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HomeMy WebLinkAboutNC0024406_Modification_20201105 +"ca STATE' *''' it ROY COOPER g ., _ v-- - ) GavPrnor • MICHAEL S. REGAN . ^,,.._.,,. . `�aa,µ „."-` Secretory a�_,,emrT'`= S.DANIEL SMITH NORTH CAROL INA Director Environmental Quality November 05, 2020 Duke Energy Carolinas LLC Attn: Michael Lanning, GM 3195 Pine Hall Road 1 Belews Creek, NC 27009 Subject: Permit Application Application No. NC0024406 Belews Creek Steam Station Stokes County Dear Applicant: The Water Quality Permitting Section acknowledges the November 4, 2020 receipt of your permit modification application and supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting branch. Per G.S. 150E-3 your current permit does not expire until permit decision on the application is made. Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a timely manner to requests for additional information necessary to allow a complete review of the application and renewal of the permit. Information regarding the status of your renewal application can be found online using the Department of Environmental Quality's Environmental Application Tracker at: https://deq.nc.gov/permits-regulations/permit-guidance/environmental-application-tracker If you have any additional questions about the permit, please contact the primary reviewer of the application using the links available within the Application Tracker. Sincerely, —3l.CUWV-P12/.(1 Wren Thedford Administrative Assistant Water Quality Permitting Section cc: Central Files w/application ec: WQPS Laserfiche File w/application North Carfl:,rs Departmentof Envranments'Quail} I D usgn ofW ter Few.rc s DE Q rstor'. em Regcrte Off 145D Vest�+anes Nifi Rosd,Sute 3D I r5t�r�s em,North Carotins 27105 V u 336-776-9800 fi DUKE Michael F.Canning General Manager ENERGY Belews Creek Steam Station 3195 Pine Hall Road Belews Creek,NC 27009 (336)445-0501 October 13, 2020 Sergei Chernikov, PhD, Acting Supervisor RECEIVED Industrial Permitting Branch NOV-0 4 2020 NC Division of Water Resources 1617 Mail Service Center NCDEQ/DWR/NPDES Raleigh, NC 27699-1617 Subject: NPDES permit modification request Belews Creek Steam station NC0024406 Stokes County Dear Dr. Chernikov, Duke Energy Carolinas, LLC (Duke Energy) hereby requests modification of the subject NPDES permit to make the following changes: 1. Incorporate updated provisions and technology based effluent limits (TBEL) found in 40 CFR part 423. Specifically, Duke Energy requests that the FGD TBELs be updated to the values in the recently modified steam electric effluent limitations guidelines and that terms related to the release of bottom ash transport water be clarified to align with updates to 40 CFR Part 423. The revised rule was signed by the US Environmental Protection Agency (EPA) on August 31, 2020 and published in the Federal Register on October 13, 2020. The rule states that "Where permits with the 2015 rule limitations have already been issued, EPA expects that the final rule requirements will be incorporated through permit modifications in most cases." If necessary, Duke Energy will work with the Department to develop a narrative permit requirement to assure that treatment components in place continue to be properly operated and maintained to provide optimum treatment. 2. With the update to the FGD TBEL's, Duke Energy requests that the attached combined waste formula be used to calculate the limits to account for the use of the FGD wastewater treatment infrastructure in providing additional treatment to FGD landfill leachate prior to release to the lined retention basin and ultimately to the Dan River. The combined waste formula calculation and supporting information can be found in Attachment 1 to this submittal. 3. Duke Energy requests clarification as to required instream sampling related to outfall 006. The current permit condition A.(22.), refers to instream sampling associated with outfall 003. Ash basin discharges through outfall 003 were eliminated as part of the work completed under Consent Order EMC SOC S 18-009. Outfall 006 is located downstream of the previous outfall 003 location. Duke Energy requests the condition in outfall A.(22.) be updated to allow for www.duke-energy.com downstream sampling at the Pine Hall Road bridge. Property access limitations and safety concerns exist downstream of outfall 006 as Duke Energy's property ends very near the outfall 006 location. There are no major tributaries between outfall 006 and the downstream bridge making it a suitable and well mixed location to measure downstream effects from the discharge. A map showing the requested sampling location is included as Attachment 2 to this submittal. 4. Duke Energy requests the domestic wastewater limits imposed on internal outfall 009 be modified to align with technology limits. This system consists of a lagoon and appropriate limits and sampling frequency for such a system found in 15A NCAC 2B .406 are 30 mg/1 BOD and 90 mg/1 TSS with sampling monthly for pH, TSS, BOD, fecal, ammonia nitrogen, and temperature. The domestic discharge per day of the sewage lagoon is approximately 9,000 gallons with that flow going to the lined retention basin before discharge to the Dan River. Copies of pump and haul applications and issued permits are attached to the submittal as Attachment 3. Pumping and hauling has been the method of disposal since the permit was issued. 5. Duke Energy requests the addition of landfill leachate flows, from the yet to be constructed CCR landfill, to the lined retention basin. A new leachate holding basin will be constructed to collect leachate and handle surges in contact water flow before being pumped to the LRB holding basin, and ultimately discharged via internal outfall 006. A diagram of the proposed leachate holding basin is attached as Attachment 4. 6. Duke Energy requests conditions A(3.) and A(4.) of the subject NPDES permit be updated to remove the limit and footnote for iron at Outfall 006a related to the discharge of chemical/metal cleaning waste to the ash basin. All flows to the ash basin ceased in March of 2019 so the condition and footnote are no longer applicable to the ash basin. A check in the amount of$1,030 is included with this submittal to cover the required permit modification fee. Should you have any questions about this request please feel free to contact Mr. Shannon Langley at (919) 546-2439 or Ms. Lori Tollie at (336)408-2591. Sincerely, WZ,4-, ' z-7 Michael Lanning General Manager III - Regulated Stations FHOCC Belews Creek Steam Station Cc: Shannon Langley Brenda Johnson Matt Hanchey Cynthia Winston Attachment 3—New CCR Landfill Leachate Storage Pond • Leachate Pond „. _ . I L- _ Dewberry' TECHNICAL MEMORANDUM Date: December 13, 2019 To: Rick Harrison, Duke Energy From: Leigh-Ann Dudley, PE, Dewberry Subject: Belews Creek FGD Treatment System Capacity Analysis Message: Duke Energy Belews Creek Steam Station (Belews Creek) utilizes an ABMet®biological system for the treatment of Flue-Gas Desulfurization (FGD) blowdown wastewater. Leachate from the FGD Gypsum Landfill and Craig's Road Landfill are currently discharged to a new lined retention pond; however, the pond effluent exceeded the allowable effluent concentration for selenium. Duke executed a sampling plan and identified the leachate wastestreams as the source. Duke is currently trucking the FGD Landfill leachate to the FGD wastewater treatment system (FGD WWT). Duke wishes to redirect the leachate wastestreams from the lined retention pond to the FGD treatment system to treat selenium. Duke wishes to evaluate the capacity of the treatment system to accept the leachate wastestreams. Duke is interested in considering the capacity of the treatment system for the following scenarios: • Scenario 1: Full Baseline Load (Two Coal Units Operational) + FGD Landfill Leachate o Daily average and maximum daily average FGD blowdown flow rates for specific unit process evaluations o Average and 25-year, 24-hour storm FGD Landfill leachate flow for specific unit process evaluations o Average and maximum constituent concentrations in FGD blowdown and FGD Landfill leachate for contaminant loading evaluation • Scenario 2: Full Baseline Load (Two Coal Units Operational) + FGD Landfill Leachate+ Craig's Road Landfill leachate o Daily average Craig's Road Landfill leachate flow for specific unit process evaluations o Average and maximum constituent concentrations in Craig's Road Landfill leachate for contaminant loading evaluation Duke anticipates an average leachate flow of 40 gallons per minute (gpm) of FGD Landfill leachate and 30 gpm of Craig's Road Landfill leachate. Dewberry evaluated the capacity of the treatment system on a hydraulic and contaminant loading basis. Average and maximum flow and concentration conditions were considered to evaluate typical conditions and extreme conditions. This analysis is based on the Basis of Design submitted to Duke as Draft on July 11, 2017 and as Final on August 23, 2019 (Attachment A). Duke provided additional data related to the FGD treatment system on September 18, 2019 and September 20, 2019. In addition, on October 8, 2019 Duke requested a capacity evaluation for the FGD Landfill leachate flow rate associated with a 25-year, 24-hour storm. Hydraulic Analysis Overall Table 1 summarizes the overall hydraulic loading to the FGD treatment system. Memorandum I 1 of 10 Dewberry- TECHNICAL MEMORANDUM Table 1. S stem Wide H draulic Summa 2017—2019 Data Parameter Average Maximum Notes (gpm) (gpm) System Design Capacity 600 - Daily FGD Blowdown 189 469 All historical operating conditions Average Daily FGD Blowdown 265 469 Two coal units operational Instantaneous 5-min FGD Blowdown 475 833 All historical operating conditions The daily average FGD blowdown flow rate and maximum daily blowdown flow rates are below the 600 gpm design flow rate for the FGD wastewater treatment process. The average instantaneous FGD blowdown is also below the design flow rate. The maximum instantaneous 5-min rate from 2017—2019 does exceed that design loading rate; however, this was sustained for less than 15 minutes in a single occurrence during the two year period. Additional analysis of individual system components is presented below. Filtrate Sump The filtrate sump has an operating capacity of approximately 37,340 gallons. Inputs to the sump include ultrafilter backwash, filter press filtrate, the continuous backwashing filter, strainer backwash, and chemical waste. Dewberry evaluated two scenarios for FGD Landfill leachate addition to the filtrate sump: (i) an average continuous flow rate of 40 gpm and (ii) a maximum continuous flow rate of 280 gpm for 29 hours to convey the total volume associated with the 25-year, 24-hour storm from the landfill (total of 487,510 gallons; 63,360 gallons leachate, 120,150 gallons wheelwash and 304,000 gallons stormwater). The proposed FGD Landfill leachate pump capacity of 280 gpm was used as the maximum flow rate in this analysis. The hydraulic analysis of the filtrate sump was based on a comparison of the combined influent flow rates and the design effluent flow rate over a three day period. Table 2 summarizes the flow streams, flow rates, total volumes discharged to the sump, and total volume pumped out of the sump for each FGD Landfill leachate scenario. There is capacity available in the filtrate sump to accept the additional influent flow from the FGD Landfill leachate associated with both average and 25-year, 24-hour storm scenarios. The capacity of the filtrate sump pumps to remove wastewater from the sump exceeds the total inputs for the three day modeling period. The filtrate sump could accept the average FGD Landfill and Craig's Road Landfill leachate flows. Memorandum 12 of 10 Dewberry' TECHNICAL MEMORANDUM Table 2. Filtrate Sum• H draulic Anal sis Estimated Total Estimated Total Maximum Volume Over Three Volume Over Three Duration Potential Days Including Days Including 25- Waste Stream Notes for Instantaneous Average FGD yr,24-hr Storm Flow(gpm) Leachate Flow FGD Leachate Flow Flow Inputs (gallons) (gallons) Inputs Ultrafilter 726 238,491 238,491 Occurs every 20 minutes' Backwash Filter Press Average 325 gpm for 20 Filtrate 500 40,950 40,950 minutes twice per day2 Cont. Backwash 60 259,200 259,200 Continuous; 3 filters x 20 Filter gpm each3 Assumes entire daily Strainer strainer backwash volume Backwash 80 5,760 5,760 discharges in single event once per day Chemical Waste 396 3,564 3564 Occurs every 21 days4 Average flow is 40 gpm FGD Landfill continuous;487,510 Leachate 172,800 590.640 gallons from 25-yr, 24-hr storm pumped at 280 gpm (29 hours) Total In uts - 720,765 1,138,605 Output Filtrate Sum Pumps p 1,200 726,600 1,144,800 (2)x 600 gpm5 1 Per M7 Operating Conditions and Maximum and Minimum Treatment Rates 2 Per August 5, 2019 email from Derek Henderson. Dewberry assumed the average flow of 325 gpm based on beginning at 500 gpm and declining to 150 gpm over 20 minutes. 3 Per August 5, 2019 email from Derek Henderson. 4 Chemical waste is from Clean in Place(CIP)process for the Ultra Filters. The CIP process occurs every 21 days. 5 For modeling purposes, the following simplified and conservative pump control logic was assumed:water level at 8 feet in sump initiates lead pump at 600 gpm, at 9 feet initiates lag pump at 600 gpm, and both pumps off at 4.5 feet. Equalization(EQ) Tank The EQ tank has an operating capacity of 177,000 gallons. The inputs to the EQ tank can be diverted to a 177,000 gallon Maintenance Tank, which we understand the operators currently use as a second EQ in series. Inputs to the EQ and Maintenance Tanks include the FGD wastewater, backwash waste return, filtrate sump effluent, and 2nd stage recycle. Flow data for the FGD blowdown is the only metered input. The effluent from the EQ tank is pumped to the reaction tanks via the forwarding pumps. As summarized in Table 3, the EQ/Maintenance Tanks can accept the additional average40 gpm flow P from the FGD Landfill leachate, but cannot accept the higher flow rate of 280 gpm for 29 hours associated with the 25-year, 24-hour storm from the landfill if the daily maximum FGD blowdown rate of 469 gpm occurs at the same time. Additional storage volume of approximately 250,000 gallons would be required for the EQ/Maintenance tanks to accept the volume associated with the 25-year, 24-hour storm from the FGD Landfill (280 gpm for 29 hours)with the FGD blowdown at the maximum daily average flow rate. The EQ/Maintenance tanks can accept a maximum continuous flow of approximately 51 gpm when the FGD blowdown flow rate is 469 gpm,which is not enough capacity for the combined average flow rates of FGD Landfill leachate and Craig's Road Landfill leachate. When the average FGD blowdown rate of 265 gpm occurs concurrently with the 29 hours of 280 gpm from the FGD Landfill, the EQ/Maintenance tanks can accept the flow. It will be critical for the landfill operator to communicate with the wastewater treatment operator to understand the tank levels and FGD blowdown flow rates prior to initiating discharge of a 25- year, 24-hour storm. Memorandum 13 of 10 Dewberry' TECHNICAL MEMORANDUM Table 3. EQ Tank H draulic Anal sis Estimated Total Volume Over Estimated Total Maximum Three Days Volume Over Three Waste Stream Potential Including Days Including 25-yr, Duration Note Instantaneous Average 24-hr Storm FGD Flow(gpm) FGD Leachate Flow Leachate (gallons) Flow (gallons) Inputs FGD Slowdown 2017-2019 daily maximum with Max Daily 469 2,026,080 2,026,080 two units operational Average Backwash Per email from Derek Waste Return 70 201,600 201,600 Henderson August 5, 2019; runs 16 hours per day Filtrate Sump 1,200 726,600 1,144,800 (2)x 600 gpm2 Pumps' Used as-needed per email 2nd Stage from Derek Henderson August Recycle Pumps500 22,500 22,500 g y5, 2019; assumed 15 minutes per day Total In.uts - 2,976,780 3,394,980 - Output Forwarding 700 2,976,800 3,024,000 700 gpm3 Pump Capacity 1The volumes from the filtrate sump include the FGD Landfill leachate. 