NC0001422_Wastewater Application Materials_20150305

i
t� DUKE L.V.Sutton Energy Complex
ENERGY, 801 Sutton SteamPlant Rd
Wilmington,
NC 28401
PROGRESS o 910.341.4750
f 910.341.4790
February 23, 2015
Mr.Jeffrey 0. Poupart
NCDENR-DWR,Water Quality Permitting Section RECEIVEDIDENRIDWR
1617 Mail Service Center
Raleigh, NC 27699-1617 MAR 0 5 2015
Subject: Duke Energy Progress, Inc. Water Quality
L.V.Sutton Energy Complex NPDES Permit NC0001422 Permitting Secttor
NPDES Wastewater Application Materials
Dear Mr. Poupart:
This letter and the attached materials are provided in response to Tom Reeder's February 6th letter
which indicated that the Department of Environment and Natural Resources (NCDENR) is preparing
draft NPDES permits for the L.V.Sutton Energy Complex(Sutton Plant). The draft is intended to address
NCDENR's November 5, 2014 notice letter reclassifying Sutton Cooling Pond as"Waters of the State".
Enclosed with this letter are preliminary application materials to modify the NPDES permit for the
Sutton Plant. Specifically we have attached the following materials:
• EPA Form 1;
• EPA Form 2C, pages 1-4 (sample data to complete the application will be provided once the full
constituent analyses of the new outfalls has been completed).
• Site map showing the location of all outfalls (internal and final);
• An updated flow chart and description of waste flows(Form 2C Attachment 2-Item Il-A);
• An updated narrative description of sources of pollution and treatment technologies(Form 2C
Attachment 3 Item Il-B);
• An updated list of potential items not covered by analysis (Form 2C Attachment 4).
Please also consider the supplemental ash pond characterization data submitted on January 20, 2015 as
part of this submittal.
With reissuance of the permit, Duke Energy also requests that NCDENR staff consider the following:
I. Inclusion of Additional Permitted Outfalls
• Please add Outfall 008 to the permit to capture the facility's recirculated water discharge
and other comingled waste streams,as described in the attached permit materials. This
new outfall would be located at the end of the effluent channel and discharge into the
cooling pond. Duke Energy staff discussed the location of the effluent channel with your
staff on February 2 and concurs with the Wilmington Regional Office's recommendation as
to the location and extent of the channel boundaries.
I - -

CONTINUED FROM THE FRONT
VII.SIC CODES 4-digit,in order of.pori
A.FIRST B.SECOND
7 4 9 11 I (speci6) . I I I (+pecifY)
Electric Power Services
15 18 19
1516 • 19
C.THIRD D.FOURTH
7
I I I (spec•tfy) 7 I I I (spec?6)
1518 19 15 16 - 19
VIII.OPERATOR INFORMATION
A.NAME B.Is the name listed in Item
I I I I I I I I I I 1 I I I I I I I I I I I I I I I I I I I I I I I I I I VIII-A also the owner?
8 Duke Energy Progress, Inc. 0 YES ❑NO
5 18 5586
C.STATUS OF OPERATOR(Enter the appropriate letter into the answer box:if"Other,"specify.) D.PHONE(area code&no.)
F=FEDERAL (specify)
S=STATE M=PUBLIC(other than federal or state) P A (910) 341-4775
P=PRIVATE
0=OTHER(specify) Public Utility
56 15 6 - 18 )19 • 21 122 - 28
E.STREET OR P.O.BOX
8011 Sutlton 1Steaml Plantl Roadl 1 1 1 1 1 1 1 1 1 1 1 1 1 1
26 55
F.CITY OR TOWN G.STATE H.ZIP CODE IX.INDIAN LAND
t I I I I I I I I I I I I I I I I I I I I l 1 1 IIII Is the facility located on Indian lands?
g Wilmington NC 28401 ❑YES 0N
i5 18 3041 L2 31 • 51 52
X.EXISTING ENVIRONMENTAL PERMITS
A.NPDES(Discharges to Surface Water) D.PSD(.lir Emissions from Proposed.oiisrces)
CT ' 1 I I I T I I I I 1 I I CT , I I I I I I 1 1 I I I I
9 N NC0001422 9 P
15 18 17 II 30 15 1817 1e 30
B.UIC(Underground Injection of Elude) E.OTHER specs )
CT 1 I I I I 1 I I I 1 1 1 1 c T I I
Wd0U001020 11 I I I I (specify)
9 U 9
NC Ash Utilization
15 1e 17 1e 3015 19 17 18 30
C.RCRA(Hazardous Wastes) E.OTHER(spec)
CII I I I I 1 I I 1 l I I I c T i 1 I I I I I I I I I 11 1
(specify)
gill NCD000830646 g 165 88CAMA Permit for intake structure
18 30 ill
11 18 30
XI.MAP
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries.The map must show the outline of the facility,the
location of each of its existing and proposed intake and discharge structures,each of its hazardous waste treatment,storage,or disposal faciliti s,and each well whereit
injects fluids underground.Include all springs,rivers,and other surface water bodies in the map area See instructions for precise requirements. (Attachment 1)
XII.NATURE OF BUSINESS(.rovide a briefdescrf.tion)
The L. V. Sutton Plant is an electric generating facility consisting of three simple-cycle internal combustion
turbine (CT) units and a natural gas-fired 2x1 Combined Cycle (CC) combustion turbine unit. Until November
2013, the plant also operated three coal-fired electric generating units, however those units have been
decomissioned and are currently being demolished.
