NC0003425_Correspondence_20180101 (2)

CPU
Caroline Power & Light Company
APR 2 3 EcA
Mr. R. Paul Wilms, Director
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, NC 27611
RE: ROXBORO STEAM ELECTRIC PLANT
NPDES PERMIT NCO003425
COMMENTS ON RENEWAL EFFORTS
Dear Mr. Wilms:
w,4Gel r �-
C OF Y
Serial: ESS-86-518
On March 21, 1986, representatives from Carolina Power & Light Company
(CP&L) met with representatives of the Water Quality Section of the Division of
Environmental Management (DEM) to discuss a rough draft of the renewed subject permit
which expired on June 30, 1981. During this meeting, which was the first opportunity
CP&L had to review this draft of the new permit, several revisions were suggested by
CP&L that were agreed to by DEM. CP&L was asked to further review the draft and
provide additional written comments to DEM at the earliest opportunity. Enclosure 1
includes those comments along with a marked -up copy of the permit reflecting our
proposed changes. Also discussed at this meeting was the status of the Special Order by
Consent (SOC). Mr. Dennis Ramsey of DEM requested CP&L to provide a more detailed
explanation of the plant's dry fly ash conversion project, and a review of possible interim
selenium reduction measures.
As a result of those additional requests, another meeting was held on April 9,
1986 at which time CP&L engineering staff presented a detailed explanation of the dry
fly ash conversion project scope and schedule to Messrs. Ramsey and Everett of DEM
along with others. Mr. Ramsey requested copies of the material used in our presentation
for DEM review. Those figures and charts are provided herewith as Enclosure 2. CP&L
strongly believes that the scheduled construction completion, 42 months after issuance of
the NPDES permit, is thoroughly justified and is prepared to offer any further
documentation or presentations as DEM may deem necessary.
CP&L has reviewed several potential methods to reduce selenium discharge
from the ash pond in the interim period between permit reissuance and complete
implementation of the dry fly ash handling system. A summary of the Company's
determinations is included as Enclosure 3.
FOS 00330707
411 Fayetteville Street • P 0 Box 1551 • Raleigh. N C 27602

Mr. R. Paul Wilms -2-
Since the Company will not be able to comply with the proposed effluent
limitation for selenium until after plant modifications are completed, an SOC will be
required, as previously agreed, to allow the plant to continue to operate. A new draft of
the SOC (Enclosure 4) has been prepared to reflect the current compliance schedule for
the selenium effluent limitation stated in the permit, and include the modification of the
existing ash pond as an interim measure to reduce selenium discharge. Enclosure 5 is a
brief explanation of the Company's estimate of the time necessary for Hyco Reservoir to
recover to selenium concentrations below 5 ug/i. As discussed in a letter to you dated
August 7, 1985 (Serial: ESS-85-866), CP&L believes an acceptable permit and SOC must
be in place before we can make the major contractual commitments to proceed with the
$38 million plant modifications that are necessary to comply with the permit effluent
limits.
CP&L hopes that the information provided herein will facilitate DEM's
efforts in developing a final draft of the renewal permit and accompanying SOC. We
look forward to the prompt resolution of this permit so that our schedule for the ash
handling conversion will not be interrupted. Your cooperation and attention to this
matter is appreciated.
Yours very truly,
Original Slgned by
R B. Starkuyl Jr.
R. B. Starkey, Jr.
Manager
Nuclear Safety and
Environmental Services
RBS/krs (3994CCW)
Enclosures
cc: Mr. Dennis Ramsey (w/enclosures)
Mr. R. W. Van Tilburg (w/enclosures)
bcc: Mr. C. V. Bailes
Mr. C. C. Carmicheal
Mr. T. J. Crawford
Mr. M. R. Greeson
Mr. D. E. Hollar
Mr. I B. McGirt
Mr. B. J. Ward
Mr. L. B. Wilson
FOS 00330709