2 For modeling purposes,the following simplified and conservative sump pump control logic was assumed:water level at 8 feet in sump initiates lead pump, at 9 feet initiates lag pump, and both pumps off at 4.5 feet. 3 For modeling purposes,the following simplified and conservative forwarding pump control logic was assumed: water level at 16 feet in EQ tank initiates pump at a maximum flow rate of 700 gpm and pump off at 10.5 feet. Solids Contact Clarifier The hydraulic capacity of the solids contact clarifiers is based on a comparison of projected loading conditions on the design rise rate. Table 4 summarizes the baseline rise rate and the rise rate with the addition of leachate flow. We understand Duke prefers to operate with a single clarifier. We have calculated the projected rise rates below with one unit operational and both units operational for comparison. Red text indicates the projected rise rate exceeds the design rise rate. Memorandum 14 of 10 Dewberry. TECHNICAL MEMORANDUM Table 4. Solids Contact Clarifier Loadin• Anal sis Parameter Unit Average Maximum Surface Area(per clarifier) square ft(sq ft) 1,649 Desi•n Rise Rate ••m/s• ft 0.205 Baseline Condition (Two Coal Units) Flow' gpm 352 578 Rise Rate—One Clarifier gpm/sq ft 0.214 0.350 Rise Rate—Two Clarifiers 0.107 0.175 Scenario 1 FGD Leachate Flow gpm 40 Combined Flow gpm 392 618 Rise Rate—One Clarifier gpm/sq ft 0 238 0.375 Rise Rate—Two Clarifiers ••m/s• ft 0.119 0.187 Scenario 2 FGD+Craigs Road Leachate gpm 70 Combined Flow gpm 422 648 Rise Rate—One Clarifier gpm/sq ft 0.256 0.393 Rise Rate—Two Clarifiers gpm/sq ft 0.128 0.196 1The baseline condition average and maximum flow rates are from forwarding pump data recorded between 2017 and 2019. Even at the baseline flow with two coal units operational, the rise rate with one clarifier in operation exceeds the design rise rate. We understand Duke has not experienced operational problems operating one clarifier. For both Scenario 1 and Scenario 2, the rise rate at average and maximum flow is projected to be above the design rise rate. At average flow conditions, the rise rates for both scenarios with one clarifier is above the design rate but it is within the range 0.214—0.350 gpm/sq ft that Duke has historically operated with one clarifier in operation during periods with two coal units in operation. The projected rise rates with two clarifiers in operation is below the design rate for both scenarios. The existing solids contact clarifiers have capacity to accept the FGD leachate and Craig's Road Landfill flow rates. Under higher flow rates Duke may have to operate more than one clarifier to maintain effluent quality. Continuous Backwash Gravity Filter The hydraulic capacity of the continuous backwash gravity filter is based on a comparison of projected loading conditions on the design rise rate. The design rise rate was provided on the Process Flow Diagram. Table 5 summarizes the baseline rise rate and the rise rate with the addition of leachate flow. Table 5. Continuous Backwash Gravit Filter Loadin• Anal sis Parameter Unit Average Maximum Surface Area square ft(sq ft) 264 Desi•n Rise Rate ••m/s• ft 3.93 Baseline Condition (Two Coal Units)' Flow' gpm 352 578 Rise Rate ••m/s. ft 1.33 2.19 Scenario 1 FGD Leachate Flow gpm 40 Combined Flow gpm 392 618 Rise Rate ••m/s• ft 1.48 2.34 Scenario 2 FGD+Craigs Road Leachate gpm 70 Combined Flow gpm 422 648 Rise Rate gpm/sq ft 1.60 2.45 'The baseline condition average and maximum flow rates are from forwarding pump data recorded between 2017 and 2019. Memorandum 15 of 10 le Dewberry'. TECHNICAL MEMORANDUM The projected rise rates for average and maximum flow conditions are within the design rise rate of the continuous backwash gravity filters for Scenario 1 and Scenario 2. Ultrafilter Table 6 summarizes the hydraulic capacity analysis of the ultrafiltration system. The historical and projected hydraulic loading to the ultrafiltration system is based on the flow data from the selenium reduction pumps. Red text indicates the projected flow is above design capacity. Table 6. Ultrafilter Loadin• Anal sis Parameter Value Design Normal Operation' 0.58 MGD 403 gpm Design Maximum Operation' 0.92 MGD 638 ••m Baseline Condition (Two Coal Units)2 Average Flow 365 gpm Maximum Flow 708 ••m Scenario 1 FGD Leachate Flow 40 gpm Projected Average Flow 405 gpm Projected Maximum Flow 748 .•m Scenario 2 FGD+Craig's Road Leachate 70 gpm Projected Average Flow 435 gpm Projected Maximum Flow 778 gpm 1 Per M7 Operating Conditions and Maximum and Minimum Treatment Rates 2The baseline condition average and maximum flow rates are from selenium reduction pump data recorded between 2017 and 2019. The historical maximum flow for the baseline condition is above the maximum design condition as is the maximum j roected flow f r p o Scenario 1 and Scenario 2. The average conditions for Scenario 1 and Scenario 2 are between the normal operation and maximum operation design conditions. Constituent Loading In addition to hydraulic loading, Dewberry evaluated the constituent loading capacity of the treatment system. Historical loading of the treatment system during periods when two coal units were operational was compared to the influent design basis in Table 7(attached). The baseline loading comparison was performed for two conditions: average flow with average concentration and maximum flow with maximum concentration. While historical data from 2017-2019 showed periods when the influent concentrations exceeded the influent design criteria, limited paired influent and effluent data was provided to allow for an analysis of the system performance specifically during historical periods when the influent concentrations exceeded the design. Duke provided additional flow and analytical data from the FGD treatment system from 2010 through 2019 to facilitate further analysis of selenium removal in the system, which is summarized in Table 8 (attached). Dewberry also used the data from 2010 through 2019 to evaluate leachate addition scenarios in Table 9 (attached) and to evaluate the biological portion of the treatment system based on biological selenium reduction rates found in the literature in Table 10 (attached). There were 238 dates where influent and effluent selenium concentrations and flow rates were recorded between 2010 and 2019 (see Table 8, attached). On average, the influent selenium concentrations and loading rates were within the influent design criteria. There have been historical loading rates that have Memorandum 16 of 10 r�p Dewberry- TECHNICAL MEMORANDUM exceeded the influent design criteria, but the data shows that the performance guarantees for selenium removal have been met under these conditions (Table 8, attached). Nitrate was a parameter of concern for this analysis as it interferes with the biological selenium removal process.As shown in Table 7, nitrate historically remained below the design influent concentration of 200 milligrams per liter(mg/L)for the baseline condition and the addition of landfill leachate is not expected to increase the nitrate concentration above the influent design criteria. The average historical selenium loading to the FGD treatment system with additional landfill leachate loading scenarios are presented in Table 9 (attached). Two scenarios of FGD Landfill leachate loading were evaluated: (i) average selenium concentration and average flow rate and (ii) average selenium concentration and flow rate from the 25-year, 24-hour storm. The FGD treatment system can handle both selenium loading scenarios from the FGD Landfill leachate. The influent design capacity on a mass basis for the system is 29 pounds of selenium per day(Ib/d). Under historical average loading, the influent selenium mass is 14 lb/d, leaving approximately 15 Ib/d remaining capacity. At the average leachate flow of 40 gpm and selenium concentration of 1.74 mg/L, the FGD Landfill leachate will contribute 0.8 lb selenium per day. An FGD leachate flow of approximately 1 million gallons per day (average of 694 gpm) at the selenium concentration of 1.74 mg/L would have to be discharged to use all of the remaining capacity when the FGD blowdown is operating at average flow and average selenium concentration. At the average Craig's Road leachate flow of 30 gpm and selenium concentration of 0.089 mg/L, the Craig's Road Landfill leachate will contribute 0.03 lb selenium per day. A flow of approximately 9 million gallons per day(average of 6,550 gpm)from the Craig's Road Landfill could be accepted on top of the average FGD blowdown and the 25-year, 24-hour storm from the FGD Landfill on a selenium capacity basis. It is important to note that there have been historical FGD blowdown purges that have exceeded the influent design criteria selenium concentration, so it is anticipated that periodic exceedances will continue to occur with the addition of the landfill leachate. Dewberry performed a literature review on biological selenium reduction to support the evaluation of the Belews Creek FGD wastewater treatment system capacity. Fujita et al. performed laboratory-scale testing in a continuous flow bioreactor and observed 99% removal of selenium for loading rates less than or equal to 0.45 milligrams of selenium per liter per hour(mg/Uh). On average, the selenium loading rates into the Belews Creek ABMet®system range from 0.03 mg/Uh when eight removal tanks are online to 0.12 mg/Uh when two removal tanks are online (see Table 10, attached). The selenium loading rates remain below the literature value of 0.45 mg/L/h when the average selenium loading rates from the FGD Landfill and Craig's Road Landfill are added to the average historical ABMet®system loading rates, regardless of the number of removal tanks online. When the maximum selenium loading rates associated with both landfill leachate streams are added to the FGD system operating at maximum historical loading, the 0.45 mg/L/hr loading rate is exceeded; however, this scenario of maximum flow and maximum concentration occurring at the same time is unlikely and has not occurred in the nine years of data reviewed. In a publication by the Water Environment Federation describing ABMet®technology, a two- to-sixteen hour empty bed contact time (EBCT) is recommended for the reduction and precipitation of selenium. Assuming the empty bed volume is two-thirds of the removal tank volume, the EBCT in the Belews Creek ABMet®system under historical average conditions with average selenium loading rates from the FGD Landfill and Craig's Road Landfill leachates is within that range as long as at least four tanks are online (see Table 10, attached). Regulatory Review Dewberry reviewed the Steam Electric Effluent Limitations Guidelines(40 CFR§423)to evaluate the regulatory impacts of the addition of one or both of the landfill leachate streams to the FGD wastewater treatment system. In particular, Dewberry reviewed impacts to the numerical limitations in the Belews Creek NPDES Permit NC0024406. The treated FGD blowdown is subject to numerical limits at internal Outfall 002 before being discharged to the lined retention basin and then ultimately discharged to an Unnamed Tributary to the Dan River. Memorandum 17 of 10 Dewberry' TECHNICAL MEMORANDUM Outfall 002, the treated FGD blowdown, is subject to the numerical effluent limits summarized in Table 11. The permit indicates the limits for arsenic, mercury, selenium, and nitrate/nitrite are not in effect until November 1, 2020. Table 11. Permit NC0024406 Outfall 002 Numerical Effluent Limits and Re.ulato References Parameter Monthly Average Daily Maximum Regulatory Reference Permit Limit Permit Limit Total Arsenic 8.0 µg/L 11.0 µg/L 40 CFR§423.13(g)(1)(i) Total Mercury 356.0 ng/L 788.0 ng/L 40 CFR §423.13(g)(1)(i) Total Selenium 12.0 µg/L 23.0 µg/L 40 CFR§423.13(g)(1)(i) Nitrate/Nitrite as N 4.4 mg/L 17.0 mg/L 40 CFR §423.13(g)(1)(i) Oil and Grease 15.0 mg/L 20.0 mg/L 40 CFR§423.12(b)(11) Total Suspended 30.0 mg/L 50.0 mg/L 40 CFR §423.12(b)(11) Solids It is anticipated that accepting landfill leachate at the FGD treatment system will impact the Outfall 002 numerical limits.According to 40 CFR§423.12(b)(13) and §423.13(n), "In the event that wastestreams from various sources are combined for treatment or discharge, the quantity of each pollutant property controlled in paragraphs...of this section attributable to each controlled waste source shall not exceed the specific limitation for that waste source." Combustion residual leachate is subject to the same TSS and oil and grease limits as FGD wastewater per 40 CFR §423.12(b)(11).As such, no changes in the TSS and oil and grease limits at Outfall 002 are anticipated by combined landfill leachate and FGD wastewater for treatment. Combustion residual leachate is not regulated for selenium, nitrate/nitrite-N, arsenic, or mercury in 40 CFR §423. As such, it is anticipated that adding one or both leachate streams to the FGD wastewater stream will decrease the concentration limits for these parameters from the existing FGD limits in NPDES Permit NC0024406. The speculative limits are calculated based on a ratio of the flow contribution from each wastestream and the numerical limits for each wastestream. The calculation approach for this is outlined in Section 5.2.2.6 of the NPDES Permit Writers Manual (EPA-833-K-10-001, 2010). Table 12 presents speculative new limits if one or both leachate streams are combined with the FGD blowdown. Table 13 presents speculative new limits for the combined wastestreams based on proposed Effluent Limitations Guidelines for Steam Electric Power Generators published November 22, 2019. Table 12. Existin I FGD Concentration Limits and Calculated Alternative Concentration Limits Selenium Nitrate/Nitrite-N Arsenic Mercury Scenario (µg/L) (mg/L) (pg/L) (ng/L) Monthly Daily Monthly Daily Monthly Daily Monthly Daily Average Maxims Average Maximum., Average Maximum Average Maximum Current Outfall 002 Limits 12 23 4.4 17 8 11 356 788 Speculative Scenario 1 Limits(FGD Landfill+ 10 20 3.8 15 7.0 10 309 685 FGD Blowdown) Speculative Scenario 2 Limits(FGD and Craig's 9 5 18 3.5 13 6.3 9 282 623 Road Landfill+ Blowdown) Memorandum 18 of 10 Dewberry. TECHNICAL MEMORANDUM Table 13. Anticipated FGD Concentration Limits and Calculated Alternative Concentration Limits Based on ELGs •ro I osed November 22, 2019. Selenium Nitrate/Nitrite-N Arsenic Mercury Scenario (µg/L) (mg/L) (µg/L) (ng/L) Monthly Daily Monthly Daily Monthly Daily Monthly Daily Avera!- Maximum Aver-ee Maximum Avera.e Maximum Avera.e Maximum Anticipated Outfall 002 Limits based on 2019 31 76 3.2 4.6 9 18 31 85 ELG revision Speculative Scenario 1 Limits(FGD Landfill+ 27 66 2.8 4.0 8 16 27 74 FGD Blowdown) Speculative Scenario 2 Limits(FGD and Craig's 25 60 2.5 3.6 7 14 25 67 Road Landfill+FGD Blowdown) Conclusions An evaluation of the FGD treatment system historical data indicates that the baseline condition when two coal units are operational may periodically exceed the concentration and mass design basis for select parameters (Table 7, attached). However, comparison of historical influent and effluent selenium concentrations and mass flow rates indicates that the performance guarantees for selenium removal have historically been met, even under high loading conditions (Table 8, attached). Under average FGD blowdown conditions, there is selenium removal capacity available for the average flow rate and the flow rate associated with the 25-year, 24-hour storm from the FGD Landfill leachate(Table 9, attached). It is important to note that there have been historical FGD blowdown discharges that have exceeded the influent design criteria selenium concentration, so it is anticipated that periodic exceedances will continue to occur with the addition of the landfill leachate. The Belews Creek ABMet®system has historically operated at selenium loading rates and empty bed contact times (EBCT) recommended for optimum biological selenium removal published in the literature(Table 10, attached). Under average FGD blowdown conditions, it is expected that the loading rates and EBCT will remain approximately within literature-recommended ranges with the addition of the average selenium loading from the FGD Landfill and Craig's Road Landfill leachate streams, when at least four bioreactor cells are in operation. On a hydraulic basis, the filtrate sump and the EQ/Maintenance tanks can accept the average FGD Landfill leachate flow of 40 gpm with the FGD blowdown at the maximum daily average flow of 469 gpm (Tables 2 and 3). The filtrate sump and EQ/Maintenance tanks cannot accept the combined average FGD Landfill leachate and Craig's Road Landfill leachate flows when the FGD blowdown is 469 gpm. Additional storage volume of approximately 250,000 gallons would be required for the EQ/Maintenance tanks to accept the volume associated with the 25-year, 24-hour storm from the FGD Landfill (280 gpm for 29 hours)with the FGD blowdown at the maximum daily average flow rate. When the average FGD blowdown rate of 265 gpm occurs concurrently with the 25-year, 24-hour storm flow(29 hours of 280 gpm)from the FGD Landfill, the EQ/Maintenance tanks can accept the flow. The EQ/Maintenance tanks can accept the combined average FGD Landfill leachate and Craig's Road Landfill leachate when the FGD blowdown is 265 gpm. It will be critical for the landfill operator to communicate with the wastewater treatment operator to understand the tank levels and FGD blowdown flow rates prior to initiating discharge of a 25-year, 24-hour storm. The flow rate to the unit processes downstream of the EQ/Maintenance tanks is limited by the forwarding pumps and discharge piping from the Equalization tank. Assuming the forwarding pumps operate at a rate of 700 gpm or lower, the hydraulic analysis indicates the solids upflow clarifiers, the ultrafilters, and the continuous backwash gravity filters have sufficient capacity to accept the additional flow. Memorandum 19 of 10 Dewberry. TECHNICAL MEMORANDUM Evaluation of the Steam Electric Effluent Limitations Guidelines (40 CFR§423) indicated that adding a combustion