NC0003433_Re-Issuance Application_20060123

�� Progress Energy
January 11, 2006
Mr. David Goodrich
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699 -1617
Subject: CP &L d/b /a Progress Energy Carolinas, Inc.
Cape Fear Steam Electric Plant
NPDES Permit No. NC0003433
Re- issuance Application
Dear Mr. Goodrich:
,y r "1n
The current NPDES permit for Cape Fear Steam Electric Plant located in Chatham County
expires on July 31, 2006. Progress Energy hereby requests that the NPDES permit for the
facility be reissued. Enclosed are EPA Application Form 1 — General Information and EPA
Application Form 2C — Wastewater Discharge Information, all in triplicate.
With re- issuance of the NPDES permit, Progress Energy requests the following:
• Reduce the monitoring frequency for oil and grease and total suspended solids at internal
Outfalls 001 and 005. Currently the permit required frequency for both is twice per
month. Monthly mo itoring should be sufficient to demonstrate compliance with the
effluent limitations.
• Reduce the monitoring frequency for Chromium, Arsenic, Selenium, Mercury, Nickel,
Copper, total nitrogen and phosphorus at Outfall 007. Currently, the permit required
frequency for all these parameters is quarterly. Based on permit renewal sampling and
monthly DMR data semi - annual monitoring should be sufficient to demonstrate
compliance with the effluent limitations.
• Reduce the monitoring frequency for Arsenic and Selenium at Outfall 005. Currently the
permit required sampling frequency is quarterly. Based on permit renewal sampling,
DMR data and its status as an internal outfall semi annual monitoring should be sufficient
to demonstrate compliance with effluent guidelines.
• Reduce the monitoring frequency for ammonia for Outfall 005. Currently the permit
required monitoring frequency is monthly. Based on monthly DMR data quarterly
sampling should be sufficient to demonstrate compliance with effluent guidelines.
Progress Energy Carolinas, Inc.
Cape Fear Steam Plant
500 CP &L Road
Moncure, NC 27559

��2. Progress Energy
• Change the required monitoring frequencies for Arsenic, Selenium and Ammonia -
Nitrogen at Outfall 001. Currently the permit monitoring frequency for Arsenic and
selenium is quarterly, and monthly for ammonia. The plant only uses this outfall as a
backup to Outfall 005, and suggests that there be a provision in the permit to allow for
quarterly sampling only if there is a discharge made to the ash pond during the quarter. k
With regard to 316(b), Progress Energy is in the midst of sampling and monitoring activities as
described in the approved study plan.
If there are any questions regarding the enclosed information, please contact Steve Cahoon at
(919) 546 -7457.
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.
Sincerely,
4&�J� ;("
Victoria K. Will
Plant Manager
Attachments
Progress Energy Carolinas, Inc.
Cape Fear Steam Plant
500 CP &L Road
Moncure, NC 27559

Cape Fear •
Plant
North Carolina
Attachment I - Form I - Item XI - Map
Progress Energy Carolinas, Inc.
Cape Fear Steam Electric Plant
Chatham County
Page 2 of 3

s
1
o�9
�'° Riper
Plant Site
003 001
n I_I
Intake
West Ash
Pond
Co
T
�d
East Ash Pond
005
-qc-- 007
Discharge Canal
IN
0 1000 2000
Meters
0 2000 4000 6000
Feet
Cape Fear Steam
Electric Plant
I NORTH CAROLINA
Buckhorn
Dam
�O
1.5 miles
Attachment 1 — Form 1 — Item XI — Map
Progress Energy Carolinas, Inc.
Cape Fear Steam Electric Plant
Chatham County
Page 3 of 3

