/I
<10
AI-Alummum, ugll
170
As -Arsenic, ugll
10*
B -Boron, up,/1
76,000
Ba -Barium, ug/I
240
Be -Beryllium, ug/I
<5 0
Ca -Calcium, ug/1
1,600
Cd -Cadmium, ug/I
<2 0
Co -Cobalt, ug/I
<50
_
Cr -Chromium Total, ug/1
<10
Cu -Copper, ug/I
20*
Fe -Iron, ug/I
370
Hg -Mercury, ug/1
<0 2
`K -Potassium, m
16_
Li -Lithium, ug/I
58
Mg -Magnesium, m 1
330 .
Mn -Manganese, ug/I
870
* denotes an elevated,PQL due to matrix spike interference and/or sampleA lution

ANALYTICAL RESULTS SHEET
NAME OF FACILITY. Allen Steam Station W WTP
Sample Dates) 06/08/2010
Grab X
Composite
NPDES Permit No
NC0004979
Sample Location Slope Drain Effluent
County Gaston
BODS, mg/1
<'2 0
Mo -Molybdenum, ug/t
200'
CC,D>Low, mg11 •
<20
Na -Sodium, mg/,I
14
Chloride, mg/1
34
Ni-NtckeLu I
12
Fluoride, mgA
<0 4
Pb -Lead, u I
<10
Sulfate,,m I
22
Sb-Antimony,•ug/l,
200*
TDS-Total Dissolved Solids, mg/1
116
Se -Selenium, ug/l
<5 0
NH; -N, mg/1
<0 02
Sn-Tm, ug/1
200*
TKN, m I
<0 2
TI-Thalhurn, ug/1
200*
NOZ +NO,, mg/1
067
Ti -Titanium, ug/1
<10
P Total, m I
<0 02
V -Vanadium, ug/I
<25
Ag -Silver, ug/1
50*
Zn -Zinc, ug/I
20
AI-Aluminum„u
110
TOC, mg/1
<2 0
As -Arsenic, u I
<2 0
B -Boron, ug/1
190
Ba -Barium, u I
160
Be -Beryllium, u l
<5 0
Ca -Calcium, ug/1
54
Cd -Cadmium, ug/1
<2 0
Co -Cobalt, u l
<50
Cr -Chromium Total, ug/1
<10
,Cu -Copper, Lign
20*
Fe -Iron, ug/1
190
-Hg-Mercury, u 1
<0 2
K -Potassium, m
23
Li -Lithium, ugfl
<25
M -Ma nesium„m 1
89
Mn -Manganese, ug/1
200
* denotes an elevated PQL due to matrtx,sptke,interference and/or sample dilution
I

Comments from MRO regarding new draft permits for Allen, Marshall, and Riverbend
Comments from Wes and Donna following inspections at Allen and Marshall Steam stations
on 617 and 6/8 (clarification given by Marcia):
They need a stormwater permit. (None of the Duke facilities have individual stormwater
permits. Since stormwater is mentioned in two of the permits already should the permit
become a combined wastewater/stormwater permit for all discharges of stormwater?)
o Marshall — no mention of stormwater discharges in NC0004987
o Allen — Stormwater is mentioned as a discharge through Outfall 002 in
NC0004979)
o Riverbend — Itormwater is mentioned as a discharge through Outfall 002 in
NC0004961
Sampling should be more than quarterly, ideally weekly.
o (This is sampling at Outfall 002 [final effluent] and applies to both facilities that
were inspected)
Sampling should be composite, if it can't be flow proportional, then at least time based.
o (This is sampling at Outfall 002 [final effluent] and applies to both facilities that
were inspected- this comment would also apply to Riverbend (M. Allocco
comment). From inception of permit (1977 copy available at MRO) until 1989
samples except for Oil & grease were composite samples. No information in
permit files (fact sheets, staff reports, etc.) detailing why the change was made.
In the 2001 version of the permit all parameters except Oil & Grease and TSS,
and sulfate are composite samples. 2002 permit notes that the monitoring has
been changed from composite to grab due to the large size and consistent
effluent out of the ash basin, grab sampling is considered to be equally
representative of the discharge (how was this determination made?).
Sumps outfalls (2a/b) should be sealed off, but if not they should be sampled regardless
of the length of the discharge event (no hour limitation) and, yes, they can be easily
sampled. (Sampling was conducted using the telescoping sampling pole owned by
MRO)
o Depending on the analysis results for samples collected by MRO staff there may
be a need to add more analytes to the sampling requirements. MRO will forward
to permitting the results of the analyses at Marshall and Allen.
Facilities should have dual classification.
o Marshall is currently classified as PC -1; should be PC -1 and WW -1 as per D.
Hood communication to M. Allocco
o Allen is currently classified as PC -1; should be PC -2 and WW -2 as per D. Hood
communication to M. Allocco
o Classification of Riverbend was not reviewed; currently PC -1
Use TPH, not oil and grease, if petroleum is a cause of concern.
Comments from Marcia
Riverbend
• Section A. (5.) Biocide Condition — Line 3 "any" is misspelled as "nay".
• Section A. (5.) Biocide Condition - This section states that a biocide worksheet is not
needed when introducing a new biocide to an outfall being currently tested for toxicity. Is
this an adequate test of toxicity? The quarterly toxicity testing is a grab sample once a