residual leachate stream to the FGD wastewater stream will likely not change limits on TSS or oil and grease and would potentially decrease numerical concentration limits for selenium, nitrate/nitrite, arsenic, and mercury. The proposed Steam Electric Effluent Limitations Guidelines published on November 22, 2019 include lower limits for mercury and nitrate/nitrite and higher limits for arsenic and selenium as compared to the current limits. Dewberry anticipates addition of the leachate stream to the FGD wastewater stream would also decrease numerical concentration limits for selenium, nitrate/nitrite, arsenic, and mercury. Attachments: Table 7: FGD System Influent Design Criteria and Baseline Condition Loading Table 8: FGD Wastewater Treatment System Influent and Effluent Conditions Table 9: Comparison of FGD Wastewater Treatment System Average Loading Rates with Added FGD Leachate Stream Scenarios to Alstom System Design Criteria Table 10: Comparison of Biological System Selenium Loading Rates to Literature Reference Values Attachment A: Dewberry Basis of Design for Landfill Leachate Treatment Evaluation Memorandum References: Fujita, M., Ike, M., Kashiwa, M., Hashimoto, R., & Soda, S. (2002). Laboratory-scale continuous reactor for soluble selenium removal using selenate-reducing bacterium, Bacillus sp. SF-1. Biotechnology and Bioengineering, 80(7), 755-761. doi: 10.1002/bit.10425 Sonstegard, J., Harwood, J., Pickett, T., & Kennedy, W. (2009). ABMet: setting the standard for selenium removal. Proceedings from the Water Environment Federation, 2009(5), 234-246. doi: 10.2175/193864709793900654 United States Environmental Protection Agency. (2010). National pollutant discharge elimination system (NPDES) permit writers' manual (EPA-833-K-10-001). Retrieved from https://www.epa.gov/sites/production/files/2015-09/documents/pwm_2010.pdf cc: Derek Henderson, Duke Energy Ed Byers, Duke Energy Ryan Ames, PE, Dewberry Katie Jones, PE, Dewberry Amber Greune, PE, Dewberry Memorandum 110 of 10 Table 7 FGD System Influent Design Criteria and Baseline Condition Loading Duke Energy Belews Creek Baseline Condition(Two Coal Units Operational) Influent Basis of Design FGD Blowdown FGD Blowdown (Average Flow) (Maximum Flow) • Flow gpm 600 265 469 gpd 864,000 381,893 675.840 Total Suspended Solids mg/I 16,000 115,292 20,000 144,115 9,333 29,725 78.360 441 575 Chloride mg/I 12,000 86,469 12,000 86,469 9.576 30,498 15,770 Nitrate mg/I 200 1,441 200 1,441 24 75 45 254 Selenium(Se) mg/I 4.0 29 4.0 29 4.1 13.2 6.1 Ammonium mg/I 14 101 14 101 - - - - Antimony(Sb) ug/I 20.0 0.14 30.0 0.22 - - - - Arsenic(As) ug/I 490 3.5 1,160 8.4 630 2.0 1 300 7.3 Barium(Ba) ug/I 7,330 53 16,490 119 - - - - Beryllium(Be) ug/I 13.0 0.09 52.0 0.37 - - - - Cadmium(Ca) ug/I 100 0.7 180 1.3 9.9 0.03 16.7 0.1 Chromium(Cr) ug/I 360 2.6 930 6.7 561 920 5.2 Cobalt(Co) ug/I 420 3.0 530 3.8 - - - - Copper(Cu) ug/I 540 3.9 760 5.5 385 1.2 _ 3.2 Fluorine(F) mg/I 39.5 285 53.7 387 - - - - Lead(Pb) ug/I 350 2.5 780 5.6 - - - - Manganese(Mn) ug/I 6,520 47 7,540 54 - - - - Mercury(Hg) ug/I 300 2.2 300 2.2 >„ 0.9 426 2.4 Molybdenum(Mo) ug/I 410 3.0 580 4.2 - - - - Nickel(Ni) ug/I 760 5.5 930 6.7 506 1.6 1,070 , Silver(Ag) ug/I 60.0 0.4 70.0 0.5 - - - - • Thallium(TI) ug/I 200 1.4 210 1.5 - - - - Vanadium(V) ugh 560 4.0 1,410 10 - - - - Zinc(Zn) ug/I 900 6.5 1,760 13 2.5 1.180 6.7 Red highlighting indicates the concentration or mass loading exceeds the influent basis of the design. Yellow highlighting indicates the concentration or mass loading is between 75"✓--100'i%of the design Notes: -"indicates no historical data was provided for this parameter and wastestream. Average historical FGD blowdown is compared to the average basis of design and the maximum condition is compared to maximum basis of design. The analytical concentrations in the FGD Blowdown were collected from Duke's sample location ID:FGD Purge between January 2017 and March 2019. Influent Basis of Design is based on the Alstom Wastewater Treatment System document Dated June 2,2006. Influent Basis of Design was provided only as influent concentrations.Dewberry calculated mass influent basis based on the flow of 600 gpm. 11/4/2019 1 of 1 $ Dewberry Table 8 FGD Wastewater Treatment System Influent and Effluent Conditions Duke Energy Belews Creek • EQ Tank Effluent Biological System Effluent • Selenium Concentration Selenium Reduction Selenium Concentration Forwarding Pump Rate Selenium Mass Flow in Biological Selenium Selenium Mass Flow P.Date in EQ Tank Effluent System Pump Rate (9Pm) (mom) (Ib/day) (gpm) Reduction System (lb/day) Effluent(mg/L) r. 24-Mar-10 303 1.77 6 272 0.008 0.03 08-Jun-11 540 3.74 24 553 0.003 0.02 22-Jun-11 561 3.83 26 592 0.003 0.02 13-Jul-11 542 4.94 32 570 0.006 0.04 27-Jul-11 327 8.98 35 345 0.006 0.02 10-Aug-11 524 9.53 60 544 0.005 0.03 24-Aug-11 540 4.65 30 576 0.005 0.03 14-Sep-11 593 5 25 37 590 0.005 0.04 28-Sep-11 563 1.07 7 587 0.005 0.04 12-Oct-11 449 4.11 22 460 0.012 0.07 26-Oct-11 608 4.20 31 596 0.003 0.02 09-Nov-11 643 3.69 28 617 0.003 0.02 13-Nov-11 614 4.42 33 585 0.003 0.02 14-Dec-11 631 4.16 31 608 0.003 0.02 28-Dec-11 434 3.74 19 427 0.003 0.01 11-Jan-12 426 3.70 19 428 0.005 0.03 25-Jan-12 601 2.46 18 604 0.003 0.02 08-Feb-12 544 3.81 25 544 0.005 0.03 14-Mar-12 499 3.71 22 497 0.003 0.01 28-Mar-12 274 3.08 10 278 0.003 0.01 25-Apr-12 257 2.69 8 267 0.005 0.02 09-May-12 483 4.98 29 523 0.005 0.03 21-May-12 458 5.25 29 468 0.005 0.03 22-May-12 514 3.85 24 527 0.007 0.04 23-May-12 480 2.69 15 479 0.007 0.04 28-May-12 488 4.20 25 476 0.013 0.08 29-May-12 494 3.86 23 493 0.014 0.08 30-May-12 519 513 32 527 0.016 0.10 13-Jun-12 515 3.97 25 510 0.003 0.02 27-Jun-12 491 4 54 27 488 0.009 0.05 08-Aug-12 479 5.01 29 454 0.008 0.05 29-Aug-12 445 0.53 3 445 0.008 0.04 12-Sep-12 497 2.74 16 494 0.006 0.04 26-Sep-12 342 3.22 13 337 0.003 0.01 10-Oct-12 388 3.80 18 383 0.003 0.01 29-Oct-12 370 413 18 369 0.006 0.03 31-Oct-12 254 4.66 14 246 0.005 0.02 02-Nov-12 390 3.97 19 388 0.003 0.01 05-Nov-12 393 2.53 12 388 0.008 0.04 09-Nov-12 546 3.77 25 554 0.005 0.04 12-Nov-12 564 4.44 30 579 0.003 0.02 14-Nov-12 513 3.71 23 522 0.003 0.02 16-Nov-12 431 4.84 25 437 0.003 0.01 19-Nov-12 418 3.35 17 421 0.008 0.04 21-Nov-12 462 3.59 20 469 0.005 0.03 11/4/2019 1 of 6 • Dewberry Table 8 FGD Wastewater Treatment System Influent and Effluent Conditions Duke Energy Belews Creek EQ Tank Effluent Biological System Effluent 'a Selenium Concentration Selenium Concentration Selenium Reduction 4 Forwarding Pump Rate Selenium Mass Flow in Biological Selenium Selenium Mass Flow in EQ Tank Effluent System Pump Rate ,. ,.a (9Pm) lm9n-) (Ibiday) (9Prn1 Reduction System (lb/day) Effluent(mg/L.) 0.009 0.06 0.006 : LILIMIIIIM0 007 MIMMIMIII ;;ELIMilliEllUMIIIMMIIIIIMENMEIM0.010 0.06 ■-MIIMISa31.11.1. 1i1aMili0.009 r,E a-MELOINIIIIIIREIMIIM11.1.20.008 IIIIIIIIMEE EMJIMUMMIIIIIIIIIMIIIIIMMIIIIIIIIIMIIMINE0.008 r, ililLEMEIMININMLEMMEMMIEMENZEIMIIIIIIIIIIIMILEMMIIMINICLI MILLIIIIIiillIELENIMIIIE iiiIMIIIIMI 0.008 r,E L- 0 003 r r • - 0.006 r r ■- r:• 0.010 0.06 a- •r 0.006 11.11r r M- r• 0.009 lill ; a- IMMillIMIEIIIM L11111111=11020.08 =1.;;IMMILUZIMIMILEMIIIIIIIiiillIMINIE0.006 IMMKIIIMM 0.006 r r r 0.003 ; 0.003 ;Iji . r 0.003 MMILIr r 0.003 rr r 0.003 r r , r 0.003 111.1.1111, gall=1111 0 006 i7LEMMIIII 0.003 :JIMMINI 0.003 _ .•, , 0.003 r r :r 0.003 11111.1120 ,. 0.003 IMIIIIIIIMIE 0 003 ;1.1 .1 . , 0.003 r, MMIZEIllillilEMMIIIIIMMEILIE r 0.005 0.003 EIMIEM 0.003 ;LliEllEM ,. 0.003 'UMMIIII 0.003111.11112=111.1 111.112231111MUIEMIEMEI=.1.11. 0.005 0.006 r, ,. - 0.003M1111 r, r: 0 005 Mill r , 0.006 M11111:112 ,rMilliEMEIMIiEEINIMMIIMIllliiii0.003 rr 0.003 r r , r• 0.008 ,r 09-Oct-13 0.008 r, 11/4/2019 2 of 6 0 Dewberry. Table 8 FGD Wastewater Treatment System Influent and Effluent Conditions Duke Energy Belews Creek EQ Tank Effluent Biological System Effluent Selenium Concentration Selenium Concentration Forwarding PumpRate Selenium Reduction {. kw 9 Selenium Mass Flow in Biological Selenium Selenium ; in EQ Tank Effluent System Pump Rate 9 (9Pm) (mg/L) (Ib/day) (9Pm) Reduction System (Ib/day) t. Effluent(mg/l-) 16-Oct-13 370 2.49 11 352 0.006 0.03 23-Oct-13 263 1.65 5 255 0.006 0.02 30-Oct-13 391 3.21 15 361 0.006 0.03 04-Nov-13 337 3.20 13 320 0.003 0.01 06-Nov-13 321 3.30 13 322 0.003 0.01 08-Nov-13 235 2.65 7 231 0.003 0.01 11-Nov-13 334 3.39 14 327 0.005 0.02 13-Nov-13 299 3.29 12 292 0.007 0.02 15-Nov-13 344 0.00 0 338 0.000 0.00 18-Nov-13 300 2.15 8 281 0.003 0.01 20-Nov-13 301 2.14 8 284 0.007 0.02 22-Nov-13 180 0.26 1 169 0.007 0.01 26-Nov-13 334 0.54 2 328 28-Nov-13 331 2.69 11 323 0.005 0.02 26-Mar-14 427 5.68 29 429 0.005 0.03 09-Apr-14 301 0.65 2 300 0.005 0.02 23-Apr-14 436 3.04 16 413 0.005 0.02 13-May-14 440 2.39 13 451 0.002 0.01 28-May-14 430 2.97 15 439 0.002 0.01 11-Jun-14 377 2.73 12 389 0.003 0.01 23-Jul-14 318 2.28 9 332 0.003 0.01 13-Aug-14 240 1.97 6 250 0.002 0.01 28-Aug-14 323 2.47 10 338 0.005 0.02 10-Sep-14 385 3.53 16 376 0.005 0.02 24-Sep-14 332 4 30 17 339 0.004 0.02 09-Oct-14 293 2.12 7 286 0.011 0.04 12-Nov-14 252 3.89 12 234 0.003 0.04 1 26-Nov-14 92 2.68 3 95 0.004 0.00 09-Dec-14 78 2.40 2 73 0.007 0.01 23-Dec-14 97 2.61 3 95 0.005 0.01 14-Jan-15 303 4.79 17 280 0.010 0.03 29-Jan-15 333 3.79 15 404 0.032 0.16 11-Feb-15 341 2.43 10 341 0.013 0.05 25-Feb-15 331 4.36 17 310 0.038 0.14 11-Mar-15 506 3.78 23 477 0.012 0.07 24-Mar-15 274 1.76 6 255 0.003 0.01 13-Apr-15 323 3.63 14 291 0.011 0.04 22-Apr-15 165 2.81 6 152 0.007 0.01 12-May-15 300 4.95 18 292 0.016 0.06 27-May-15 411 4.88 24 392 0.013 0.06 09-Jun-15 432 3.09 16 425 0.011 0.06 23-Jun-15 373 6.00 27 367 0.008 0.04 07-Jul-15 464 4.39 24 459 0.010 0.06 22-Jul-15 370 3.60 16 353 0.013 0.06 11-Aug-15 348 2.33 10 327 0.014 0.05 11/4/2019 3 of 6 0 Dewberry Table 8 FGD Wastewater Treatment System Influent and Effluent Conditions Duke Energy Belews Creek EQ Tank Effluent Biological System Effluent r,ki4 Selenium Concentration a Selenium Concentration Selenium Reduction Forwarding Pump Rate in EQ Tank Effluent Selenium Mass Flow System Pump Rate in Biological Selenium Selenium Mass Flow (9P^r) (mglL) (Ibfday) (gpm) Reduction System (lb/day) Effluent(mg7L) 26-Aug-15 257 3.11 10 232 0.008 0.02 10-Sep-15 280 2.66 9 270 0.016 0.05 22-Sep-15 318 3.97 15 309 0.014 0.05 14-Oct-15 209 2.84 7 209 0.010 0.02 27-Oct-15 407 4.88 24 408 0.013 0.06 16-Nov-15 112 3.80 5 109 0.009 0.01 18-Nov-15 248 3.05 9 245 0 008 0.02 23-Nov-15 458 3.04 17 469 0.015 0.09 26-Nov-15 310 3.12 12 314 0.014 0.05 30-Nov-15 311 2.52 9 313 0.016 0.06 02-Dec-15 258 3.10 10 257 0.010 0.03 07-Dec-15 256 4.64 14 258 0 009 0.03 09-Dec-15 371 5.86 26 397 0.009 0.04 13-Dec-15 222 5.98 16 216 0.013 0.03 16-Dec-15 173 3.31 7 170 0.014 0.03 20-Dec-15 227 3.83 10 223 0.009 0.02 06-Jan-16 492 8.68 51 495 0.023 0.13 13-Jan-16 505 3.34 20 504 0.015 0.09 27-Jan-16 436 4.13 22 425 0.045 0.23 09-Feb-16 492 3.20 19 473 0 009 0.05 26-Feb-16 219 3.36 9 214 0.008 0.02 08-Mar-16 340 3 14 13 328 0 011 0.04 23-Mar-16 233 3.72 10 219 0.007 0.02 12-Apr-16 295 5.34 19 286 0.009 0.03 27-Apr-16 273 2.98 10 260 0.008 0.02 25-May-16 320 2.97 11 315 0.003 0.01 07-Jun-16 481 4 51 26 484 0.003 0.02 21-Jun-16 401 3.62 17 - 392 0.002 0.01 26-Jul-16 344 4 51 19 351 0.003 0.01 09-Aug-16 336 5.15 21 356 - 0.003 0.01 23-Aug-16 292 4.50 16 302 0.003 0.01 13-Sep-16 411 5.81 29 432 0.003 0.02 27-Sep-16 348 6.43 27 362 0.004 0.02 11-Oct-16 224 7.89 21 241 0.004 0.01 25-Oct-16 230 4.29 12 240 0.022 0.06 08-Nov-16 229 4.16 11 246 0.003 0.01 21-Nov-16 61 4.62 3 70 0.004 0.00 13-Dec-16 181 4.62 10 183 0.001 0.00 27-Dec-16 168 3.81 8 164 0.002 0.00 11-Jan-17 384 4.60 21 357 0.001 0.00 24-Jan-17 121 4.36 6 115 0.001 0.00 07-Feb-17 155 3.33 6 180 0.004 0.01 21-Feb-17 83 3.12 3 89 0.006 0.01 07-Mar-17 241 4.03 12 261 0.008 0.02 21-Mar-17 330 4.22 17 334 - 0.001 0.00 11/4/2019 4 of 6 ® Dewberry. Table 8 FGD Wastewater Treatment System Influent and Effluent Conditions Duke Energy Belews Creek EQ Tank Effluent Biological System Effluent a Selenium Concentration Selenium Reduction Selenium Concentration Forwarding Pump Rate Selenium Mass Flow In Biological Selenium Selett < ( in EQ Tank Effluent System Pump Rate 9 ,- 18pm) (mgll) (lb/day) Reduction System (lb/day) (9Pm) Effluent(mg/L) 11-Apr-17 358 -.03 22 381 0.007 0.03 25-Apr-17 176 4.80 10 188 0.001 0.00 09-May-17 248 3.73 11 254 0.001 0.00 23-May-17 290 4.61 16 291 0.001 0.00 13-Jun-17 381 4.05 19 389 0.002 0.01 27-Jun-17 399 4.32 21 408 0.001 0.00 11-Jul-17 442 4.94 26 453 0.003 0.01 25-Jul-17 304 410 15 309 0.002 0.01 09-Aug-17 323 3.49 14 339 0.003 0.01 22-Aug-17 387 5.59 26 414 0.002 0.01 17-Sep-17 173 3.90 8 190 0.001 0.00 29-Sep-17 131 5.52 9 143 0.002 0.00 11-Oct-17 185 4.66 10 201 0.002 0.01 22-Oct-17 72 3.51 3 71 0.001 0.00 20-Nov-17 214 4.81 12 219 0.002 0.01 12-Dec-17 158 4 96 9 177 0.001 0.00 29-Dec-17 189 4.04 9 212 0.001 0.00 09-Jan-18 447 3.57 19 487 0.002 0.01 23-Jan-18 317 2.15 8 _ 346 0.001 0.00 16-Feb-18 85 4.28 4 91 0.001 0.00 28-Feb-18 59 4.00 3 63 0.001 0.00 14-Mar-18 219 2.69 7 235 0.001 0.00 28-Mar-18 243 2.17 6 262 0.001 0.00 16-Apr-18 64 1.98 2 66 0.001 0.00 25-Apr-18 53 2.07 1 57 0.001 0.00 08-May-18 203 3.91 10 211 0.001 0.00 22-May-18 375 3.66 16 386 0.001 0.00 12-Jun-18 387 2.23 10 408 0.003 0.01 10-Jul-18 327 1.44 6 343 0.001 0.00 26-Jul-18 252 2.60 8 - 258 0.001 0.00 - 09-Aug-18 503 2.68 16 520 0.001 0.01 22-Aug-18 417 3.14 16 422 0.001 0.01 13-Sep-18 407 1.78 9 349 0.001 - 0.00 27-Sep-18 318 2.48 9 280 0.001 0.00 12-Oct-18 188 1.59 4 170 0.001 0.00 30-Oct-18 28 0.95 0 19 0.001 0.00 15-Nov-18 332 2.45 10 332 0.007 0.03 29-Nov-18 308 4.18 15 310 0.001 0.00 12-Dec-18 311 3.28 12 318 0.001 0.00 27-Dec-18 322 2.09 8 285 0.001 0.00 09-Jan-19 210 1.36 3 205 0.001 0.00 27-Jan-19 331 1.41 6 364 0.001 0.00 12-Feb-19 83 1.24 1 92 0.001 0.00 25-Feb-19 134 0.68 1 140 0.001 0.00 12-Mar-19 324 3.31 13 350 0.001 0.00 11/4/2019 5 of 6 Dewberry. Table 8 FGD Wastewater Treatment System Influent and Effluent Conditions Duke Energy Belews Creek EQ Tank Effluent Biological System Effluent Selenium Concentration ? Forwarding Pump Rate Selenium Concentration Selenium Mass Flow Selenium Reduction in Biological Selenium Selenium Mass Flow (gpm) in E0 Tank Effluent (lb/day) System Pump Rate Reduction System (lb/day) (mg/L) (gpm) Effluent(mg/L) 26-Mar-19 350 1.93 8 354 0.001 0.00 09-Apr-19 204 1.79 4 202 0.001 0.00 23-Apr-19 37 1.29 1 25 0.001 0.00 02-May-19 222 0.84 2 219 0.001 0.00 06-May-19 339 2.61 11 317 0.001 0.00 09-May-19 276 1.54 5 281 0.010 0.03 16-May-19 177 1.01 2 183 0.001 0.00 21-May-19 178 1.89 4 187 0.001 0.00 23-May-19 379 1.88 9 387 0.004 0.02 12-Jun-19 184 2.17 5 184 0.001 0.00 27-J u n-19 510 1.78 11 517 0.001 0.01 12-Jul-19 572 3.02 21 574 0.003 0.02 23-Jul-19 532 2.89 18 555 0.001 0.01 350 3.37 14 349 0.006 0.02 643 9.53 60 617 0.045 0.23 Notes. The influent flow rates in this table were recorded from the forwarding pumps and the effluent flow rates were recorded from the selenium reduction system pumps. Flow rates less than 10 gallons per minute(gpm)were converted to 0 gpm. The analytical concentrations in the FGD wastewater treatment system influent were collected from Duke's sample location ID:EQ TANK EFF. The analytical concentrations in the Biological System Effluent section of this table were collected from Duke's sample location ID:Bio Sys Elf. The selenium mass flow(pounds per day)was calculated by multiplying the pump flow rates and the selenium concentrations. Alstom System influent design criteria and performance guarantees from specification no.BCS-6202.04-00-0001 rev.05 02 June 2006. Influent conditions exceeding the Alstom system design criteria are highlighted in red. The influent design criteria for selenium mass flow(lb/di was calculated by multiplying the influent design criteria for the average flow and average selenium concentration. No exceedances of the Alstom system performance guarantee for effluent selenium concentration were observed in this dataset. -'indicates no historical data was provided for a particular parameter on a particular date. gpm indicates gallons per minute. mg/L indicates milligrams per liter. Ib/d indicates pounds per day. • 11/4/2019 6 of 6 0 Dewberry. Table 9 Comparison of FGD Wastewater Treatment System Average Loading Rates with Added FGD Leachate Stream Scenarios to Alstom System Design Criteria Duke Energy Belews Creek Flow Ig pin) Influent Selenium Concentration(mg/L) Influent Selenium Mass Flow(Ib/d) Historical Data from Historical FGD Wastewater System Historical Data from Historical FGD Wastewater System Historical Data from Historical FGD Wastewater System FGD W W Treatment System+FGD Influent Design EO Tank Effluent System+FGO Influent Design FGD W W Treatment System+FGD Influent Design Syste PuroPsarditog Landfill Leachate Criteria Sampling Location Landfill Leachate Criteria System Influent Landfill Leachate Criteria Average FGD Slowdown and Average FGD Landfill Leachate flows and selenium concentrations 350 390 600 3 4 3 2 4 14 15 29 Average FGD Slowdown flow and selenium concentration and FGD Landfill