+
�}
\/
tm
\}
(E
co
0
2
S
G
0
0
z
k
tm
o
L
j
_
I
§
»�
q
m
/
6
CL e
£ tE
0
or-
-
I
7
f k
(
)`
7
V
E
`
/ k,
/
(
E
�
k!
z
k§
` k
k E,
0
/
a±
± o
<
4
§ /
2
�,C
t
m
_
k
k
(
«
e
(
&
-
3
)
k
\
\
0
j
/
c
c
c c
$
»
>
p
#
�0
)CL
e
\�
a m
�E
2 E
\ .2 m
) )'
co
0
2
2
£
�\
�/
�{
ƒ\
§
E
E
E
z.
:
)�
«;
)�
e0
aw
°o
CL
�
2
E
CL
\z
}z.
a_
C
,0
Ez
z
/{
)�
E z
'§
,[ p
T
CL
CL
ui
L---i
c a
.2
c
-
2
0
Q
))
_
CD
_
Q
C
\
kE
\/
-2
c _
-
)®
\\
U)
3¥
/
)
\�
/2
ƒ
_
)$
_
2 __
<$
-_
f/
\�
�$
§
\2
/@
e
_
\ _
\
a
E
Q
-
M2
-
�
f
_3
¥
2 -
J
a@
# %
.
«
{
3 5
£
2°
�
»}
_
�
�-
\
/_
g
)
d
y
/®
3
3
J
A
2
l\
$
±
§, I I
L
-1
Ll

Carolina Power & Light Company
Cape Fear Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0003433
Attachment 2
Form 2C - Item 11 -B Flows, Sources of Pollution, and Treatment Technologies
Once - through Cooling
Stream
Estimated Average Flow
Comments
A,
0 58 MGD
West,Ash Pond discharge to discharge canal
B
0 51 MGD
East Ash pond discharge to discharge canal
C
182 8 MGD
Cooling water °discharge to discharge canal
D
0 001 MGD
Evaporation
E
0 MGD
Evaporation
H
0,51 MGD
Provides water for ash sluicing
I
50,000 gallons /event
Electrostatic precipitator washing
J
50,000 gallons /event
Air preheater washing
K
0 005-MGD
County water supply
L
0 140 MGD
Boiler water makeup supply
,M
0 MGD
Used only if cooling towers operate in closed cycle
Valve is normally closed
N'
183 4 MGD
Intake from Cape Fear River
O
183 4 MGD
Discharge to Cape Fear River
P
0 004 MGD
Coal pile runoff, average rainfall — 50% runoff
Q
0 002 MGD
Sanitary Wastes
R
0 052 MGD
Storm water, average rainfall — 50 %, runoff
S
0 001 MGD
Evaporation
T
0 34 MGD
Ash Sluice water from East Ash Pond to West Ash
Pond
2

0 Y m 16 Y
y E c 2 m
C E N
m N
L
N
Q 7 d
d �
E 0
0
CO
W
W c
0
3 'm
CL
0 >
C, W
g
U
LL
c
m
IL
L
N
Q E-
0
m a
W
d
O1 —
lV m
C
m
NU
0
L
Q c
C
N O
da
O
2
N
W
V W
Z
O O
Z F-
0 C7,
Z Z
w O
m O
� V
Q
Z
O
N
_
d
E c
U rn
� 0 c
d m
N
O c N
m
.d.
y
>
_C
N
LL d
LL N
N
>
0
a
O
L
3
a
_
aW
Y
U
m
E
U
Q
W
E
,? d,
U
y
d
T
Z
O
F-
V/
U
m
N
r
�
-
y
U
o
w
0 Y m 16 Y
y E c 2 m
C E N
m N
L
N
Q 7 d
d �
E 0
0
CO
W
W c
0
3 'm
CL
0 >
C, W
g
U
LL
c
m
IL
L
N
Q E-
0
m a
W
d
O1 —
lV m
C
m
NU
0
L
Q c
C
N O
da
O
2
N
W
V W
Z
O O
Z F-
0 C7,
Z Z
w O
m O
� V
Q
Z
O
N
_
d
E c
U rn
� 0 c
d m
O c N
m
"� m
p
c
_C
N
0 4
J
C CI C p
O O O
B'N N (O .m. O1 C C 'O
O O
CL no no EeZ %m mN Nn
:3 n3 az a' Z EZ CZ
d a a
mllw�
MALE
v
N C
O p
U O
T T
m m
E
c c
N' N
N
0
N
d
c
m
p
c
_C
N
N
0
2
O
C
3 0)
°
c
2
Y
c
E
f0
T
d
m
m
y
d
0
F-
V/
m
N
, s
U)
y
U
w
Z
)
v
N C
O p
U O
T T
m m
E
c c
N' N
0
9v
0
CL
c
0
c
0
CL
(n O
CO
N
OE z
m
`
°
Ez
T
a
:3
a
W''
loxf
lox:
af
0:
(n
N
C
N
C
y
N
C
N
C
m
N
C C
N
-2
o E
E
N
O
O
$
0
00
E
7
N
-g
cu
d
3
d
0 d
d d
C=am
Ct
'O f0
m
C°
d D
3
�p
v m
c
0-6
IE
v_
L w
E
N'
m
m
CL
L
z
O
z
7"
w
c
r
dt
N
j
r
c
p
7 10
W w
C.
1-1
Li
—
—

