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HomeMy WebLinkAboutNCG500582_Regional Office Historical File Pre 2018a Y -oopm mli Rl Gtt? i Srerary - l ter C 1MPI"pisE - �R, . September 2.t�, 2019 SEP 2 �9pORF wQRos To Scott A McMillan sv,Cc� RF�101VAc or--r/a� ' Pto�`ec�lVSanager.-Environmental Affairs? Sruthern Power Company j 3�35 �olonttaclePa�"kwa� . Bi'rmtnglatn, AI, 35243 From Hannah Headrick A," uatc Toxte 1aich. a Sub}ec�w' Braccle rti�ev!Re�:evv' - $,qol qrn Power Cgmpom Plant Raw tt, County Pow*{S'fahori NFDBS # fi1CGS0.Q582' RowaCotiiit Southern dower Compan} Plank ILwowan bounty Power Station has 'r�qucsted appro�ral of the: following cherr>1aT, Gengard' 7004 ;Thesp:produets wi11, be dshargecl into fhetr;()utfalt QQ2 and; irif4 Second Meek.. A Calculatwns ppO- i0klhe use of'theseroctucts, at'the stated dosage rates? well not -cause toxic impacts to aquatic lxe fihe receuuig:streamSecond Creep T$er`efore .tle.use of this piodieti as an additi a to their coals g taw er-,blowdau?n,'oon contact, cooling grater; td&i ceaszonal draining from other operafiatial sy,:slems at Southern Power Company. PTantRwan CouaLy Powertatton<i acceptable:: ' , d - u cc �7izlie Grzyb ,Complex Permrttxng Branch. x Cato�in� !pope , e�to >taron nta off iris a fW a ; r s: ,A EI1 v 4 !- 5 (3PSOt�LPW VatAr 4. ~ f $e�ences.SepUon ,.. T. .440�xReedy<G�a k,Road [a1(x .i�ad.:S nuce,Cent�r.[rR�feh„No[th �arali[ca 276991fi21; + 9',�7433A�i 3 Water Resources Environmental Quality February 27, 2017 Mr. Shane Short Southern Power Company 5755 North Carolina 801 Highway Salisbury, North Carolina 28147 SUBJECT: Compliance Evaluation Inspection Southern Power Company NPDES- Permit NCG500582 Rowan County, NC Dear Mr. Short: ROY COOPER . Governor MICHAEL S. REGAN Secretary S. JAY ZIMMERMAN Director On . February 22, 2, 2017, ko.berto*.Schelle.r of this. Office -conducte d a compliance inspection at the, subject facility. This inspection was conducted as a Compliance ' * Evaluation Inspection'(CEI) to insure compliance with permit requirements and conditions. At the time of inspection facility appeared to be well maintained and operated. We wish to thank you and the operating, §taff for assistance regarding this inspection. 'No The enclosed report should be Self-explanatory; however, should you have any questions; please do not hesitate to contact myself or Roberto Scheller at (704).235-2204 or roberto.scheller@ncdenr.gov. Sincerely, W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosed cc: Wastewater Branch File <5---"Nothing Compares ----'..- State of North Carolina I Envirorunental Quality 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 919-707-9000 United States Environmental Protection Agency Form Approved. EPA Washington, D.C.20460 1 _OMB No. 2040-0057 Water Compliance Inspection Report Approval expiresB-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector FacType 1 IN 2 15 1 3 I NCG500582 111 • 12 17/02/22 17 18 ICI 19 I ! i 201 21111111 1111111111111111111111111 11111.111111 f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CIA Reserved-- — 67 70 i, i 71 Lj 72 i N i 73 I I I 174 75 Ll LJ LJ I I 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES Permit Number) 10:0OAM .17/02/22 16/04/22 Plant Rowan County Exit Time/Date permit Expiration Date 5755 NC Hwy 801 Salisbury NC 28147 12:10PM 17/02/22 20/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Officialfritle/Phone and Fax Number Contacted Scott Dial,5755 NC 801 Hwy Salisbury NC 28147/Plant No Manager(/04-278-6603I7042786620 Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Laboratory Storm Water Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Roberto Scheller MRO WQ//252-946-6481/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date . W. Corey Basinger MRO WQ//704-235-2194/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.. Page# 1 NPDES yr/mo/day Inspection Type 1 31 NCG500582 I11 1217102/22 17. 18ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# 2 Permit: NCG500582 Owner - Facility: Plant Rowan County Inspection Date: 02/22/2017 Inspection Type:- Compliance Evaluation Permit Yes No NA NE (if the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ 0 ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ❑ M. ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑, ❑ Is the inspector granted access to all areas for inspection?' ❑ ❑ ❑ Comment: This facility is permitted under NCG 500582 which expires 7/31/2020. This facility has two designated outfalls (001 &002). The last compliance evaluation was performed on 01 /30/2013. Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or> 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Yes No NA NE M ❑ ❑ . El • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ M ❑ ❑ ❑ ❑❑■❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ M ❑ ❑ ❑ M ❑ ❑ ❑ ■ ❑ ❑ ❑ ® ❑ ❑ ❑ ® ❑ X ❑ ❑ ❑ ❑ ❑ ® ❑ Page# 3 Permit: NCG500582 Owner - Facility: Plant Rowan County Inspection Date: 02/22/2017 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ N. ❑ ❑ Comment: Verified flow meter caaibration Laboratory Yes No .NA NE Are field parameters performed by certified personnel or laboratory? ❑ 0 ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? ❑ ❑ ❑ # Is the facility using a contract lab? ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees E ❑ ❑ ❑ Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 0 ❑ Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees? ❑ - ❑ .E ❑ Comment: Facilitv uses Pace Labatory as contract lab. Field parameters for pH, Temperature, and Cl2 are performed under Field Labatory Certification #5588. Instruments used for NPDES reporting should be identified in calibration log by assigned ID number or instrument serial number. Reagents used for instrument calibration should display open date on container. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of'foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ . Comment: Outfall #001 was not discharging at time of inspection. Outfall #002 was discharginq at time of inspection. The effluent was clear with no foam or suspended solids being discharged Cl2 was not detected in effluent discharge. Page# . 4 Weaver, Charles M�o NtC:EIVED/NCDENR/DWR From: Weaver, Charles Sent: Friday, April 22, 2016 10:58 AM APR 2 7 2016 To: 'mrkroh@southernco.com' wQRos Cc: 'cstarks@southernco.com' MOORESVILLE REGIONAL OFFICE Subject: renewal of NCG500582 Attachments: Technical Bulletin - NCG500000 2015.doc; NCG50 Final 093015.pdf Importance: High Attached you will find the updated version of NPDES General Permit NCG500000, effective 10/1/2015. Discard any _previous versions of the General'Permit and use this version until further notice. You do not need a reprinted Certificate of Coverage, as the one issued to you in 2007 is still applicable. Thank you for your patience during the longer -than -expected renewal period. If you have any questions about this matter, simply reply to this message. Charles H. Weaver Environmental Specialist N.C. Division of Water Resources N.C. Department of Environmental Quality 919-807-6391 charles.weaver(a)ncdenr.aov (physical address) 512 North Salisbury Street, Raleigh, NC 27604 (mailing address) 1617 Mail Service Center, Raleigh, NC 27699-1617 Nothing Compares - .. Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. 1 Weaver, Charles From: Microsoft Outlook To: mrkroh@southernco.com; cstarks@southernco.com Sent: Friday, April 22, 2016 10:59 AM Subject: Relayed: renewal of NCG500582 Delivery to these recipients or groups is complete, but no delivery notification was sent by the destination server: mrkroh0southernco.com (mrkroh0southernco com) cstarks@southernco.com (cstarksCa)southernco comb Subject: ��renewal of NCG500582 LJ -renewal of NCG500582 1 A4iLA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Charles Wakild, P.E. John E. Skvarla, III Governor Director Secretary February 11, 2013 Mr. Ronnie Walston, Plant Manager Southern Power Company 5755 NC Hwy. 801 N Salisbury, North Carolina 28147 Subject: Compliance Evaluation Inspection Southern Power Co./Plant Rowan County NPDES Permit No. NCG500582 Rowan County Dear Mr. Walston: Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on January 30, 2013. Please inform the facility's staff responsible for the implementation of this Permit by forwarding a copy of the enclosed report. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Wes Bell at (704) 235-2192, or at wes.bell@ncdenr.gov. Sincerely, Michael L. Parker Regional Supervisor Surface Water Protection Section Enclosure: Inspection Report cc: Rowan County Health Department IME Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service:1-877-623-6748 Internet: www.ncwaterquality.org One - NorthCarohna Agtlmilly An Equal Opportunity t Affirmative Action Employer-30% Recycledl10% Post Consumer paper United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 INI 2 15I 31 NCG500582 111 121 13/01/30 117 181 C I 19I S I 20I I Remarks 211 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 116 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA------------ 671 1.0 169 70141 71 I N I 72I N I 73 W 74 751 I I I I I I 180 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) Plant Rowan County 09:55 AM 13/01/30 07/08/01 Exit Time/Date Permit Expiration Date 5755 NC Hwy 801 Salisbury NC 28147 12:28 PM 13/01/30 12/07/31 Name(s) of Onsite Representative(s)fTities(s)/Phone and Fax Number(s) Other Facility Data /// Michael Thompson//704-278-6613 / Randy G Alexander/Compliance Special ist/205-257-301 7 /2052576336 Name, Address of Responsible Official/Tifle/Phone and Fax Number Contacted Ronnie Walston,5755 NC Hwy 801 N Salisbury NC 28147/Plant Manager/704-278-6613/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Laboratory Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Wesley N Belll" MRO WQ//704-663-1699 Ext.2192/ S' nature of Management Q A Re ' r ency/Office/Phone and Fax Numbers Date Marcia A locco MRO W0704-663-1699 Ext.2204/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES yr/mo/day 3 1 N CG500582 11 12 1 13/01 /30 117 Inspection Type 18l CI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page # 2 Permit: NCG500582 Inspection Date: 01/30/2013 Owner - Facility: Plant Rowan County Inspection Type: Compliance Evaluation (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: The facility has designated two discharge outfalls (001 and 002). The last compliance evaluation inspection was performed on 7/22/2010. Record Keeping - Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Comment: The records reviewed during the inspection were organized and well maintained. The sampling results were reviewed for 2012. The facility complied with all permit limits and monitoring frequencies. Yes No NA NE nn■n ■nnn nn■n ■ n n n ■nnn ■nnn ■ n nn■n nn■n nn■n nn■n nn■n nn■n ■nnn nn■n Page # 3 Permit: NCG500582 Owner - Facility: Plant Rowan County Inspection Date: 01/30/2013 Inspection Type: Compliance Evaluation Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ® n n n Are all other parameters(excluding field parameters) performed by a certified lab? n n ■ n # Is the facility using a contract lab? n n ■ n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? n n ■ n Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? n n ■ Cl Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? n n ■ n Comment: On -site field analyses (pH, temperature, total residual chlorine) are performed under the facility's laboratory certification #5588. The laboratory instrumentation used for field analyses appeared to be properly calibrated/verified and documented. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? n n ■ n Is sample collected below all treatment units? ■ n n n Is proper volume collected? ■ n n n Is the tubing clean? n n ■ n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? n n ■ n Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■. n n n Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ n n n Comment: Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Vnc Nn IJA KIP ■nnn Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge n n ■ n Judge, and other that are applicable? Comment: The facility appeared to be properly operated and well maintained. Effluent discharge events are based on the measured levels of silica and specific conductance in the recirculation water. The facility installed a blow down sump for Units 1-3 evaporative coolers to allow blow down water to be collected and pumped into the cooling tower system. In addition, the boiler blowdown is also piped into the cooling tower system. De -chlorination Type of system ? V-- Ali. AIA KIC Liquid Page # 4 Permit: NCG500582 Inspection Date: 01/30/2013 Owner - Facility: Plant Rowan County Inspection Type: Compliance Evaluation De -chlorination Yes No NA NE Is the feed ratio proportional to chlorine amount (1 to 1)? ® n Cl ❑ Is storage appropriate for cylinders? n n ■ n # Is de -chlorination substance stored away from chlorine containers? 0 n .■ n Are the tablets the proper size and type? n n ■ n Comment: Aqueous sodium bisulfite is added for dechlorination. Are tablet de -chlorinators operational? n ❑ ■ n Number of tubes in use? Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ■ n n n Is flow meter calibrated annually? ■ n n n Is the flow meter operational? ■ n n n (If units are separated) Does the chart recorder match the flow meter? ❑ n ■ n Comment: The flow meter is calibrated/verified annually and was calibrated/verified on 10/29/2012 by Emerson Process Managament - Instrument & Valve Services. ^--- Is right of way to the outfall properly maintained? n 1=1 n ■ Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑ ■ If effluent (diffuser pipes are required) are they operating properly? n n ■ n Comment: No discharges were observed at the time of the inspection. Page # 5 Southern Power 600 North 18t Street Birmingham, Alabama 35203-2206 205-257 2647 DIViSi0101 0'�. � "A S ER, QUAU T Y SOUTHE ARM R14 Wk NY MAR 2 7 2012 COMP March 16, 2012Ur��:Tlj: �d MOORESV;L LE RE010NAL OFFICE Mr. Charles H. Weaver, Jr. NC DENR / DWQ / NPDES �� 1617 Mail Service Center D Raleigh, North Carolina 27699-1617 EDENRiWA 9 2012 Subject: Notice of Renewal Intent Application R QUALITYGeneral Permit NCG500000 CE BRANCH Existing Certificate of Coverage NCG500582 Dear Mr. Weaver: Southern Power Company is pleased to submit this Notice of Renewal Intent Application for General Permit NCG500000, Existing Certificate Coverage NCG500582 for the Plant Rowan County power station. The current permit became effective on August 1, 2007 and will expire at midnight on July 31, 2012. The Plant Rowan County power station is located at 5755 NC HWY 801, Salisbury, NC 28147 and includes three simple -cycle combustion turbines, two combined cycle combustion turbines, switch and substation yards containing the necessary supporting equipment and systems needed for operation. Specifically, the station contains five combustion turbine units, one steam turbine unit and cooling tower with associated water treatment chemicals. The following provides additional information as referenced by number in Attachment 1 — Notice of Renewal Intent: 1. Item 3(a) — Description of Discharge a. Outfall 001 discharges from a storm water retention pond to an unnamed tributary of Second Creek. See Attachment 2 — Site Map b. Outfall 002 discharges directly to Second Creek via an underground outfall pipe. See Attachment 2 — Site Map 2. Item 3(c) Other — Description of Discharge Outfall 001: a. Storm water which accumulates in an outdoor retention pond located adjacent to the cooling tower and chemical storage areas. See Attachment 2 — Site Map. b. rWastewater from operational systems during infrequent draining of various process units, piping, components and storage tanks during maintenance and operational activities (i.e. circulation y water, steam drain blowdown, hotwell, gland seal, heat -recovery steam generator (HRSG), and N,.demineralized water). See Attachment 3 — April 26 and June 18, 2004 correspondence. Outfall 002: a. Non -contact cooling water. b. Water conditioning products (i.e. Corrshield MD4100, Propylene Glycol, Sodium Hypochlorite, GENGARD GN8005, Sulfuric Acid, and Spectrus DT 1404). c. Wastewater from operational systems during infrequent draining of various process units, piping, components and storage tanks during maintenance and operational activities (i.e. circulation water, steam drain blowdown, hotwell, gland seal, HRSG, and demineralized water). See Attachment 3 — April 26 and June 18, 2004 correspondence. d. Blowdown wastewaters (cooling tower, evaporative coolers, and boiler). 3. Items 4 and 5 — Chemicals Added to Wastewater (Outfall 002) a. See Attachment 3 for correspondence from Plant Rowan County to the North Carolina Department of Natural Resources, Division of Water Quality (NC DWQ) regarding the use of specific corrosion inhibitors (i.e. Corrshield MD4100 and Propylene Glycol). The facility uses Sodium Hypochlorite , GENGARD GN8005, and Sulfuric Acid as water conditioning products in the cooling tower, as well as Spectrus DT 1404 (sodium bisulfite) to eliminate residual chlorine. MSDS sheets for Sodium Hypochlorite, GENGARD GN8005, Sulfuric Acid and Spectrus DT 1404 are included in Attachment 4. In addition, the appropriate Biocide 101 Form and MSDS sheets will be submitted to the Aquatic Toxicology Unit. 4. Item 6 — Wastewater Treatment a. Outfall 001 — A storm water retention pond is located adjacent to the cooling tower. The pond collects surface water runoff from the area surrounding the cooling tower and water chemical storage areas (water chemical storage areas are in containment with valves in order to control stormwater discharge). The discharge from the pond is monitored under this waste water permit. The pond is specifically designed to provide storm water retention capabilities and not serve as wastewater treatment. The pond has an overflow discharge pipe which discharges to an unnamed tributary of Second Creek. b. Outfall 002 = Wastewater treatment associated with Outfall 002 is limited to the use of sodium bisulfite for the elimination of chlorine. 5. Item 7 — Discharge Frequency a. The discharge for 001 pis intermittent depending on the amount of rainfall. Historically the pond will discharge a small amount of water (less than 25 gallons per day) during normal conditions. The pond will discharge more water (approximately 250 gallons a day) during heavy rain events. The discharge for 002 which is continuous during intermittent plant operations ranges from 150,00 gallons per day under normal conditions up to 240,000 gallons per day during full plant operation (24 hours a day 7 days a week). The plant typically does not operate every day because it is an intermediate/peaking resource. Please feel free to contact Michelle Kroh at 704-278-6657 or myself at 205-257-2647 if you have any questions regarding this submittal. Sincerely, Circe Starks Environmental Affairs Manager Southern Power Company Attachments: Attachment 1: Notice of Renewal Intent for NCG500582 Attachment 2: Site Map Attachment 3: Agency Correspondence Attachment 4: MSDSs Attachment 5: Water Flow Diagram HC DENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman Governor Director Secretary NOTICE OF RENEWAL INTENT Application for renewal of existing coverage under General Permit NCG500000 Existing Certificate of Coverage (CoQ: NCG500582 (Please print or type) 1) Mailing address' of facility owner/operator: Company Name Southern Power Company Owner Name Southern Power Company Street Address 600 18t" Street North/15N-8198 City. Birmingham State AL ZIP Code 35203 Telephone Number (205) 257-2647 Fax: (205) 257-6336 Email address cstarks@southernco.com (Circe Starks, Environmental Affairs Manager) * Address to which all permit correspondence should be mailed 2) Location of facility producing discharge: Facility Name Plant Rowan County Facility Contact Michelle Kroh Street Address 5755 NC 801 Highway City Salisbury State NC County Rowan Telephone Number 704-278-6657 Fax 704-278-6620 Email address mrkroh@southernco.com 3) Description of Discharge: ZIP Code 28147 a) Is the discharge directly to the receiving stream? Z Yes ® No Please see Cover Letter, -part 1 (If no, submit a site map with the pathway to the potential receiving waters clearly marked. This includes tracing the pathway of the storm sewer to the discharge point, if the storm sewer is the only viable means of discharge.) b) Number of discharge outfalls (ditches, pipes, channels, etc. that convey wastewater from the property): Two 2 c) What type of wastewater is discharged? Indicate which discharge points, if more than one. ® Non -contact cooling water ® Boiler Blowdown Outfall(s) #: 002 Outfall (s) #: 002 Page 1 of 3 NCG500000 renewal application_ ® Cooling Tower Blowdown ® Condensate ® Other Outfall (s) #: 002 Outfall (s) #: 002 Outfall (s) #: 001 & 002 (Please describe "Other") Please see Cover Letter, part 2 d) Volume of discharge per each_discharge point (in GPD): Please see Cover Letter, part 5 #001:250 #002:240,000 #003: #004 4) Please check the type of chemical [s] added to the wastewater for treatment, per each separate discharge . point (if applicable, use separate sheet): Please see Cover LetterLpart 3 ® Chlorine ®Biocides ® Corrosion inhibitors ® Algaecide ® Other ❑ None 5) If any box in item (4) above [other than None] was checked, a completed Biocide 101 Form and manufacturers' information on the additive must be submitted to the following address for approval: NC DENR / DWQ / Environmental Sciences Section Aquatic Toxicology Unit 1621 Mail Service Center Raleigh, NC 27699-1621 6) Is there any type of treatment being provided to the wastewater before discharge (i.e., retention ponds, settling ponds, etc.)? ® Yes ❑ No Please see Cover Letter, part 4 (if yes, please include design specifics (i.e., design volume, retention time, surface area, etc.) with submittal package. Existing treatment facilities should be described in detail. ) 7) Discharge Frequency: a) The discharge is: ❑ Continuous ® Intermittent ❑ Seasonal* i) If the discharge is intermittent, describe when the discharge will occur: During cooling tower blowdown activities. Please see Cover Letter, part 5 ii) *Check the month(s) the discharge occurs: ❑ Jan ❑ Feb ❑ Mar. ❑ Apr ❑ May ❑ Jun ❑ Jul ❑ Aug. ❑ Sept. ❑ Oct. ❑ Nov. ❑ Dec. How many days per week is there a discharge? Please check the days discharge occurs:❑ Sat. ❑ Sun ❑ Mon. ❑ Tue. ❑ Wed. ❑ Thu. ❑ Fri. Page 2 of 3 M NCG500000 renewal application Additional Application Requirements: The following information must be included in duplicate [original + 1 copy] with this application or it will be returned as incomplete. ➢. Site map. If the discharge is not directly to a stream, the pathway to the receiving stream must be clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point. ➢ Authorization for representatives. If this application will be submitted by a consulting engineer (or engineering firm), include documentation from the Permittee showing that the consultant submitting the application has been designated an Authorized Representative of the applicant. Certification I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: Ronnie Walston Title: Plant Manager _zetw� Oj(" .3 /.5- ono/`,2- (Signature of Applicant) (Date igned) North Carolina General Statute 143-215.6 b (i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) aEasasaEasa£asasasasaea This Notice of Renewal Intent does NOT require a separate fee. The permitted facility already pays an annual fee for coverage under N0500000. a EaEaEaEmmoxaemmma Mail the original and one copy of the entire package to: Mr. Charles H. Weaver NC DENR / DWQ / NPDES 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Page 3 of 3 Path: , 4M� 4—� yz z v k!'001in Ig r I Ower11 Owerr r N 4W 2 '112 ij V( v"Y 0.1 Vater, Pon 'a (Oil J_ (Underground /k Discharge Pip 7 j7". 5 it % It A r r J': .,Sampling I P� n 71vi 'F 4:1- -N%,�A j kA N Ki 4Y + r � '7 . � .: s �« @g'' �`"'°�c.. �'�r 'a" .v.ti` s � } >i } r�F �—,.,•:,��� +,s r p ,j d f r''L —A Map Location Legend �O - H Attachment 2 DE Property Boundary Cooling Tower topographic opographic Site Map Site Boundary Storm Water Pond &WkMmunal cmudaig & Teduwbgy, k-r- W� Outfall Locations Plant Rowan Nc Outfall Underground 5755 Highway 801 sc Discharge Pipe Salisbury N cni Rowan County, NC 2,0 0. 1,000 00 Scale: 1:24.000 March 2012 Feet (1=2,000')A t1SG,9 24k Topographic. Quadrangle Nowan Mills, NC (1987) Septic Tank System Tank bottom condensate Pump and haul Roofed Potable Use Fuel Oil Storage Fuel Oil . Fuel Oil Forwarding Unloading Plant Fire Loop Pumps Sump Sump City Double walled,tank Water Site I•-•-•-•-•-•-•-•-. Steam Storm Waste taken offsite I Water .. Cleaning Wastes (Pump & Haul) Steam Portable Water Or Discharge Turbine • Demineralizer Storage I Drains Leaks/Rinses • Condenser Evap/Consump I . Losses QC 3 CTs 2 Steam 2 CTs Generators Evap Cooler Sump Plant False Start WatjTank Systems Drain Tank Drai City Pump & Water Haul Losses Water Evap/Consump Condensate Losses e Cooling Tower Basin Outfall .....> 001 all Dechlorination 002 Ar.iwA FILE NCDENR Pat McCrory Governor John E. Skvarla, III . Secretary May 15, 2014 Mr. Bruce Triplett 350 Skysail Road Salisbury, North Carolina 28146 Subject: Compliance Evaluation Inspection Triplett Single Family Residence COC # NCG550436 Rowan County Dear Mr. Triplett: Enclosed is a copy of the Compliance Evaluation Inspection report (CEI) for the inspection conducted at the subject facility on April 30, 2014 by Ms. Barbara Sifford with this Office. Thank you for your assistance and cooperation during the inspection. Overall the facility was in good operational condition and well maintained. The report should be self-explanatory. Please note that Part I, Section A of the permit includes analytical testing for total residual chlorine (TRC) along with the footnote that indicates that instream TRC levels are not to exceed 17ug/1. This permit footnote was also noted in the previous inspection of your facility performed in 2008. Sampling the chlorine contact chamber will likely not comply with this limit and the use of pool chlorine tablets will likely not produce the necessary chlorination required by the permit. It is requested that the analytical results from your 2014 annual testing be submitted to this Office when completed so that the chlorine residual concentrations can be verified. Information has also been included with this report regarding, the specific type of chlorine tablets required for wastewater treatment facilities. If you have any questions, comments, or need assistance with understanding any aspect of your permit or this,report, please do not hesitate to contact Ms. Sifford or myself at (704)-663-1699. Sincerely, Michael L. Parker, Regional Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division-of-W-ater-Resources; NCDENR-- - - Cc: MSC-1617 Central Files CEI- Report (BIMS) Chlorine Tablets -Suppliers Mooresville Regional Office, 610 East Center Avenue, Mooresville, North Carolina 28155 Phone: 704-663-16991 Internet: www.ncdenr.gov An Equal Opportunity 1 Affirmative Action Employer— Made in part by recycled paper United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 _ _ .. . ____,. •_-.._........ _-_..._._...._ .__ _.:-.....W;;Pr,;=djanC.:nni Ap royal ex Tres 8-31-98 P _- _..._.P..._..- ..... r Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 INI 2 15 I 31 NCG550436 111 121 14/04/30 117 18I C I 19I S I 20I I Remarks 211111 1111111111111111111111111111 1111111111111116 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------Reserved----- --- 671 169 70III 711 I 721 N I 73 I I 174 751 I I I I I I 180 t__t__I Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 350 Skysail Road 01:00 PM 14/04/30 13/08/01 Exit Time/Date Permit Expiration Date 350 Skysail Rd Salisbury NC 28146 02:00 PM 14/04/30 18/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Bruce Triplett,350 Skysail Rd Salisbury NC 28146//704-633-1187/ Contato No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Operations & Maintenance N Records/Reports Self -Monitoring Program . Sludge Handling Disposal ■ Facility Site Review Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Barbara Sifford Division of Water Quality//704-663-1699 Ext.2196/ Signature of Management @ A Reviewer-- agency/Office/Phone-and-Fax- lumbers- -- Date - - - EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES I yr/mo/day Inspection Type 1 3 111 ' 12 I- �..17 18 �NC - -- G550435 -- •-� - _. -- 14/04/30 - - ... ......:... .. .. Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) 1. Copy of permit included. 2. Information on proper chlorine tablets included and required analytical for permit no limit at this time. 3. Annual septic tank pumping was in April of 2013. Page # 2 Permit: NCG550436 Owner - Facility: 350 Skysail Road Inspection Date: 04/30/2014 Inspection Type: Compliance Evaluation Operations & Maintenance LL Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■nnn Does the facility analyze process control parameters, for ex: MLSS, MCRT,*Settleable Solids, pH, DO, Sludge n n ■ n Judge, and other that are applicable? Comment: Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: System was constructed as described in permit, pump tank and sand filter are after original septic tank. Permit was renewed in August 20.13 for 5 years. Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? Is the level of chlorine residual acceptable? Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de -chlorination? Comment: Chlorine residual has not been evaluated, sample for this should be taken near the lake at the dischage and not in the chlorine -tank. Norweco and USA Blue Book are companies that can provide proper disinfection tablets for wastewater that is discharged to a stream, pool chlorine tablets are not permisssible and will not meet the lower chlorine levels required. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? 1sVruperVatunse-ollected? — V...- K1_ RIA \IG Yes No NA NE ■nnn. n■nn 2 nnn■ nnn■ ■nnn Yes No NA NE nn■n ■nnn Is the tubing clean? ❑ n ■ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ n n n Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ n ❑ n Page # 3 Permit: NCG550436 Owner - Facility: 350 Skysail Road Inspection Date: 04/30/2014 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Comment: Annual data was reviewed for 2011, 2012 and 2013 BOD, TSS and Fecal are in compliance with permit conditions. Copy of new permit included with this letter for reference to chlorine levels that are required to be documented. Please submit the 2014 annual compliance coopy to this office when completed with this data. Sand Filters (Low rate) (If pumps are used) Is an audible and visible alarm Present and operational? Is the distribution box level and watertight? Is sand filter free of ponding? Is the sand filter effluent re -circulated at a valid ratio? # Is the sand filter surface free of algae or excessive vegetation? # Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1) Comment: Sand filter is covered to prevent grass from growing.on sandbed, alarm is located in basement of house. Yes No NA NE ■ n n n ■nnn ■nnn p■nn ■nnn noon Page # 4 Southern Power 600 North 18th Street .Birmingham, Alabama 35203-2206 Contact Number 205-257-3017 October 20, 2011 RECEIVED OivieioPj bF WATER; QUALITY OCT 2 4 2011 MOORESVILLE REGIO:,iA'- OFFICE SOUTHERN ,r. Ms. Donna Hood North Carolina Division of Water Quality Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, North Carolina 2..8115 Subject: Blow Down Sump Installation Southern Power Company, Plant Rowan County General Permit NCG500000 Dear Ms.Hood, We would like to inform you that the plant will install a blow down sump for the Units 1-3- Evaporative Coolers later this year. The: sump will allow blow down water from the Evaporative Coolers to be pumped to the Units 4&5 Cooling Tower. This allows the water to be used twice for cooling and will reduce the amount of water consumed by the plant. If you have any questions, .please call Randy Alexander at (205)257-3017. Sincerely, po,-V� Ronnie Walston Plant Manager cc: w/att: Plant file RECEIVED DIVISION OF WATER QUALITY Southern Power 0 C T 2 4 2011 600 North 18u, Street SWP SECTION Birmingham, Alabama 35203-2206 MOORESVILLE REGIONAL OFFICE Contact Number_I 205-257-3017''`- `. I E ` { October 20, 2011 COPY Ms. Donna Hood North Carolina Division of Water Quality Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, North Carolina 28115 Subject: Blow Down Sump Installation Southern Power Company, Plant Rowan County General Permit NCG500000 Dear Ms.Hood, We would like to inform you that the plant will install a blow down sump for the Units 1-3 Evaporative Coolers later this year. The sump will allow blow down water from the - Evaporative Coolers to be pumped to the Units 4&5 Cooling Tower. This allows the water to be used twice for cooling and will reduce the amount of water consumed by the plant. If you have any questions, please call Randy. Alexander at (205)257-3017. Sincerely, Ronnie Walston Plant Manager cc: w/att: Plant file %9, 6/LA3P—) Southern Power Company Plant Rowan County 5755 NC Highway 801 Salisbury, NC 28147 September 03, 2010 Mrs. Marcia Allocco Surface Water Protection Section Suite 301 610 East Central Avenue Mooresville, NC 28115 RE: Compliance Sampling Inspection Report Southern Power Company - Plant Rowan NPDES Permit No. NCG500582 Rowan County, N.C. Tracking #: NOV-2010-PC-0947 Dear Mrs. Allocco: WA SOUTHERNAEZk COMPANY Energy to Serve Your World' RECEIVED DIVISION OF WATER QUALITY SEP -7 2010 SWP SECTION MOORESVILLE REGIONAL OFFICE On behalf of Southern Power Company ("Southern Power"), please accept this letter as Southern Power's written response to the August 13, 2010 Compliance Sampling Inspection Report and its corresponding Notice of Violation ("NOV") issued to Plant Rowan concerning compliance with certain NPDES permit requirements. The specific issues raised in the report and the corresponding corrective actions are addressed below (the comment from the report is stated first, and then our response follows): Inspection Report, Page 4, Laboratory: Prism Laboratories, Inc (Cert # 402) was contracted to perform the permit required monitoring in 2009. The facility staff initiated the on -site monitoring of all parameters in 2010. The total residual chlorine (TRC) meter was not properly calibrated/verifted and the pH check standard had not been documented. In addition, one of the pH buffers had expired. Please refer to the attached guidance document regarding the calibration and documentation requirements for the pH and TRC meters and thermometer. Southern Power's Response: For 2010, the facility will utilize an outside vendor to perform the required monitoring for the remainder of the year. Additionally, the total residual chorine analyzer will be submitted to a certified lab to be appropriately calibrated and certified. The pH check standard has been added to the pH log (See Attachment). Training will be provided to plant personnel to ensure compliance with the required procedures. A work order will be initiated monthly to check documentation of data and standards. All efforts will be consistent with the technical assistance documents provided with the NOV. Inspection Report Page 4, Upstream/Downstream Sampling No upstream and downstream monitoring was performed for Outfall 001 in 2009. The Notice of Intent renewal documentation indicates that Outfall 001 discharges into an unnamed tributary to North Second Creek The facility staff must provide safe and accessible areas for the upstream and downstream sampling (for Outfall 001) at this unnamed tributary. The facility complied with the upstream/downstream monitoring requirements at Outfall 002 for the review period (2009-May 2010). Southern Power's Response: Prism Laboratories was on site on May 8, September 14, and December 23, 2009 to perform sampling. Combustion Turbines 1, 2 & 3 were not running on May 8 and December 23 which means there was no discharge to Outfall 001. The Combustion Turbines were running with the evaporative coolers in service and blowing down on September I&h and no discharge was observed at Outfall 001. There has consistently been no observed discharge from Outfall 001 from the time Southern Power acquired the facility (other than storm water during a heavy rainfall) until recently due to a project to remove vegetation from the storm water pond. Prior to the vegetation being removed, the wastewater from the combustion turbines' evaporative cooler process was collected in the pond and evaporated instead of discharging. If there is a discharge at Outfall 001, the temperature will be monitored both upstream and downstream. If the discharge includes stormwater, that fact will be noted on the report. A contractor has been hired to clear a path to provide improved access for potential upstream and downstream sampling. This work is expected to be completed by the end of this month. Inspection Report, Page 5, Operations and Maintenance: All domestic wastewater is treated on -site by a subsurface disposal system (septic tank/drain field). The if 001 discharge is intermittent and based on seasonal conditions. The staff had not incorporated a dechlorination system for this discharge outfall. The facility staff must ensure wastewater from Outfall 001 is properly treated (dechlorinated) prior to discharge. Southern Power's Response: The Plant has instituted a new procedure to address chlorinated wastewater from the evaporative coolers. The new procedure is to close the blow -down valves for units 1, 2, and 3 and hold the process water in the cooler system while the evaporative coolers are running. Once it is determined that the water needs to be released due to conductivity reasons, it will be measured in accordance with the procedures for both chlorine and pH. When the measurements are within the permit limits, the water will be released to the pond. This new procedure will prevent any future TRC exceedances because (1) the potential discharge of wastewater from Outfall 001 only occurs when the evaporative coolers are in service, and (2) the only potentially chlorinated process water comes from the evaporative coolers. Inspection Report, Page 5, Flow Measurement Effluent: The facility staff must ensure that the flows at both Outfalls are measured and documented during the permit required effluent sampling events. Southern Power's Response: The Bucket -and Stopwatch procedure will be used to measure the flow at Outfall 001. This process is described in the attached procedure (See Attachment). Flow at Outfall 002 is measured by a differential pressure flow meter and the data is collected by the data historian. Report Page 5, Effluent Pipe: Only Outfall 001 was discharging at the time of the inspection. DWQ staffperformed pH, temperature, and TRC measurements at the time of the inspection. The results of the analyses were as follows: 8.63 s. u. (pM, 32. 7 degrees Celsius, and 152 ug/L (TRC). The TRC effluent value exceeded the 17 ug/L permit limit and the 50 ug/L TRC compliance level currently being implemented by the Division. Southern Power's Response: Please see above response to the Operations and Maintenance comment. Also, please be aware that the Plant adds no chorine to the water used in its various operations, including the evaporative coolers. The chlorine present in the wastewater comes to the Plant from the City of Salisbury Water Department. Southern Power is committed to environmental compliance at all of its facilities. We trust that this response will fully address any past water quality monitoring/recordkeeping issues at Plant Rowan. As discussed above, we believe we have instituted appropriate corrective action to prevent reoccurrence of similar events. If you have any questions or concerns, please contact Randy Alexander at 205-257-3017. Si erel Scott Dial Plant Manager Facility: Southern Company Plant Rowan County, Salisbury, North Carolina Document NPDES Procedures for General Wastewater Permit NCG500000 Title: Certificate of Coverage NCG500682 Applies to: Wastewater/Storm Water Monitoring, Sampling and Reporting Requirements Authority State of North Carolina Department of Environment and Natural Resources Division of Water Quality NPDES Permitting Unit Purpose To provide a procedure ensuring compliance with the NPDES permit monitoring, sampling, recordkeeping, and reporting requirements. Allowed Facility Discharges Outfall 001 1. Storm water which accumulates in an outdoor retention pond located adjacent to the cooling towers and chemical storage areas. 2. Combustion Turbine 1-3 evaporative cooling water blowdown. 3. Wastewater overflow from operational systems during infrequent draining of various process units, piping, components and storage tanks during maintenance and operational activities (i.e. Circulation water and evaporative cooling water). Outfall 002 1. Non -contact cooling water. 2. Water conditioning products (i.e. Sodium Hypochlorite, Gengard GN8005, Sulfuric Acid (98%), and Spectrus DT 1404). 3. Wastewater from operational systems during infrequent draining of various process units, piping, components and storage tanks during maintenance and operational activities (i.e. circulation water, boiler blowdown, hotwell, gland seal, HRSG, and demineralized water). Coverage Permit effective on August 1, 2007 Permit expires on July 31, 2012 References 1. National Pollutant Discharge Elimination System General Permit No. NCG500000. 2. Technical Bulletin for General Permit NCG500000, Volume 1, August 1, 2002. 3. Certificate of Coverage No. NCG500582 for General Permit No. NCG500000. 