Leachate now from 25-year,24-hour storm and average selenium concentrations 350 688 600 3 4 2 6 4 14 22 29 Notes: The FGO wastewater treatment system influent lbw rates in this table were recorded horn the forwarding pumps The analytical concentrations in the FGD wastewater treatment system are from Duke's sample location ID EC/TANK EFF. FGD landfill leachale data from 2016 to 2018(so data punts total)provided by Duce.Average selenium concentration 1 24 mg/L and average flow rate 40 gpm FGD landfill leachate flow rate of 338 gpm horn 25-year,24-hour storm event provided by Duke. The selenium mass(pounds per day)was caleuated by multiplying the pump flow rates and the selenium concentrations. Wastewater System influent design criteria from Alstom specification no BCS-6202.04-00.0001 rev.05 02 June 2006 Influent conditions exceeding the Alstom system design criteria are highlighted in red. The influent design cntena for selenium mass flow(Ib/d)was calculated by multiplying the influent design criteria for the average flow and average selenium concentration gpm indicates gallons per minute. mg/L indicates milligrams per liter Ib/d indicates pounds per day. 11/42019 1 of 1 if Dewberry Table 10 Companson of Biological System Selenium Loading Rates to Literature Reference Values Duke Energy Belews Creek Selenium Loading Rate(mg/L/tar) 1111111„ (; Empty Bed Contact Time(hour) Historical 8iologtcal - Historical B a' •ical Data from Historical Biological - Histoncal Biological System«FGD Landfill Literature System.FGD s Literaturea,ce iU + • l System m System Landfill Biological System System Landfill to ` a Leachate+Craig's Road Reference Value Leachate«Cralg' rfulceY_. Influent leachate Landfill leachate Influent Leachate Landfill Lea 0.23 0.23 1 2 1.0 1 0 3.03 3 03 0.7 0.6 0.6 0.06 0.11 0.12 0.45 2.3 2.1 1.9 2-16 1 44 1.51 1 52 1.4 1.3 1 2 0.03 0.06 0.06 4.6 4.2 3.9 0.72 0.76 076 27 2.6 2.4 Notes Average selenium loading rates for the biological system calculated using average Row rate cacuated from the selenium reduction pump data and average selenium concentration from the biological system influent(2010-2019 data). Maximum selenium loading rates for the biological system calculated using maximum flow rate calculated horn the selenium reduction pump data and maximum selenium concentration from the biological system influent(2010.2019 data). Average selenium loading rates from the FGD and Craig's Road Landfill Leachates calculated using the average flow rates and average selenium concentrations. Maximum selenium loading rates from the FGD and Craig's Road Landfill Leachates calculated using the average flow rates and the maximum selenium concentrations. FGD landfill leachate data from 2016 to 2018(six data points total)provided by Duke Craig's Road landfill leachate data from 2016-2019(seven data points total)provided by Duke. This analysis assumes no selenium removal from the leachate streams in the physical chemical treatment process of the FGD wastewater treatment system Empty Bed Contact Time(EBCT)calculated assuming the empty bed volume is two-thirds of the tank volume. Average EBCT calculated using average flow rates horn the selenium reduction pumps and of the landfill leachate streams Maximum EBCT calculated using maximum flow rates from the selenium reduction pumps and the average flow rates from the landfill leachate streams Influent cond8ans outside the range of the recommendations found in the literature are highlighted in red Selenium loading rate literature reference value from DOt 10.1002Ak.10425. Empty Bed Contact Time(EBCT)literature reference value from DOI.10.2175/193864709793900654. mg/LAr indicates milligrams per liter per hour 11/4/2019 1 of 1 I)Dewberry I!) Dewberry- MEMORANDUM Date: July 11, 2019 To: Rick Harrison, Duke Energy From: Leigh-Ann Dudley, Dewberry Subject: Basis of Design for Landfill Leachate Treatment Evaluation Background Duke Energy (Duke) Belews Creek Steam Station (Belews Creek) currently generates leachate from two onsite landfills: the FGD Gypsum Landfill and the Craig's Road Fly Ash Landfill. These streams are discharged to a new lined retention pond. Recently, the retention pond effluent exceeded its permitted effluent concentration of 85 pg/L for selenium. Duke identified the leachate wastestreams as the source of the selenium and has initiated periodic pump and haul of the leachate streams to the existing onsite Flue- Gas Desulfurization (FGD)treatment system. At this time, Duke wishes to evaluate the potential to treat the leachate streams onsite using the existing treatment system. The FGD treatment system consists of equalization, a physical chemical treatment system with reaction tanks and solids contact clarifiers, followed by continuous backwash gravity filters. Following the physical/chemical system are heat exchangers and a two-stage biological selenium reduction system. Effluent from the biological system is discharged to an ultrafiltration system before being discharged to the lined retention pond. Solids from the physical/chemical system and solids wasted from the biological selenium system are wasted to a sludge holding tank which feeds plate-and-frame filter presses for solids dewatering. The process flow diagrams provided to Dewberry which include equipment sizing specifications are provided in Attachment A. The FGD system was designed to accept FGD blowdown alone; the design criteria did not include treatment of other onsite wastestreams. However, capacity exists within the FGD system, and Duke has retained Dewberry to evaluate the capacity of the existing FGD system to treat the additional hydraulic and constituent loads from the FGD Landfill leachate and the Craig's Road landfill leachate. We understand Duke is interested in considering the capacity of the treatment system for the following scenarios: • FGD blowdown + FGD Landfill leachate • FGD blowdown + FGD Landfill leachate+Craig's Road Landfill leachate For FGD blowdown, it is assumed this condition will be modeled as full baseline load with two coal units operational. This memorandum serves to document the basis of design for the capacity evaluation for the FGD treatment system with FGD Landfill Leachate. Depending on the findings of the FGD Landfill Leachate, Duke will consider extending the evaluation with Craig's Road Landfill Leachate. Memorandum I 1 of 6 * Dewberry MEMORANDUM Influent and Operational Basis of Design Duke provided the FGD system Design Data/Performance Guarantees document dated June 2, 2006 (Attachment B). This document included the design influent flow and contaminant loading conditions summarized in Table 1. Table 1. Influent Desi.n Criteria Summarized from Attachment B Parameter Units Design Operating Range Flow(Normal gpm 600 0—600 gpm Operation) Flow (48 hr Surge) gpm `615 (estimated) Total Suspended % 1.6 0.5—2.0 Solids Total Dissolved mg/L 25,000 0—35,000 Solids Chloride mg/L 12,000 0— 12,000 Temperature °F 124 115— 130 Nitrate m /L < 200 Selenium (Se) mg/L 2.44 4.0 4.0 Ammonium (NH4) mg/L <_ 14 <_ 14 14 Antimony (Sb) pg/L 20.0 20.0 30.0 Arsenic (As) pg/L 220 490 1,160 Barium (Ba) pg/L 7,330 7,330 1,6490 Beryllium (Be) pg/L 2.00 13.0 52.0 Cadmium (Cd) pg/L 70.0 100 180 Chromium (Cr) pg/L 70.0 360 930 Cobalt(Co) pg/L 420 420 530 Copper(Cu) pg/L 500 540 760 Fluorine (F) mg/L 39.5 39.5 53.7 Lead (Pb) pg/L 130 350 780 Manganese(Mn) pg/L 6,520 6,520 7,540 Mercury (Hg) pg/L 30.0 300 300 Molybdenum (Mo) pg/L 410 410 580 Nickel (Ni) pg/L 740 760 930 Silver(Ag) pg/L 60.0 60.0 70.0 Thallium (TI) pg/L 200 200 210 Vanadium (V) pg/L 190 560 1,410 Zinc (Zn) pg/L 340 900 1,760 *Duke expects the second purge line to have the same flow rate as the existing and directed Dewberry to change the flow from 720 to 615 gpm Dewberry understands that when each power generation unit is running, it generates approximately 300 gpm each of FGD blowdown wastewater. The blowdown, or purge, is sent to the FGD wastewater plant intermittently. Generally, there are 6 hours of purge and 4 hours off. This varies depending on how much power is being generated and the quality of the coal being used as the blowdown is controlled by the density of the scrubber water and chloride concentration. Dewberry assumes both leachate streams will be discharged into the filtrate sump. The filtrate sump also collects the backwash from the continuously backwashing gravity filters, ultrafilter backwash, strainer backwash, and filter press filtrate. We understand the flow rates for individual backwash and filtrate streams are not metered, but we assume they are captured in the flow data provided for the forwarding Memorandum 12 of 6 Dewberry- MEMORANDUM pumps. Dewberry will consider the hydraulic capacity of the filtrate sump and filtrate sump pumps in the evaluation. We understand the EQ tanks have a minimum operating level of 10 feet due to the configuration of the tank mixer. Under normal operating conditions the EQ Tank and Maintenance Tank are both used as EQ tanks and are operated in parallel. Operators try to maintain the level in these tanks below 26 feet. When the tank levels exceed 26 feet, the operators minimize flow into the tanks by stopping processes that generate recycle streams such as filter press filtrate. The tanks overflow to the filtrate sump at a water level of 36 feet. When less wastewater is generated overnight or when operators anticipate a plant shut down, wastewater is accumulated in the EQ tanks in order to maintain wastewater to feed the treatment system. Dewberry will consider the hydraulic capacity of the EQ tanks in the evaluation. Dewberry understands typically one solids contact clarifier is operated at a time and each clarifier is intended to be 100% redundant. Dewberry understands the preference is to maintain 100% redundancy in the solids contact clarifiers. Dewberry understands from the June 21, 2019 site visit that the heat exchangers are currently a limiting factor. There are two heat exchangers. Each heat exchanger is designed for 600 gpm, however, when Duke operates close to 600 gpm the heat exchanger performance quickly declines with respect to flow and heat capacity due to the suspended solids present in the FGD blowdown. Dewberry understands that since Duke initiated pump and haul operations of the FGD landfill leachate, the leachate provides some cooling and at times has been sufficient to reduce the combined water temperature below the ABMetTM target operating temperature of 95°F, in which case Duke can bypass the heat exchangers. Dewberry will consider the hydraulic capacity of the heat exchangers in the capacity evaluation. Dewberry expects the leachate to have a positive impact on influent temperature,which has been observed during the leachate pump and haul, and therefore will not model temperature for the combined discharges. The first and second-stage selenium reduction systems each contain eight trains. Dewberry will evaluate the hydraulic capacity of the selenium reduction system and will evaluate constituent loading capacity with specific focus on selenium and nitrate. Dewberry understands the ultrafilter system has four ultrafilter banks. The ultrafilters operate in a rotation with three in service and one in backwash cycle. A filter runs for 15 minutes and then the backwash cycle is five minutes. Backwash flow is 600—750 gpm for one minute of the five minute backwash cycle. The operational flow rates to be used as the basis for the hydraulic capacity analysis for the ultrafilters are included in Attachment D. Dewberry understands the filter presses represent a solids and hydraulic limitation. Currently, Duke does not condition solids and indicated solids settle and dewater well. Operators indicated when both power generation units are running, they are near capacity with the four filter presses. Sources of solids include the solids in the FGD wastewater and solids generated by the precipitation and biological process. Higher than typical solids concentrations in the FGD wastewater cause capacity limitations in the filter presses. Dewberry will evaluate the hydraulic capacity of the presses, but will focus on the additional solids loading on the treatment system provided by the additional treatment of the FGD landfill leachate. FGD Blowdown Basis of Design Duke provided FGD blowdown data from 1/11/2017—5/6/2019. Dewberry analyzed the data for periods when two coal units were operational. Table 2 summarizes the FGD blowdown data during periods when two coal units were operational and that will be used for the baseline influent for the capacity evaluation. Memorandum 13 of 6 ligf Dewberry MEMORANDUM Table 2. Historical FGD Blowdown with Two Coal Units 0.erational Parameter Units FGD Blowdown Avera•e Maximum Flow gpd 417,792 561,805 Arsenic mg/I 0.63 1.30 Mercury pg/I 269 426 Nitrate/Nitrite mg/I 24 45 Total Suspended Solids mg/I No Data No Data Selenium (dissolved) pg/I 322 784 Selenium (total) pg/I 4,139 6,070 Methylseleninic acid pg/I 6.7 17 Selenite (IV) pg/I 362 2,000 Selenium (unknown speciation) pg/I 8.8 67 Selenate (VI) pg/I 85 157 Selenocyanate pg/I 4.7 36 Selenomethionine pg/I 3.4 3.5 Chloride mg/I 9,576 15,770 Sulfate mg/I 1,359 1,610 Boron mg/I 279 416 Cadmium mg/I 0.01 0.02 Chromium mg/I 0.56 0.92 Copper mg/I 0.39 0.57 Nickel mg/I 0.51 1.1 Zinc mg/I 0.77 1.2 Bromine mg/I 128 196 Total Dissolved Solids mg/I 24.290 39,000 Leachate Basis of Design Duke provided constituent data for the FGD Gypsum Landfill leachate and Craig's Road Landfill leachate. For The FGD Gypsum Landfill, Duke provided semiannual data from 2016-2018, six data points in total. For the Craig's Road Landfill leachate, Duke provided semiannual data from 2016—2019, totaling seven data points. Table 3 summarizes the average and maximum flow and constituent data for each landfill leachate. The average flow data were provided by Duke during proposal development. For the capacity evaluation, Dewberry will evaluate the capacity based on average flow with maximum concentration. From communications with Duke, Dewberry understands the FGD Landfill Leachate can have a maximum instantaneous flow of 120 gpm. Memorandum 14 of 6 :Ii'fie . Dewberry MEMORANDUM Table 3. Landfill Leachate Data Parameter Units FGD Landfill Leachate Craig's Road Landfill Leachate Average Maximum Avera•e Maximum Flow gpm 40 Not Provided 30 Not Provided pH s.u. 6.58 6.85 5.11 7.55 Total Dissolved Solids mg/I 2,104 2,660 2,960 3,940 Nitrate mg/I 0.813 1.12 25.1 39.2 Chloride mg/I 71.1 104 344 562 Sulfate mg/I 1,588 1,730 1,815 2,410 Fluoride mg/I 1.55 2.57 <2.00 <2.50 Arsenic pg/I <1.25 <5.0 25 46 Barium pg/I 18 23 29 39 Cadmium pg/I <1.25 <5.00 3.49 5.74 Chromium pg/I <2.50 <2.50 <2.50 <2.50 Copper pg/I <2.50 <2.50 3.12 6.85 Iron mg/I No Data 0.441 1.820 Lead pg/I <1.25 <5.00 5.2 7.8 Nickel pg/I <2.50 <2.50 90 156 Selenium mg/I 1.74 2.25 0.089 0.118 Mercury pg/I <0.03 <0.03 <0.03 0.06 Effluent Basis of Design Dewberry understands the FGD treatment system effluent measured at the ultrafilter effluent is subject to NPDES limits as Outfall 002 in NC0024406 (Attachment C). Table 4 summarizes the effluent limits and the effluent performance guarantees provided by the vendor for the FGD treatment system. Table 4. Effluent Limit and Effluent Performance Guarantees b Alstom NC0024406 Outfall 002 FGD Treatment System NC0024406 Limit Effluent Performance Parameter Units Outfall 002 Guarantee Sampling Monthly Daily Normal Surge Frequency Average Maximum Operating Operating Conditions Conditions Flow gpm Daily Monitor and Report 600 720 Total Arsenic pg/L Quarterly 8.0 11 Not included Total Mercury ng/L Quarterly 356 788 1,000 Total Selenium pg/L Quarterly 12 23 100 Nitrate/nitrite as N mg/L Quarterly 4.4 17 Not included Oil and Grease mg/L Quarterly 15 20 Not included Total Suspended mg/L Quarterly 30 50 50 100 Solids Chloride' mg/L Not included in permit 12,000 14,000 pH S.U. Not included in permit 5.3-9.0 __ Memorandum 15 of 6 IN Dewberry. MEMORANDUM ' Dewberry understands the chloride effluent performance guarantee was based on meeting a maximum chloride concentration for discharge to the wetlands. Since the wetlands are no longer in service and there is not an Outfall 002 chloride limit, chloride will not be considered further in our capacity evaluation. As part of the study, Dewberry will evaluate if the effluent from the FGD treatment system will be subject to the same Outfall 002 limits if leachate is treated through the FGD treatment system. Dewberry anticipates using the ELG's Combined Waste Stream formula for determining discharge limits. Attachments: Attachment A: Process Flow Diagrams Attachment B: Design Data/Performance Guarantees dated June 2, 2006 Attachment C: Outfall 002 Limits extracted from NC0024406 dated March 25, 2019 Attachment D: M7 Operating Conditions at Maximum and Minimum Treatment Rates CC: Name I Organization Derek Henderson Duke Energy Travis Thornton Duke Energy Ed Byers Duke Energy Ryan Ames Dewberry Katie Jones Dewberry Memorandum 16 of 6 I I I w I o I I I D. Is, I`, I E 5 §5 74 4g 1111 g f E VS 9 N _1 LI IMP,— urAirIL g]as Aa lIEE r 30 i !E �g oAp ee>>>° € �!