Marshall Steam Station (14)

To Brian Lowther June 9, 2011
From: Rob Krebs
Prepared By: Michael Parker
NCS000548 Duke Energy Carolinas, LLC - Marshall Steam Station
Catawba County
Site inspection conducted on June 7, 2011, by Michael Parker Facility contact: Mr. Mark McGary
[phone] (cell) and Ms Donna Burrell This request is for a new SW permit This facility is in
the business of producing electricity via coal fired turbine generation. The majority of the SW
generated at the Marshall Steam Station (MSS) site is routed through two yard drain sumps which
carry the SW to an existing ash basin. This ash basin discharges through outfall 002, which is covered
under the facilities existing NPDES wastewater permit (NC0004987) There are, however, areas of the
site where SW drains back to surface waters (Lake Norman, WS -IV, B, CA), and these areas (and the
associated outfalls) are to be covered under the subject SW permit. The only SW testing data available
for review in this application was collected in 2008 at SW outfall SW007
There are 11 existing SW outfalls that are to be included in the proposed permit. SW outfalls draining
the Miscellaneous Material Storage area include SW outfalls SW001 — SW004 Duke Energy has also
requested that the areas draining to outfalls SW012 and SW022 be considered as consistent with the
areas draining to outfalls SW001 — SW004. In addition, Duke Energy has requested that SW outfall
SW004 be representative of outfalls SW001 — SW004, SW012, and SW022 During the site visit, it
was noted that SW outfall SW004 drains very little, if any of the area designated as the Miscellaneous
Materials Storage area, so it was decided during the site visit that SW outfall SW003 would be more
representative of the SW discharge from this area than outfall SW004 Mr. McGary indicated that he
would submit a revised permit application reflecting the change. Collecting a sample of the discharge
from outfall SW003, however, may require some modifications of the discharge channel as it is
currently lined with rip rap and not conductive for sample collection SW outfalls SW001 — SW004
receive drainage from areas that are mostly gravel with some vegetative cover at or near the point of
discharge. The fines associated with the gravel will likely be problematic for MSS staff once
analytical testing begins at this facility Unless the proposed benchmark values are modified, this
facility will likely have difficulty in consistently complying with the benchmark TSS levels proposed
in the draft SW permit It was suggested to Mr McGary during the site visit that MSS staff move
forward with the collection of some analytical data at SW003, so that MSS staff could see how the
results compared to the proposed benchmarks values prior to the issuance of the permit. It was noted,
however, that there was area available for the construction of BMPs, should the testing results reflect
benchmark exceedances.
Other SW outfalls to be included in this permit are outfalls SW006 — SW009, and SWO11 Duke
Energy staff has requested that outfall SW007 be considered representative of outfalls, SW006,
SW008, SW009, and SWO11. Outfall SW007 drains a significant portion of the MSS site. Some of the
drainage area is paved; however, a majority of it is graveled in and around many of the storm drains
that eventually discharge at outfall SW007. As discussed with SW outfall SW003 above, Duke Energy
may have difficulty in complying with the proposed benchmark value for TSS at outfall SW007 once
the permit is in effect During the site visit, MSS staff were encouraged to look at ways to minimize
TSS impacts at outfall SW007 through BMP installation and housekeeping improvements. This Office
has no objection to making outfall SW007 representative of outfalls SW006 — SW009, and SWO11