quarter and would not correspond to the detailed review by DWQ personnel a biocide
sheet submission would afford.
• Section (6.) Special Conditions bullet #1 states, "There shall be no discharge of
polychlorinated bi phenyl compounds." From a compliance standpoint how do we
assure this? Is it through the one analysis completed for permit renewal? What is the
inspector to review?
• Section (6.) Special Conditions bullet #3 states, "If the permittee, after monitoring for at
least six months, determines that he/she is consistently meeting the effluent limits
contained herein, the permittee may request of the Director that the monitoring
requirement be reduced to a lesser frequency." While this text has appeared in the
permit since 1977 (oldest permit at MRO) I question whether 6 months of data is enough
to determine if a constituent is absent from a discharge. Is this the timeframe given to all
permittees or something special to power plants? If it is not consistent with DWQ
procedures and other permits then it should be changed. Should there be a caveat that
any changes to a treatment system or chemicals used in a treatment system the
frequency will be increased.
• Section (6.) Special Conditioft bullet #5 "waters" is misspelled as "wasters"
• Section (6.) Special Conditions bullet #5 states, "Discharge of chlorine from the use of
chlorine gas, sodium hypochlorite, or other similar chlorination compounds for
disinfection in the plant potable and service water systems and in sewage treatment is
authorized." At what level is the chlorine discharge authorized? We are making all other
permittees meet a 50 µg/L TRC compliance level with permit limits of either 17 µg/L or
28 µg/L. This includes Water Treatment Plants that chlorinate the water they provide
and then dechlorinate or otherwise strip chlorine before discharge.
• Section (6.) Special Conditions bullet #5 states, "Use of restricted use pesticides for lake
management purposes by applicators licensed by the NC Pesticide Board is allowed."
The EPA has just promulgated regulations that require a permit when pesticides are
applied to waters of the US. I assume this requirement may be permitted by DWQ but it
might also be given to the NC Pesticide Board. Need to ensure we are not providing
conflicting authorizations and we may not know for —2 years.
• Section (7.) Permit Terms bullet #2 states, "Chemical metal cleaning will be conducted
according to Duke Power approved equivalency demonstration." The Duke Power
approved equivalency demonstration was submitted at some point in the past and is
stored in the permit files. This does not give the inspector anything to verify when
inspecting the plant.
• Section (7.) Permit Terms bullet #3 states, "It has been determined from information
submitted that the plans and procedures in place at Riverbend Steam Station are
equivalent to that of a BMP." What does this statement refer to? Somewhere between
1980 and 1984 the following caveat was removed from the permit general text and may
be what this statement refers to. If so, the language in this bullet needs to be tightened
to require the plans and procedure be updated on a specific schedule and available for
review by DWQ inspectors or is this something that is more appropriate in a stormwater
permit? To me it implies that this is currently a wastewater/stormwater permit. "The
Permittee shall develop and implement a Best management practices (BMP) Plan to
identify and control the discharge of oils and the Hazardous and toxic substances listed
in 40 CFR, part 117 and Tables II and II of Appendix D to 40 CFR, Part 122. The plan
shall include a listing of all potential sources of spills or leaks of these materials, a
method for containment, a description of training, inspection and security procedures,
and emergency response measures to be taken in the event of a discharge to surface
waters. Sources of such discharges may include but are not limited to, materials storage