4. Residual Chlorine Limit Change Letter May 01, 2008 Rev. 8/31/2010 Page 1 of 8 1.0 Monitoring, Controls, and Discharge Limitations for Outfalls 001 and 002 Parameter Limit Test Frequency Flow Estimate from DCS & Semi -Annually Observation Oil & Grease 15.0 mg/1(monthly avg.) 20 Semi -Annually (see 1.1.2) mg/1(daily max Temperature Receiving water <32 °C and Semi -Annually 52.8 °C above natural water temperature. Total Residual Chlorine 17 maximum No lower than 6.0 or greateri-Annually tSei-AnnuallpH' than 9.0 1.1 Representative Sampling Samples collected and measurements taken must be characteristic of the volume and nature of the permitted discharge. Samples should be taken on a day and time that is characteristic of the discharge over the entire period which the sample represents. All samples must be taken at the monitoring points specified in the permit or in the locations indicated in the procedure below and, unless otherwise specified, before the effluent joins or is diluted by any other waste stream, body of water, or substance. The monitoring points indicated further in the procedure have been approved by the permit issuing authority. Outfall 001: Outfall 001 is sampled on the discharge side of the retention pond. All samples are obtained at the same location for pH, flow, oil and grease, temperature, and chlorine. Sample needs to be taken if sufficient water is present. If sufficient water is not present, it needs to be reported as such. Also, the total residual chlorine must be checked in each of the evaporative coolers to ensure it is below 50 pg/I before being discharged to Outfall 001. NOTE: If a sample is not available at Outfall 001 while process water is being discharged (i.e. evaporative cooler blowdown) then a sample should be taken at the process discharge point upstream of Outfall 001 (i.e. blowdown or sump drain) and tested for pH, total residual chlorine, and temperature. Outfall 001 should be monitored until process discharge is complete to verify flow or no flow. Verify no flow is observed at Outfall 001 during evaporative cooler discharge. If no flow is observed then the stream differential temperature can be measured when there is flow at Outfall 001 due to evaporative cooler discharge combined with water from a rain event. The make-up of the discharge (i.e. storm water/evaporative cooler water mixture) should be noted at the time of the temperature measurement. Outfall002: Outfall 002 is sampled from valve # 2-EQ461-BV-9598, the manhole on the effluent line, or the effluent line discharge point into second creek. Samples are obtained at the same location for pH, flow, temperature, oil and grease, and chlorine. In addition, temperature samples from the upstream and downstream side of the discharge into Second Creek are collected. 1.1.1 Discharge flow will be estimated and measured semi-annually. 1.1.2 Oil and Grease will be measured semi-annually with a grab sample of the discharge. Oil and Grease monitoring applies only for air compressor condensate discharges. Oil and Grease has a monthly average discharge limit of 15 mg/L and a daily maximum of 20 mg/L. Laboratory analysis is performed by an outside laboratory. 1.1.3 Temperature will be recorded semi-annually upstream, downstream, and at the discharge point. The temperature must be measured with a NIST traceable Rev. 8/31/2010 1 Page 2 of 8 thermometer. The temperature of the effluent will be regulated so that the temperature of the fresh water receiving stream does not increase more than: • 2.8°C above the natural water temperature. • Receiving water temperature must not exceed a maximum of 32°C. • Three locations must be tested for Outfall 001 1) 50ft upstream where streams converge. Sample is accessed by walking down trail to unnamed tributary of North Second Creek. 2) 50 ft downstream of discharge point. Sample is accessed by walking down trail to unnamed tributary of North Second Creek. 3) Discharge into unnamed tributary of North Second Creek. • Three locations must be tested for Outfall 002 1) 100ft upstream of discharge point, by route 70 bridge. 2) 50ft downstream of discharge point. Sample is accessed by walking up Second Creek. 3) Directly from discharge pipe. Sample is also accessed by walking up Second Creek. 1.1.4 Total residual chlorine will be measured semi-annually with a grab sample of the discharge. Total Chlorine will need to be tested at the sample location where discharge temperature is taken. Semi-annual tests will be done by Plant personal. Although the limit for Total Residual Chlorine is 17 pg/I, the sample may not exceed 50 pg/I to be considered in compliance. The test must comply with EPA Method 330.5. Analysis must be performed within 15 minutes of obtaining sample using the Hach DR 2800 analyzer and Hach Method 10014. (NOTE: Hach DR2800 calibration curve must be verified/certified annually.) 1.1.5 The pH will be measured semi-annually from the discharge pipe into Second Creek with a calibrated device. The pH must not be less than 6.0 standard units or greater than 9.0 standard units. The pH meter must be calibrated according to manufacturer's recommendations and DWQ technical guidance prior to each use and the pH calibration form must be completed. If third party does sampling, written verification regarding pH calibration needs to be supplied. Analysis must be done within 15 minutes of obtaining sample. 1.2 Flow Measurement Outfalls 001 and 002: Flow is measured in gallons per minute. Flow is estimated at Outfall 001 by using a container (such as a 5 gallon bucket) to capture a known volume of water and measuring the time it takes to fill the container. Flow at Outfall 002 is measured by a differential pressure flow meter and the data is collected by the data historian. 1.3 Test Procedures • Oil and Grease analysis is performed in accordance with EPA Method 1664A. • Total Chlorine analysis is performed in accordance with EPA Method 330.5. The Hach DR 2800 analyzer using Method 10014 for ultra low chlorine complies with this requirement. All test procedures must produce minimum detection and reporting levels that are below the permit discharge requirements and all data generated must be reported down to the minimum detection or lower reporting level of the procedure. 1.4 Plant Rowan County does not discharge once through cooling waters; therefore, hydroelectric facilities (generator cooling water, generator thrust bearing cooling water, turbine guide cooling water & transformer cooling water) requirements are not applicable. Notes: Rev. 8/31/2010 Page 3 of 8 Plant Rowan must obtain authorization from the Division prior to the use of any chemical additive in the discharge. Plant Rowan must notify the Director in writing at least nine 90 days prior to instituting use of any additional additive in the discharge which may be toxic to aquatic life. There must be no chromium, zinc or copper added to the discharge except as pre -approved additives to biocidal compounds. There must be no discharge of floating solids or visible foam (other than trace amounts) in the effluent. 2.0 Definitions Instantaneous Flow Measurement: A measure of flow taken at the time of sampling in gallons per minute, when both the sample and flow will be representative of the total discharge. Grab Samples: An individual sample of at least 100ml collected over a period of time not exceeding 15 minutes. Grab samples can be collected manually. mg/L: Milligrams per liter pg/L: Micrograms per liter NPDES: National Pollutant Discharge Elimination System EPA: Environmental Protection Agency 3.0 Records 3.1 Records Retention Southern must retain records of all monitoring information, including all calibration and maintenance records, copies of all reports required by the permit, for a period of at least 3 years from the date of the sample, measurement, report or application. 3.2 Recording Results For each measurement or sample, Southern must record the following information: • The date, exact place, and time of sampling or measurements; • The individual(s) who performed the sampling or measurements; • The date(s) analyses were performed; • The individual(s) who performed the analyses; • The analytical techniques or methods used; and • The results of such analyses. • The date of the last chlorine analyzer calibration. Note: Use Attachment 1 & 2 for recording sampling results. 4.0 Reporting Requirements 4.1 Submission of Reports Submission of standardized monitoring forms or other monitoring reports to the Division is not required. All monitoring information and copies of any reports required by the permit must be retained on site for a period of at least 3 years from the date of the sample, measurement, report or application. This period may be extended by request of the Director at any time. Southern must furnish to the Permit Issuing Authority upon request, copies of records required to be kept. Rev. 8/31 /2010 Page 4 of 8 Change in Discharge All discharges must be consistent with the terms and conditions of the permit. The discharge of any pollutant at a level in excess of that authorized must constitute a violation of the permit. Planned Changes Southern must give notice to the Director as soon as possible of any planned physical alterations or additions to the facility that would affect type or quantity of discharges. Duty to Report Southern Power must report to the central office in Raleigh (919) 733-7015 or the Mooresville Regional Office (704) 663-1699 any noncompliance which may endanger health or the environment. Information must be provided orally within 24 hours followed by a written submission within 5 days. 5.0 Operation and Maintenance of Pollution Controls 5.1 Proper Operation and Maintenance At all times proper operation and maintenance for all facilities and systems of treatment and control which are used to achieve compliance will be implemented. 5.2 Bypassing of Treatment Facilities 5.2.1 Plant Rowan may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if; 1. It is for essential maintenance to assure efficient operation, or 2. The bypass was unavoidable to prevent loss of life, personal injury or severe property damage, or 3. There was no feasible alternative. 5.2.2 Anticipated Bypass — Plant Rowan is required to submit prior notice at least 10 days before the date of the bypass. 6.2.3 Unanticipated Bypass — Plant Rowan is required to submit notice with 24 hours. 5.3 Removed Substances Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters must be disposed of in accordance with NCGS 143-215.1 and in a manner which prevents any pollutant from such materials from entering waters of the State or navigable waters of the United States. Attachments: Attachment 1 — Sampling Form for Outfall 001 Attachment 2 — Sampling Form for Outfall 002 Attachment 3 — pH Meter Calibration Sheet Rev. 8/31/2010 1 Page 5 of 8 Attachment 1 Date: Outfall 001 Sampling Form Southern Power Plant Rowan Analyst Name: Date of last Hach DR 2800 Certification: Check Standard Actual Value Measured Value Parameter Limits Sample Within Time Time Analytical Results Limits Collected Analyzed Method (Y or N) Flow n/a n/a Temperature Receiving Upstream: water <32 °C and <2.8 °C above natural water temperature Temperature Receiving Downstream water <32 °C and <2.8 °C above natural water temperature Temperature Receiving Effluent water <32 °C and <2.8 °C above natural water temperature pH 6.0-9.0 Chlorine 50 µg/1 (analyzer) 17 119/1 (permit limit) Rev. 8/31/2010 Page 6 of 8 Date: Attachment 2 Outfall 002 Sampling Form Southern Power Plant Rowan Analyst Name: Date of last Hach DR 2800 Certification: Check Standard Actual Value Measured Value Parameter Limits Sample Within Time Time Analytical Results Limits Collected Analyzed Method (Y or N) Flow n/a n/a Temperature Receiving Upstream: water <32 °C and <2.8 °C above natural water temperature Temperature Receiving Downstream water <32 °C and <2.8 °C above natural water temperature Temperature Receiving Effluent water <32 °C and <2.8 °C above natural water temperature pH 6.0-9.0 Chlorine 50 µg/1 (analyzer) 17 µgd (permit limit) Rev. 8/31/2010 1 Page 7 of 8 Attachment 3 pH Calibration Log Date 4.0 Buffer 7.0 Buffer 10.0 Buffer Verification pH % Slope Initials with 7.0 Buffer (must be within +/- 0.1) During calibration all values set to match buffer value. Check expiration date of all buffers. Rev. 8/31/2010 1 Page 8 of 8 CEN North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director August 13, 2010 Mr. Scott Dial, Plant Manager Southern Power Company 5755 NC 801 HWY Salisbury, North Carolina 28147 Subject: Notice of Violation Compliance Sampling Inspection Southern Power Company/ Plant Rowan County NPDES Permit No. NCG500582 Rowan County, N.C. Tracking 9: NOV-2010-PC-0947 Dear Mr. Dial: Enclosed is a copy of the Compliance Sampling Inspection Report for the inspection conducted at the subject facility on July 22, 2010 by Mr. Wes Bell of this Office. Dee Freeman Secretary This report is being issued as a Notice of Violation (NOV) due to the facility's failures to conduct the permit -required monitoring (effluent, upstream, downstream) at Outfall 001 in 2009 and total residual monitoring, effluent limit violation measured during the inspection at Outfall 001 (by DWQ Staff), all violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1, as detailed in the Effluent Sampling, Upstream/Downstream Sampling, Operation & Maintenance, and Effluent Pipe Sections of the attached report. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per violation, per day, may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. It is requested that a written response be submitted to this Office by September 3, 2010, addressing the above -noted violations and the discrepancies noted in the Laboratory Section of the attached report. In responding to the violations, please address your comments to the attention of Mrs. Marcia Allocco. Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service:1-877-623-6748 NorthCarolina Internet: http://portal.ncdenr.org/web/wq Nahmallil An Equal opportunity 1 Affirmative Action Employer — 50% Recycled/10% Post Consumer paper Mr. Scott Dial August 13, 2010 Page Two The report should be self-explanatory; however, should you have questions concerning this report, please do not hesitate to contact Mrs. Allocco or Mr. Bell at (704) 663-1699. Sincerely, Robert B. Krebs Surface Water Protection Regional Supervisor Enclosures: Inspection Report Laboratory Technical Guidance Document cc: Rowan County Health Department i1 ; United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Rdport Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 I NI 2 15I 31 NCG500582 111 121 10/07/22 117 18I SI 191 SI 20I II Remarks 21111111111111111111111111111111111111111111111116 Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA -------------- ---------- Reserved-------------- 67I 1.5 169 70121 711 NJ 72I N I 73 74 751 I I I I III 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 01:50 PM 10/07/22 07/08/01 Plant Rowan County Exit Time/Date Permit Expiration Date 5755 NC Hwy 801 Salisbury NC 28147 04:28 PM 10/07/22 12/07/31 Name(s) of Onsite Representative (s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Tom Collins//704-278-6613 /7042786620 Name, Address of Responsible Official/Title/Phone and Fax Number Scott Dial,5755 NC 801 Hwyy Salisbury NC 28147/Plant Contacted Yes Manager/704-278-6603/7042786620 Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit ® Flow Measurement ® Operations & Maintenance ® Records/Reports Self -Monitoring Program is Facility Site Review ® Effluent/Receiving Waters ® Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s). and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Wesley N Bell �y MRO WQ//704-663-1699 Ext.2192/ Si nature of Management Q A ew r Agency/Office/Phone and Fax Numbers Dale a� `l Marcia Allocco - MRO WQ//704-663-1699 Ext:2204/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES yr/mo/day Inspection Type 1 3I NCG500582 I11 .12I 10/07/22 117 18Isl Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) u Page # 2 Permit: NCG500582 Owner - Facility: Plant Rowan County Inspection Date: 07/22/2010 Inspection Type: Compliance Sampling Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? n n n Is the facility as described in the permit? ® n ❑ n # Are there any special conditions for the permit? ❑ fl 00 Is access to the plant site restricted to the general public? n n fl Is the inspector granted access to all areas for inspection? o n n n Comment: The general permit expires on 7/31/12. The facility has designated two discharge outfalls (001 and 002). Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ®❑ ❑ n Is all required information readily available, complete and current? ®❑ ❑ n Are all.records maintained -for 3 years (lab. reg. required 5 years)? ® n ❑ ❑ Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? ® fl n n Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? ❑ ❑ ® ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ n 0 n (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? rl n ® n Is the ORC visitation log available and current? f 1 fl ® n Is the. ORC certified at grade equal to or higher than the facility classification? ❑ n ■ Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? ®n - n Facility has copy of previous year's Annual Report on file for review? ❑ fl ® 0 Comment: The facility's records were organized and well maintained. Self -monitoring data was reviewed for 2009 - 2010. The facility was in compliance with the effluent limits at Outfall 002 during the review period. Laboratory Yes No NA NE Page # 3 Permit: NCG500582 Owner - Facility: Plant Rowan County Inspection Date: 07/22/2010 Inspection Type: Compliance Sampling Yes No NA NE Laboratory Are field parameters performed by certified personnel or laboratory? ❑ ❑ ■ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? ❑ ❑ ■ n # Is the facility using a contract lab? ❑ ❑ ■ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? n n ■ n Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? n ❑ ■ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? n n ■ ❑ Comment: Prism Laboratories, Inc. (Certification #402) was contracted to perform the permit -required monitoring in 2009. The facility staff initiated the on -site monitoring of all parameters in 2010. The total residual chlorine (TRC) meter was not properly calibrated/verified and the pH meter check standard had not been documented. In addition, one of the pH buffers had expired. Please refer to the attached guidance document regarding the calibration and documentation requirements for the pH and TRC meters and thermometer. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ n ■ n Is sample collected below all treatment units? n n ■ n nn■.o Is proper volume collected? nn■n Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? n ❑ n Is the facility sampling performed as required by the permit (frequency, sampling type representative)? n ■ n n Comment: The subject permit requires effluent grab samples. No effluent monitoring was performed for Outfall 001 in 2009. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ❑ ® n ❑ Comment: No upstream and downstream monitoring was performed for Outfall 001 in 2009. The Notice of Intent renewal documentation indicates that Outfall 001 discharges into an unnamed tributary to North Second Creek. The facility staff must provide safe and accessible areas for the upstream and downstream sampling (for Outfall 001) at this unnamed tributary. The facility complied with the upstream/downstream monitoring requirements. at'0utfall 002 for the review period (2009 - May 2010). Yes No NA NE Operations & Maintenance Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑ Does the facility.analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑ ❑ ■ ❑ Judge, and other that are applicable? Page # 4 Permit: NCG500582 Owner- Facility: Plant Rowan County Inspection Date: 07/22/2010 Inspection Type: Compliance Sampling Operations & Maintenance Yes No NA NE Comment: All domestic wastewater is treated on -site by a subsurface disposal system (septic tank/drain field). The Outfall 001 discharge is intermittent and based on seasonal conditions. The staff had not incorporated a dechlorination system for this discharge outfall (See Effluent Pipe Section for effluent results). The facility staff must ensure wastewater from Outfall '001 is properly treated (dechlorinated) prior to, discharge. De -chlorination Yes No NA NE Type of system ? Liquid Is the feed ratio proportional to chlorine amount (1 to 1)? n n ■ n Is storage appropriate for cylinders? ❑ n ■ ❑ # Is de -chlorination substance stored away from chlorine containers? n n ■ n, Are the tablets the proper size and type? n ❑ ■ - ❑ Comment: Aqueous sodium bisulfite is used for dechlorination at Outfall 002. Are tablet de -chlorinators operational? n n ■ n Number of tubes in use? Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? n n ■ n Is flow meter calibrated annually? n n 00 Is the flow meter operational? n n ■ n (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ■ Comment: The facility staff must ensure that the flows at both Outfalls are measured and documented during the permit -required effluent sampling events. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ® ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? n n n If effluent (diffuser pipes are required) are they operating properly? n n ® n Comment: Only Outfall 001 was discharging at the time. of the inspection. DWQ staff performed pH, temperature, and TRC measurements at the time of the inspection. The results of the analyses were as follows: 8.63 s.u. (pH), 32.7degrees celsius, and 152 ug/L (TRC). The TRC effluent value exceeded the 17 ug/L permit limit and the 50 ug/L TRC compliance level currently being implementd by the Division. Page # 5 Southern Power Company Plant Rowan County 5755 NC Highway 801 Salisbury, NC 28147 Contact Number 704-278-6601 OCT — 1 2009 September 28, 2009 SOUTHERNAZk Mr. Wes Bell C®P� Surface Water. Protection Section 14, ''' "'' '`' " ''`" "'' energy to Serve Your World Suite 301 610 East Central Avenue Mooresville, NC 28115 RE: Southern Power; Plant Rowan County; General Wastewater Discharge Permit NCG500582 Dear Mr. Bell: As you are aware, Plant Rowan operates pursuant to General Wastewater Discharge Permit NCG500582 (effective date August 1, 2607). Section A(1) of the General Permit (Effluent Limitations and Monitoring Requirements), requires the facility to conduct semi-annual testing on water flow, temperature, residual chlorine, oil and grease, and pH. During an internal audit performed at the facility during the week of September 1, 2009, Southern Company personnel were unable to locate 2007 and 2008 sampling records for temperature. Although Southern Power is still working with its outside compliance vendor to see if these records were retained off -site, at this time these records are unavailable and it is unclear whether temperature was properly sampled for 2007 and 2008. All required sampling for permitted parameters was performed for 2009 and operational records for 2007 and 2008 indicate no temperature exceedances at the cooling tower. Since the audit, Plant Rowan compliance personnel have been counseled regarding the full scope of water quality sampling required under the facility's General Permit, and these sampling events/recordkeeping requirements have been input into Plant Rowan's work order management system. Accordingly, any reoccurrence of this problem is unlikely. Plant Rowan believes that this notification complies with NCDENR's "Enforcement Penalty for Self - Reported Violations" (dated Sept. 1, 1995, revised, July 2000). Based on the facts associated with this notification, (1) the deficiency was not due to lack of a good faith effort to comply,.(2) the deficiency was not done willfully, (3) the deficiency did not cause significant harm to the environment or risk public health, (4) Southern Power promptly and voluntarily disclosed the deficiency to the Department in writing, and (5) Southern Power took immediate and effective action to cease/remediate the violation. As to Item 4 of NCDENR's policy, we would note that Plant Rowan's General Permit does not include a requirement to report monitoring/recordkeeping problems at the facility, and therefore, this notification should be considered voluntary and consistent with NCDENR's self -disclosure policy. _Southern Power is committed to environmental compliance at all of its facilities, and trusts that this notification will fully address any past water quality monitoring/recordkeeping issues at Plant Rowan. As discussed above, we. believe we have instituted aggressive corrective action to prevent reoccurrence of similar events. If you have any questions or concerns, please call. incerely, Scott Dial Plant Manager OF WAIF I el .. er r NCDENR KEC, s, J S r North Carolina Department of Environment and Natural Resources `C ,ql�e� H� S{, Director iws o of er Quality September 7, 2007 Mr. James C. Walker NC DENR MRO 1775 Barringer Road M-Surface dater Protection Salisbury, NC 28147 Subject: NPDES Permit NCG500582 Southern Power Company Rowan County Dear Mr. Walker: I have.been asked to respond to your letter dated August 31, 2007, addressed to the Director of the Division of Water Quality. This letter raises two issues related to our NPDES permit program: The first regarding Public Notice for renewal of the Certificate of Coverage NCG500582, and the second regarding proposed changes'you would like to have made to the Certificate of Coverage. To address the first issue, an explanation is necessary. A General Permit, such as NCG500000 (Non Contact Cooling Water) is a blanket permit covering certain defined situations. The General Permit has a lifespan of five years, after which it expires and must be renewed. When General Permits are ready for renewal, they are required to be posted for Public Notice. There is a 30 day period for comments. NCG500000 expired on July 31, 2007, and was renewed on August 1, 2007. On May 15, 2007, the proposed renewal was published in the North Carolina State Register electronically, and notices were sent to 11 different newspapers across the State. We did receive a few comments from interested parties, which were considered in the renewal. Your local newspaper, The Salisbury Post, was not one of the 11 newspapers, but The Charlotte Observer was. Normally for a specific NPDES permit in Rowan County, we do post Public Notices in the Salisbury Evening Post, but for the Statewide notices for the General Permits, we selected only the 11 largest circulation newspapers across the state. When an application is made for coverage under a General Permit, a Certificate of Coverage (CoC) is issued. NCG500582 is such a CoC.. CoC's expire when the General Permit expires and must be renewed for another five years.. We do not post Certificates of Coverage for public notice on issuance or on renewal since the parent General Permit has already been posted. To address the. second issue, which is to request changes. to the CoC, we cannot accommodate this. The General Permit has already been issued, and the COC renewal has also been issued. Under the General Permit program, all permittees Have the same requirements, there are no changes allowed. However, if you read the permit NCG500000, I think you will find that what you are requesting is already in the permit. You can find the permit text on our website http://h2o.enr.state.nc.us/NPDES/. Click on "General Permits", then by NCG500000, click on "Permit Text". Go to Part II, Section B, item 5 on page 8. You should find the following text: N. C. Division of Water Quality / NPDES Unit Phone: (919) 733-5083, ext 595 1617 Mail Service Center, Raleigh, NC 27699-1617 fax: (919) 733-0719 . Internet: h2o.enr.state.nc.us DENR Customer Service Center: 1 800 623-7748 pp, 5. Properly Rights The issuance of this permit does not convey any properly rights in either real or personal properly, or any exclusive privileges, nor does it authorize any injury to private. property or any invasion of personal rights, nor any infringement of Federal, State or local laws or regulations. (emphasis added) If you believe that the permittee is in violation of the .NPDES General permit, you should contact the Mooresville Regional Office and discuss your concerns with a representative_ of the Surface Water Protection Section. The Regional Office personnel are responsible for enforcement of permit terms, limits and conditions. If you have any further questions regarding NPDES permits, please contact me. Sincerely, Jim McKay Eastern NPDES Program cc. Coleen H. Sullins Mooresville Regional Office/Surface'Water- Protection Section`, NPDES File __ pip James C. Walker 1775 Barringer'Road Salisbury, NC 28147 (704-636-8529) State of North Carolina Department of Environment and Natural Resources Division of Water Quaff ty Coleen Sullis, Dire or 1617 Mail Servi.c Center Raleigh, NC 2 99-1617 August 31, 2007 RE: Permit Number NCG500582 Dear Coleen, M _ �OV SEP D.. of .