XIII.CERTIFICATION(see instructions)
I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that,based on my
inquiry of those persons immediately responsible for obtaining the information contained in the application,I believe that the information is true,accurate,and complete.I
am aware that there are significant penalties for submitting false information,including the possibility of fine and imprisonment.
A.NAME&OFFICIAL TITLE(type or print) B.SIG ' . • C.DAT SIGN D
Allen A. Clare ��
Station Manager
COMMENTS FOR OFFICIAL USE ONLY
C
is]I6 55 _
EPA Form 3510-1(8-90)

EPA I.D.NUMBER(copy from hem I of Form I) Form Approved.
MB No.2040-0086.
Please rintortype inthe unshaded areas only. NCD 000830646 Approval expires3-31-98.
FORMU.S.U.S.ENVIRONMENTAL PROTECTION AGENCY
2C ��EPA GE WASTEWATER
EXISTING MANUFACTURING,COMMERCIAL,MININCATION FOR PERMIT TO G AND SILVICULTURE OPERATIONS
NPDES Consolidated Permits Program
I.OUTFALL LOCATION
For each outfall,list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
A.OUTFALL NUMBER B.LATITUDE C.LONGITUDE
(list) 1.DEG. 2.MIN. 3.SEC. 1.DEG. 2.MIN. 3.SEC. D.RECEIVING WATER(name)
001 34 16 57 77 59 20 Cape Fear River
002 34 17 33 77 59 35 Sutton Cooling Pond
004 34 17 56 77 59 32 Sutton Cooling Pond
008 34 17 29 77 59 36 Sutton Cooling Pond
Il.FLOWS,SOURCES OF POLLUTION,AND TREATMENT TECHNOLOGIES
A. Attach a line drawing showing the water flow through the facility.Indicate sources of intake water,operations contributing wastewater to the effluent,and treatment units
labeled to correspond to the more detailed descriptions in Item B.Construct a water balance on the line drawing by showing average flows between intakes,operations,
treatment units,and outfalls.If a water balance cannot be determined(e.g.,for certain mining activities),provide a pictorial description of the nature and amount of any
sources of water and any collection or treatment measures.
B. For each outfall,provide a description of:(1)All operations contributing wastewater to the effluent,including process wastewater,sanitary wastewater,cooling water,
and storm water runoff; (2)The average flow contributed by each operation; and(3)The treatment received by the wastewater. Continue on additional sheets if
necessary.
1.OUT- 2.OPERATION(S)CONTRIBUTING FLOW 3.TREATMENT
FALL b.AVERAGE FLOW b.LIST CODES FROM
NO.(list) a.OPERATION(list) (include units) a.DESCRIPTION TABLE 2C-1
1984 Ash pond discharge through 4 45 MGD. (2013 average) Sedimentation, neutralization 1-U 2-K
001
diverter structure to Cape Fear
River.
1971 Ash pond discharge Sedimentation, neutralization
002 0 MGD• 1-U 2-K
Low volume wastes Sedimentation, neutralization, oxidation (2-8),
0.35 MGDprecipitation(2-C),sorption(1-X),reduction(2-L) 1-U 2-K
Stormwater Sedimentation, neutralization
0.08 MGD 1-U 2-K
Coal pile runoff Sedimentation, neutralization
0.2 MGD 1-U 2-K
1984 Ash pond discharge through 4.45 MGD. (2013 average? Sedimentation, neutralization 1-U 2-K
004
diverter structure to cooling
pond.
Recirculated cooling water 288 MGD. Evaporation 1-F
008
Non-contact cooling service water0 MGD Evaporation 1-F
Low volume wastes Sedimentation, neutralization, oxidation (2-B),
0.96 MGD precipitation(2-C),sorption(1-X),reduction(2-L) 1-U 2-K
Stormwater 0.04 MGD Sedimentation, sorption 1-U 1-X
• The ash ponds and cooling pond
have not discharged since Nov 2013.
See Attachment 2 for line drawing showing the water flow through the facility.
See Attachment 3 for additional descriptions of contributing flows.
OFFICIAL USE ONLY(efuentguidehnes sub-categories)
EPA Form 3510-2C(8-90) PAGE 1 of 4 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
C.Except for storm runoff,leaks,or spills,are any of the discharges described in Items II-A or B intermittent or seasonal?
YES(complete the following table) ❑NO(go to Section III)
3.FREQUENCY 4 FLOW
a DAYS PER B.TOTAL VOLUME
2.OPERATION(s) WEEK b.MONTHS a FLOW RATE(ft,mgLI) (.sp.:16..1th umrs)
1.OUTFALL CONTRIBUTING FLOW (spc'eife PER YEAR 1 LONG TERM 2 MAXIMUM 1.LONG TERM 2.MAXIMUM C.DURATION
NUMBER(hst) (list) average) (sped i ave'age) AVERAGE DAILY AVERAGE DAILY t"dayT)
001 Ash pond discharge from 004 diverter 0-5 (est) 12 (est) 4.54 MGD 9.84 MOD
(expected discharge due to ash pond
dewatering or in response to excees (2013 (2013
precipitation) data) data)
*flow data is based on 2013
discharges from 004 to Sutton Cooling
Pond
III.PRODUCTION
A.Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility?