North Carolina
Beverly Eaves Perdue
Governor
Mr Mark McGary, PE
Duke Energy Carolinas, LLC
8320 East NC Highway 150
Terrell, North Carolina 28682
Dear Mr McGary
ENR
Department Department of Environment and Natural Resources
Division of Water Quality
Coleen H Sullins
Director
June 20, 2011
Subject. Draft NPDES Stormwater Permit
Permit No. NCS000548
Marshall Steam Station
Catawba County
Dee Freeman
Secretary
Enclosed with this letter is a copy of the draft stormwater permit for your facility Your request for
representative outfall status is being reviewed and our response will be included with the final permit
Please review the draft very carefully to ensure thorough understanding of the conditions and requirements
it contains.
The draft permit contains the following significant items that should be noted about analytical
monitoring:
1 Analytical monitoring parameters including 15 metals, sulfate, and oil & grease have been added to this
permit as an effort to investigate the pollution potential of stormwater discharges
2 pH has been added to the analytical monitoring requirements
3 All analytical monitoring has been set to semi-annually during a representative storm event as defined in
Part II Section B The permittee must also document the total precipitation for each event. If no discharge
occurs during the sampling period, the permittee must submit a monitoring report indicating "No Flow'
within 30 days of the end of the six-month sampling period. Additionally, samples must be taken a
minimum of 60 days apart, as specified in Table 2
4 Benchmarks for analytical monitoring have been added to this draft permit Exceedances of benchmark
values require the permittee to increase monitoring, increase management actions, increase record
keeping, and/or install stormwater Best Management Practices (BMPs) in a tiered program. If the
sampling results are above a benchmark value, or outside of the benchmark range, for any parameter at
any outfall then the facility shall follow the Tier 1 guidelines which require a facility inspection within
two weeks and implementation of a mitigation plan within two months. If during the term of this permit,
the sampling results are above the benchmark values, or outside of the benchmark range, for any specific
parameter at a specific discharge outfall two times in a row (consecutive), then the facility shall follow the
Tier 2 guidelines which require a repetition of the steps listed for Tier 1 and also immediately instbite
monthly monitoring for all parameters at every outfall where a sampling result exceeded the benchmark
value for two consecutive samples
5. You are required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part Il Section B Qualitative monitoring is required regardless of
representative outfall status
6 You are responsible for all monitoring until the renewal permit is issued See Footnote 1 of Tables 1, 4,
and 5.
Wetlands and Stormwater Branch One
1617 Mall Service Center, Raleigh, North Carolina 27699-1617 NorthCarolina
Location 5 N Salisbury St Raleigh, North Carolina 27604 ��`��
Phone [phone] FAX [phone] Customer Service 1-877-623-6748
Internet www ncwaterquality org �atui
An Equal Opportunity 1 Affirmative Action Employer

Marshall Steam Station s
Permit No NCS000548
Please submit any comments to me no later than thirty (30) days following your receipt of the draft
Comments should be sent to the address listed at the bottom of this page. If no adverse comments are
received from the public or from you, this permit will likely be issued in about two months
If you have any questions or comments concerning this draft permit, contact me at [phone] or
Brian lowther®ncdenr gov
cc* Mooresville Regional Office
Stormwater Permitting Unit
Attachments
2
Sincerely,
IX—L :Z6?'�
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit

Analytical testing submitted with the permit application for outfall SW007 reflected a number of
parameters where previous analytical testing has exceeded the proposed benchmark values for
Aluminum, Chromium, Copper, Zinc, Total Suspended Residue, and COD This data was collected in
2008, based on the information submitted with the permit application Site changes at MSS since 2008
may also reflect a change the characteristics of the site's SW, which would render the submitted data
as not being indicative of current site conditions. Additional testing will be necessary to determine
whether or not compliance with the proposed benchmark values can be consistently obtained
During the site visit, there was one outfall identified that was not included on the SW drainage area site
plan submitted with the permit application This outfall originates in a graveled parking area on the
north side of Drainage Area 12 (see site plan) and discharges into an existing sediment basin at the
bottom of a hill adjacent to the intake canal. This sediment basin was installed when the site was
graded prior to the construction of the nearby Flu Gas Desulfurization system. From the sediment
basin, the discharge would travel approximately 75 yards through a vegetative channel before entering
the intake canal MSS staff was unaware of the existence of this outfall until it was discovered during
the site visit Mr McGary indicated that this previously unknown outfall would be added to the permit
application and it would also be included in the representative outfall status request for outfall SW007.
In conclusion, it is recommended that the subject SW permit be issued with consideration given to the
comments/recommendations as contained in this report.
/mlp