Sera' ESS-86-518
Ent ;ure 1
Exhibit 1
Page 1 of 2
ROXBORO STEAM ELECTRIC PLANT COMMENTS
ON DRAFT OF NPDES PERMIT NCO003425
The following are explanations of proposed revisions in the draft permit
provided by DEM in a meeting with CP&L on March 21, 1986. This is not intended to
cover items already agreed upon by CP&L and DEM during that meeting. A marked up
copy of the draft permit is included herewith as Exhibit 3 for reference.
Outfalls 001, east ash pond, and 002, west ash pond, had been combined into a
single effluent page with identical monitoring require nand sampling for both locationsfrequencies be
requests that these outfalls be put on separate pages
changed for the reasons discussed in the following paragraphs.
The east ash pond has not had ash sluiced to it since March 1985. Since that
time, the only flow to that pond has been 1) a low volume waste stream that only
amounts to a few thousand gallons per day from one generating unit and 2) rainfall runoff
from the pond's drainage basin. The pond's spillway is located upstream of the settled
ash so that most runoff is released from the pond with little or no contact with the
deposited ash. In the past twelve months, many sampling visits to the discharge point
have noted no discharge, indicating that the effluent quantity is highly dependent on
rainfall runoff. As such, it is not appropriate to attempt composite sampling in this
stream, where flow is very sporadic and largely beyond the control of the permittee. The
attached Exhibit 2 is a table of monthly average selenium discharges from both ash ponds
for the past year. Since the east ash pond was abandoned as an actively used ash settling
basin, the selenium load from it has averaged approximately 0.16 lbs/day as compared to
18.3 lbs/day for the west ash pond in the same period. It should be also noted that the
east ash pond sampling point is located at the end of two concrete culverts in a difficult -
to -access location on a canal embankment. In such a location, installation and operation
of a flow measuring device would be very difficult and obviously pump records would be
of no use in estimating effluent flow. For these reasons, CP&L requests that Serial
Numbers 001 and 002 be covered by separate pages in the permit, and that 001 require
only effluent grab samples on a two -per -month frequency. This should provide adequate
indication of selenium and other trace element loading from a source that is such a minor
contributor to Hyco Reservoir.
Regarding the west pond, CP&L believes that daily composite sampling for
selenium is unnecessarily burdensome. While it appears that the two per month sampling
as required in the current permit does not demonstrate a reliable and well -correlated
relationship between flow and selenium load, a greater than tenfold increase in sampling
will in all probability provide a great volume of data that will be very redundant and in
excess of any practical benefit to environmental concerns. CP&L is willing to cooperate
in an effort to determine a reliable correlation between flow, which is recorded
continuously, and selenium load. Toward that end, we suggest that selenium and pH be
grab sampled on a daily basis for a period of six months after completion (currently
scheduled for Dec. 1986) of the active construction of ash pond modifications as a special
condition in Part III of the permit. While construction is under way, access to the pond
effluent for sampling purposes will often be very difficult, and sampling should therefore
be limited to once a week. The effluent page would have a selenium and pFI monitoring
frequency of once per week which, in conjunction with daily flow records, should be
adequate once a suitable correlation is developed from the daily sampling data. Wording
in the permit that would make an automatic transfer back to the long term sampling
(3991CCW /jww)
FOS 00330709

Se; ESS-86-518
Enciosure 1
Exhibit 1
Page 2 of 2
frequency of once per week, would be preferable to making the daily monitoring a
permanent permit requirement which is not expected to be necessary for the full
duration of the permit.
CP&L would like to point out that the west ash pond is in a remote location
from the plant and the security for a piece of equipment such as an automatic composite
sampler would be difficult to guarantee. In addition, this entire plant operates as a
baseload facility for the CP&L system, and as such, there is a minimum of generation
cycling during the day. Since these units generally operate continuously for extended
periods, relatively little fluctuation can be expected in the nature and quantity of their
input to the ash pond on a day-to-day basis. When the current ash pond expansion is
completed by December 1986, the initial usable capacity is expected to be approximately
700 acre-feet which, with an inflow of 24 MGD, will produce a detention time of about
9.5 days. This detention time will serve to effectively dampen any significant
fluctuation in effluent characteristics to such a point that composite sampling will not be
necessary. For these reasons, CP&L requests the sampling type for the ash pond be
changed to "grab" in the permit.
For Outfall Serial Number 003, heated water discharge canal, the wording in
footnote 1 has been revised to agree with the current permit.
For Outfall Serial Number 004, cooling tower Unit 3, the date for starting the
once through mode is corrected to October 15 as is in the current permit.
For Outfall Serial Number 007, low volume waste -fuel oil unloading station,
CP&L requests that the sample type for TSS be grab rather than composite. As discussed
in the March 21 meeting regarding coal pile runoff, this Outfall is entirely dependent on
rainfall runoff and therefore sporadic and difficult to sample on a composite basis. Also,
since this flow is from an impervious area and treated by an oil/water separator prior to
release, it is very unlikely that total suspended solids will represent a compliance
problem that would justify the expense and effort of composite sampling.
For Outfall Serial Number 008, domestic waste, CP&L requests that flow be
monitored no more frequently than twice per month as is already required for BOD and
TSS. Compliance with flow requirements has not been a problem at this facility and
therefore does not warrant a special trip to measure when no other characteristics are
sampled. Also, CP&L requests the temperature monitoring requirements in the draft
permit be deleted. This facility is an extended aeration package plant that discharges to
Hyco Reservoir, a 4,000-acre body of water. It is very unlikely that this facility would
generate any significant heat at all. The discharge is not to a small stream that would be
influenced by any possible temperature difference, but rather to a very large body of
water that should never show any impact from the temperature of such a small quantity
of flow. Therefore, we believe temperature monitoring is unnecessary at this particular
facility.
FOS 00330710
(3991CCW /jww)