®YES(complete Item Ill-H) ❑NO(go to Section It')
B.Are the limitations in the applicable effluent guideline expressed in terms of production(or other measure of operation)?
❑YES(complete Item 111-(') NO(go to Section 11')
C. If you answered'yes'to Item III-B,list the quantity which represents an actual measurement of your level of production,expressed in the terms and units used in the
applicable effluent guideline,and indicate the affected outfalls.
1.AVERAGE DAILY PRODUCTION
2.AFFECTED OUTFALLS
c.OPERATION,PRODUCT,MATERIAL,ETC.
a.QUANTITY PER DAY b.UNITS OF MEASURE (list outfall numbers)
(iPecsJi')
NA
IV.IMPROVEMENTS
A. Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operations of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application?This includes,but is not limited to,
permit conditions,administrative or enforcement orders,enforcement compliance schedule letters,stipulations,court orders,and grant or loan conditions.
❑YES(complete the Jicllowing gable) gl NO(go to Item ll'-f1)
1.IDENTIFICATION OF CONDITION, 2.AFFECTED OUTFALLS 3.BRIEF DESCRIPTION OF PROJECT 4.FINAL COMPLIANCE DATE
AGREEMENT,ETC.
a NO. b.SOURCE OF DISCHARGE a.REQUIRED b.PROJECTED
NA
B. OPTIONAL You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your
discharges)you now have underway or which you plan.Indicate whether each program is now underway or planned,and indicate your actual or planned schedules for
construction.
❑MARK"X"IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATTACHED
EPA Form 3510-2C(8-90) PAGE 2 of 4 CONTINUE ON PAGE 3

EPA I.D.NUMBER(copy from Item I ofForm I)
CONTINUED FROM PAGE 2 NCD000830646
V.INTAKE AND EFFLUENT CHARACTERISTICS
A,B,8 C: See instructions before proceeding-Complete one set of tables for each outfall-Annotate the outfall number in the space provided.
NOTE:Tables V-A,V-B,and V-C are included on separate sheets numbered V-1 through V-9.
D. Use the space below to list any of the pollutants listed in Table 2c-3 of the instructions,which you know or have reason to believe is discharged or may be discharged
from any outfall.For every pollutant you list.briefly describe the reasons you believe it to be present and report any analytical data in your possession.
1.POLLUTANT 2.SOURCE 1.POLLUTANT 2.SOURCE
Retired Coal Units
Strontium Occasionally found in coal
Uranium Occasionally found in coal
Vanadium Occasionally found in coal
Zirconium Occasionally found in coal
Asbestos Used in insulation
CC Block
None
VI.POTENTIAL DISCHARGES NOT COVERED BY ANALYSIS
Is any pollutant listed in Item V-C a substance or a component of a substance which you currently use or manufacture as an intermediate or final product or byproduct?
YES(list all such pollutants below) ONO(go to Item VI-B)
Retired Coal Units
Antimony
Arsenic
Beryllium
Cadmium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
CC Block
None
See Attachment 4 for other substances used during operational processes or at the plant that potentially may be discharged.
EPA Form 3510-2C(8-90) PAGE 3 d 4 CONTINUE ON REVERSE

•
CONTINUED FROM THE FRONT
VII.BIOLOGICAL TOXICITY TESTING DATA
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in
relation to your discharge within the last 3 years?
©YES(idents the test(s)and describe their purposes he/ow) ❑NO(go to Section VIII)
24-hour static acute toxicity tests using fathead minnows were required to be conducted quarterly on the
wastewater discharge from Outfall 001 (historically from cooling pond to Cape Fear River) . The facility has
passed all toxicity tests.
VIII.CONTRACT ANALYSIS INFORMATION
Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm?
❑YES(list the name,address,and telephone number of,and pollutants analyzed by, ®NO(go to Section IX)
each such laboratory or firm below)
A.NAME B.ADDRESS C.TELEPHONE D.POLLUTANTS ANALYZED
(area code&no.) (list)
NA
IX.CERTIFICATION
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 fine and imprisonment for knowing violations.
A.NAME&OFFICIAL TITLE(type or print) B.PHONE NO.(area code&no.)
Allen A. Clare, Station Manager (910) 341-4750
z:::;eC.SIGNATUREle____(2.4 D.DATE SIGNED /�
,,,?/'
EPA Form 3510-2C(8-90) PAGE 4 of 4

Duke Energy Progress, Inc.