Carolina Power &, Light Company
Cape Fear Steam Electric Plant
National Pollutant.Discharge Elimination System Permit Number NCO 003433
Attachment 2
Form 2C - Item II -B Flows, Sources of Pollution, and Treatment Technologies
Once - through Cooling Towers
Stream
Estimated Average Flow
Comments
A
0 58 MGD
West' Ash Pond discharge to,discharge canal'
B
0 51 MGD
East Ash pond discharge to discharge canal
C
269 0 MGD
Cooling Tower discharge to discharge canal
D
0 001 MGD
Evaporation
E
8 657 MGD
Evaporation
F
269 0 MGD
Effluent from Cooling Tower
G
277 8 MGD
Influent'to'Coolmg Tower
`H
0 51 MGD
Provides water for ash sluicing
I
50,000 gallons /event
Electrostatic precipitator washing
J
50,000 gallons /event
Air preheaterwashing
K
0 005 MGD
County water supply
L
0 140 MGD
Boiler water makeup supply
M
0 MGD
Used only if,cooling towers operate in closed,
cycle Valve is normally closed
N
278 4 MGD'
Intake from -Cape Fear River
O
269 7 MGD
Discharge to Cape Fear River
P
0 004 MGD
Coal pile runoff, average rainfall —50% runoff
Q
0 002 MGD
Sanitary Waste
R
0 052 MGD
Storm water, average rainfall —�50% runoff
S
0 001 MGD
Evaporation
T
0 34 MGD
Ash Sluice,water from East Ash Pond to West
Ash Pond
4

Carolina Power & Light Company
Cape Fear Steam Electric Plant
National ,Pollutant Discharge Elimination System Permit, Number,NC0003433
Attachment 3
Form 2C - Item II -B Flows, Sources of Pollution, and Treatment Technologies
The Cape Fear Steam Electric Plant is as coal -fated steam cycle electric generating plant with
two units Two heat recovery boilers and 4 Internal Combustion (IC) Turbines are also located
on the plant site Water is withdrawn from the Cape Fear River as required
Chemical constituents contained in the discharges from this plant will, in part be representative
of the naturally occurring chemical quality of the intake water and will also have chemical
constituents of such quality and quantity associated with similar discharges for fossil generating
facilities of this size, type, and'in the geographical location Either all or part of the elements
listed on the Periodic Table, either singularly or in any combination, may from time,to time be
contained in the discharge
Outfall 007 Combined Wastewater Discharge,to Unnamed Tributary Canal to Cape Fear
River
This outfall is located in the discharge canal approximately 250 feet below the point where the
East Ash Pond discharges into the canal This discharge contains all waste stream flows
including once - through cooling water,. East Ash pond discharge, and West Ash pond discharge
Internal Outfall 001 - West Ash Pond
The West Ash Pond receives ash transport waters (bottom and fly ash), coal pile runoff, No 2
fuel oil tank runoff, settling basin drains, sand bed °filter backwash, parking lot drains, equipment
cooling tower blowdown and drain, boiler, blowdown, oil unloading, area drains, derriineralizer
regenerate, various yard and floor drains, and ash trench drain Detailed descriptions of the
individual waste streams are below
Coal Pile Runoff
Storm water runoff from the coal pile is collected in drainage ditches that surround the
coal pile The drainage ditches are routed to the west ash pond for treatment
During maintenance activities, sludges "removed from catch basins, sumps, etc may be
transported to the west and /or east ash pond for disposal