� eddoa° ! a I q E6,1°.1i I a ti i6� 1 t ® il< e� I E — /1-8—T1 01.6 11 id i I 4s L:r� -+- }mot A ! ,I 0 B �,6aij 61 ii t ' 6k ll • ii — ��U _ iiil . - ......... . ill . I • FF66 I 14 N h€ 4, N 1 1 1 1 - ...ma gam ars ' I j� F 1 1 ' 1 1 1 m 1 ` 1 I 2 I 3 I 4 I 3 I 6 I 7 I 8 I 9 I 10 I Il 'DWG NO.57001271-PRO-A02-02 IT H H G G — F • Am 1 F 1 worm 8 -- 1 (1�A TT' 4 4 / E I7 ')---.,1 nY0 4.' I ® efl I e I e . 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I 9 1 10 I 11 1 I 2 I 3 I 4 I 5 I 6 I 7 I 8 I 9 I 10 I 11 !DWG NO.57001271-PRO-A02-03 I i N N la. / .....p G G now E E I14.4 .. > i IT p CK j 1 ) "L'.'s l'a."5.24.... > - • am 6, nA.afErtea. woman QesilsVr C C • B agirtIrr r c-.�rtria mra B 1 ALSTOM 4.,... 8 ��.aEo4Cf"9 c. - .iall g ..Rs� A ,k, Rao CO LS ovum Ra.sas.R.....R ti Biwa WV. asses..�s a .sw PROCESS MOW A _ _ minis ERNn6 MPs so_ . { �III......... � REVISIDRS s * ls~t 1I�3�271-PRO-A02-03 I1 1 2 ( 3 I 4 I 5 I 6 7 I B I 9 c.eerR I r 10 I 11 , a I I 1 I I AtbaFFnertf A ' 1, ID It5 Process Flow Diagram and Mass Balance 1 ................ moose.owwcawaw.sa. em.w eas....•.ma m.wee •111.111.1.11.4.1 — Mal ra.•••73 11•4•91 c....,,••••,..,.....,,................,..• 0... - l•um...a. R.. 04,13/141 r ,; _i ...,-_ .......,...,;:, .............—.. .......... ,--1,- ---, .o.....; .... , , ....,..,„,...1 ... .. : i I No..... 1 H,'' 1 • P..ma.ow.. ,_... ,.......yr,i ....... SwaY,.. 2........ .6.133. 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' . it gm In.. :.I., :al. .... ,`,•,•.. —. .-..., --.• we aor•se•ft• es.•••• we woe wc=os"::==:..7::::::::=====4T,T.:=MY=Z.T.1‘..... cm..own,.160.1.6.1643610.1101.10041EAM 10 1m• .1.Me reecurk416,1.DECaue TO 01 I,1.,,,. , now..•.Mauna mope A...To PUT 11.Si.l.on 610 oi,...•nd remm map.uerr 40.alto mom..Kt 31 , Pill.ei Mama So..not 8...11. , .101.0.111..3 Con.e..I.0 Wuemohrrmasera UwaRirm.smat A Con.o11.6•MO 1 1— , 1 —--.............."..........M.'L'''' '''.MS PROCESS FL.PAGRAM AND W.BAUNCE- —-—— 47,....I.Ii...V41.7.7,=.1.4 aft sem 1 ,to.o.,mn.oars..=a.r. 1-- ,,,,. .,,,, ., E!:"...+41•Zia1/4...iarill°':"7: ''.0;so V•001....10,.....00.1 DEZ•ti.aFir...,F.:=L: -,-- Attachment B WASTEWATER TREATMENT SPECIFICATION NO.: AL ST 5 M■'■ SYSTEM REV 0502.04-00-0001 DATE: 02 JUNE 2006 PAGE 28 OF 60 ATTACHMENT A: DESIGN DATA / PERFORMANCE GUARANTEES Application Data: Service FGD System Purge Stream Quantity of Systems Required One(1) System Operating Frequency Continuous or Intermittent System Location Indoors/Outdoors (Building by Supplier) FGD System Purge Stream: Stream Characteristic Units Design Amount Operation Notes Range Influent(Maximum under gpm 600 0—600 NORMAL operation) Event duration is 48 hours. For Influent (Maximum under 720 design purposes, SURGE condition) gpm (estimated) assume this event only occurs once every three years. Influent (NORMAL lb./hr. 307,459 0—307,459 operation) Water wt% 98.4 98.0—99.5 Total Suspended Solids wt% 1.6 0.5—2.0 Total Dissolved Solids mg/I 25,000 0—35,000 Stream Specific Gravity - 1.028 1.020—1.050 Solids Specific Gravity - 2.4 2.2—2.5 pH - 5.6 5-7 Temperature °F 124 115— 130 Oil and Grease mg/I < 1.0 < 1.0 Nitrate mg/I 200 max. Expected FGD Purge Stream Suspended Solids Composition: \\Nt000101\Fgdshared\TS&C Central Engineering\Programs\Wastewater Treatment\Belews Creek\Drawings And Manuals\BCSS VWVT Technical Specification.Docx I Attachment B WASTEWATER TREATMENT SPECIFICATION NO.: Al L STO)11 SYSTEM BCS-6202.04-00-0001 REV. 05 DATE: 02 JUNE 2006 PAGE 29 OF 60 ATTACHMENT A: DESIGN DATA / PERFORMANCE GUARANTEES Constituent Units Design Amount Operation Notes (Normal Operation) Range CaSO4•2H20 wt% 49.70 30-55 CaSO3• Y2H20 wt% 0.19 0— 1 CaCO3 wt% 4.04 0- 10 CaF2 wt % 0.42 0-2 Flyash wt% 6.82 0— 15 Inerts wt% 38.7 0—55 FGD Purge Stream Dissolved Solids Composition: Constituent Units Design Amount Operation Notes (Normal Operation) Range Chloride(aq), Maximum under NORMAL Operation mg/I 12,000 0— 12,000 Event duration is 48 Chloride(aq), Maximum 14,000 hours. For design under SURGE Conditions mg/I estimated purposes, assume this event only occurs once every three years. Dibasic Acid (DBA) Range conditions could Mixture (aq) mg/I 0 0— 1,000 occur several times per year for several days Predicted Particle Size Distribution of FGD Purge Stream Solids: wt% Size (microns) Notes 100% less than 10 94% less than 5 27% less than 1 Typical Organic Acid Mixture to the FGD System: Constituent Units Amount Operation Notes Range Succinic Acid wt% 18—28 Glutaric Acid wt% 51 —61 Adipic Acid wt% 15—25 Typical Design and Maximum of Dissolved Constituents in FGD Wastewater Before Solids Removal: \\Nt000101\Fgdshared\TS&C Central Engineering\Programs\Wastewater Treatment\Belews Creek\Drawings And Manuals\BCSS VVV T Technical Specification.Docx Attachment B WASTEWATER TREATMENT SPECIFICATION NO.: AL STO M SYSTEM REV 0502.04-00-0001 DATE: 02 JUNE 2006 PAGE 30 OF 60 ATTACHMENT A: DESIGN DATA / PERFORMANCE GUARANTEES Elements in Minimum Estimated Average Estimated Maximum Estimated Wastewater Concentration in Concentration in Concentration in Wastewater Wastewater Wastewater (PPm) (PPm) (PPm) Ammonium (NH4) <_ 14 5 14 14 Antimony(Sb) 0.02 0.02 0.03 Arsenic(As) 0.22 0.49 1.16 Barium (Ba) 7.33 7.33 16.49 Beryllium (Be) 0.002 0.013 0.052 Cadmium (Cd) 0.07 0.10 0.18 Chromium (Cr) 0.07 0.36 0.93 Cobalt (Co) 0.42 0.42 0.53 Copper(Cu) 0.50 0.54 0.76 Fluorine(F) 39.5 39.5 53.7 Lead (Pb) 0.13 0.35 0.78 Manganese (Mn) 6.52 6.52 7.54 Mercury (Hg) 0.03 0.30 0.30 Molybdenum (Mo) 0.41 0.41 0.58 Nickel (Ni) 0.74 0.76 0.93 Selenium (Se) 2.44 4.00 4.00 Silver(Ag) 0.06 0.06 0.07 Thallium (TI) 0.20 0.20 0.21 Vanadium (V) 0.19 0.56 1.41 Zinc(Zn) 0.34 0.90 1.76 \\Nt000101\Fgdshared\TS&C Central Engineering\Programs\Wastewater Treatment\Belews Creek\Drawings And Manuals\BCSS WVVT Technical Specification.Docx Attachment B WASTEWATER TREATMENT SPECIFICATION NO.: A L ST�, "M SYSTEM BCS-6202.04-00-0001 REV. 05 DATE: 02 JUNE 2006 PAGE 31 OF 60 Performance Guarantees for Wastewater Treatment System: Description Quantity Units Test Method Notes pH (Effluent) 5.3—9.0 EPA 150.1 Inlet to Wetlands Supply Tank (Prior to Dilution) TSS (Effluent) 50 max mg/I EPA 160.3 NORMAL Operation Inlet to Wetlands Supply Tank (Prior to Dilution) TSS (Effluent) 100 max mg/I EPA 160.3 For SURGE Condition Only Inlet to Wetlands Supply Tank (Prior to Dilution) Chloride(Effluent) 12,000 max mg/I EPA 300.0 Inlet to Wetlands Normal Supply Tank 14,000 max (Prior to Dilution) Surge Selenium (Se) 0.10 mg/I EPA 200.8— Inlet to Wetlands ICP/MS; Supply Tank Detection Limit (Prior to Dilution) 1.2 ppb EPA 200.7— ICP; Detection Limit 36 ppb Mercury (Hg) 0.001 mg/I EPA 245.1 — Inlet to Wetlands Graphite Supply Tank Furnace/AA; (Prior to Dilution) Detection Limit 0.07 ppb Maximum sound pressure 85 dB(A) level (ref. 0.0002 microbar) at three (3)feet from all equipment provided based on a free field condition Availability 100 NOTE: Final diluted stream to the wetlands shall be at maximum temperature of 108°F or less. Dilution water (max 1,200 gpm available) at a temperature range of 35 - 92°F may be used to dilute chloride concentration of the 600 gpm of wastewater treatment system effluent from a concentration range of 0 - 12,000 ppm to a final value for delivery to the wetlands of 4,000 ppm. Any additional cooling beyond that flow which is required for dilution of chlorides shall be accomplished without increasing total wastewater flow to the wetlands. A minimum dilution flow of 300 gpm may be assumed based on 600 gpm purge flow, for a total flow to the wetlands of 900 gpm. \\Nt000101\Fgdshared\TS&C Central Engineering\Programs\Wastewater Treatment\Belews Creek\Drawings And Manuals\BCSS VWVr Technical Specification.Docx Attachment C Extracted from NC0024406 Dated March 15,2019 Permit NC0024406 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Internal Outfall 002) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Internal Outfall 002 (treated FGD wet scrubber wastewater to ash settling basin). Such discharges shall be limited and monitored' by the Permittee as specified below: PARAMETER LIMITS MONITORING REQUIREMENTS Monthly Daily Measurement Sample Type Sample Location Average Maximum Frequency Flow,MGD Weekly Pump Logs or similar Effluent readings Total Arsenic 8.0 pg1L2 11.0 pg/L2 Quarterly Grab Effluent Total Mercury3 356.0 ng/L2 788.0 ng/L2 , Quarterly Grab Effluent Total Selenium 12.0 pglL2 23.0 pg/L2 Quarterly Grab Effluent Nitrate/nitrite as N 4.4 mg/L2 . 17.0 mg1L2 Quarterly Grab Effluent Oil and Grease 15.0 mg1L 20.0 mglL Quarterly Grab Effluent Total Suspended Solids 30.0 mg/L 50.0 mg/L Quarterly Grab Effluent Notes: 1. Please See Special Condition A. (23.). 2. In accord with the Steam Electric Effluent Limitations Guidelines for FGD wastewater (40 C.F.R. 423), these limits shall become effective on November 1, 2020. This permit may be reopened and modified if changes are made to 40 C.F.R. 423. 3. The facility shall use EPA method 1631E. All flows shall be reported on monthly DMRs, should no flow occur during a given month, the words "No Flow" shall be clearly written on the front of the DMR. All samples shall be of a representative discharge. Page 5 of 23 Attachment D M7 Operating Conditions at Maximum and Minimum Treatment Rates Project Name:Belews Creek Steam Station Evoqua Project No.:2034-000768 BMcD Project#88673 Contract Name:fet Wastewater Treatment Uitrafiltration System Contract No:5.3210 8nvn Belews Creek Steam Station Customer Parameter Sheet Revision 3 Plant Capacity Operation Maximum Operation Normal Operation Occasional Operation System Type 4 X CPII MR1,30(L4ON) 4 X CPII MR1,30(L4ON) 3 X CPII MR1,30(L4ON) Design Capacity(MGD) 0.92 MGD 0.58 MGD 0.58 MGD Unit Operation N+2 w/CR N+2 N+2 w/CR Filtrate Flow Maximum Inst Design Flow Design Capacity Setpoint per Unit(gpm) 331 gpm 242 gpm 413 gpm Minimum Inst Design Flow Setpoint per Unit(gpm) 232 gpm 170 gpm 289 gpm Feed Water Requirements Operating pH Range 6 to 9 Operating Temperature Range 15.6-35 deg C/60-95 deg F Badcwash Backwash Interval(min) 20 min Backwash Duration(min) 2.08 min TMP increase during filtration cycle to backwash 1 psi Resistance increase during filtration cycle to backwash 0.5 Aeration Air Flow(SCFM/module) 5.9 SCFM/module Total Aeration Air Flow(SCFM) 177 SCFM Aeration,ADBW and Sweeping Flow(gpm) 396 gpm Sweeping with Aeration Flow(gpm) 396 gpm Sweeping Flow(gpm) 726 gpm Lumen Fill Flow(gpm) 396 gpm Waste Volume per Backwash(gal) 853 gallons Air Hold Test(AHT) AHT Interval(hrs) 24 hours AHT Duration(min) 15 min AHT Regulator Setpoint(psi) 15 psi Integrity System Volume(gal) 114 gallons General Clean in Place(CIP) CIP Interval 21 operational days per unit,not to exceed 42 calendar days CIP Regime Order Acid followed by Chlorine Chemical Cleaning Volume(gal) 741 gallons CIP Recirculation Flow(gpm/module) 13.2 gpm/module CIP Recirculation Flow(gpm) 396 gpm Each CIP or MW Waste Volume(gal) 3587 gallons Acid Clean In Place(A-CIP) Acid CIP-Tank Solution Temperature 30°C Acid CIP Duration(min) 180 min 50%Citric Acid bulk dosed to 1%cleaning solution+31.45%Hydrochloric Acid bulk dosed to 0.06% Acid CIP Solution Cleaning Concentration cleaning solution(pH of 2.0) Estimated Acid Chemical Volume Required(gal) 12.04 gallons-50%Citric Acid+1.22 gallons-31.45%Hydrochloric Acid,dosed to pH of 2.0 Chlorine Clean In Place(C-CIP) Chlorine CIP-Tank Solution Temperature 20'C Chlorine CIP Duration(min) 180 min Chlorine CIP Solution Cleaning Concentration 12.5%Sodium Hypochlorite bulk dosed to 500 ppm,350 ppm free chlorine Estimated Chlorine Chemical Volume Required(gal) 2.48 gallons-12.5%Sodium Hypochlorite Acid Maintenance Wash(A-MW) Interval and Temperature 48 operational hours,not to exceed 96 calendar hours,ambient temperature Acid MW Duration(min) 45 min Acid MW Solution Cleaning Concentration 31.45%Hydrochloric Acid bulk dosed to 0.06%cleaning solution(pH of 2.2) Estimated Acid Chemical Volume Required(gal) 1.22 gallons-31.45%Hydrochloric Acid Chlorine Maintenance Wash(C-MW) Interval and Temperature 48 operational hours,not to exceed 96 calendar hours,ambient temperature Chlorine MW Duration(min) 45 min Chlorine MW Solution Cleaning Concentration 12.5%Sodium Hypochlorite bulk dosed to 100 ppm,70 ppm free chlorine Estimated Chlorine Chemical Volume Required(gal) 0.5 gallons-12.5%Sodium Hypochlorite Notes Operational time includes all time except time spent in standby,shutdown,waiting or CIP Halt. *Occasional operation should only be used when CIPs,MWs or maintenance events are performed. ROY COOPER ,{; Governor01 MICHAEL S.REGAN �� �, Secretary S.DANIEL SMITH NORTH CAROLINA Director Environmental Quality June 18, 2020 Mr. Michael Lanning, General Manager III - Regulated Stations Belews Creek Steam Station Duke Energy Carolinas, LLC 3195 Pine Hall Road Belews Creek,North Carolina 27009 SUBJECT: Wastewater Pump&Haul Permit Application Belews Creek Steam Station Stokes County Permit No. WQ0041747 Dear Mr. Lanning: In accordance with your permit application received June 15, 2020, we are forwarding herewith Permit No. WQ0041747,dated June 18,2020,to Duke Energy Carolinas LLC for the time-limited operation of a domestic wastewater pump and haul operation.This permit shall become effective August 18, 2020 and will expire on February 14, 2021; shall void previously issued Permit No.WQ0041493 which will expire on August 17,2020; and shall be subject to the conditions and limitations as specified therein. This cover letter shall be considered a part of this permit and is therefore incorporated therein by reference. Please pay particular attention to Permit Condition 13,which requires accurate record keeping and reporting. Also note Permit Condition 18, which requires that the facilities associated with the pump and haul activities be inspected and pumped as often as necessary to prevent any malfunctions, overflows, or nuisances. Permission is hereby granted to Duke Energy Carolinas, LLC for the operation of: • A domestic wastewater pump and haul operation for the sanitary lagoon located at the Belews Creek Steam to allow for design and construction of upgrades to the system. The upgrade will be mechanical filtration. The sanitary lagoon will be permitted as a new internal outfall in the NPDES permit. • The anticipated flow for this pump and haul operation is greater than 10,000 gallons per day gallons per day of domestic wastewater generated in the station administration building. D �4 North Winston CarolinaSalem DepartmentRegionalOffi of Environmental Quality I Division of Water Resources ce 450 West Hanes Mill Road,Suite 300 I Winston Salem.North Carolina 27105 336.776.9800 • Please notify this office when the modification of the septic system is complete and the pump and haul operation is no longer necessary. The wastewater collected by this system shall be pumped by Shamrock Environmental Corporation for treatment or discharge into the City of Eden, Mebane Bridge Wastewater Treatment Plant(WWTP)for final treatment. This permit shall become voidable unless the agreements between Shamrock Environmental Corporation, Duke Energy Carolinas, LLC, and the City of Eden, Mebane Bridge WWTP for the pumping, hauling and/or final treatment of wastewater are in full force and effect. If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request must be in the form of a written petition, conforming to Chapter 150B of North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding. If you have any questions regarding this permit or require any additional information, please contact Jim Gonsiewski or me by phone at(336) 776-9800. Sincerely, r—DocuSigned by: mgcr "—145B49E225C94EA... for S. Daniel Smith, Director Division of Water Resources by Lon T. Snider Regional Supervisor, Water Quality Regional Operations Division of Water Resources cc: Joyce Dishmon—Duke Energy (Electronic Copy) Stokes County Health Department(Electronic Copy) WSRO Electronic Files Laserfiche Files NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY DOMESTIC WASTEWATER PUMP& HAUL PERMIT PERMIT No. WQ0041747 This permit shall be effective August 18, 2020, will expire on February 14, 2021, and shall be subject to the following specified conditions and limitations: 1. This permit shall become voidable unless the subject pump and haul activities are carried out in a manner that has been approved by this Division. 2. This permit is effective only with respect to the nature and volume of wastes described in the application dated June 10, 2020 and other supporting data. 3. The facilities shall be properly maintained and operated at all times. 4. This permit is NOT transferable. In the event that there is a desire for the facilities to change ownership, or there is a name change of the Permittee, a formal request must be submitted to the Division. 5. No type,kind or quantity of wastewater other than the pumped and hauled wastewater from Duke Energy Carolinas,LLC shall be included in these pump and haul activities. 