L.V. Sutton Electric Plant
NPDES Permit NC00001422
2015 Permit Application Update
N
Dike
0 500
1000
Makeup
Meters
Pump
0 1000 2000
3000
Feet
Outfall 004
ro
4
Sutton Cooling Pond
Q
CT
New Ash Pond
(1984)
•Outfal 1002
Outfall 008 (approx) Old Ash
Pond (1971)
Effluent Channel
to Cooling Pond
Internal
L�
utfall 009 Internal(approx)
outfall007
(approx
• Final (external) Outfalls
Cooling Pond
• Internal Outfalls
Withdrawal
Recirculating
Condenser
Cooling Water
Outfall 001
Release
CC Block
Internal Outfall 006
CC Block
Sutton Energy Internal Outfall 005
Complex
NORTH CAROLINA
NPDES Wastewater Outfalls
L. V. Sutton Energy Complex
New Hanover County

Duke Energy Progress,Inc. NPDES Permit NC0001422
L.V.Sutton Energy Complex 2015 Permit Application Update
Attachment 2
Form 2C - Item Il-A Flow, Sources of Pollution, and Treatment Technologies
Water Average Flow
Path' (MGD) Flow Comments
A 72 Maximum river water makeup to cooling pond(intermittent)
B 0 Water intake for the coal-fired units
C 0 Ash sluice water routed to new ash pond—variable 0-7 MGD
D – Flow path removed
E 4.45 Outfall 004—Ash sluice water from New(1984)Ash pond to cooling
pond(optionally routed to Outfall 001
F 0 Ash sluice water routed to old ash pond—variable 0-7 MGD
G 0 Outfall 002—Discharge from Old(1971)ash pond to cooling pond
H 4.45 Alternate discharge to Outfall 001
0 Non-contact cooling water(service water)for coal-fired units
J 0 Heated water discharge from coal units condensers to cooling pond
K 0 Supply well water withdrawal for coal-fired units
L 0.17 Low volume waste waters from coal-fired units(estimated)
M 0.18 Internal Outfall 007-Maximum flow from the west retention basin .
This waste stream is expected to be re-routed from the old(1971)ash
pond in 2015.
N 0 Internal Outfall 003—Chemical metal cleaning wastes were historically
disposed of by evaporation in the boilers; Outfall 003 was an alternate
for discharging into an ash pond .These wastes are no longer
generated since the retirement of the coal-fired units.
O 0.11 Coal pile and tank farm area runoff—estimated 80 dpy(expected to be
eliminated by 2015)
P - Flow path removed
Q - Flow path removed
R - Flow path removed
S 19.7 Discharge from cooling pond to the Cape Fear River. Estimate based
on standard practice. 2013 average was 19.95 MGD for days where
there was a release)
T 0.0(Coal units); County water for potable water and sanitary systems
0.002(CC block)
AA 0.67 Supply well water withdrawal for the combined cycle power block
A2-1

Duke Energy Progress,Inc. NPDES Permit NC0001422
L.V.Sutton Energy Complex 2015 Permit Application Update
Water Average Flow2
Path' (MGD) Flow Comments
BB 0.07 Water treatment filter backwash to Internal Outfall 005 via low volume
waste collection sump
CC 0.29 Service water to the Closed Cooling Water Cooler(CCWC)
DD 0.14 Closed cooling water cooler blowdown discharge to Internal Outfall 005
via low volume waste collection sump
EE 0.14 Closed cooling water cooler evaporation and drift losses
FF 0.007 Service water for combined cycle power block plant systems
GG 0.11 Service water to blowdown tanks
HH 0.130 Internal Outfall 006—Heat recovery steam generators blowdown tank
discharge to the cooling pond (actual monthly avge since Nov 2013)
II 0.033 Blowdown tank flash evaporation
JJ 0.12 Demineralized water to Heat Recovery Steam Generators(HRSGs)
KK 0.088 Heat recovery steam generators blowdown
LL variable Heat recovery steam generators cleaning wastes
MM 0.023 Heat recovery steam generators vent losses
NN 0-0.02 Auxiliary boiler blowdown
00 0.3 Oil/water separator discharge to Internal Outfall 005 via low volume
waste collection sump
PP 0.25 Demineralized water to Combined Turbine Generator(CTG)NOx
injection system
QQ 0.003 Combustion turbine generator wash water and false start losses
RR 0.25 Combustion turbine generator NOx injection system water losses
SS 0.127 Reverse Osmosis(RO)and Electrodeionization(EDI)water treatment
system reject water to Internal Outfall 005 via low volume waste
collection sump
TT 288 Combined cycle power block recirculated condenser cooling water
withdrawal from the cooling pond
UU 288 Outfall 008-Combined cycle power block recirculated condenser
heated water discharge with comingled wastestreams(to the effluent
channel)
W 0.64 Internal Outfall 005—Combined cycle power block wastewater
discharge to the cooling pond(actual monthly avg since Nov 2013)
WW 0.29 Low volume wastes from coal-fired units
XX .0072 CT oil water separator(plant drains)
YY .078 CT reverse osmosis system reject
A2-2

Duke Energy Progress, Inc. NPDES Permit NC0001422
L.V.Sutton Energy Complex 2015 Permit Application Update
Water Average Flow2
Path' (MGD) Flow Comments
ZZ .085 Discharge from CT low volume waste sump.
'Water path color indication:
Blue = Coal-fired units water paths
Red = Combined cycle power block water paths
Green = Conjoined systems water paths
2Average flow values for the combined cycle power block are estimated based on proposed plant
design.