Carolina Power & Light Company
Cape Fear Steam ;Electric Plant
National Pollutant Discharge Elimination System Permit' Number NC0003433
Low Volume Wastes
Boiler water make up is withdrawn from the Cape Fear River and purified utilizing plant
equipment or„ on rare occasions, vendor supplied equipment In February 2006 a
Reverse Osmosis (RO) unit and Electrodeionization unit will be installed at the plant °to
treat surface water withdrawn from the river and used for plant processes RO reject
water and cleaning solutions wastes will be routed directly from low volume waste to the
West Ash pond Boiler water is treated with morpholine,, trisodium phosphate, and
sod ium'heptametaphosphate Boiler'blowdbwn and drainage is sent to the ash pond
and may contain small quantities of the chemicals The equipment cooling tower and it's
associated heat exchangers are treated with Spectrus OX103 and Dianodic DN2126 for
corrosion and biofouling control Small amounts of cooling tower blowdown are
produced and discharged to the low °volume retention basin
Ash Sluice Water
Fly ash and bottom ash from both units are hydraulically conveyed by an ash sluice
pipeline to the ash pond A Rotamix system is used to inject urea into Units 5 and 6 In
the boiler, the ammonia /urea will react with NOz to form water Vapor and nitrogen The
system will be designed to minimize any ammonia,formation and ammonia slip
Any unreacted ammonia adsorbed on the fly ash from this system will be carried to .the
ash pond via ash sluice water
Dry Ash Stacking
From time to time fly ash and bottom ash from the East,Ash Pond (Outfall 005) will be
excavated and transported and stacked or relocated into the diked boundary of the West
Ash Pond The ash will be placed in the vegetated areas of the West Ash Pond No ash
stacking or relocation will occur 1n areas of the pond that contain water No ichange in,
the nature of the discharge to the discharge canal is anticipated
Ash Sluice Water From East Ash Pond
From time to time fly ash and bottom ash may be sluiced from the East Ash Pond to the
West Ash Pond A floating dredge will be, placed in the, East Ash Pond and ash will be
suctioned from the East Ash Pond and sent to the West Ash Pond via ash sluice lines

Carolina Power & Light Company
Cape Fear Steam Electric Plant
National Pollutant Discharge Elimination System 'Permit Number NC0003433
Plant area floor and yard drains are routed "to the west ash pond and include equipment
drainage, wash down water, and rainfall runoff Drains from areas likely to contain oil -
filled equipment or storage are routed to the low volume retention basin which contains
an oil /waterseparator, Waste oil is disposed of,according to'the appropriate regulations
During maintenance activities sludges removed from the retention basin, ash trench,
catch basins, sumps, etc may be transported to the east and /or west ash pond for
disposal
Internal Outfall 003 - Once - through Cooling Water
Once - through condenser cooling water for the coal fired units and heat recovery units is
withdrawn from the Cape Fear River, passed through the condenser, and discharged directly
into the discharge canal Some cooling is accomplished in the discharge canal When the
temperature at Outfall 007 approaches 32 °C, cooling towers are placed in service in once -
through mode to keep the canal water at or below 32 °C If 32 °C or less cannot be maintained
by orice- through cooling ,mode, operation is either`shifted to closed cycle cooling tower mode or
the plant operation is modified such that the temperature remains below 32 °C Normally the
cooling towers are placed in service in once - through mode during -the months of June through
September The once - through flow may range from 58 8 MGD to 385 -4 MGD
Internal Outfall 005- East Ash Pond
The East Ash Pond receives ash transport waters (bottom and fly ash), runoff from yard drains,
air preheater,washes, electrostatic precipitator washes, spent sandblast material, and sewage
treatment plant effluent The ash pond provides treatment by sedimentation, oxidation,
neutralization, equalization, and adsorption
Domestic Wastes
Domestic wastes are treated gat an extended aeration package plant priorto discharge to
the east ash pond .which provides secondary treatment for the effluent Flow from the
plant is dependent upon fluctuating demand due to variations in the number of personnel
onsite The effluent from the plant is disinfected prior to discharge into the ash pond
When needed, residuals are disposed of off-site by a licensed contract disposal firm
'3