�`2oo, Q ma's pgG/7y t a �. SEP 2007 I.wish to bring to your attention the manner in which NPDES Wastewater Discharge Permit Number NCG500582 was issued. = I had talked with Mr. Michael Parker at the Mooresville office back in 2003. i told him then that I wanted to object to the renewal of this permit at it was written. He told me to file my comments when the time came for renewal and a public notice would be in the paper to alert the public as.to its renewal. I again visited the Mooresville office and spoke with Dee Broder in September of 2006. This was to check on the status of this permit as the permitted company (Progress Energy to Southern Power) had changed hands. I also told her I wanted to comment on my objection to renew this permit as it,was written to protect us and our property. After looking these companies up, we talked and she told me the comment period for this permit would be advertised prior to being reissued and to file my comment/objection at that time. The NPDES Administrative Procedures require that the public be notified and allowed to comment on NPDES permit applications and renewals. The published procedures for public notification were not followed, as it never appeared in our local paper, The Salisbury Post. On August 03, 2007, I visited the Mooresville office to check on the status of this permit thinking it had.run out since no notice was given concerning its renewal. At this time, I find out it had been renewed without any public disclosure and therefore, I was denied my right to comment on this renewal. Since I was unable to comment before its renewal, I think it is right that I should be able to petition you now for an addendum to be attached to this permit stating "No discharge covered under this permit is to touch, damage or devalue the adjacent Walker property in any way." That's it, nothing else. My objection, without this new clause included, is based on the property rights clause in the permit where it states, "The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize arty injury to private property or any invasion of personal rights, nor anv infringement of Federal,.State or local laws or regulations." This is supported and sustained by the worth Carolina General Statue 14-128 which states in part, "Anv person, not being on his own lands', who shall without the consent of the owner thereof, willfully comrait any damage, injury, or spoliation to or upon any tree, wood, Underwood, timber, garden, crops, vegetables, plants, -lands, springs, or any. other matter or thing growing or being thereon, or who cuts, breaks, injures, or removes any tree, plant, or flower, shall be guilty of a Class I Misdemeanor:.." This Southern Power Company takes pride in reporting that their policy is toward community service and to being a good neighbor. .I really do not, see how they could object to us wanting to protect our property and for them to obey the law. I feel I have fully stated my case for you and ask that our stated addendum be made a part of NPDFS Wastewater Discharge Permit-NCG500582 issued to Southern Power. Sincerely, Dar-- James c. Walker NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor July 23, 2007 Terry Syverson Southern Power Company 5755 NC Highway 801 Salisbury, NC 28147 William G. Ross, Jr., Secretary Coleen H. Sullins, Director Subject: Renewal of coverage / General Permit NCG500000 Rowan County Plant .Certificate of Coverage NCG500582 Rowan County Dear Permittee: In accordance with your renewal application. [received on February 5, 20071, the Division is renewing Certificate of Coverage (CoC) NCG500582 to discharge under NCG500000. This CoC is issued pursuant to the requirements of North Carolina General Statue 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated May 9, 1994 [or as subsequently amended]. If any parts, measurement frequencies or sampling requirements contained in this General Permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, the certificate of coverage shall be final and binding. Please take notice that this Certificate of Coverage is. not transferable.except after notice to the Division. The Division may require modification or revocation and reissuance of the certificate'of coverage. Contact the Mooresville Regional Office prior to any sale or transfer of the permitted facility. Regional Office staff will assist you in documenting the transfer of this CoC. This permit does not affect the legal requirements to obtain other permits which may be required by. the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have -any questions concerning the requirements of the General Permit, please contact Jim McKay [919 733-5083, extension 595 or james.mckay@ncmail.net].. Sincerely, . `�. WmMfg �y"t^`-`✓ � t2 �.- .(� ti+. ` , V ram: "'-� , MOO ="LLE 1�u� or Coleen H. Sullins JUL f 3k cc: Central Files ooresviille Re oval O+ f ice /Surface Water Protectio a tw NPDES file but 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One 512 North Salisbury Street, Raleigh, North Carolina 27604 NofthCarohna Phone: 919 733-5083 / FAX 919 733-0719 / Internet: wwwmwaterquality.org Nahmallff I - An Equal Opportunity/Affirmative Action Employer — 50% Recycled /10%Post Consumer Paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY _ GENERAL PERMIT NCG500000 CERTIFICATE OF COVERAGE NCG500582 TO DISCHARGE NON -CONTACT COOLING WATER, COOLING TOWER AND BOILER BLOWDOWN, CONDENSATE AND SIMILAR WASTEWATERS UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted bythe North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Southern Power Company is hereby authorized to discharge Non -contact Cooling Water, Boiler Blowdown, Cooling Tower Blowdown & Condensate from a.facility located at Rowan County Plant 5755 NC Hwy 801 Salisbury Rowan. County to receiving waters designated as Second Creek in subbasin 30704 of the Yadkin River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This ,certificate of coverage .shall become effective August 1, 2007. This Certificate of Coverage shall remain in effect for the. duration of the General Permit. Signed this day July 23, 2007. for Coleen H. Sullins, Director -Division of Water Quality By Authority of the Environmental Management Commission To: Permits and Engineering Unit Water Quality Section Attention: Charles Weaver SOC PRIORITY PROJECT: No Date: June 8, 2007 NPDES STAFF REPORT AND RECOMMENDATIONS County: Rowan NPDES Permit No.: NCG500582 PART I - GENERAL INFORMATION 1. Facility and address:. Southern Power Company (formally Rowan County Power, LLC) 5755 NC Hwy. 801 Salisbury, N.C. 28144 2. Date of investigation: June .6, 2007 3. Report prepared by: Michael L. Parker, Environmental Engineer II 4. - Person contacted and telephone number: John Cheek, Scott Dial, (704) 278-6601 5. Directions to site: From the jct. of US Hwy. 70 and NC Hwy. 801 in westernRowan County, travel north on NC Hwy. 801 z 1.0 mile. The entrance to the site is on the right (east) side of Hwy 801. 6. Discharge point(s), list for all discharge points: - outfall 001 outfall 002 Latitude: 350431 55" Latitude: 350 43' 18" Longitude: 80' 35' 55" Longitude: 800 35' 27" Attach a USGS Map Extract and indicate treatment plant site and discharge point on map. USGS Quad No.: E 16 NE 7. Site size and expansion area consistent with application: Yes. There is ample room for WWTP construction, if necessary. 8. Topography (relationship to flood plain included): The site is gently rolling with slopes ranging from 3-12%. The plant site is not located in a flood plain. 9. Location of nearest dwelling: Approx. 500+ feet from the plant site. "4N Page Two 10. Receiving stream or affected surface waters: UT to North Second Creek — outfall 001; North Second Creek - outfall 002 a. Classification: C (both outfalls) b. River Basin and Subbasin No.: Yadkin 030706 C. Describe receiving stream features and pertinent downstream uses: The area both upstream and downstream is generally rural in nature with agriculture being the primary use, however, there is one large industrial discharger = 2/3 mile upstream (Kosa - NC0004944). PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS Outfall 001 Outfall 002 1. a. Volume of Wastewater: 0.240 MGD 250 GPD b. What is the current permitted capacity: There is no capacity listed in the permit. C. Actual treatment capacity of current facility (current design capacity): N/A d. Date(s) and construction activities allowed by previous ATCs issued in the previous two years: There have been no ATCs issued in the past two years. e. Description of existing or substantially constructed WWT facilities: The applicant operates dechlorination facilities to remove TRC prior to discharge. f. Description of proposed WWT facilities:.The applicant does not propose any additional WWT facilities at this time. The discharge consists of non -contact cooling water from existing cooling towers. g. Possible toxic impacts to surface waters: Toxic impacts are possible with biocides, corrosion inhibitors, chlorine, and algaecides added to the waste stream. 2. Residual handling and utilization/disposal scheme: There are no residuals generated at this facility. 3. Treatment Plant Classification: N/A 4. SIC Code(s): 4911 Wastewater Code(s): 14 MTU Code(s): N/A PART III - OTHER PERTINENT INFORMATION Is this facility being constructed with Construction Grant Funds or are any public monies involved? No. Public monies are not being used in the construction of this facility. 2. Special monitoring or limitations (including toxicity) requests: None pending approval by the Toxicity Unit of the chemical additives included in this COC renewal request. V. Page Three 3. Important SOC/JOC or Compliance Schedule dates: This facility is neither under an SOC nor is one being considered at this time. 4. Alternative Analysis Evaluation a. Spray Irrigation: Insufficient area, shallow soils. b. Connect to regional sewer system: There is a package WWTP within the service area of this proposed facility, however, an expansion of this plant would be necessary before it could accept the existing waste stream. Also the cooling water may be detrimental to the operation of the WWTP since the cooling water waste stream would dominate the plant's influent resulting in an unfavorable F/M ratio. C. Subsurface: Insufficient area, shallow soils. d. Other disposal options: None that we are aware: PART IV - EVALUATION AND RECOMMENDATIONS Southern Power Company currently operates a combustion turbine electrical generation facility in western Rowan County. A COC has been issued for this facility (NCG500582) for the discharge of wastewater from an evaporative cooling process for the combustion turbines. All domestic wastewater is disposed of on -site via subsurface disposal permitted through the Division of Environmental Health. Other wastewater sources that may have pollutants (such as oil/grease) are collected for disposal and then hauled off -site to a waste oil reclamation facility. Pending a technical review and approval of the renewal application and supporting information submitted with this request, it is recommended that the COC be reissued as requested. hAdsrldsr071soouthempwr.dsr Signature of Report Preparer Water Qual' I� ional Supervisor Date ENSR 4701 Cox Road, Suite 200, Glen Allen, VA 23060 T 804-290-7920 F 804-290-7921 www.ensr.aecom.com February 1, 2007 Mr. Charles H. Weaver, Jr. NC DENR / DWQ / NPDES 1617 Mail Service Center Raleigh, North Carolina 27699-1617 ENSR IAECOM _ �_`�.:,�;�"C;h,•-=tom ` � MAR 0 6 2007 Subject: Notice of Renewal Intent Application General Permit NCG500000 Existing Certificate of Coverage NCG500582 �' 4l A �`�o E Iu�0 S" _ -_ Dear Mr. Weaver: On behalf of Southern Power Company, ENSR is pleased to submit this Notice of Renewal Intent Application for General Permit NCG500000, Existing Certificate of Coverage NCG500582 for the Plant Rowan County power station. The current permit became effective on August 1, 2002 and will expire at midnight on July 31, 2007. The Plant Rowan County power station is located at 5755 NC HWY 801, Salisbury, NC 28147 and includes simple -cycle natural gas combustion turbines, combined cycle combustion turbines, switch, and substation yards containing the necessary supporting equipment and systems needed for operation. Specifically, the station contains five combustion turbine units, one steam turbine unit and cooling towers with associated water treatment chemicals. Thy i.-11.- Ali^^ :.J�v �.J.J:i:.:�.�1 F.:r ..i:.;i! ^� ..F^..v.. p.�l h..:1,.. h_ A ffach.. b- 4 Inn —, 44 ...v . .. i'-y' 1'r..�iL... .....viCw .i i:'v :iiG•... ..... rG.... :....... Vy ...........7i --. .:i :........ ........• -a: aii.. iy i, 2007 Notice of Renewal Intent: 1. Item 3(a) — Description of Discharge 1. Outfall 001 discharges from a storm water retention pond to an unnamed tributary of North Second Creek. See Attachment 2 — Site Map. 2. Outfall 002 discharges directly to North Second Creek. 2. Item 3(c) Other —Description of Discharge Outfall 001 1. Storm water which accumulates in an outdoor retention pond located adjacent to the cooling towers and chemical storage areas. See Attachment 2 — Site Map. 2. Wastewater from operational systems during infrequent draining of various process units, piping, components and storage tanks during maintenance and operational activities (i.e. circulation water, steam drain blowdown, hotwell, gland Seal, heat -recovery steam generator (HRSG), and demineralized water). See Attachment 3 —April 26- and June 18, 2004 correspondence. Outfall 002 1. Non -contact cooling water. 