A2-3

Duke Energy Progress, Inc.
NPDES Permit NC0001422
L. V. Sutton Electric Plant
2015 Permit Application Update
Coal-fired units water paths Fast Start CT units water paths
—Combined cycle water paths —Conjoined water paths
Supply wells
County water
®Waste streams removed as of 7/31/14
Water treatment
Plant systems
Potable water
s stem and drains
Fire system r
West Retention t O/W
Sanitary
I
basin
Se arator
systems
Evaporation
I
I
Yard drains
Evaporation
Septic tanks
I
I
Internal
Internal Outfall003
Outfall 003
i
New Ash Pond
C
Intake structure
OldAsh
Leach fields
I
F
Pond
Screen wash
I
g I
OO
D
I
Makeup water
Coal pile &tank
Infiltration
intake structure
,
I
farm runoff
Cape Fear River
I
Internal Outfall0071 O
X
A
,
(Discharge path
I
Outfall 002 I
Stormwater
eliminated)
G
Outfall 004
I
E
UU
Cooling Pond
Screen wash
Outfall 001
TT
Intake structure
Effluent Channel
H
to Outfall 008
S
Supply wells
Condensers
Cape Fear River
Internal
AA Outfall001
W Outfall
005
Ultrafilter water
Filter backwash
9B
Low volume waste
treatment system
collection sump
EE Evaporation
HH
Closed cooling
Internal
CC i III,
water cooler
DD
Outfall
006
Storm wate
00
Service water
FF
Plant systems
CC block low
Oil/water
II
storage tank
volume wastes
se arator
Internal
Coal units low
Outfall
It Evaporation
volume wastes
009
GG
Blowdown tanks
NN KK Vent losses
CT low volume
Auxiliary boiler
HRSGs
tL
wastes
O
ti
RR Water loss —off -site disposal
O
CT RO water
RO/EDI
water
Demin water
CTG NOx
treatment
treatment s stem
stora a tanks
PP
in'ection
CTG wash &false start
4 losses —off -site disposal
CT Oil/water
SS
separator
A2-4

Duke Energy Progress,Inc. NPDES Permit NC0001422
L.V.Sutton Energy Complex 2015 Permit Application Update
Attachment 3
Form 2C - Item Il-B Flow, Sources of Pollution, and Treatment Technologies
The L.V. Sutton Electric Plant has three simple-cycle Internal Combustion(IC)turbine units and a natural
gas-fired 2x1 Combined Cycle(CC)combustion turbine. Prior to November 2013,the plant operated
three coal-fired generating units. These units were retired once the CC block came online and are
currently being prepared for demolition. The plant has a 1,110-acre(6,900 acre-ft)wastewater cooling
pond on the east side of the Cape Fear River approximately ten river miles upstream of Wilmington, North
Carolina. Water is withdrawn from the Cape Fear River,as required,to makeup evaporative and
blowdown losses from the cooling pond.
Chemical constituents contained in the discharge from the permitted outfall will, in part, be representative
of the naturally-occurring chemical quality and quantity of the intake water and will also have chemical
constituents of such quality associated with similar discharges for fossil generating facilities of this size,
type,and in this geographical location. Either all or part of the elements in the Periodic Table, either
singularly or in any combination, may from time to time be contained in the discharge.
Prior to 2015, the Sutton Plant had one external permitted outfall to the Cape Fear River. This outfall was
a discharge from the cooling pond(Outfall 001)which received all combined wastewaters from the plant
(including several internal outfalls).
In 2015, Duke Energy provided an updated permit application, upon request of the Division of Water
Resources, to support the characterization of the Cooling Pond as Waters of the State. Based on that
classification,the site has the following outfalls:
• Outfall 001 discharging from the New(1984)Ash Pond through the diverter structure to the
Cape Fear River.
• Outfall 002(formerly an internal outfall). This outfall discharges wastewater from the Old
(1971)Ash Pond to the Cooling Pond.
• Outfall 004(formerly an internal outfall). This outfall discharges from the New(1984)Ash Pond
through the diverter structure to the Cooling Pond.
• Outfall 008. This new outfall primarily consists of recirculated cooling water from the CC
generating unit. The outfall is located at a compliance point at the end of the effluent channel
into the Cooling Pond. Internal outfalls 005,006,007 and 009 discharge into the effluent
channel and contribute to flows at Outfall 008.
The waste streams contributing to these outfalls are described in further detail below.
Historic Cooling Pond Discharge
Historically Sutton Plant's discharge of recirculated cooling water from the Cooling Pond to the Cape Fear
River was considered a regulated NPDES outfall. However, due to NCDENR's reclassification of the
cooling pond,the only plant waste stream that will be discharged through outfall 001 is the diverted ash
pond discharge(see description below). Under current site operations,the cooling pond is not expected
to discharge without a concurrent ash pond discharge except for maintenance purposes or in anticipation
of an extreme weather event,such as a hurricane,when additional freeboard is needed to prevent
overtopping of the pond dikes. These discharges to alter the level of water in the cooling pond would not
be regulated under the NPDES permit.