ESS-86-518
Enclosure 1
Exhibit 2
Roxboro Steam Electric Plant
Total Selenium Released in Pounds/Day
Month
East Ash Pond
West Ash Pond
Both Ponds
4/85
.43
10.00
10.43
5/85
.01
15.28
15.29
6/85
.19
20.35
20.54
7/85
.87
20.10
20.97
8/85
.01
18.49
18.50
9/$5
.00
19.29
19.29
10/85
.00
10.93
10.93
11/85
.17
18.81
18.98
12/85
.05
17.75
17.80
1/86
.01
14.48
14.49
2/86
.01
23.35
23.36
3/86
.19
30.62
30.81
AVERAGE
.16
18.29
18.45
East Ash Pond contributes approximately 1," of total Selenium
FOS 00330711

kZ1 III, L 000Yz f
ESS-86-518
Enclosure 1
Exhibit 3
STATE OF NORTH CAROLINA
DEPARTMENT OF NATURAL RESOURCES & COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
P E R M I T
To Discharge Wastewater Under the NATIONAL
POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
Carolina Power & Light Company
is hereby authorized to discharge wastewater from a facility located at
Roxboro Steam Electric Generating Plant
Person County
to receiving waters designated Hyco Lake in the Roanoke River Basin
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, and III hereof.
This permit shall become effective
on This permit and the authorization to discharge shall expire at midnight
Signed this day of
Ml & 11
Robert F. Helms, Director
Division of Environmental Management
By Authority of the Environmental
Management Commission
FOS 00330712

Permit No. NCO003425
SUPPLEMENT TO PERMIT COVER SHEET
Carolina Power & Light Company
is hereby authorized to:
1_ Enter into a contract for construction of any additional waste—
water treatment facility necessary to comply with the final
effluent limitation contained in this permit, and
2. After receiving an Authorization to Construct from the Division
of Environmental Management, construct and operate additional
wastewater treatment facilities necessary to comply with the
final effluent limitations contained in this permit, and con-
tinue to operate and maintain the existing wastewater treatment
facility located at the Roxboro Steam Electric Generating Plant
(See Part III of this permit), and
3. Discharge from said treatment worksintoH co 7jake which is
classified Class "C" waters L..� 02+ A""' '
FOS 00330713

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FOS 00330721

Permit No. NC0003425
N. plans, drawings, or maps. The BMP Plan shall be developed no later than
(cont) six months after issuance of the final permit (or modification), and
shall be implemented no later than one year after issuance of the final
permit (or modification). The EMP Plan shall be maintained at the plant
site and shall be available for inspection by EPA and DEH personnel."
Ell
P.
1. Water quality standards for temperature will not apply within a
miring zone which shall include the North Hyco arm downstream of NC
Highwav 57, the main body of Hyco Lake downstream of the confluence
of the Cobbs Creek Arm and the North Hyco Arm, and the entire after -
bay lake. The area described does not include the South Hyco Arm of
the first three finger arms on the west side of the Lake lying upsti
of the dam.
2. All water discharged from the afterbay to Hyco River shall comply w:
all applicable standards including temperature standards.
3. Waters within the main lake and the afterbay lake to Hyco River sha:
comply with water quality standards except the temperature standard!
in the areas of the lake defined herein as a mixing zone.
4. Temperature measurements made to monitor compliance with this provi!
shall be made at least six inches but not more than one foot below t
surface of the lake. A monthly average temperature shall consist of
least five determination conducted on five separate days represent
5. Temperature increases shall be determined as the increase
above that temperature measured at the confluence of two
arms on the north side of the lake (N.C. Grid coordinates
East 1,981,000).
Biological Monitoring
in temperi
southern fj
►forth 1,0C
In accordance with the previously submitted biological monitoring
program (as approved by the Director of the Division of Environmenta
Management and as it may be amended) the permittee shall submit rest
of biological studies and monitoring programs in a manner and under
schedule to be approved by the Director of the Division of Environme
Management.
FOS 00330724