2. Water conditioning products (i.e. Corrshield'MD4100, Propylene Glycol, Sodium Hypochlorite, Continuum AEC3108 and Spectrus DT 1404). 3. Wastewater from operational systems during infrequent draining of various process units, piping, components and storage tanks during maintenance and operational activities (i.e. circulation water, steam drain blowdown, hotwell, gland seal, HRSG, and demineralized water). See Attachment 3 —April 26 and June 18, 2004 correspondence. 4. Blowdown wastewaters (cooling tower and boiler). Mr. Charles H. Weaver, Jr. February 1, 2007 Page 2 3. Items 4 and 5 — Corrosion Inhibitors See Attachment 3 for correspondence from Plant Rowan County to the North Carolina Department of Natural Resources, Division of Water Quality (NC DENR DWQ) regarding the approval for use of specific corrosion inhibitors (i.e. Corrshield MD4100 and Propylene Glycol). The facility also uses Sodium Hypochlorite and Continuum AEC3108 as water conditioning products in addition to Spectrus DT 1404 (sodium bisulfite) to eliminate residual chlorine. MSDS sheets for Sodium Hypochlorite, Continuum AEC3108 and Spectrus DT 1404 are included in Attachment 4. In addition, completed Biocide 101 Forms and MSDS sheets will be submitted to the Aquatic Toxicology Unit for Sodium Hypochlorite, Continuum AEC3108 and Spectrus DT 1404. 4. Item 6 — Wastewater Treatment Outfall 001 — A storm water retention pond is located adjacent to the cooling towers. The pond collects surface water runoff from the area surrounding the cooling towers and water chemical storage areas. Due to potential impacts from the adjacent cooling towers and chemical storage areas to storm water located within the pond, the discharge is monitored under this waste water permit. The pond is specifically designed to provide storm water retention capabilities and not serve as.wastewater treatment. The pond has an overflow discharge pipe which discharges to an unnamed tributary of North Second Creek. Outfall 002 — Wastewater treatment associated with Outfall 002 is limited to the use of sodium bisulfite for the elimination of chlorine. 5. Item 7 — Discharge Frequency The discharge for 001 is intermittent depending on the amount of rainfall. Historically the pond will discharge a small amount of water (less than 25 gallons per day) during normal conditions. The pond will discharge more water (approximately 250 gallon a day) during heavy rain events. The discharge for 002 which is continuous during intermittent plant operations ranges from 150,000 gallons per day under normal conditions up to 240,000 gallons per day during full plant operation (24 hours a day 7 days a week). The plant typically does not operate every day due to limitation imposed by the air permit (i.e. 2,000 hours per year .for each turbine). Please feel free to contact either Mr. Hare at 804-516-9551 or Mr. Syverson at 704-450-9862 if you have any questions about this letter. Sincerely yours, Robert Hare Project Manager rhare(@-ensr.aecom.com Cc: Terry Syverson — Plant Rowan County Laura Rose Senior Project Manager IroseCaD-ensr.aecom.com Attachments: Attachment 1— January 31, 2007 Notice of Renewal Intent Attachment 2 — Site Map Attachment 3 — Agency Correspondence Attachment 4 — MSDS Sheets Attachment 5 — Authorization for Representatives ENSR I AECOM Mr. Charles H. Weaver, Jr. February 1, 2007 Page 3 Attachment 1 January 31, 2007 Notice of Renewal Intent ENSR I AECOM FLB 0 5 Z007 NCDENR._ - - North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director NOTICE OF RENEWAL INTENT Application for renewal of existing coverage under General Permit NCG500000 Existing Certificate of Coverage (CoC): NCG500 582 (Please print or type) 1) Mailing address' of facility owner/operator: Company Name Southern Power Company Owner Name Southern Company Street Address 5755 NC 801 HWY City Salisbury State NC ZIP Code 28147 Telephone Number 704-278-6603 Fax: 704-278-6620 Email address tdsyyers@southernco.com Address to which all permit correspondence should be mailed .q Uocatdon o� ia�iii�y producing aiscnarge: Facility Name Plant Rowan County Facility Contact Terry Syverson Street Address 5755 NC 801 HWY City Salisbury State NC ZIP Code 28147 County Rowan County Telephone Number 704-278-6603 Fax: 704-278-6620 Email address tdsyvers@southernco.com 3) Description of Discharge: *See Cover Letter a) Is the discharge directly to the receiving stream? ! Yes ■ No (If no, submit a site map with the pathway to the potential receiving waters clearly marked. This includes tracing the pathway of the storm sewer to the discharge point, if the storm sewer is the only.viable means of discharge.) b) Number of discharge outfalls (ditches, pipes, channels, etc. that convey wastewater from the property): Two (2) c) What type of wastewater is discharged? Indicate which discharge points, if more than one. ■ Non -contact cooling water Outfall(s) #: 002 ■ Boiler Blowdown Outfall (s) #: 00L Page 1 of 3 NCG500000 renewal application ■ Cooling Tower Blowdown Outfall (s) #: 002 ■ Condensate Outfall (s) #: 002 ■ Other Outfall (s) #: 001 and 002 (Please describe "Other") See Cover Letter d) Volume of discharge per each discharge point (in GPD): #001: 250 #002: 240,000 (max)#003: #004 4) Please check the type of chemical [s] added to the wastewater for treatment, per each separate discharge point (if applicable, use separate sheet): See Cover Letter ■ Chlorine ■ Biocides ■ Corrosion inhibitors ! Algaecide ❑ Other ❑ None - - - - _. - - - - - - ----- -- - - -- ----- 5) If any box in item (4) above [other than None] was checked, a completed Biocide 101 Form and manufacturers' information on the additive must be submitted to the following address for approval: See Cover Letter NC DENR / DWQ / Environmental Sciences Section Aquatic Toxicology Unit 1621 Mail Service Center Raleigh, NC 27699-1621 6) Is there any type of treatment being provided to the wastewater before discharge (i.e., retention ponds, settling ponds, etc.)? ■ Yes ❑ No See Cover Letter (If yes, please include design specifics (i.e., design volume, retention time, surface area, etc.) with submittal package. Existing treatment facilities should be described in detail. ) 7) Discharge Frequency: See Cover Letter The discharge is: ❑ Continuous ,■ Intermittent ❑ Seasonal* i) If the discharge is intermittent, describe when the discharge will occur: During cooling tower blowdown activities ii) *Check the month(s) the discharge occurs: ❑ Jan ❑ Feb ❑ Mar. ❑ Apr ❑ May ❑ Jun ❑ Jul ❑ Aug. ❑ Sept. ❑ Oct. ❑ Nov. ❑ Dec. b) How many days per week is there a discharge? c) Please check the days discharge occurs: ❑ Sat. ❑ Sun. ❑ Mon. ❑ Tue. ❑ Wed. ❑ Thu. ❑ Fri. 8) Receiving stream a) To what body or bodies of water (creek, stream, river, lake, etc.) does the facility discharge wastewater? North Second Creek b) Stream Classification: Fresh Water — Class C Page 2 of 3 NCG500000 renewal application Additional Application Requirements: The following information must be included in triplicate [original + 2 copies] with this application or it will be returned as incomplete. ➢ Site map. If the discharge is not directly to a stream, the pathway to the receiving stream must be clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point. ➢ Authorization for representatives. If this application will be submitted by a consulting engineer (or engineering firm), include documentation from the Permittee showing that the consultant submitting the application has been designated an Authorized Representative of the applicant. Certification I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: gobe.C� �. �Gt'e Jf Title: rd , e CA- Manad e (' M (Signature of Applicant) OZ v O (Date Signed) North Carolina General Statute 143-215.6 b (i) provides that: --_ Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (1 S U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) asasaeaeasasaeasasarasa This Notice of Renewal Intent does NOT require a separate fee. The permitted facility already pays an annual fee for coverage under NCG500000. asaeasasasasasasasasasa Mail the original and two copies of the entire package to: Mr. Charles H. Weaver NC DENR / DWQ / NPDES 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Page 3 of 3 Mr. Charles H. Weaver, Jr. February 1, 2007 Page 4 Attachment 2 Site Map ENSRIAECOM Mr. Charles H. Weaver, Jr. February 1, 2007 Page 5 Attachment 3 Agency Correspondence ENSR I AECOM �JR,?-0114 I ® Filed by PCD I Progress Energy U, Progress Energy April 26, 2004 Aisha Lau Storm Water and General Permits Unit Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Subject:, Progress Energy, Inc. Rowan County Power, LLC Certificate of Coverage NCG500582 Amendment to NOI/NPDES General Permit Application Dear Ms. Lau: Rowan County Power, LLC is proposing to amend their April 11, 2002 Notice of Intent/NPDES General Permit application for the subject facility. The amendment consists of the following items: 1) It has, come to our attention, through the Environmental Protection Agency's (EPA) Enforcement and Compliance History Online (ECHO) database that our permit application lists the wrong zip code for the Vf,lID ty. awaL, Makearc. uac appi'brc71'iaics rnanvPc in vn.�rnnn�Ae r.. �eACC4 a,._ .,____. �•. r ges in yol rec-c-wa — reAlL.HL ulc wtject Lip code of 28147 for All — the facility. The following address listed below is the address to which all permit correspondence should be mailed. Rowan County Power, LLC 5755 NC Route 801 Salisbury, NC 28147 2) In addition there may be,several potential drainages of process units, piping, components and storage tanks during very infrequent maintenance and operational activities. We would like to amend Attachment 2 Page 3 paragraph 3 of the Notice of Intent referenced above to reflect these potential discharges from several different operating systems within the plant. The amended paragraph should read as follows: There will be infrequent draining of various process units, piping, components and storage tanks during maintenance and operational activities. The drainages will include but not be limited to wastewater from the following operational systems: circulation water, , closed cooling water, boiler water, steam drain blowdown, hotwell, gland seal, heat -recovery steam generator (HRSG), cooling tower and demineralized water. The characteristics of the wastewater generated from these activities should be within the boundaries of those wastewaters contemplated by the activities addressed by NCG500000. The drainage of these various units may be to ground or may be discharged via 001 or 002 depending upon the characteristics of the drainage. Rowan County Power, LLC 5755 NC 801 Hwy Salisbury. NC 28147 wing additional water conditioning products are used at the facility and with the above described discharges may be discharged to surface waters via outfall 001 or outfall 002. They would be via air vents or pressure relief valves in the closed cooling water system as a safety to ensure the system is not full of air or'over pressurized. Discharges are expected to occur ;d ;in Id MD4100 — A water based corrosion inhibitor in the closed cooling water system Propylene Glycol —A water based coolant in the closed cooling water and boiler water systems The following documents are transmitted with this letter: • MSDS for the Products Steve Cahoon of our Environmental Services Section has spoken with Mr. Todd. Christenson of e Aquatic Toxicology Unit pertaining to the potential toxic effects of above referenced water conditioning products on the aquatic life. Mr. Christenson reviewed the MSDS sheets of the products and concluded both -products were innocuous, especially with very infrequent discharges. He indicated that no biocide worksheets needed to be completed for the products, as neither product would be toxic to aquatic life. As always we appreciate your Icooperation in responding expeditiously to our permitting needs. If there are any questions about this information please contact. Steve Cahoon at (9.19) 362-3568 (steve cahoon(awanmail.com) I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather <<�e s.nrcnn -r arsons who manage the r .•,;_ ....—fffoi% Ra.1 d on my iiwuii y :,� ....., �,....._.. p and evaluate the infJrmacivn )w.,.....e- system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my. knowledge and belief, true, accurate, and complete. I am aware that there are lion, including the possibility of fines and imprisonment significant penalties for submitting false informa for knowing violations. Since ly, Small plant Manager Attachments . c: Todd Christenson ! with attachments Division of Water Quality Aquatic Toxicology Unit 1621 Mail Service Center . Raleigh, NC 27699-1621 N P D-0115 i B Filed by PCD I Progress Energy C� Progress.. Energy June 18, 2004 Aisha Lau Storm Water and General Permits Unit Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Progress Energy, Inc. Rowan County Power, LLC Certificate of Coverage NCG500582 -Modification to-4/26/04 Amendment to NOI/NPDES General Permit Application _-._.: _-.....__:...:.:.... .:::.:.... _...:.. Dear Ms. Lau This letter serves to modify our April 26. 2004 Amendment to NOI/NPDES General Permit Application letter. This modification removes the condensate vacuum skid from the.last paragraph of the 1# page of that letter. The modified paragraph should read as follows: There will be infrequent draining of various process units, piping, components and storage tanks during rRairtenance and o_m-arional activities. "I ne drainagcs will include but not be iirmted to wastewater rrofl;. the following operational systems: circulation water, closed cooling water, boiler water, steam drain blowdown, hotwell, gland seal, heat -recovery steam generator (iMG), cooling tower and demineralized water. The characteristics of the wastewater generated from these activities should be within the boundaries of those wastewaters contemplated by the activities addressed by NCG500000. The drainage of these various units may be to ground or may be discharged via 001 or 002 depending upon the characteristics of the drainage. All other aspects of the April 26, 2004 letter remain the same. As always'we appreciate your cooperation in responding expeditiously to our permitting needs. If there are any questions about this information please contact Steve Cahoon at (919) 362-3568 (steve.cahoon a@pgmmail.com) Rowan County Power. I.I.C. 5755 NC 801 Hwt Salisbury. NC 28147 Mr. Charles H. Weaver, Jr. February 1, 2007 Page 6 Attachment 4 MSDS Sheets ENSR I AECOM GE Betz, Inc. Material Safety Data Sheet 4636 Somcrton Road Trevose, PA 19053. - Issue Date: 09-JUL-2002 Business telephonc:.