Outfall 001 and Outfall 004-New(1984)Ash Pond
Effluent from the new ash pond can be discharged to either the cooling pond(to Outfall 004)or to
the Cape Fear River(to Outfall 001). Historic practice was to route a minimum of 4.0 MGD to the
A3-1

Duke Energy Progress, Inc. NPDES Permit NC0001422
L.V.Sutton Energy Complex 2015 Permit Application Update
cooling pond before additional effluent routed to the Cape Fear River. The ash ponds have not
discharged since November 2013. In the future,the old ash pond is only expected to discharge
as a result of dewatering efforts to facilitate pond closure. A detailed dewatering plan was
submitted to NCDENR in January 2015.As described in the Dewatering Plan, dewatering waters
may be routed from the old(1971)ash pond,or other site ash storage areas,to the new ash pond
for additional treatment and discharge. As the water in the ash pond is lowered,additional
treatment may be brought onsite to ensure the ash pond discharge maintains compliance with
NPDES permitted limits, such as a portable filtration unit.
Historically the plant's routine practice has been to facilitate diverted ash pond discharges
(through 001)by concurrently releasing water from the cooling pond. When ash pond releases
were being diverted to the Cape Fear River,the cooling pond was drawn down by an estimated
19.7 MGD.
Outfall 002-Old(1971)Ash Pond
Coal Pile Runoff
Storm water runoff from the coal pile is routed to the old ash pond ,which provides neutralization
and sedimentation treatment. This waste stream will cease when all material is removed from
the coal pile area and final grading has been achieved in accordance with the NCDENR-
approved Erosion and Sedimentation Control Plan.
West Retention Basin Flows
The coal-fired units were decommissioned in November 2013. Upon retirement of the coal fired
units,waste streams from processes which historically went to the ash pond are either no longer
generated or will be redirected to the west retention basin until closure is complete. Wastewaters
may also be properly disposed of off-site. Waste streams from closure activities associated with
the coal-fired unit may be sent to the retention basin until closure is complete. These waste
streams could include wash waters from various components that would be expected to contain
coal-combustion residuals. To support the closure of the old ash pond,the discharge from the
west retention basin will be redirected from the New(1984)Ash pond to effluent channel via
internal Outfall 007. More detail on these historic low volume waste streams are provided below:
• Process water used in the coal-fired units was treated prior to use by an ion-exchange
demineralizer which was periodically regenerated with solutions of sodium chloride, sodium
hydroxide,and sulfuric acid. Alternatively a vendor was used to provide treatment of plant
process water.
• Blowdown of boiler water to control boiler chemistry was routed through low-volume prior to
discharge in the ash pond. Boiler vacuuming sediment was routed through low-volume prior to
discharge to the ash ponds. The precipitators were water washed approximately every 1 to 3
years with the wastewater discharging to the ash pond.
• Drains from areas likely to contain oil-filled equipment or storage were routed through an oil-water
separator with the effluent routed through low volume prior to discharge to the ash pond. Waste
oil is disposed of according to the appropriate regulations.
• Laboratory processes produce small amounts of wastewater which were routed to plant drains.
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Duke Energy Progress,Inc. NPDES Permit NC0001422
L.V.Sutton Energy Complex 2015 Permit Application Update
• Wash/rinse wastewater from an on-site washing machine was also routed to plant drains. Drains
may also convey equipment and machinery wash-down and other miscellaneous facility
housekeeping and maintenance activities.
Outfall 008-Effluent Channel
Recirculated Condenser Cooling Water
The condenser cooling water for the CC block is withdrawn from and discharged to the cooling
pond.The heated discharge is routed around baffle dikes within the cooling pond to achieve
maximum surface cooling efficiency and before being recirculated through the condenser cooling
water intake structure. Evaporation,which is estimated to consume approximately 1.5 MGD
above natural evaporation rates during times of full operation,effectively cools the heated water
discharge. Biological fouling control agents are used on heat exchanger surfaces.
Non-contact Cooling Water
Non-contact cooling water is also withdrawn from and returned to the cooling pond. This water
provides indirect cooling for various equipment by absorbing heat as it passes through a heat
exchanger. No direct contact is made with any other equipment or process.
Stormwater
Historically, stormwater generated onsite that may have had contact with industrial activity or
materials was routed to the old ash pond while exempt stormwater from parking lots or other
areas was routed to the effluent channel. In 2015,all site stormwater will be routed to the effluent
channel to support ash pond closure activities.There are several discrete stormwater
conveyances to the effluent channel including two discharges from stormwater basins(the South
Wet Detention Basin and the North infiltration Basin).
During certain extreme storm events(e.g.,25-year,24-hour),storm water may inundate areas
around the plant site and accumulate beyond design capacity. Storm water collected during
these conditions may be pumped directly to the cooling pond or to the surrounding landscape.
Internal Outfall 007
In 2015 the discharge from the west retention basin will be routed directly to the effluent channel
(see section on Outfall 002 for more details on flows to the west retention basin). .