areas; in -plant transfer, process and material handling areas; loading and unloading
operations; plant site runoff; and sludge and waste disposal areas. The BMP plan shall
be developed in accordance with good engineering practices, shall be documented in
narrative form; and shall include any necessary plot, plans, drawings, and maps. The
BMP Plan shall be developed no later than six months after issuance of the final permit
(or modification), and shall be implemented no later than one year after issuance of the
final permit (or modifications). The BMP Plan shall be maintained at the plant site and
shall be available for inspection by EPA and DEM personnel."
Section (8.) Special Condition for Discharge of Wastewater discusses the need for Duke
to ensure there is adequate room in the ash basin for the solids and associated water
generated at the plant along with stormwater runoff. It requires annual reporting to DWQ
unless Duke can certify before issuance of the permit they have adequate room for the
life of the permit. However, the following statement in this section is unclear or
confusing. "Present information indicates a needed volume of 86.2 acre-feet in addition
to solids that will be deposited to the ash pond; any change to plant operations affecting
such certification shall be reported to the Director within five days." Does this statement
mean that Duke needs to clear out 86.2 acre-feet before the permit is issued; need to
clarify language? They must notify us within 5 days of what; first knowledge of the
change in the plant operations? Since the ash basins are now high -hazard dams
inspected by DLR does DLR have a say in how much solids and water are maintained in
the pond?
Section (9.) Special Condition — Boiler Cleaning Wastes third paragraph "at" is
misspelled as "oat" and in Item #4 "has" has been misspelled as "ahs".
Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 001 — Note
#1 states, "Downstream sampling point: down stream at Mountain Island lake." This
does not describe where in Mountain Island Lake the downstream sample should be
collected. Should this be worded "downstream at Mountain Island Lake dam"?
Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 002 - Note
#2 under the table states, "Total metals are defined by 40 CFR 136. Any method
specified by 40 CFR is considered acceptable for analysis." This is too vague of a
statement. 40 CFR 136 allows for atomic absorption analysis of metals that will only
obtain a detection limit in the mg/L range. Although Duke is analyzing via ICP -MS this
statement allows them to backtrack and use a method with a lower detection limit.
Although I doubt this will happen we should tighten up our requirements; either require a
specific method such as ICP -MS or require that they detect below the applicable water
quality standard.
Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 002 - there is
no monitoring for mercury at Outfall 002. Since all waters within North Carolina are
impaired for mercury due to fish tissue concentrations (not noted in the fact sheet) Duke
should have to monitor for mercury especially since coal-fired power plants are a major
source of mercury in the environment. They should be required to use Method 1631 E
with a detection limit of 12 ng/L.
Due to the recent release of monitoring data for Mountain Island Lake from the Catawba
Riverkeeper the permit should not be released until the data has been reviewed. It is
unclear whether the Duke data collected during the 316(a) variance request can be
compared to the Riverkeeper's data. Duke is only performing sediment analyses on
sediment fines and it appears the Riverkeepr's results are for all sediment within a
sediment core. We need to be able to compare. The 2004 study by Duke appears to
show an increase in arsenic in sediment directly down stream of the cove where Outfall
002 discharges (their statement). No data in MRO files regarding 316(a) data since

2004. In addition, no data has ever been collected by Duke in the discharge cove. It
may be appropriate to request additional sampling by Duke in this cove for water quality
(including metals), sediment, and fish in light of the recent Mecklenburg County arsenic
data. Original permit in 1977 required metals sampling in mountain Island Lake
downstream of the discharge which had to meet water quality standards.
New Comments added - Marcia
Marshall
Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 002 — DWQ
asks permittee to monitor and report multiple metals. We should provide the level to
which we require Duke to analyze and with respect to mercury we should note we want it
analyzed via Method 1631 E which obtains a detection limit of 12 ng/L.