6. This permit shall become voidable unless the agreements between Shamrock Environmental Corporation, Duke Energy Carolinas, LLC, and the City of Eden, Mebane Bridge WWTP for the pumping,hauling and/or final treatment of wastewater are in full force and effect. 7. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, Duke Energy Carolinas, LLC shall cease operation of all pump and haul activities and take such immediate corrective actions as may be required by this Division. 8. The wastewater collected by this system shall be properly treated in the Shamrock Environmental Corporation treatment facility, Permit Number NCS-00790 or in the City of Eden, Mebane Bridge WWTP (NC0025071) for final treatment and disposal. 9. Duke Energy Carolinas, LLC is liable for any damages caused by a spill or failure of the pump and haul operations. 10. Adequate inspection, maintenance, and cleaning shall be provided by Duke Energy Carolinas, LLC to ensure proper operation of the subject facilities. 11. Duke Energy Carolinas, LLC or its designee, shall inspect the pump and haul collection facilities to prevent malfunctions and deterioration, operator errors, and discharges that may cause or lead to the release of wastes to the environment,a threat to human health, or a nuisance. 12. Any duly authorized officer, employee, or representative of the Division of Water Resources may, upon presentation of credentials, enter and inspect any property, premises, or place on or related to the pump and haul collection facilities at any reasonable time for the purpose of determining compliance with the Division's approval; may inspect or copy any records that must be maintained under the terms and conditions of this permit; and may obtain samples. 13. An accurate record of the pump and haul activities must be maintained by Duke Energy Carolinas, LLC indicating: • Date and times wastewater is removed from the facility • Name of contract hauler • Name of facility receiving wastewater • Volume of wastewater removed • An inspection log including the date and time of inspections,observations made, and any maintenance,repairs, or corrective actions taken by the Permittee. These records shall be submitted quarterly by the following Wednesday to the Water Quality Regional Operations Supervisor,at address 450 West Hanes Mill Road, Suite 300,Winston- Salem,NC 27105 14. Failure to abide by the conditions and limitations contained in this permit may subject Duke Energy Carolinas, LLC to appropriate enforcement actions available to the Division. 15. The granting of this permit does not preclude Duke Energy Carolinas, LLC from complying with any and all statutes, rules, regulations, or ordinances, which may be imposed by other government agencies (local, state, and federal), which have jurisdiction. 16. Noncompliance Notification: Duke Energy Carolinas, LLC shall report by telephone to the Winston-Salem Regional Office, telephone no. (336) 776-9800, as soon as possible, but in no case more than twenty-four (24) hours or on the next working day following the occurrence or first knowledge of the occurrence of any of the following: a. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate wastewater storage and/or treatment such as failures of tanks, piping, pumps, etc. b. Any failure of a pumping station, sewer line,etc., resulting in a spill or by-pass directly to receiving waters without treatment of all or any portion of the influent to such station or facility. 17. Persons reporting such occurrences by telephone shall also file a written report in letter form within five(5)business days following first knowledge of the occurrence. This report must outline the actions taken or proposed to be taken to ensure that the problem does not recur. 18. The facilities associated with the pump and haul activities shall be inspected and pumped as often as necessary to prevent malfunctions, overflows, or nuisances. 19. Should ownership or financial circumstances change during this permit, immediate notification should be made to the regional office. 20. When these pump and haul activities are no longer necessary, please send written notification to: Water Quality Regional Supervisor Winston-Salem Regional Office NCDEQ-DWR 450 W. Hanes Mill Rd, Suite 300 Winston-Salem,NC 27105 21. Sixty (60) days prior to the expiration of this permit (i.e. December 16, 2020), a status report of the permanent wastewater treatment system shall be submitted to the Winston-Salem Regional Office. This report shall include: i.Anticipated flows; and ii.Proposed start-up date; or iii.Other alternatives being considered for permanent or temporary treatment of wastewater. Permit issued this the 18th day of June 2020,with a Permit Effective date of August 18, 2020. EDocuSign.d by: L-ox. SAiate 145849E225C94EA... for S. Daniel Smith, Director Division of Water Resources by Lon T. Snider Regional Supervisor, Water Quality Regional Operations Division of Water Resources DUKE Belews Creek Steam Station je ENERGY, Duke Energy Carolinas 3195 Pine Nall Road Belews Creek,NC 27009 August 20, 2019 Mr. Lon Snider NC DWR 450 West Hanes Mill Road, Suite 300 Winston-Salem, NC 27415 Subject: Duke Energy Belews Creek Steam Station Pump and Haul Permit Application Stokes County Dear Mr. Snider: Pursuant to 15A NCAC 02T 0.0204 Duke Energy Carolinas LLC (Duke Energy) is requesting a permit to pump and haul domestic wastewater from Belews Creek Steam Station to Shamrock Environmental to allow Duke Energy additional time to complete design and installation of upgrade to our sanitary lagoon. The request is for one year. The submittal package includes the following: I. Pump and Haul Application P&H 1-16 2. Letter and permit from Shamrock Environmental 3. Check for permitting fee -$1310.00 Belews Creek began evaluating the sanitary lagoon treatment system in preparation for the issuance of the new NPDES permit. The new permit included an internal outfall 009 for this system. The evaluation revealed concerns with meeting BOD and TSS permit limits. NC DEQ provided Pump and Haul Permit#WQ0040669. Hazen and Sawyer, Hazen, was contracted to evaluate treatment options for the sanitary lagoon treatment system to reduce BOD and TSS. It was determined that algae growth in the lagoon and chlorination of the algae is affecting both the BOD and TSS. Hazen evaluated the use of bag and cartridge filters using various micron filters to remove the algae. It has been determined that cartridge filters would remove the algae but at a reduced flow rate and cost. Hazen presented their findings to Belews Creek on June 17,2019. Their recommendation included evaluation of sand filters as a treatment option. Belews Creek requested that Hazen also evaluate additional alternative treatment options to include installation of a septic and spray irrigation system. Hazen advised that the evaluations requested would take until September 2019 to complete. Upon completion of evaluation of treatment options Duke Energy will require the additional time for potential permitting,design,and installation. Thus, Duke Energy has requested a permit duration of one year for this permit. Should you have any questions regarding this submittal or require additional information, please contact Joyce Dishmon at 336-623-0238 or joyce.dishmon@duke-energy.com. Since, ' Reginald D. Anderson General Manager III, Regulated Stations Belews Creek Steam Station Power Generation Carolinas East cc: Brenda Johnson, Environmental Field Support Joyce Dishmon/Filenet State of North Carolina DWR Department of Environmental Quality Division of Water Resources Division of Water Resources ISA NCAC 02T.0200—WASTEWATER PUMP AND HAUL SYSTEMS INSTRUCTIONS FOR FORM P&H 01-16&SUPPORTING DOCUMENTATION Documents shall be prepared in accordance with 15A NCAC 02T.0100 15A NCAC 02T.0200,and Division policies. Failure to submit all required items will necessitate additional processing and review time. For more information, visit the Wastewater Branch's website or contact the Regional Office serving your county. General—This permit application applies to all pump and haul activities of wastewater under the authority of the Division on Water Resources. Permit coverage is required for the system producing the wastewater. This permit does not apply to the transport of animal waste from an animal waste management systems,not the transport of wastewater residuals or biosolids. NOTE:Pump and haul permits are not acceptable long term domestic wastewater treatment alternatives and shall only be issued in cases of environmental emergencies,nuisance conditions,health problems,or for unavoidable delays in construction of system previously permitted by the Division. The Applicant shall submit one original and one copy of the application and supporting documentation. A. Pre-submittal Contact&Cover Letter ® Contact the appropriate Regional Office prior to submittal ® Submit a cover letter explaining the circumstances associated with this pump and haul permit request B. Application Fee(Domestic Wastewater Only) ® Submit a check made payable to: North Carolina Department of Environmental Quality(NCDEQ) The appropriate application fee is:$810.00 for flows<10,000 GPD and$1,310.00 for flows>10,000 GPD C. Wastewater Pump and Haul(FORM:P&H 01-16)Application: ® Submit the completed and appropriately executed Wastewater Pump and Haul (FORM: P&H 01-16) application. Any unauthorized content changes to this form shall result in the application package being returned. If necessary for clarity or due to space restrictions, attachments to the application may be made, as long as the attachments are numbered to correspond to the section and item to which they refer D. Receiving Facility Letter: ® Submit a letter from the owner/authority of the receiving wastewater treatment facility,as required by 15A NCAC 02T.0204 (b),stating that the pumped and hauled wastewater will be accepted and specifying the volume and type of wastewater that will be accepted. The letter should be signed by an authorized signing official in accordance with 15A NCAC 02T.0106fb1 E. Contract Hauler Letter: ® Submit a letter from the hauler stating their capability and willingness to perform the pump and haul activity Letter shall include: Owner/Company Name,Contact Information,&Hauling Volume of Vehicle(s) F. Certifications: El The Applicant's Certification on Page 4 of the application shall be signed in accordance with 15A NCAC 02T.0106(b). Per 15A NCAC 02T .0106(c), an alternate person may be designated as the signing official if a delegation letter is provided from a person who meets the criteria in 15A NCAC 02T.0106(b) ❑ The Professional Engineer's Certification on Page 5 of the application shall be signed, sealed and dated by a North Carolina licensed Professional Engineer (if required) G. Plans and Specifications(Required for activities that result in the Practice of Engineering per G.S.89C-3): ❑ Submit two sets of plans and specifications(signed, sealed and dated by a N.C_Licensed Professional Engineer) ❑ Plans must include: A general location map Diagram of the components associated with the pump and haul activity(drains,piping,tanks,pumps,etc) Tank Details that indicate high water alarm Other items as required INSTRUCTIONS FOR APPLICATION P&H 01-16 Page 1 of 5 Industrial Pump and Haul Activities Per 15A NCAC 02T.0203(A)(2),Industrial pump and haul activities are deemed permitted provided the following criteria is met: %- The facility notifies the appropriate Division regional office in writing advising of the type of operation, type and quantity of wastewater generated, location, and the receiving wastewater treatment facility. A letter from the facility accepting the wastewater(type and quantity)specifically agreeing to accept wastewater from the applicant shall be included. The wastewater does not contain any human waste. %- The waste is collected and discharged into a sewer or treatment system designed and permitted to accept the type of wastewater being pumped and hauled. The pump and haul activity is not to alleviate a failing wastewater system. The Division regional office concurs in writing that the activity meets the criteria in this Rule. CONTACT THE REGIONAL OFFICE PRIOR TO INITIATING ANY INDUSTRIAL PUMP AND HAUL ACTIVITES. SUBMITTAL OF THIS APPLICATION/DOCUMENTS AND WRITTEN APPROVAL IS STILL REQUIRED FOR INDUSTRIAL PUMP AND HAUL ACTIVITIES THE COMPLETED APPLICATION PACKAGE INCLDING ALL SUPPORTING INFORMATION AND MATERIALS,SHOULD BE SENT TO THE APPROPRIATE REGIONAL OFFICE: REGIONAL OFFICE ADDRESS COUNTIES SERVED Asheville Regional Office 2090 US Highway 70 Water QualityOperations Avery, Buncombe, Burke,Caldwell,Cherokee, P Swannanoa, North Carolina 28778 Clay,Graham,Haywood, Henderson,Jackson, (828) 296-4500 Macon, Madison, McDowell, Mitchell, Polk, (828)299-7043 Fax Rutherford,Swain,Transylvania,Yancey Fayetteville Regional Office 225 Green Street Suite 714 Anson, Bladen,Cumberland, Harnett, Hoke, Water Quality Operations Fayetteville, North Carolina 28301 Montgomery, Moore, Robeson, Richmond, (910)433-3300 Sampson,Scotland (910)486-0707 Fax Mooresville Regional Office 610 E.Center Avenue Alexander,Cabarrus,Catawba,Cleveland, Water Quality Operations Mooresville,North Carolina 28115 Gaston, Iredell, Lincoln,Mecklenburg,Rowan, (704)663-1699 Stanly, Union (704)663-6040 Fax Raleigh Regional Office 1628 Mail Service Center Chatham,Durham, Edgecombe, Franklin, Water Quality Operations Raleigh, North Carolina 27699-1628 Granville, Halifax,Johnston,Lee, Nash, (919)791-4200 Northampton, Orange, Person, Vance,Wake, (919)788-7159 Fax Warren,Wilson Washington Regional Office 943 Washington Square Mall Beaufort, Bertie,Camden,Chowan, Craven, Water Quality Operations Washington, North Carolina 27889 Currituck, Dare,Gates,Greene, Hertford, Hyde, (252)946-6481 Jones, Lenoir, Martin, Pamlico,Pasquotank, (252)975-3716 Fax Perquimans, Pitt,Tyrrell,Washington,Wayne Wilmington Regional Office 127 Cardinal Drive Extension Brunswick,Carteret,Columbus, Duplin,New Water Quality Operations Wilmington, North Carolina 28405 Hanover, Onslow, Pender (910)796-7215 (910)350-2004 Fax Winston-Salem Regional Office 450 W.Hanes Mill Road Alamance,Alleghany,Ashe,Caswell, Davidson, Suite 300 Davie, Forsyth, Guilford, Rockingham, Randolph, Winston-Salem, North Carolina 27105 Stokes,Surry,Watauga,Wilkes,Yadkin (336)-776-9800 INSTRUCTIONS FOR APPLICATION P&H 01-16 Page 2 of 5 I. PRESUBMITTAL INFORMATION: 1. Contacted representative from regional office (Pre-submittal)?. ® Yes No iewski s 2. Contact name (For Regional Office): Lon Snider.James Gon i ❑ U. APPLICANT INFORMATION: 1. Applicant's name (Municipality, Individual, Corporation, etc): Duke Ener Carolinas LLC Belews Creek Steam Station 2. Applicant type: ❑ Municipal i❑State ❑Privately-Owned Public Utility ❑County Other: orati _R on 3. Origin of Wastewater: ❑Residential Subdivision ❑ Retail(Stores,Shop ping Centers) Domestic: 100❑Apartments/Condominiums ❑ Institution ❑ Mobile Home Park ❑ Commercial: g% Hospital Industrial: ❑School ❑Church ❑Restaurant Other: go ❑ Nursing Home []Office ® Other(specify) 4. Signature authority's name: Reginald Anderson per 15A NCAC 02T 0106(b) Title: GM III - Regulated Stations 5. Applicant's mailing address: 3195 Pine Hall Road City: Belews Creek State:NC Zip: 27009- 6. Applicant's contact information: Phone number: (336)445-0501 Email: Re inald.Anderson@duke-ener .com III. CONTACT/CONSULTANT INFORMATION: 1. Contact name:Aaron Babson Title/Affiliation:Senior Associate Hazen and Saw er 2. Contact's information: Phone number: (336)478-3378 Email:ababson hazenandsaw er.com IV. RECEIVING FACILITY INFORMATION: If more than 1 facility has agreed to accept the wastewater, please list all the owners, facility names, and permit numbers as a separate attachment) 1. Owner: Shamrock Environmental 2. Facility name: 3. Facility permit number: NCS-00790 4. WWTF permit number: 5. WWTF contact name:Jim Hollin sworth Title/Affiliation: HSE Director 6. WWTF contact information: Phone number: (336)478-1202 Email:jhollinesworth@shamrockenviro.com APPLICATION P&H 01-16 Page 3 of 5 v. PROJECT INFORMATION: 1. Location of Project (physical address): 3195 Pine Hall Road, Belews Creek , NC Approximate Coordinates(Decimal Degrees): Latitude: 36.2883330 Longitude: -80.055o 2. Duration of Pump and Haul Request(Six Months Typical): 12 months 3. Has a prior permit been issued? El New ® Prior Pump& Haul Permit Permit No.: W00040669 4. Permanent Method of Wastewater Disposal: Evaluating treatment/discharge under current NPDES versus design and installation of alternate system-spray irrigation/septic system 5. Date Permanent Disposal will be available: 6. Have permits/approvals for permanent disposal been obtained? Yes ® No Permit Number: 7. Is there a Pretreatment Program in effect? 0 Yes ® No 8. Describe any pretreatment prior to pumping and hauling: 9. Volume of Wastewater Generated: >10,000 Gallons per Day 10. Explain how the wastewater flow was determined:Q 15A NCAC 02T .0114 or® Representative Data If representative data,describe: Operation of the facility requires the volumes remain within the range of discharge. 