Internal Outfall 005
Drains from the CC block which may contain oil and grease are routed to an oil/water separator
before discharging into the cooling pond via Internal Outfall 005. Incidental leaks associated with
the operation of the HRSG,Combustion Turbine Generators(CTGs), RO/EDI system,and
infrequent draining and cleaning of various processes may generate wastewater that is captured
by Internal Outfall 005. During the initial startup phase, HRSG blowdown of up to 1.5 MGD may
be released to Outfall 006 for several days.
Wastewater from routine HRSG cleaning,fuel oil/water condensate,and equipment drains
potentially containing oil is directed to plant drains which are treated by the oil/water separator.
The combustion turbine false start drains, NOx injection,and compressor waste water is directed
to a holding tank and transported off-site. HRSG chemical metal cleaning wastes may also be
generated and hauled offsite. For a more extensive cleaning, the HRSGs may require flushing
with a large volume of water. The wastewater from this flushing would be discharged via Internal
Outfall 005 to the cooling pond or taken off-site.
Various equipment,including fuel oil storage tanks, transformers, lube oil filters,etc.have
containment areas for spills. Storm water collected in these areas is visually inspected for the
presence of oil prior to release to the ground or released to plant drains which flow to the oil/water
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Duke Energy Progress, Inc. NPDES Permit NC0001422
L.V.Sutton Energy Complex 2015 Permit Application Update
separator. Laboratory processes produce small amounts of wastewater which are routed to plant
drains.
Internal Outfall 006
Process wastewaters generated in the natural gas combined cycle block will be discharged to the
cooling pond via two new internal outfalls. Low volume wastewaters including the ultrafilter water
treatment system filter backwash, Closed Cooling Water Cooler(CCWC)blowdown, Reverse
Osmosis/Electrodeionization(RO/EDI)system reject wastewater,and other wastewaters entering
the oil/water separator are directed to the low volume waste collection sump for discharge to the
cooling pond via Internal Outfall 005. Low volume wastewaters including the Heat Recovery
Steam Generator(HRSG)blowdown and auxiliary boiler blowdown will be discharged to the
cooling pond via Internal Outfall 006.
Other Site Wastewaters
During maintenance activities, sludge removed from basins,sumps,etc.will be transported off-
site for proper disposal.
Internal Outfall 009
The three existing simple-cycle combustion turbine(CT)units(total 61 MW)are scheduled for
replacement in 2017. The two replacement"Fast Start CTs"will have a total generation of 80-90
MW. To support the operation of those units, supporting low-volume waste treatment will be
installed. Specifically,the site will install a new oil-water separator to treat service water drains
and a reverse osmosis water treatment system. These low volume wastes will be combined in a
new low volume waste sump and discharged through a new outfall 009 to the effluent channel.
Other Site Wastes
Domestic Wastes
Sanitary wastes are treated by an onsite septic tank and drainage field that is permitted by the
New Hanover County Health Department. The septage is exempt from the 40 CFR 503
standards. Duke Energy Progress, Inc.will submit appropriate information to the EPA if
required. Wash/rinse wastewater from an on-site washing machine is also routed to the septic
system.
Low-Volume Wastes
All waste streams not identified above are categorized as low-volume wastes.These wastes
include plant drains,which convey miscellaneous equipment leakage,equipment drainage for
maintenance, equipment washdown water,sampling streams,service water system blowdown,
and water treatment wastes. Any of the chemical additives disclosed in Attachment 4 may be
present in Low Volume Wastes.
Chemical Metal Cleaning Wastes
Chemical metal cleaning wastes were formerly generated during chemical boiler cleaning every
5 to 10 years. The cleaning solution and rinses were stored on site for disposal by evaporation in
the boilers. If chemical metal cleaning wastes were not evaporated,they were either treated by
neutralization and precipitation in retention basin prior to discharge to the ash ponds, or disposed
of off-site. These wastes will no longer be generated with the retirement of the coal-fired units..
Fire Water System
Several plant heat exchangers are cooled by the fire water system. Fire water is withdrawn from
the cooling pond.
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Duke Energy Progress, Inc. NPDES Permit NC0001422
L.V.Sutton Energy Complex 2015 Permit Application Update
Intake Screen Backwash
The intake structure from the cooling pond to the former coal generating site will be removed
during coal-site demolition. The combined cycle power block has a separate intake structure with
an automatic intake screen backwash system that will remain operational.
Ash Reclamation
In the event a practicable market becomes available, Duke Energy Progress, Inc.,may exercise
the option of reclaiming ash from the ash ponds. However,due to the limited scope of such an
operation no additional discharges would be expected.
Inactive Hazardous Waste Sites List Areas
A former ash disposal area and the old ash pond were listed on the State's Inactive Hazardous
Waste Sites List.
Pesticide Usage in Sutton Cooling Pond
Herbicides are used when needed to control nuisance aquatic vegetation. These herbicides are
applied by licensed applicators,or persons under the immediate supervision of a licensed
applicator, in accordance with the manufacturer's instructions. Pesticides are used when needed
to perform biological assessments of fish populations. These pesticides are applied by licensed
applicators, or persons under the immediate supervision of a licensed applicator, in accordance
with the manufacturer's instructions.