s s
Carolina Power & Light Company
Cape Fear Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0003433
Air Pre - heater Washes
The, air preheaters are water washed approxi °mately, once every 5 years Approximately
50,000 gallons of wastewater is produced and is discharged to the east ash pond via the
ash sluice pipelines
Electrostatic Precipitators
The electrostatic precipitators are washed approximately once every 5 years
Approximately, 50,000 gallons of wastewater is produced and is discharged, to the east
ash pond via,the ash sluice pipelines
Spent Sandblast Material
Approximately every 5 years the interior of the boiler is sandblasted. Approximately
2000 pounds of spent sandblast material is produced This material is discharged to the
east ash pond via the, ash sluice pipelines
Other Wastes
Chemical Metal Cleaning Wastes
The boilers are chemically cleaned every 8 to 10 years using one of the following chemical
processes. 1) citric acid, ammonium hydroxide, Cronox inhibitor, sodium nitrite, ammonium
bicarbonate, or 2) Tetraammonium Ethylenediaminetetraacetic acid ,(EDTA) and A300 inhibitor,
On occasion soda ash, ammonium persulfate, ammonium bifluonde, sodium bromate, and
hydrochloric acid may also be used This cleaning solution and its rinses are stored on -site for
disposal by evaporation in an operating unit's boiler Typical cleariings would result in a waste
of approximately 60,000 gallons
4

f
RO at CapeTear Plant - NC0003433
• � 7
y
Subject: RO at Cape Fear Plant - NC0003433
From: Teresa' Rodriguez <teresa.rodnguez @ncmatl.net>
Date: Tue, 13 Dec 2005 14.51.22 -0500
To: "Cahoon, Steve" < Steve Cahoon @pgnmatl com>
CC: Gil Vinzani <gil.vtnzam @ncmail.net>
Steve, we - received Progress Energy's letter regarding the replacement of the
deminerali.zer for Reverse Osmosis and Electrodeionizati.on at the Cape Fear Plant,.
The.wastewater flows generated by these units are considered low volume wastes. A
permit modification,is not necesary since low volume wastes are cove-red under the
permit.
Teresa
Teresa Rodriguez; P.E
Division of Water Quality
EAST NP,DES ,Program
9,19 -733 -5083 ext. 553
1 of 1 i2/13/2005 2 52 PM

4
`2,,,, Progress Energy
November 14, 2005
Ms. Teresa Rodriguez I
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699 -1617
NOV 7 2005 '
OV
Subject: CP &L dba Progress Energy Carolinas, Inc.
Cape Fear Steam Electric Plant
NPDES Permit No. NC0003433
NPDES Permit Application Amendment - Reverse Osmosis - Electrodeionization
Water Purification System
Cape Fear File Point: 12520B -1
Dear Teresa:
CP &L dba Progress Energy Carolinas, Inc. will be utilizing a temporary portable Reverse
Osmosis (RO) unit and Electrodeionization (EDI) unit to remove dissolved solids from filtered
surface water (process water) at the Cape Fear Steam Electric Plant beginning December 15,
2005. The system is will be used on a rental basis until February 2006. At that time, the
technology will be permanently installed.
Reverse osmosis uses a membrane that is semi - permeable, allowing the fluid that is being
purified to pass through it, while rejecting the contaminants that remain. Most reverse osmosis
technology uses a process known as crossflow to allow the membrane to continually clean
itself. As some of the fluid passes through the membrane the rest continues downstream,
sweeping the rejected species away from the membrane. Electrodeionization is a process by
which the demineralizer resin is regenerated by electric voltage. Acid and caustic solutions are
not needed to regenerate this equipment.
Previously, the Cape Fear Steam Electric Plant used a demineralizer to purify surface water for
use in plant systems, the system will be removed and low volume waste from this process will
cease. A RO unit followed by an EDI unit will be used to filter the surface water prior to
entering package demineralizer units. The package demineralizer units used with both the
temporary and permanent RO systems will be regenerated offsite. Low volume waste
associated with the RO system is expected to be 24,000 GPD. Chemical reductions of sodium
hydroxide (14,200 gals /yr to 0 gal /yr) and sulfuric acid (6,300 gals /yr to 0 gal /yr) will occur
(See Attachment 4). Antiscalant, sodium hydroxide, and /or biocide may be added during the
operation of the RO. The RO membrane will be cleaned approximately 12 times per year with 3
additional chemicals used at the time of cleaning (See Attachment 4). Also, the plant may use
a biocide (See enclosed MSDS and Biocide Worksheet) to reduce biofouling in the RO
membranes when the system is not in use, the biocide worksheet has been attached for your
convenience, but not required since there is a toxicity monitoring requirement at Outfall 007.
The EDI will be cleaned approximately 4 times per year with one additional chemical used only
at the time of cleaning (See Attachment 4).
In reverse osmosis treatment, the supply water is typically cycled up to four (4) times its
normal concentration before being discharged from the unit. This water (Reverse Osmosis
Progress Energy Carolinas, Inc.
Cape Fear Steam Plant
500 CP &L Road
Moncure, NC 27559