NCS000548
MrA
P.•
it.
PAL
;.r. y..
,,.
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H Sullins Dee Freeman
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name
Marshall Steam Station
Compliance history
NPDES Permit Number
NCS000548
3
Facility Location
8320 East NC Highway, Terrell, NC (Catawba County)
Type of Activity
Power Plant
Difficulty Rating:
SIC Code
4911
Receiving Streams
See Figure 1
River Basin
Catawba River Basin, Sub -basin 03-08-32
D Rk-L-.5 �
Stream Classification
WS-IV,B, CA
Proposed Permit Requirements
See attached draft permit
, (.- 't'
JUN 1 3 2011
Monitoring Data
See Table 1;
We $ WA CaU
Response Requested by (Date)
�neh
Central Office Staff Contact:
Return to: Brian Lowther, [phone]
Special Issues:
Issue ,
Rating Scale: 1 eas to 10 hard
Compliance history
3
Benchmark exceedance
3
Location (TMDL, T&V_
species, etc)
4
Other Challenges
• Large Site
• New Site
7
Difficulty Rating:
17/40
Special Issues Explanation -
• Previously this facility only had an NPDES WW permit for its discharges (NC0004987)
Description of Onsite Activities:
• The Marshall Steam Station is a`fossil-fueled,'electric generation plant located approximately one mile
east of the community of Terrell in Catawba County, NC. The facility has four production units with a
generating capacity of 2,090 megawatts, a Flue Gas Desulfurization (FGD) system, a Selective Catalytic
Reduction (SCR) system, a wetlands wastewater treatment plant, a limestone unloadmg and stacker system,
a gypsum stacker, a FGD landfill, and various storage and maintenance buildings
Page 1 of 7

NCS000548
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File
• Central Files
• EPA Sector -Specific Permit, 2008
• 303(d) List, 2010
• July 2010 Catawba Basmwide Plan
History:
• March 31, 2011 • Date permittee submitted application
Until now, the facility has only had a wastewater permit and sampled some stormwater outfalls as part of the NPDES
WW renewal application In 2010, Mooresville Regional Office staff inspected two Duke Energy facilities and
noted that this site needed a stormwater permit (see NPDES NC0004987 file) The Division prefers to issue a
separate NPDES SW permit rather than combine wastewater and stormwater requirements under one permit The
attached permit was drafted to reflect the permitting strategy for all coal-fired power plants set by the Stormwater
Permitting Unit (SPU) in 2009
Page 2 of 7

NCS000548
Figure 1: Map of Facility
Page 3 of 7
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NCS000548
Duke Energy Carolinas, LLC
Marshall Steam Station
-
Il
Lab tude- 350 35' 50" N
_ Y
1
Longitude; 800 5755" W
a�
County; Catawba
Rece mng Stream; Catawba River (Lake Norman)
Stream Class- SW-IV,B, CA
M9P S'Cale 1,24,000
Sub-bas7n- 03-08-32 (Catawba River Basin)
Facility Location
Page 3 of 7