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Duke Energy Progress,Inc. NPDES Permit NC0001422
L.V.Sutton Electric Plant 2015 Permit Application Update
Attachment 4
Form 2C - Item VI Potential Discharges Not Covered by Analysis
Estimated
Quantity
Chemical (per year) Frequency Purpose
Coal-fired Units
Listed chemicals for the coal-fired units are no longer being utilized for the purposes identified below. However,they were
used during historic operations and trace amounts have the potential to be discharged during plant demolition.
Hydrazine Trace Not actively Oxygen scavenger in boiler
used
Ammonia Trace Not actively pH control in boiler
used
Phosphate Trace Not actively pH control in boiler
used
Sodium hydroxide(50%) Trace Not actively Demineralizer regeneration
used
Sodium hydroxide(50%) Trace Not actively Ash pond pH control
used
Sulfuric acid(93%) Trace Not actively Ash pond pH control
used
Alum Trace Not actively Ash pond total suspended
used solids control
EcoGreen Barrier Trace As needed Ash pond fugitive dust
suppressant
BioCover Trace As needed Ash pond fugitive dust
suppressant
Gorilla Snot Trace As needed Ash pond fugitive dust
suppressant
Sulfuric acid(93%) Trace Not actively Demineralizer regeneration
used
Sodium chloride Trace Not actively Water softener regeneration
used
Bromine/Chlorine[Biotrol 88P(1-bromo- Trace Not actively Control of biofouling on heat
3-chloro-5,5-dimethylhydantoin)] used exchangers
Sodium hypochlorite Trace Not actively Control of biofouling on heat
used exchangers
Sodium molybdate and sodium nitrate Trace Not actively Corrosion control in cooling
used water system
Cleaner(sodium hydroxide,metasilicate, Trace Not actively Cleaner
and ethlenediaminetetraacetic acid) used
Ethylene glycol Trace Not actively Equipment freeze protection
used
Urea Trace Not actively NOx Control
used
Citric Acid(50%) Trace Not actively Boiler cleaning
used
Ammonium hydroxide Trace Not actively Boiler cleaning
used
Cronex Inhibitor Trace Not actively Boiler cleaning
used
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Duke Energy Progress, Inc. NPDES Permit NC0001422
L.V.Sutton Electric Plant 2015 Permit Application Update
Estimated
Quantity
Chemical (per year) Frequency Purpose
Sodium nitrite Trace Not actively Boiler cleaning
used
Ammonium bicarbonate Trace Not actively Boiler cleaning
used
Citric Acid—dry Trace Not actively Boiler cleaning
used
Tetraammonium Trace Not actively Boiler cleaning
ethylenediaminetetraacetic(EDTA),and used
ammonium hydroxide
AP 1000 Trace Not actively Boiler cleaning
used
Low hazard corrosion inhibitor Trace Not actively Boiler cleaning
used
Silicone antifoam agent Trace Not actively Boiler cleaning
used
Antifoam agent Trace Not actively Boiler cleaning
used
Liquid oxygen Trace Not actively Boiler cleaning
used
Powerback Premix with anti-foam agent Trace Not actively IC unit cleaning
used
Freeze control products(i.e.,varying Trace Not actively Coal freeze conditioning agent
solutions of glycol,calcium chloride, used
glycerin,diethylene,etc.)
Combined Cycle Power Block
Hydrazine <8000 gallons Not actively Steam cycle oxygen scavenger
used
Amine/ammonia <8000 gallons Continuous Steam cycle pH control
Phosphate <8000 gallons Continuous Steam cycle scale and pH
control
Corrosion inhibitor <8000 gallons Continuous Cooling water system corrosion
inhibitor
Sodium hypochlorite or sodium bromide <25,000 Continuous Cooling water system
gallons biofouling control
Mineral dispersant <8000 gallons Continuous Cooling water system scale
inhibitor
Sulfuric acid <8000 gallons Continuous Cooling water system pH
control
Citric acid <8000 gallons Continuous Water treatment system low
pH reagent
Sodium hydroxide(50%) <8000 gallons Continuous Water treatment system high
pH reagent
Sodium hypochlorite <8000 gallons Continuous Inlet water oxidation and filter
backwash reagent
Potassium permanganate <8000 gallons Continuous Filter inlet water chemical
Sodium bisulfite <8000 gallons TBD Plant systems process water
dechlorination
Sodium bisulfite <8000 gallons TBD Reverse osmosis water system
inlet water dechlorination
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Duke Energy Progress,Inc. NPDES Permit NC0001422
L.V.Sutton Electric Plant 2015 Permit Application Update
Estimated
Quantity
Chemical (per year) Frequency Purpose
Sodium hydroxide(50%) <8000 gallons Continuous Reverse osmosis water system
chemical
Anti-scalant <8000 gallons Continuous Reverse osmosis water system
scale prevention
Bromine antimicrobial(sodium <8000 gallons TBD
hypochlorite,sodium bromide,sodium
hydroxide)
Cooling Pond Vegetation Control
Liquid copper-based herbicide(15.9% As needed, Twice/year Lyngbia vegetation control
Copper Carbonate) According to
manufacturer
directions
Fluridone-based herbicide(5%fluridone) As needed, Seasonal Macrophyte vegetation control
According to
manufacturer
directions
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