11. Describe Tank/Container wastewater will be pumped from (attach description if necessary): Concrete Vault 12. Is Tank/Container in place or will it be installed (attach description if necessary): In place 13. What type of high water alarm does the container have (and/or): 0 Audible and Visual Telemetry(Auto Dialer/SCADA) VI. CERTIFICATION: 1. Applicant's Certification: (Signature of Signing Official and Project Name) I, Reginald Anderson ,attest that this application for Pump and Haul Permit has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting documentation and attachments are not included,this application package is subject to being returned as incomplete. I understand that issuance of a permit will require pump and haul facilities or activities to be inspected at least daily by me or a designated representative, Note: In accordance with North Carolina General Statutes 143-215.6A and 143-215.66,any person who knowingly makes any false statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor, which may include a fine not to exceed $10,000 as well as civil penalties up tp- ,000 per violation. la. Signing Of Signature Date APPLICATION P&H 01 16 Page 4 of 5 ENGINEERING DOCUMENTS MUST BE COMPLETED PRIOR TO SUBMITTAL. ACTIVITIES SHALL BE INSPECTED AT LEAST DAILY BY THE PERMITTEE OR IT'S REPRESENTATIVE PER ISA NCAC 02T.0204(d(. THE ENGINEER'S CERTFICATION IS REQUIRED FOR ACTIVITIES THAT RESULT IN THE PRACTICE OF ENGINEERING PER G.S.89C-3. ENGINEERING DOCUMENTS MUST BE COMPLETED PRIOR TO SUBMITTAL. IF CERTIFICATION BY AND ENGINEER IS REQUIRED, THIS PAGE IS NOT NECESSARY. 2. Professional Engineer's Certification: (Signature of Design Engineer and Project Name) I, ,attest that this application for accurate, complete and consistent with the information in the engineering plans, calculations,tios bean alleoth by me and is documentation to the best of my knowledge. I further attest that to the best of my knowledge the proposed design as been prepared in accordance with all the applicable regulations. Although other professionals may have developed certain portions of this submittal package, inclusion of these materials under my signature and seal signifies that I have reviewed this material and have judged it to be consistent with the proposed design. Note: In accordance with NC General Statutes 143-215 6A and 143 215.68 any person who knowingly makes any false statement, representation,or certification in any application shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed $10,000 as well as civil penalties up to $25,000 per violation. 2a Professional Engineer Name 2b. Engineering Firm 2c, Mailing Address 2d. 2e. 2f. City State Zip 2g. 2h. 2i. Telephone p Facsimile E mail NC PE Seal,Signature&Date APPLICATION P&H 01 16 Page 5 015 ENVIRONMENTAL CORPORATION6106 Corporate Park Drive Browns Summit, NC 27214 336-375-1989 • 800-881-1098 • Fax 336-478-1202 illt.""P- Pi www.shamrockenviro.com • info@shamrockenviro corn February 19,2019 Joyce Dishmon Duke Energy EHS CCP Permitting and Compliance Office:336-623-0238 Cell: 336-394-5524 Email: ioyce.dishmon a.duke-enersv.com Re: Pump& Haul Permit Dear Ms. Dishmon: As duly authorized representative of the owner/authority, please be advised that Shamrock Environmental Corporation a North Carolina Corporation and owner operator of the permits, vehicles and site described herein is permitted to haul septage in NC under Septage Management Permit NCS-00790. We have several vacuum loader equipped vehicles permitted to haul septage ranging between 3500 gallons to 6000 gallons in capacity which gives us more than adequate capacity to handle 5000 to 8000 per day from Belews Creek,NC. Furthermore, we are permitted under NC Septage Detention & Management Permit Number SDTF-41-03 to receive and treat regulated septage at our facility located at 6106 Corporate Park Drive in Browns Summit,NC with capacity to accept and treat an average daily maximum of 150,000 gallons per day of this type of wastewater. (Facility is permitted for 275,000 gallons average daily maximum). In summary, Shamrock Environmental is fully permitted, capable and willing to accept the proposed daily volume in your proposed permit application of 5,000 to 8,000 gallons per day subject to conformance with our profiling and acceptance procedures. For any questions related to this matter, please contact me direct at 336.478.1202, toll-free at 800.881.1098 or by email at jhollingsworth kshamrockenviro.com. Sincerely, 41 Jim lingswort C1H, C ,CHMM, REM Dir for of Health, Safety & Environmental File:Duke t3ele%%s Septage Page I of 1 04,2157 31 400E ENERGY BUSINESS SERVICES !LC �a DUKE 400 5 TRYON STREET ACCOUNTS PAYABLE - 5725Ble ENERGY Page 1 of 1 CHARLOTTE, NC 28202 Date: 08/08/2019 Check#: 1000177899 000017 R3K1SDA Payment Amount: 1,310.00 i • NORTH CAROLINA DEPARTMENT OF Vendor#: 0000071949 ENVIRONMENTAL QUALITY WINSTON-SALEM REGIONAL OFFICE 450 HANES MILL ROAD SUITE 300 WINSTON-SALEM NC 27105 Remittance Advice Invoice Date Invoice# Voucher ID# Invoice Gross Amt Discount Amount Invoice Net Am! 08/01/2019 BCPUMPAPP 11280218 1,310.00 0.00 1,310.00 PLEASE DETACH BEFORE DEPOSITING CHECK SHADED AREA MUST GRADUALLY CHANGE FROM BLUE AT TOP TO GREEN AT BOTTOM DUKE ENERGY BUSINESS SERVICES LLC 400 5 TRYON STREET tif. DUKE 50-917/213 ACCOUNTS PAYABLE • 5T25B ENERGY® Date: 08/08/2019 CHARLOTTE, NC 28202le Check#: 1000177899 i Pay Exactly '"One Thousand Three Hundred Ten and 00/100-US Dollars'* Amount $*A**1,310.00 TO THE NORTH CAROLINA DEPARTMENT OF 8 ORDER ENVIRONMENTAL QUALITY VOID AFTER 180 DAYS OF JP MORGAN CHASE BANK ,N A A thorized Signer SYRACUSE,NY 13206 IIt /0001778990 1:0 2 1 309 3 791: 60 18t,656 lii. ROY COOPER . ' .c Governor VS, 0 /l . MICHAEL S.REGAN Secretory LINDA CULPEPPER NORTH CAROLINA Director Environmental Quality February 26,2019 Mr.Reginald Anderson, General Manager III-Regulated Stations Belews Creek Steam Station Duke Energy Carolinas, LLC 3195 Pine Hall Road Belews Creek,North Carolina 27009 SUBJECT: Wastewater Pump&Haul Permit Application Belews Creek Steam Station Stokes County Permit No. WQ0040669 Dear Mr.Anderson: In accordance with your permit application received February 22, 2019, we are forwarding herewith Permit No. WQ0040669, dated February 26, 2019, to Duke Energy Carolinas LLC for the time-limited operation of a domestic wastewater pump and haul operation. This permit shall become effective February 26,2019 and will expire on August 24,2019; and shall be subject to the conditions and limitations as specified therein. This cover letter shall be considered a part of this permit and is therefore incorporated therein by reference. Please pay particular attention to Permit Condition 13,which requires accurate record keeping and reporting. Also note Permit Condition 18, which requires that the facilities associated with the pump and haul activities be inspected and pumped as often as necessary to prevent any malfunctions, overflows, or nuisances. Permission is hereby granted to Duke Energy Carolinas,LLC for the operation of: • A domestic wastewater pump and haul operation for the sanitary lagoon located at the Belews Creek Steam to allow for design and construction of upgrades to the system. The upgrade will be mechanical filtration. The sanitary lagoon will be permitted as a new internal outfall in the NPDES permit. • The anticipated flow for this pump and haul operation is a maximum of 8,000 gallons per day gallons per day or less of domestic wastewater generated in the station administration Q� North Carolina Department of Environmental Quality I Division of Water Resources ) Winston-Salem Regional Office I450 Hanes Mill Road,Suhe 300 I Winston-Salem.North Carolina 27103 • NORM CAROL D E on IMfil Lv�nueuiaumr� /� 336.776.9800 building. It is the Permittee's responsibility to notify the Division within 24 hours if the flow volume estimated above is exceeded by any amount on any day. • Please notify this office when the modification of the septic system is complete and the pump and haul operation is no longer necessary. The wastewater collected by this system shall be pumped by Shamrock Environmental Corporation for treatment and discharged into the City of Greensboro TZ Osborne Water Reclamation Facility for final treatment. This permit shall become voidable unless the agreements between Shamrock Environmental Corporation, Duke Energy Carolinas, LLC, and the City of TZ Osborne Water Reclamation Facility for the pumping,hauling and/or final treatment of wastewater are in full force and effect. If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request must be in the form of a written petition,conforming to Chapter 150B of North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding. If you have any questions regarding this permit or require any additional information, please contact Jim Gonsiewski or me by phone at(336) 776-9800. Sincerely, CDocuslpn.d by: L.A. T SM�� 145549E22iC94EA for S.Jay Zimmerman,Director Division of Water Resources by Lon T. Snider Assistant Regional Supervisor, Water Quality Regional Operations Division of Water Resources cc: Joyce Dishmon—Duke Energy Stokes County Health Department . DWR Central Office—Permit File WQ0040669 WSRO Files NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY DOMESTIC WASTEWATER PUMP&HAUL PERMIT PERMIT No.WQ0040669 This permit shall be effective February 26, 2019, will expire on August 24, 2019, and shall be subject to the following specified conditions and limitations: 1. This permit shall become voidable unless the subject pump and haul activities are carried out in a manner that has been approved by this Division. 2. This permit is effective only with respect to the nature and volume of wastes described in the application dated February 22, 2019 and other supporting data. 3. The facilities shall be properly maintained and operated at all times. 4. This permit is NOT transferable. In the event that there is a desire for the facilities to change ownership, or there is a name change of the Permittee, a formal request must be submitted to the Division. 5. No type,kind or quantity of wastewater other than the pumped and hauled wastewater from Duke Energy Carolinas,LLC shall be included in these pump and haul activities. 6. This permit shall become voidable unless the agreements between Shamrock Environmental Corporation, Duke Energy Carolinas, LLC, and the City of Greensboro TZ Osborne Water Reclamation Facility for the pumping,hauling and/or final treatment of wastewater are in full force and effect. 7. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, Duke Energy Carolinas, LLC shall cease operation of all pump and haul activities and take such immediate corrective actions as may be required by this Division. 8. The wastewater collected by this system shall be properly treated in the Shamrock Environmental Corporation treatment facility, Permit Number SDTF-41-03, prior to discharge into the City of Greensboro TZ Osborne Water Reclamation Facility (NC0047384) for final treatment and disposal. 9. Duke Energy Carolinas, LLC is liable for any damages caused by a spill or failure of the pump and haul operations. . i 10. Adequate inspection, maintenance, and cleaning shall be provided by Duke Energy Carolinas,LLC to ensure proper operation of the subject facilities. 11. Duke Energy Carolinas, LLC or its designee, shall inspect the pump and haul collection facilities to prevent malfunctions and deterioration, operator errors, and discharges that may cause or lead to the release of wastes to the environment,a threat to human health, or a nuisance. 12. Any duly authorized officer, employee, or representative of the Division of Water Resources may, upon presentation of credentials, enter and inspect any property, premises, or place on or related to the pump and haul collection facilities at any reasonable time for the purpose of determining compliance with the Division's approval; may inspect or copy any records that must be maintained under the terms and conditions of this permit;and may obtain samples. 13. An accurate record of the pump and haul activities must be maintained by Duke Energy Carolinas,LLC indicating: • Date and times wastewater is removed from the facility • Name of contract hauler • Name of facility receiving wastewater • Volume of wastewater removed • An inspection log including the date and time of inspections,observations made, and any maintenance, repairs,or corrective actions taken by the Permittee. These records shall be submitted quarterly by the following Wednesday to the Water Quality Regional Operations Supervisor,at address 450 West Hanes Mill Road,Suite 300,Winston- Salem,NC 27105 14. Failure to abide by the conditions and limitations contained in this permit may subject Duke Energy Carolinas, LLC to appropriate enforcement actions available to the Division. 15. The granting of this permit does not preclude Duke Energy Carolinas, LLC from complying with any and all statutes, rules, regulations, or ordinances,which may be imposed by other government agencies (local, state, and federal), which have jurisdiction. 16. Noncompliance Notification: Duke Energy Carolinas, LLC shall report by telephone to the Winston-Salem Regional Office, telephone no. (336) 77b-9800, as soon as possible, but in no case more than twenty-four (24) hours or on the next working day following the occurrence or first knowledge of the occurrence of any of the following: a. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate wastewater storage and/or treatment such as failures of tanks,piping,pumps,etc. it } b. Any failure of a pumping station, sewer line,etc.,resulting in a spill or by-pass directly to receiving waters without treatment of all or any portion of the influent to such station or facility. 17. Persons reporting such occurrences by telephone shall also file a written report in letter form within five(5)business days following first knowledge of the occurrence. This report must outline the actions taken or proposed to be taken to ensure that the problem does not recur. 18. The facilities associated with the pump and haul activities shall be inspected and pumped as often as necessary to prevent malfunctions,overflows, or nuisances. 19. Should ownership or financial circumstances change during this permit, immediate notification should be made to the regional office. 20. When these pump and haul activities are no longer necessary, please send written notification to: f Water Quality Regional Supervisor Winston-Salem Regional Office NCDEQ-DWR 450 W.Hanes Mill Rd, Suite 300 Winston-Salem,NC 27105 21. Sixty(60)days prior to the expiration of this permit(i.e. June 26,2019), a status report of the permanent wastewater treatment system shall be submitted to the Winston-Salem Regional Office. This report shall include: i.Anticipated flows; and ii.Proposed start-up date; or iii.Other alternatives being considered for permanent or temporary treatment of wastewater. Permit issued this the 26th day of February,2019,with a Permit Effective date of February 26, 2019. EDcculle by: L-0A "t SAA/Iv 145040E225Cg4EA... for S.Jay Zimmerman, Director Division of Water Resources by Lon T. Snider Assistant Regional Supervisor, Water Quality Regional Operations Division of Water Resources 4 ROY COOPER ,� i�{ ��g t.S H'"., Governor A 10,_` G MICHAEL S.REGAN ° Secretary S.DANIEL SMITH NORTH CAROLINA Director Environmental Quality February 20,2020 Mr. Reginald Anderson, General Manager III-Regulated Stations Belews Creek Steam Station Duke Energy Carolinas, LLC 3195 Pine Hall Road Belews Creek,North Carolina 27009 SUBJECT: Wastewater Pump&Haul Permit Application Belews Creek Steam Station Stokes County Permit No. WQ0041493 Dear Mr. Anderson: In accordance with your permit application received February 10, 2020, we are forwarding herewith Permit No. WQ0041493, dated February 20, 2020, to Duke Energy Carolinas LLC for the time-limited operation of a domestic wastewater pump and haul operation. This permit shall become effective February 20,2020 and will expire on August 17,2020; and shall be subject to the conditions and limitations as specified therein. This cover letter shall be considered a part of this permit and is therefore incorporated therein by reference. Please pay particular attention to Permit Condition 13,which requires accurate record keeping and reporting. Also note Permit Condition 18, which requires that the facilities associated with the pump and haul activities be inspected and pumped as often as necessary to prevent any malfunctions,overflows, or nuisances. Permission is hereby granted to Duke Energy Carolinas, LLC for the operation of: + A domestic wastewater pump and haul operation for the sanitary lagoon located at the Belews Creek Steam to allow for design and construction of upgrades to the system. The upgrade will be mechanical filtration. The sanitary lagoon will be permitted as a new internal outfall in the NPDES permit. • The anticipated flow for this pump and haul operation is greater than 10,000 gallons per day gallons per day of domestic wastewater generated in the station administration building. North Carolina Department of Environmental Quality I Division of Water Resources ces Winston-Salem Regional Office 1450 West Hanes Mill Road.Suite 300 I Winston-Salem,North Carolina 27105 rc:aFtra,lLVaD�� aismwaar.