NCS000548
Central Office Review Summary: `
1 Owner's Other Permits NPDES — NC0004987, Landfill permit — SWP 18-09, Distr. Of residual solids —
WQ0000452
2 General Observations
• Runoff is collected by catch basms and conveyed through a buried network of corrugated metal pipes
The network originally routed flow to Lake Norman but in 1976 runoff from most areas with significant
materials and activities were re-routed into a yard sump system Stormwater entering the yard sump system
is pumped to the ash settling basm
• Site has six NPDES process water outfalls
• There are 13 stormwater outfalls and 2 of them have been abandoned Detailed descriptions were
provided with the application
Herbicides are used on the site
Impairment. The Catawba River (Lake Norman) is not on the 2010 303(d) list The Catawba Basinwide Plan
mentions coal ash ponds and the potential for causing human and environmental harm if the dam fails It also states
the Lake Norman watershed does not contain any impaired or impacted waterbodies and displays overall good water
quality and aquatic life health This may be in large part due to,the size of Lake Norman However, the lake should
be closely monitored in the future to ensure upstreamactivities Flo riot start to affect this highly recreational lake The
basmwide plan also recommended that lake front property owners exempt from these buffer rules allow a 50 -foot
riparian zone to grow with minimal maintenance on a voluntarily basis. Trees, low growing shrubs or other ground
cover plants will not only assist in filtering pollutants and excess nutrients from stormwater runoff, but also secure
bank stability to prevent erosion which will inevitably reduce the size of the property
4 Threatened and Endangered Based on the Natural Heritage Virtual Workroom there are no federally endangered
or threatened species within 2 miles of the facility
5 Location WS-IV,B, CA
6 Analytical Monitoring
• Outfalls SW001 through SW004. Potential pollutants are ash and oil
• Outfall SW005 Abandoned
• Outfall SW006 Potential pollutants are ash and oil.
• Outfall SW007 Potential pollutants are oil, gypsum, limestone, coal and chemicals The chemicals include
small containers of hydrazine, glycerin and 2 -propanol are stored inside the warehouse The containers are
not routinely exposed to stormwater
• Outfall SW008 The drainage area is comprised primarily of paved roadway on the east side of the
Powerhouse No significant materials were listed for this area
• Outfall SW009 Potential pollutants are oil and inert materials. The inert materials include office trailers,
equipment, and materials stores temporarily in the drainage area during plant outages This outfall
commingles with NPDES WW003 condensate discharge.
• Outfall SWO10 Abandoned
• Outfall SWO11 Potential pollutants are gypsum and limestone. Maintenance activities such as sandblasting
and painting tanks take place in this drainage area but these are rare occurrences and the stormwater would
be temporarily blocked and the areas surrounding the tank would be covered
• Outfall SW012• Drainage area comprised of graveled yard areas and vegetated slopes located north and west
of the FGD Facility No significant materials were listed for this area.
Page 4of7

NCS000548
• Outfall SW022• This drainage area is comprised of a portion of the paved FGD facility access road, paved
road ditch, and vegetated embankment slopes. No significant materials were listed for this area
The permittee has requested representative outfall status They would like Outfall SNV004 to represent
SWOO1, SWO02, SWO03, SWO04, SW012, and SW022 and Outfall SWO07 to represent SWO06, SWO07, SW008,
SkN'009, and SWO11
Submitted Data at Outfall SWO07:
Parameters
Benchmark
Outfall SWO07
Outfall SWO07
Oil and Grease
30 mg1
ND mg/1
Aluminum
0 75 mg/1
3 310 nig 1
4 010 mg'I
Arsenic
0 36 mg; l
ND mg/1
7-4 mg/1 0
Barium
0 0636 mg/I
0 0716 mg/1
Boron
0 030 mg/I
ND mg/1
Cadmium
0 001 mg/I
ND mg/1
ND mg/1
Chromium
I 0 ing/1
ND mg/1
--5-4 mg,11- 0 oz:, S
Cobalt
0 03 nw/I
ND mg/1
ND mg/1
Copper
0 007 mg/I
[).1111>1 1ug'i
0 018 nw I
Iron
6.120 mg/1
7.480 1ng1
Magnesium
32 mg/I
2 460 mg/1
2 590 mg/1
Manganese
0 135 mg/I
0 152 mg/1
Nickel
0 26 mg'I
0.006 mg/1
0 0064 mg/1
Selenium
0 056 nig/1
ND mg/1
ND mg/l
Silver
0 001 in(,,
ND inI
ND mg/I
Titanium
0 270 mg/1
0 326 mg/I
Zinc
0 067 mg/I
0 108111"d
1) 117 ru- I
Mercury
0 000012 mg.l
ND rng/i
ND mg/I
Apparent Color
100 units
Tss
100 1111/1
136 ing; I
BOD
30 in -1
8 0 mg/1
8 0 mg/1
Nitrogen, Ammonia
7 2 11 Ig/1
ND mg/1
Nitrogen, Kjeldahl, Total
20 mgrl
0 91 mg/1
Nitrogen NO2 plus NO3
10 mg/1
0 40 mg/1
Phosphorus
2 mg/1
0.20 mg/1
Phenol
4 5 mg/1(tlout)
ND mg/1
Chloride
860 mg/I
ND mg/1
COD
120 mg/1
178 n1g,'I
Sulfate
500 inWl
25 7 mg/1
Page -5 of 7