Q. 1) For an initial period of 12 months after issuance of this permit,
the permittee shall conduct effluent sampling for outfall serial
number 002, west ash pond, as required in I -A. (2) except that
selenium and pH shall be sampled according to the following
schedule:
a) While the permittee's ash pond expansion project is under active
construction such that access to the sampling point is limited,
sampling will be once per week.
b) After construction is completed, and for a period of at least
6 months, sampling will be conducted daily.
2) Due to the remote and potentially hazardous location of the effluent
sampling point, sampling for the west ash pond will not be required
on days where weather or other unavoidable conditions present a
reasonable safety concern.
R. In accordance with Section 302(a) of the Federal Water Pollution
Control Act, compliance for selenium contained herein shall be deemed
as compliance with 15 NCAC 2B .0211 (b)(3)(L)(xv).
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FOS 00330725

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Enclosure
Exhibit 2
FOS 00330727

ESS-8 6-518
Enclosure 3
Exhibit 1
Page 1 of 3
INTERIM MEASURES FOR THE REDUCTION OF SELENIUM IN THE
ASH POND EFFLUENT AT ROXBORO STEAM ELECTRIC PLANT
As a result of a revision in the North Carolina Water Quality Standards for
selenium and an anticipated effluent limitation for selenium from the Roxboro Steam
Electric Plant's ash ponds, Carolina Power & Light Company (CP&L) has tentatively
committed to install dry fly ash handling equipment at the Roxboro Plant. The
installation of these modifications will take approximately 42 months after the NPDES
Permit issues. CP&L has conducted an evaluation of measures which could be
implemented before the modifications are complete that may provide a more immediate
reduction in selenium loading to Hyco Lake. Those alternatives include the addition of
acid directly to the ash pond, addition of ferric chloride to the ash pond, oxidation of the
ash pond, and modifications to the existing ash ponds.
Acid Addition
CP&L conducted studies in the fail of 1984 and the early part of 1985 which
addressed chemical treatment of ash pond effluent for the potential removal of selenium
and arsenic. This effort is described in the attached article labeled as Exhibit 2. As a
result of those studies and literature research, it is known that selenium is less soluble at
a lower pH. Examination of Figure 2 shown in Exhibit 2 illustrates the theory of
selenium removal by the adjustment of pH. It should be noted that our studies show that
the primary factor for selenium removal in the pH range of 6 to 9, is indeed pH and not
the addition of a precipitation aid such as ferric chloride (discussed later).
CP&L is also aware of attempts by Duke Power Company to reduce selenium
by the addition of acid to the ash pond at their Belews Creek Station. The duration of
Duke's experience with acid addition amounted to a few months in early 1984.
Specifically, when Duke started to add acid in January of 1984, the pH in their ash pond
was 7.8. The pH dropped very quickly to 6 such that Duke had to cease their acid
addition at the end of January in order to avoid a violation of pH limits in their
effluent. After a period of stabilization, Duke began to add acid again around the first
of March of 1984 and did so for 5 weeks. Again, Duke experienced a significant problem
with low pH in their effluent and ceased acid addition.
As would be expected from examining Figure 2 in Exhibit 2, the acid addition
reduced selenium concentrations in the ash pond effluent at Belews Lake. However,
Duke had significant problems in controlling the p1l. Once the buffering capacity of the
ash pond was consumed, the pH dropped and stayed at or below 6. To the extent that a
pH of less than 6 would constitute a violation of their NPDES permit, Duke permanently
stopped this treatment method the first week in April of 1984.
At Roxboro, the pH in the ash pond averages approximately 7.0 on an annual
basis. As can be seen by examining Figure 2 of Exhibit 2, the addition of acid may
reduce selenium at Roxboro to some extent, but it would not be nearly as effective as
Duke had experienced.. Duke started with a pH of 7.8, whereas Roxboro would start with
an average pH of 7.0. The portion of the curve where CP&L would start versus where
Duke started is much flatter and would indicate less effective treatment. Also,
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4 Enclosure 3
Exhibit 1
Page 2 of 3
CP&L would expect severe pH control problems similar to those experienced by Duke and
consequently, possible NPDES permit violations with regard to pH. Although difficult to
estimate, another problem may arise from an increase in the discharge of other trace
