WQ0000020_NOV2009PC0049Response_20090209

C Progress Energy
CERTIFIED MAIL: 7006 0100 0003 6098 4813
File Point: 12570-A, 12570-D
Landon Davidson, Supervisor
NC Division of Water Quality, Aquifer Protection Section
NCDENR Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Response to NO V- 2009 -PC -0049
Progress Energy Ash Distribution Program
Permit W000020
Buncombe County
Dear Mr. Davidson,
FEB 10 2C09
',rJ lionw Office
February 9, 2009
This letter is sent in response to your letter dated January 22, 2009. We appreciate your consideration of
the points raised herein and your willingness to meet with us on January 29, 2009 to discuss these issues.
As we have discussed with you, our staff has been in the process of taking several actions to try to
alleviate any dusting problems in the neighborhood adjacent to the plant's ash pond.
Our staff have a slightly different interpretation of the language of the subject permit and offer these
comments in support of that position. The structure cited in your letter as "an ash storage area" is, in fact,
an NPDES permitted wastewater treatment unit and, therefore, not a storage/stockpile from the ash reuse
permit perspective. The plant collects ash from the boilers in hoppers and uses a water stream to sluice
the ash to the ash pond. In the ash pond, the sluice water is subject to equalization and neutralization and
the heavier ash is settled in the pond while lighter material such as cenospheres rise to the surface of the
pond. The overflow from the pond passes through a skimmer and is discharged as per the NPDES permit.
Furthermore, the ash pond should be considered the "source of coal combustion byproducts" or the point
of origin, not a stockpile. It is our belief that since the accumulation in the wastewater treatment pond
does not constitute a distribution of ash for reuse the ash reuse permit conditions are not applicable and no
violation of the permit occurred.
Progress Energy Carolinas, Inc. as a company takes its commitment to protect the environment, comply
with regulatory requirements and maintain good community relations very seriously. As has been
presented to you previously via email and in discussions, below is some basic information about
cenospheres along with a list of actions that have been undertaken (prior to involvement of the DENR
regional office):
• Cenospheres are formed during the combustion process where silica melts and forms hollow
spheres as it falls (silica dioxide composition).
• Cenospheres are collected with ash and sluiced to the ash pond (a permitted NPDES wastewater
treatment unit) with water, where they eventually float to the top of the pond due to their hollow
nature.
• Cenospheres are harvested at Asheville Plant by Sphere One and used to make refractories, the
center of bowling balls, and other products.
Progress Energy Carolinas, Inc.
Manville Steam Rant
200 CP&L give
Anlen, NC 29709

• Cenospheres are harvested by placing a boom on the top of the surface of the ash pond and
dragging it by boat to the edge of the pond where a crane with a bucket scoops up the
cenospheres and piles them on the side of the pond and then into a truck for hauling.
• In winter, the cenospheres can freeze on the top of the ash pond and become dry, thereby
becoming airborne in winds. Extended periods of sub -freezing weather halt any ability to harvest
cenospheres from the top of the pond.
• At Asheville Plant, cenospheres are physically harvested at the ash pond corner nearest the
property line which has been stripped of trees by the adjacent landowner, creating a wind tunnel
that facilitates wind travel from the pond onto neighboring property (Lake Julian Trails condos,
Aberdeen Drive).
• In the spring of 2008, Asheville Plant staff planted 10 Leland cypress trees at the property line to
create a wind screen; the trees, unfortunately, are dying and are planned for replacement in spring
2009.
• In mid-December 2008, Charah (the onsite contractor responsible for removing ash from the
active pond for the Asheville Airport structural fill project) applied mulch with a dust suppressant
product to the cenosphere-harvesting area in an effort to stabilize cenospheres at the harvesting
point. Rain removed the mulch and product; and Sphere One placed straw at the harvesting point
in early January 2009. Charah reapplied mulch and dust suppressant onto the harvesting area on
January 25, 2009.
• In January, 2009, with the extreme cold temperatures the region has faced along with strong
winds, cenospheres blew from the pond onto property at Lake Julian Trails. Staff of the
Asheville Plant and PE Corporate Environmental Services received a complaint from a neighbor
in the community and, in response, the plant staff visited Lake Julian Trails to assess the
situation. At the same time, 2 Asheville Plant engineers investigated the ash pond to consider
new methods of stabilizing the cenospheres on the pond during this period of extended sub-
freezing temperatures.
• Charah began utilizing a water truck to wet the cenospheres at the harvesting area. Charah also is
attempting to spray water with a water cannon onto the ash pond, itself, to wet the cenospheres.
We note that Charah attempted to do this on January 21, 2009 but the strong winds would not
allow water spray to reach the cenospheres on the top of the pond. Charah was successful in
pouring water from the pond's edge directly onto the frozen cenospheres, thereby keeping a layer
of ice over the cenospheres for the remainder of January, 21, 22 and 23.
• Asheville Plant staff directed Sphere One to stay onsite and begin harvesting cenospheres once
the temperatures permitted. This activity has commenced since our initial discussions with you.
• Charah plans to apply mulch and dust suppressant product to areas in the cenosphere-harvesting
area once temperatures allow. In the meantime, Charah will continue with water applications as
noted above. Additionally, Charah is supplementing cenosphere removal with Sphere One.
In addition to the actions Asheville Plant staff have taken prior to the complaint you received, our staff
are vigorously evaluating additional alternatives and actions. Some of the things under evaluation
include:
• Asheville Plant is evaluating the establishment of an alternate harvesting area that has more wind
buffer to eliminate cenosphere travel from the harvesting site proper.
• Asheville Plant is evaluating other harvesting methods that might allow cenosphere collection in
areas that are hard to reach and that will allow a more consistent harvesting.
• Asheville Plant is evaluating wind break options at the existing harvesting area including natural
and constricted barriers.
• Asheville Plant is evaluating options to accomplish more frequent harvesting of cenospheres.

• Asheville Plant is working with our Community Relations Manager in an effort to develop
reasonable options as well as communicating these to the neighbors of Lake Julian Trails.
We hope that these detailed actions show the commitment we have to addressing this issue appropriately.
In light of the significant steps Asheville Plant staff have taken and the differing interpretations of the
provisions of the ash reuse permit, we ask that you reconsider the Notice of Violation issued against the
subject permit. This permit is applicable to several of our facilities throughout the State and, as we
discussed at our meeting in your office, we are concerned about the extent to which the interpretation
might be used with respect to operations at those facilities. Thank you for your consideration in
evaluating this request. I look forward to your reply. If you have any questions, please feel free to
contact Mr. John Toepfer at [phone].
Sincerely, 1���/,f�
Garry A: W non[ Plant Manager
Asheville Steam Electric Plant

March 17, 2009
Page 3 of 3
agreements, deed restrictions etc. between Progress Energy and the Asheville Airport in regard to this structural fill
project.
If you feel that the above -referenced items can be sufficiently addressed, please forward the supporting
documentation to APS ARO for additional review and reconsideration of your request. If you should have any questions,
please do not hesitate to contact me directly at 828.296.4680.
Sincerely,
G. Landon Davidson, LG
Regional Supervisor Aquifer Protection Section
cc: SWP ARO — Roger Edwards
Cyndi Karoli J John Dorny — 401 certification DWQ
Jon Risgaard - APS ND CO
Director — Asheville Airport
AQUIFER PROTECTION SECTION —Asheville Regional Once (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778A211
Phone: [phone]W t FAX: [phone]
Customer Service: 1-877-623-6748
Internet www.nowaterauality.om
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