NCS000548
7 Qualitative Monitoring Notes. None submitted
Permit Recommendations: Analytical Monitoring:
1 Adding parameters the following parameters were added as part of a comprehensive effort to investigate
stormwater pollution associated with coal-fired power plant facilities.
a TSS — to track solids concentration Sandy soils and equipment/truck traffic potential source,
b COD — submitted analytical results show moderate oxygen demand in stormwater
c 13 priority pollutant metals (Ag, As, Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb, Se, Tl, Zn) plus Al and B — basis
known association with coal and coal combustion Draft RTI Study (`Human and Ecological Risk
Assessment of Coal Combustion Wastes', RTI, August 2007) and discussions with Robert Schreusdale
of RTI suggest these metals may signal contamination problems Have also discussed contaminants with
Dr. Avner Vengosh from Duke University, who researched ash pond spills in TN last year. In addition,
RRO/DWQ has sampled discharges from cogeneration plants in the FRO area and flagged several of
these metals of concern. Finally, DWQ has little data with which to characterize stormwater discharges
from this industry but knows there is concern;
d Sulfate — conventional pollutant associated coal,
e O&G — conventional pollutant associated with onsite petroleum storage and truck traffic
2 pH added — standard addition to permit
3 All analytical monitoring set to semi-annually Cover letter to permittee will include language to allow the
permittee to contact DWQ and request modifications of the required monitoring parameters and/or frequency if
justified by sufficient data collection
4 Benchmarks for analytical monitoring and Tiered monitoring,systep included in this draft permit
5 Analytical and qualitative monitoring required during representative storm events Qualitative monitoring
required regardless of representative outfall status '
Other Proposed Requirements:
1 Because the wastewater permit NC0004987 has outfall 003 that is shared with stormwater outfall SWO09, the
draft permit clarifies that corresponding SWO09 stormwater outfalls should be sampled for all parameters in this
permit. However, the facility is requesting outfall SWO04 to represent SWO09 and therefore if represented
outfall status is granted the clarification may be removed for the final permit
Discussions with permittee: Mark McGary, [phone], 5/4/11,
Mark recommended talking to Donna Burrell for specific questions about the site.
1 What types of herbicides are used on the site?
a Not sure Would need to ask on site personal but they apply at as needed according to the manufactures
instructions
2 Why were samples only taken at 007? What happened to the 010 samples?
a Samples taken an 2008 for another reason Outfall 10 as from and old trap tank and as abandoned
There are values above out benchmarks for Copper, Iron, Zinc, TSS and COD at outfall 007. Any idea way these
might be present9
a This as a worst case outfall which has large amount of industrial activity
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4r,

NCS000548
Recommendations: Based on the documents reviewed, the application information submitted on March 31, 2011
sufficient to issue an Individual Stormw�ater Permit
Prepared by (Signature) Date Slir. �1t
Stormwater Permitting Unit Supervisor Date V1712-01(
2-011
Concurrence by Re
RO Water Quality
Date
Regional Office Staff Comments (attach additional pages as necessary)
Please review the attached Representative Outfall Status Request Form and provide comments
g-ce a&�w "
Page 7 of 7