elements since they are more soluble at a lower pH.
Ferric Chloride Addition
Also evaluated was the addition of ferric chloride as a precipitation aid. The
basis for this alternative involves the insolubility of ferric iron at a pH of 7. As the iron
precipitates, it should remove selenium in the process. The studies mentioned earlier
verified that ferric iron is a good cation for promoting the precipitation of selenium.
However, upon examination of this alternative it was determined that its
success would be severely limited in that any significant addition of iron would result in a
violation of the one part per million effluent limitation for iron that is proposed for the
NPDES permit.
Oxidation
Another alternative explored was the oxidation of the ash pond waters either
chemically or physically. The theory was that any existing ferrous iron in the ash pond
could be oxidized to the ferric form which would precipitate out as described above,
removing selenium in the process. The difficulty with this treatment is that selenium
would also be oxidized such that any seienite would be oxidized to selenate. Selenate is
more soluble than seienite and as a result of oxidation, the total selenium in the effluent
would probably not be significantly reduced and may even be increased.
Ash Pond Modifications
The most promising alternative for reducing selenium discharges before the
fly ash modifications are completed involves the substantial modification of the existing
ash ponds. The first part of the modification package was completed in March of 1985.
At that time, the east ash pond which had received ash primarily from Units 1 and 2 was
abandoned. In recent years, as the east ash pond neared its disposal capacity, it was
clear that some suspended ash carryover was present in the discharge. The elimination
of this carryover has also eliminated the peaks in selenium discharge that were being
contributed by the east ash pond, particularly during storm events. The ash from Units 1
and 2 is now being sluiced to the west ash pond.
The second part of the modifications to the existing ash disposal systems will
involve an expansion of the west ash pond and a significant change in the flow
configuration of the ash sluice water within the pond. Specifically, the water level in the
active portion of the ash pond will ultimately be raised by 16 feet. Also, by use of dikes
and canals, the sluice water will flow toward the upper end of the active ash pond where
it will discharge into the upper reaches of the existing ash pond. This upper end of the
ash pond will remain at its current surface elevation and will function as a secondary
settling basin. Water will then flow from the upper reach of the ash pond through a
series of canals down to the existing discharge structure into Hyco Lake. These
modifications are shown on Exhibit 3. In addition to a more efficient flow pattern within
the ash pond, the upper dike will also prevent storm water from flowing into the active
settling area of the ash pond. This diversion should reduce scouring and the resulting
carryover. In combination, CP&L is convinced the ash pond modifications described
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Enclosure 3
Exhibit 1
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herein will result in a much more efficient treatment facility and will therefore reduce
selenium in the discharge. However, it is very difficult to accurately estimate the
extent to which these reductions will occur for the following reasons: 1)the difficulty of
estimating scouring and carryover from storm events, 2)an accurate estimate of the
increase in retention time is dependent on effective settling volume available in the ash
pond which is dynamic, and 3) there is not a precise relationship between settling
efficiency and total selenium reduction.
Conclusions
As discussed above, CP&L has evaluated several alternatives which were
considered for the removal of selenium in the interim period while the modifications are
being completed for the dry fly ash handling system. The chemical treatment
alternatives would produce marginal improvements at best, and in most cases present
significant problems with process control and compliance with the NPDES permit
limits. The physical alteration of our existing ash pond disposal scheme is already
planned and makes use of reliable, proven treatment methods. For this reason, CP&L
believes the only appropriate interim reduction measure would be the ash pond
modifications, as described. Currently, it is estimated that this project will be
completed by the end of 1986 or early 1987 at the latest. The estimated cost for this
project is $3.5 million.
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