+..r.weuWn� /'d 336.776.9800 • Please notify this office when the modification of the septic system is complete and the pump and haul operation is no longer necessary. The wastewater collected by this system shall be pumped by. Shamrock Environmental Corporation for treatment or discharge into the City of Eden, Mebane Bridge Wastewater Treatment Plant(WWTP)for final treatment. This permit shall become voidable unless the agreements between Shamrock Environmental Corporation, Duke Energy Carolinas, LLC, and the City of Eden, Mebane Bridge WWTP for the pumping,hauling and/or final treatment of wastewater are in full force and effect. If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request must be in the form of a written petition,conforming to Chapter 150B of North Carolina General Statutes,and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding. If you have any questions regarding this permit or require any additional information, please contact Jim Gonsiewski or me by phone at(336) 776-9800. Sincerely, CGOQU8IQned by:• 5MJ4t 145B49E225C94EA... for S. Daniel Smith,Director Division of Water Resources by Lon T. Snider Regional Supervisor,Water Quality Regional Operations Division of Water Resources cc: Joyce Dishmon—Duke Energy(Electronic Copy) Stokes County Health Department(Electronic Copy) NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY DOMESTIC WASTEWATER PUMP& HAUL PERMIT PERMIT No.WQ0041493 This permit shall be effective February 20, 2020, will expire on August 17, 2020, and shall be subject to the following specified conditions and limitations: 1. This permit shall become voidable unless the subject pump and haul activities are carried out in a manner that has been approved by this Division. 2. This permit is effective only with respect to the nature and volume of wastes described in the application dated February 14,2020 and other supporting data. 3. The facilities shall be properly maintained and operated at all times. 4. This permit is NOT transferable. In the event that there is a desire for the facilities to change ownership, or there is a name change of the Permittee, a formal request must be submitted to the Division. 5. No type,kind or quantity of wastewater other than the pumped and hauled wastewater from Duke Energy Carolinas,LLC shall be included in these pump and haul activities. 6. This permit shall become voidable unless the agreements between Shamrock Environmental Corporation, Duke Energy Carolinas, LLC, and the City of Eden, Mebane Bridge WWTP for the pumping,hauling and/or final treatment of wastewater are in full force and effect. 7. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, Duke Energy Carolinas, LLC shall cease operation of all pump and haul activities and take such immediate corrective actions as may be required by this Division. 8. The wastewater collected by this system shall be properly treated in the Shamrock Environmental Corporation treatment facility, Permit Number NCS-00790 or in the City of Eden,Mebane Bridge WWTP(NC0025071)for final treatment and disposal. 9. Duke Energy Carolinas,LLC is liable for any damages caused by a spill or failure of the pump and haul operations. 10. Adequate inspection, maintenance, and cleaning shall be provided by Duke Energy Carolinas, LLC to ensure proper operation of the subject facilities. 11. Duke Energy Carolinas, LLC or its designee, shall inspect the pump and haul collection facilities to prevent malfunctions and deterioration, operator errors, and discharges that may cause or lead to the release of wastes to the environment,a threat to human health, or a nuisance. 12. Any duly authorized officer, employee, or representative of the Division of Water Resources may, upon presentation of credentials, enter and inspect any property, premises, or place on or related to the pump and haul collection facilities at any reasonable time for the purpose of determining compliance with the Division's approval; may inspect or copyanyrecords that must be maintained under the terms and conditions of this permit; and may obtain samples. 13. An accurate record of the pump and haul activities must be maintained by Duke Energy Carolinas, LLC indicating: • Date and times wastewater is removed from the facility • Name of contract hauler • Name of facility receiving wastewater • Volume of wastewater removed • An inspection log including the date and time of inspections,observations made, and any maintenance, repairs, or corrective actions taken by the Permittee. These records shall be submitted quarterly by the following Wednesday to the Water Quality Regional Operations Supervisor,at address 450 West Hanes Mill Road, Suite 300,Winston- Salem,NC 27105 14. Failure to abide by the conditions and limitations contained in this permit may subject Duke Energy Carolinas, LLC to appropriate enforcement actions available to the Division. 15. The granting of this permit does not preclude Duke Energy Carolinas, LLC from complying with any and all statutes, rules,regulations, or ordinances, which may be imposed by other government agencies (local, state, and federal), which have jurisdiction. 16. Noncompliance Notification: Duke Energy Carolinas, LLC shall report by telephone to the Winston-Salem Regional Office, telephone no. (336) 776-9800, as soon as possible, but in no case more than twenty-four (24) hours or on the next working day following the occurrence or first knowledge of the occurrence of any of the following: a. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate wastewater storage and/or treatment such as failures of tanks,piping, pumps,etc. b. Any failure of a pumping station,sewer line, etc.,resulting in a spill or by-pass directly to receiving waters without treatment of all or any portion of the influent to such station or facility. 17. Persons reporting such occurrences by telephone shall also file a written report in letter form within five(5)business days following first knowledge of the occurrence. This report must outline the actions taken or proposed to be taken to ensure that the problem does not recur. 18. The facilities associated with the pump and haul activities shall be inspected and pumped as often as necessary to prevent malfunctions,overflows,or nuisances. 19. Should ownership or financial circumstances change during this permit, immediate notification should be made to the regional office. 20. When these pump and haul activities are no longer necessary, please send written notification to: Water Quality Regional Supervisor Winston-Salem Regional Office NCDEQ-DWR 450 W.Hanes Mill Rd, Suite 300 Winston-Salem,NC 27105 21. Sixty (60) daysprior to the expiration of thispermit(i.e. June 19,2024 ,a status Y F ) report of the permanent wastewater treatment system shall be submitted to the Winston-Salem Regional Office. This report shall include: i.Anticipated flows;and ii.Proposed start-up date; or iii.Other alternatives being considered for permanent or temporary treatment of wastewater. Permit issued this the 20th day of February 2020, with a Permit Effective date of February 20, 2020. CD_ocusTgned by: L-0M l SMatt` 146849E2%C94EA. for S.Daniel Smith,Director Division of Water Resources by Lon T. Snider Regional Supervisor, Water Quality Regional Operations Division of Water Resources ROY COOPER 1 r Governor '\ MICHAEL S.REGAN �' ' Secretary LINDA CULPEPPER NORTH CAROLINA Director Environmental Quality August 21, 2019 Mr. Reginald Anderson, General Manager III -Regulated Stations Belews Creek Steam Station Duke Energy Carolinas, LLC 3195 Pine Hall Road Belews Creek,North Carolina 27009 SUBJECT: Wastewater Pump&Haul Permit Application Belews Creek Steam Station Stokes County Permit No. WQ0041120 Dear Mr.Anderson: In accordance with your permit application received August 20,2019,we are forwarding herewith Permit No. WQ0041120, dated August 21, 2019, to Duke Energy Carolinas LLC for the time- limited operation of a domestic wastewater pumpand haul operation. This permit shall become P P andshall be to the 21, 2019 and will expire on Februa 21,2020; effective Augustp rvsubject { g conditions and limitations as specified therein. This cover letter shall be considered a part of this permit and is therefore incorporated therein by reference. Please pay particular attention to Permit Condition 13,which requires accurate record keeping and reporting. Also note Permit Condition 18, which requires that the facilities associated with the pump and haul activities be inspected and pumped as often as necessary to prevent any malfunctions,overflows, or nuisances. Permission is hereby granted to Duke Energy Carolinas,LLC for the operation of: • A domestic wastewater pump and haul operation for the sanitary lagoon located at the Belews Creek Steam to allow for design and construction of upgrades to the system. The upgrade will be mechanical filtration. The sanitary lagoon will be permitted as a new internal outfall in the NPDES permit. • The anticipated flow for this pump and haul operation is greater than 10,000 gallons per day gallons per day of domestic wastewater generated in the station administration building. North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road.Suite 300 I Winston-Salem.North Carolina 27105 I� u0 �nw atw�D 336.776.9800 v j • Please notify this office when the modification of the septic system is complete and the pump and haul operation is no longer necessary. The wastewater collected by this system shall be pumped by Shamrock Environmental Corporation for treatment and discharged into the City of Greensboro TZ Osborne Water Reclamation Facility for final treatment. This permit shall become voidable unless the agreements between Shamrock Environmental Corporation, Duke Energy Carolinas, LLC, and the City of TZ Osborne Water Reclamation Facility for the pumping, hauling and/or final treatment of wastewater are in full force and effect. If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request must be in the form of a written petition,conforming to Chapter 150B of North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding. If you have any questions regarding this permit or require any additional information, please contact Jim Gonsiewski or me by phone at(336) 776-9800. Sincerely, E.-6A,Docueignes1 by: l SMAIJ 1461319E225C94Ek.. for Linda Culpepper, Director Division of Water Resources by Lon T. Snider Regional Supervisor, Water Quality Regional Operations Division of Water Resources cc: Joyce Dishmon—Duke Energy Stokes County Health Department DWR Central Office—Permit File WQ0041120 WSRO Files NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY DOMESTIC WASTEWATER PUMP&HAUL PERMIT PERMIT No. WQ0041120 This permit shall be effective August 21, 2019, will expire on February 21, 2020, and shall be subject to the following specified conditions and limitations: 1. This permit shall become voidable unless the subject pump and haul activities are carried out in a manner that has been approved by this Division. 2. This permit is effective only with respect to the nature and volume of wastes described in the application dated August 20, 2019 and other supporting data. 3. The facilities shall be properly maintained and operated at all times. 4. This permit is NOT transferable. In the event that there is a desire for the facilities to change ownership, or there is a name change of the Permittee, a formal request must be submitted to the Division. 5. No type,kind or quantity of wastewater other than the pumped and hauled wastewater from Duke Energy Carolinas,LLC shall be included in these pump and haul activities. 6. This permit shall become voidable unless the agreements between Shamrock Environmental Corporation, Duke Energy Carolinas, LLC, and the City of Greensboro TZ Osborne Water Reclamation Facility for the pumping,hauling and/or final treatment of wastewater are in full force and effect. 7. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, Duke Energy Carolinas, LLC shall cease operation of all pump and haul activities and take such immediate corrective actions as may be required by this Division. 8. The wastewater collected by this system shall be properly treated in the Shamrock Environmental Corporation treatment facility, Permit Number NCS-00790, prior to discharge into the City of Greensboro TZ Osborne Water Reclamation Facility (NC0047384)for final treatment and disposal. 9. Duke Energy Carolinas, LLC is liable for any damages caused by a spill or failure of the pump and haul operations. 10. Adequate inspection, maintenance, and cleaning shall be provided by Duke Energy Carolinas, LLC to ensure proper operation of the subject facilities. i 11. Duke Energy Carolinas, LLC or its designee, shall inspect the pump and haul collection facilities to prevent malfunctions and deterioration, operator errors, and discharges that may cause or lead to the release of wastes to the environment, a threat to human health, or a nuisance. 12. Any duly authorized officer, employee, or representative of the Division of Water Resources may, upon presentation of credentials, enter and inspect any property, premises,or place on or related to the pump and haul collection facilities at any reasonable time for the purpose of determining compliance with the Division's approval; may inspect or copy any records that must be maintained under the terms and conditions of this permit;and may obtain samples. 13. An accurate record of the pump and haul activities must be maintained by Duke EnergyCarolinas, as, LLC indicating: • Date and times wastewater is removed from the facility • Name of contract hauler • Name of facility receiving wastewater • Volume of wastewater removed • An inspection log including the date and time of inspections,observations made, , and any maintenance, repairs, or corrective actions taken by the Permittee. These records shall be submitted quarterly by the following Wednesday to the Water Quality Regional Operations Supervisor,at address 450 West Hanes Mill Road,Suite 300,Winston- Salem,NC 27105 14. Failure to abide by the conditions and limitations contained in this permit may subject Duke Energy Carolinas, LLC to appropriate enforcement actions available to the Division. 15. The granting of this permit does not preclude Duke Energy Carolinas, LLC from complying with any and all statutes,rules, regulations, or ordinances, which may be imposed by other government agencies (local, state, and federal), which have jurisdiction. 16. NoncompIiance Notification: Duke Energy Carolinas, LLC shall report by telephone to the Winston-Salem Regional Office, telephone no. (336) 776-9800, as soon as possible, but in no case more than twenty-four (24) hours or on the next working day following the occurrence or first knowledge of the occurrence of any of the following: a. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate wastewater storage and/or treatment such as failures of tanks,piping,pumps, etc. b. Any failure of a pumping station, sewer line, etc.,resulting in a spill or by-pass directly to receiving waters without treatment of all or any portion of the influent to such station or facility. 17. Persons reporting such occurrences by telephone shall also file a written report in letter form within five(5)business days following first knowledge of the occurrence. This report must outline the actions taken or proposed to be taken to ensure that the problem does not recur. 18. The facilities associated with the pump and haul activities shall be inspected and pumped as often as necessary to prevent malfunctions,overflows,or nuisances. 19. Should ownership or financial circumstances change during this permit, immediate notification should be made to the regional office. 20. When these pump and haul activities are no longer necessary, please send written notification to: Water Quality Regional Supervisor Winston-Salem Regional Office NCDEQ-DWR 450 W. Hanes Mill Rd, Suite 300 Winston-Salem,NC 27105 21. Sixty (60) days prior to the expiration of this permit(i.e. December 24,2019), a status report of the permanent wastewater treatment system shall be submitted to the Winston-Salem Regional Office. This report shall include: i.Anticipated flows;and ii.Proposed start-up date; or iii.Other alternatives being considered for permanent or temporary treatment of wastewater. Permit issued this the 21st day of August 2019,with a Permit Effective date of August 21,2019. EDoousigned by: L*. T 5 4Xv 1451340E225014EA... for Linda Culpepper,Director Division of Water Resources by Lon T. Snider Regional Supervisor,Water Quality Regional Operations Division of Water Resources .-,..., .....300251.°°. .ftw, G5 -' - -. . v• ir i • I C'' Me Cou `I'De Aki, Proposed Instream River G Sampling Location Duke Energy Property Line 7 Outfall 006 x , • ,.................---, ., . r _, f_ _. . 11. % . 0.4km /'- Nsz...,.--...____ ----\\ 0.2mi a