reject water) would then be sent to the Low Volume Retention Basin. Based on the proposed
design for this system, this RO rejection water flow rate would be about 24,000 gallons per day.
Because of the addition of the RO and EDI, the Cape Fear Plant wishes to amend the current
NPDES Permit Application to include the RO and EDI as part of the low volume waste stream.
Enclosed is an amended Attachment 3 and 4 of the NPDES permit application and the MSDS
sheets for the water treatment additives.
Previously, a similar system was constructed at the Weatherspoon Plant (NPDES Permit # NC
0005363); DWQ concluded this waste steam was considered to be a low volume waste and is
currently addressed by the facilities NPDES permit (see attached letter from DWQ). Therefore,
consistent with previous guidance from DWQ; we do not believe that a permit modification is
needed for this activity. Progress Energy would appreciate a response from DWQ confirming
that a permit modification is not needed for this activity.
Also please note that Attachment 3 has been updated to reflect a change with the ROFA &
Rotamix system for units 5 and 6. Currently, the plant uses ammonia in conjunction with the
ROFA Rotomix system to reduce NOx emissions; in the coming ozone season (May through
September) the ammonia will be replaced with urea. We do not expect any change in our
discharge as a result of the change from ammonia to urea.
If you have any questions regarding any information in this submittal please call Steve Cahoon
at (919) 546 -7457.
1 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.
Sincerely,
Mrz M
Victoria K. Will
Plant Manager
Attachments
M
reject water) would then be sent to the Low Volume Retention Basin. Based on the proposed
design for this system, this RO rejection water flow rate would be about 24,000 gallons per day.
Because of the addition of the RO and EDI, the Cape Fear Plant wishes to amend the current
NPDES Permit Application to include the RO and EDI as part of the low volume waste stream.
Enclosed is an amended Attachment 3 and 4 of the NPDES permit application and the MSDS
sheets for the water treatment additives.
Previously, a similar system was constructed at the Weatherspoon Plant (NPDES Permit # NC
0005363); DWQ concluded this waste steam was considered to be a low volume waste and is
currently addressed by the facilities NPDES permit (see attached letter from DWQ). Therefore,
consistent with previous guidance from DWQ; we do not believe that a permit modification is
needed for this activity. Progress Energy would appreciate a response from DWQ confirming
that a permit modification is not needed for this activity.
Also please note that Attachment 3 has been updated to reflect a change with the ROFA &
Rotamix system for units 5 and 6. Currently, the plant uses ammonia in conjunction with the
ROFA Rotomix system to reduce NOx emissions; in the coming ozone season (May through
September) the ammonia will be replaced with urea. We do not expect any change in our
discharge as a result of the change from ammonia to urea.
If you have any questions regarding any information in this submittal please call Steve Cahoon
at (919) 546 -7457.
1 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.
Sincerely,
Mrz M
Victoria K. Will
Plant Manager
Attachments