(215) 355-3300 EMERGENCY TELEPHONE (Health/Accident): (800) 877-1940 I PRODUCT IDENTIFICATION PRODUCT NAME: SPEC'TRUS DT1404 " PRODUCT APPLICATION ARF,A: CHEMICAL. CLEANING CONIPOUND. 2 COMPOSITIOti / INFORMATIO` ON INGREDIENTS Information for spec:fxc product :ngredients as required by the U.S. OSHA HAZARD CCMMCNICATION STANDARD is :fisted. Refer to additional sections o! this MSDS for our assessment of the po-entia: hazards of this for-ulation. HAZARDOUS INGREDXENTe: CASb CHEMICAL NAME a 7631-90-5 SODIUM BISULFITE May be corrosive in aqueous solutions.; irritant; sensitizer (skin and respiratory); may generate S02 No component is considered to be a carcinogen by the National Toxicology Program, the International Agency for Research or. Cancer, or the Occ%:paticral Safety and Health Adninistration at OSHA thresholds for carcinogens. 3 HAZARDS IDENTIFICATION' •.••ww•••wan••••aa••••aa•a•••••a•►•aa••••r•♦•a••w•••••aa•••awaa••wa•a•••w•ww•••• EMERGENCY OV$RVIEW WARNING May cause moderate irritation to the skip.. Skin sensitizer. Severe irritant to the eyes. Dusts or mists are irritating to mucous membranes. Repeated exposure may result in respiratory sensitization. DOT hazard: Corrosive to steel - Emergency Response Guide 0154 odor: Mild; Appearance: colorless To Yellow, Liquid Fire fighters should wear positive pressure self-contained breathing apparatus(full face -piece type). Proper fire -extinguishing media: dry chemical, carbon dioxide, foam or water ••��rrr�r��r�rrrrr�rrr�rrrr��rrrrrrrrrrrrrrrrrrrrrrrrrrrr Nrrrr�rrrrr�rrr+rw�rr• POTENTIAL HEALTH EFFECTS ACUTE SKIN EFFECTS: Primary route of exoosure;.May cause moderate irritation to the skin. Skin sensitizer. ACUTE EYE EFFECTS: Severe irritant.to the eyes. ACUTE RESPIRATORY EFFECTS. Dusts or mists are irritating to mucous membranes. Repeated exposure may result in respiratory sensitization. INGESTION EFFECTS:... May cause gastrointestinal irritation. very large doses may cause diarrhea, depression, colic and death: May also'cause severe allergic reactions in sensitive individuals. TARGET ORGANS: Prolonged or repeated exposures may cause primary irritant dermatitis, skin sensitization, and/or allergic respiratory reactions. MEDICAL CONDITIONS AGGRAVATED: Asthma. SYMPTOMS OF EXPOSURE: Inhalation may cause eye, nose, throat and lung irritation and possible respiratory sensitization or asthma. Skin contact may cause moderate irritation to severe burns and sensitization. 4 FIRST AID MEASURES SKIN CONTACT: wash thoroughly with soap and water. Remove contaminated clothing. Thoroughly wash clothing before reuse. Get medical attention if irritation develops or persists. EYE CONTACT: Remove contact lenses. hold eyelids apart. Immediately flush eyes with plenty of low-pressure water for at least 25 minutes. Get immediate medical attention. xNHnzATION: If nasal, throat or lung irritation develops - remove to fresh air and get medical attention. INGESTION: Do not feed anything by mouth to an unconscious or convulsive victim. Do not induce vomiting. Immediately contact physician. Dilute contents of stomach using 3-4 glasses milk or water. NOTES TO PHYSICIANS: No special instructions 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: Fire fighters should wear positive pressure self-ccntai.ed breathing apparatus (full face -piece type). EXTINGUISHING MEDIA: dry chemica:, carbon dxcxide, foam or water HAZARDOUS DECOMPOSITION PRODUCTS: Therral decomposition (destructive fires;vieids e:ementa: oxides. FLASH POINT: > 20CF > 93C F-M(CC) MISCELLANEOUS: Corrosive to steel '42693;Enercency Response Guide 11:54 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: Venti:ate area. Cse specified protective equipment. Cortai and absorb on absornent mat"r:a:. Place in waste disposa: container. :lust: area Rita water. Wer area may be s'ippery. Spread sand/qri DISPOSAL INSTRUCTIONS: " water contaminated wit;, :^is product may be sent _.__... Y ••- to a an_tary sewer treatment facil:ty,in accordance with any leca:•agreement,a permitted waste nreatment fac_:ity or discharged under a permit. Product as is - Lrcinera-.e or land dispose in an approved landfill. 7 HANDLING & STORAGE HANDLING: Vent carefully before Opening. Sulfur dioxide can be forced during the normal use and handling of this product.. STORAGE. Keep containers closed when not in use. Do not freeze. I` frozen, thaw and t::x comp letely "ricr to use. 8 EXPOSURE CONTROLS / PERSONAL PROTECTION cxzMzcAL NAME. EXPOSURE LIMITS SODIUM SISUL?I'i E PEL ;OS;IA; : 5 MG/M3 ^.LJ (ACG:k): 5 MG/M3 ENGINEERING CONTROLS: Adequate verti:atio.: to mainta;n air contaminants below exposure limits. PERSONAL PROTECTIVE EQUIPMENT. Use protective equipment in accordance with 29CFR 191C Su.boart I RESPIRATORY PROTECTION: A RES?:RA—oRY PROTECT:Ol; PROGRAM 71HAT VZ-r S OSSA,S 29 CFR 1910.134 AND ANS: 288.2 REQU:REMENTS MUST BE FOLLOWED Wis.vEVER WORKPLACr CONDIT:ONS. WAR-%kN T A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITA:h USE LIN.:TA' IONs ASSOCIATEi WITH :r:s EQU'IPMEN^. OR ELSE USE SUPPLED AIR-RRSP:RATCRS. If air -purifying respirator use is appropriate, use a respirator wit: acid gas cartridges and dust/mist pre:filters. SKIN PROTECTION: gauntlet -type neoprene gloves, the-lica; resistant apron-- wash off after each use. Replace as necessary. EYE PROTECTION: splash proof chemical goggles, face shield . 9 PHYSICAL & CHEMICAL PROPERTIES Specific Gray.(70F,21C) 1.360 Vapor Pressure (mmHG) Freeze Point (F) 27 Vapor Density (air-1) Freeze Point (C) . - -3 Viscosity(cps 70F,21C) 20 ; Solubility (Water) Odor Mild Appearance Colorless To Yellow Pysical State Liquid Flash Point P-M(CC) > 20OF > 93C . pH. As Is (approx. ) 3.8 Evaporation Rate (Ether-1) a 1.00 NA-_ not applicable ND = not determined - 18.0 c 1.00 200.0 10 STABILITY & REACTIVITY STABILITY: Stable under normal storage conditions. HAZARDOUS POLYMERIZATION: Will not occur. INCOMPATIBILITIES: May react with strong oxidizers. DECOMPOSITION PRODUCTS: Thermal decomposition (destructive fires) yields elemental oxides. INTERNAL PUMPOUT/CLEANOUT CATEGORIES: agn 11 TOXICOLOGICAL INFORMATION Oral LD50 RAT: 2,OOC mg/kg Dermal LD50 RABBIT: >2,000 mg/kg NOTE - Estimated value 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY Daphnia macna 48 Hour Static Renewal Bioassay LC50o 175; No Effect Level- 125 me/L Fathead Minnow 96 Hour Static Renewal Bioassay LC50. 175; No Effect Level. 125 mg/L Rainbow Trout 96 Hour Static Renewal Bioassay (pH adjusted) LC50. 330; No Effect Level. 125 mg/L BIODEGRADATION Product contains only inorganics that are not subject to typical biological degradation.. Assimilation by microbes may.occur in waste treatment or the environment. 13 DISPOSAL CONSIDERATIONS GE Betz GE Betz, Inc. Material Safety Data Sheet 4636 Somerton Road Trevose, PA 19053 Issue Date: 24-MAR-2005 Business telephone: (215) 355-3300 EMERGENCY TELEPHONE (Health/Accident): (800) 877-1940 1 PRODUCT IDENTIFICATION PRODUCT NAME: CONTINUUM AEC3108 PRODUCT APPLICATION AREA: WATER -BASED DEPOSIT CONTROL AGENT. 2 COMPOSITION / INFORMATION ON INGREDIENTS f product ingredients as recruire d yy the iufOiivativn for spec -if p 1 �n `' U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to additional sections of this MSDS for our assessment of the potential hazards of this formulation. HAZARDOUS INGREDIENTS: CAS# CHEMICAL NAME 1310-73-2 SODIUM HYDROXIDE (CAUSTIC SODA) Corrosive; toxic (by ingestion). 7631-95-0 SODIUM MOLYBDATE (MOLYBDIC ACID,DISODIUM SALT) Potential irritant (respiratory); potential lung toxicity No component is considered to -be a carcinogen by the National Toxicology Program, the International Agency for Research on Cancer, or the Occupational Safety and Health Administration at OSHA thresholds for carcinogens. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW . CAUTION May cause slight irritation to the skin. May cause moderate irritation to the eyes. Mists/aerosols may cause irritation to upper respiratory tract.. DOT hazard is not applicable Emergency Response Guide is not applicable Odor: Slight; Appearance- Amber, Liquid Fire fighters should wear*positive pressure self-contained breathing apparatus (full face -piece type). Proper fire -extinguishing media: dry chemical, carbon dioxide, foam or water POTENTIAL HEALTH EFFECTS ACUTE SKIN EFFECTS: Primary route of exposure; May cause slight irritation to the skin. ACUTE EYE EFFECTS: May cause moderate irritation to the eyes. ACUTE RESPIRATORY EFFECTS: Mists/aerosols may.cause irritation to upper respiratory tract. INGESTION EFFECTS: May cause gastrointestinal irritation. TARGET ORGANS: Prolonged or repeated exposures may cause toxicity to the lung. MEDICAL CONDITIONS AGGRAVATED: Not known. vYvw?Tv::►Ci OF EXPOSURE: May cause redness or itching of skin. 4 FIRST AID MEASURES SKIN CONTACT: wash thoroughly with soap and water.',Remove contaminated clothing. Get medical attention if irritation develops or persists. EYE CONTACT: Remove contact lenses. Hold eyelids apart. Immediately flush eyes with plenty of low-pressure water for at least 15 minutes. Get immediate medical attention. INHALATION: If nasal, throat or lung irritation develops - remove to fresh air and get medical attention. INGESTION: Do not feed anything by mouth to an unconscious or convulsive victim. Do not induce vomiting. Immediately contact physician. Dilute contents of stomach using 3-4 glasses milk or water. NOTES TO PHYSICIANS: No special instructions 5 . FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: Fire fighters should wear positive pressure self-contained breathing apparatus (full face -piece type).. EXTINGUISHING MEDIA: d chemical carbon dioxide, foam or water rY , HAZARDOUS DECOMPOSITION PRODUCTS:. Thermal decomposition (destructive fires) yields elemental oxides. FLASH POINT: > 20OF > 93C P-M (CC) 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND.SPILL CONTAINMENT: Ventilate area. Use specified protective equipment. Contain and absorb on absorbent material. Place in waste disposal container. Flush area with water. Wet area may be slippery. Spread sand/grit. DISPOSAL INSTRUCTIONS: Water contaminated with this product may be sent to a sanitary sewer treatment facility,in accordance with any local agreement,a permitted waste treatment facility or discharged under a permit. Product as is - Incinerate or land dispose in an approved landfill. . 7 HANDLING & STORAGE HANDLING: Alkaline. Do not mix with acidic material. STORAGE: Keep containers closed when not in use. Store in cool ventilated location. Store away.'from oxidizers. 8 EXPOSURE CONTROLS / PERSONAL PROTECTION ►sX7POS MmE T=AITS CHEMICAL NAME SODIUM HYDROXIDE (CAUSTIC SODA) PEL (OSHA): 2 MG/M3 TLV (ACGIH):.2 MG/M3(CEILING) SODIUM MOLYBDATE (MOLYBDIC ACID,DISODIUM SALT) PEL (OSHA): 5 MG/M3(AS Mo) TLV (ACGIH): 0.5 MG/M3(AS Mo) RESPIRABLE FRACTION ENGINEERING CONTROLS: Adequate ventilation to maintain air contaminants below exposure -limits. PERSONAL PROTECTIVE EQUIPMENT: Use protective.equipment in accordance with 29CFR 1910 Subpart I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR -RESPIRATORS. If air -purifying respirator use is appropriate, use a respirator with dust/mist filters. SKIN PROTECTION: neoprene gloves- Wash off..after each use. Replace as necessary. EYE PROTECTION: splash proof chemical.goggles 9 PHYSICAL & CHEMICAL PROPERTIES Specific Gray.(70F,21C) 1.281 Vapor Pressure (mmHG) - 18.0 Freeze Point (F) 14 Vapor Density (air=1) < 1.00 Freeze Point (C) -10 Viscosity(cps 70F,21C) 56 Solubility (water) 100.0 Odor Slight Appearance Amber Physical State Liquid Flash Point P-M(CC) > 20OF > 93C pH As Is (approx-) > 13.0 Evaporation Rate (Ether=l)' < 1.00 NA = not applicable ND = not determined 10 STABILITY & REACTIVITY STABILITY: Stable under normal storage conditions. HAZARDOUS POLYMERIZATION: Will not occur: INCOMPATIBILITIES:• May react with strong oxidizers. DECOMPOSITION PRODUCTS: . Thermal decomposition (destructive fires) yields elemental oxides. INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "Bn 11 TOXICOLOGICAL INFORMATION Oral LD50 RAT:. >.2,000 mg/kg NOTE - Estimated value Dermal LD50 RABBIT: >2,000 mg/kg NOTE - Estimated value 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY Ceriodaphnia 48 Hour Static Acute Bioassay (pH adjusted) LC50= 2000; No Effect Level= 1300 mg/L Ceriodaphnia 7 Day Chronic Bioassay (pH adjusted) Reproduction NOEL= 1000; Reproduction LOEC= 2000 mg/L Daphnia magna 48 Hour Static Acute Bioassay (pH adjusted) LC50= 1811; No Effect Level= 1300 mg/L Fathead Minnow 7 Day Chronic Bioassay (pH adjusted) Growth NOEL= 1250; Growth LOEL= 2500 mg/L Fathead Minnow 95 Hour Static Bioassay with 48-Hour,Renewal (pH adjusted) 0% Mortality= 2000 mg/L Rainbow Trout 96 Hour,Static Bioassay with 48-Hour Renewal (pH adjusted) LC50= 3535; No Effect Level= 2500 mg/L . BIODEGRADATION BOD-28 (mg/g): 21 BOD-5 ,(mg/g): 10 COD (mg/g): 25.9 TOC (mg/g) : Ill 13 DISPOSAL CONSIDERATIONS If this undiluted product is discarded as a waste, the US RCRA hazardous waste identification number is D002=Corrosive(pH). Please be advised; however, that state and local requirements for. waste disposal may be more restrictive or otherwise different from federal regulations. Consult state and local regulations regarding the proper disposal of this material. 14 TRANSPORT INFORMATION DOT HAZARD: - Not Applicable. UN / NA NUMBER: Not applicable DOT.EMERGENCY RESPONSE GUIDE #: Not applicable 15 REGULATORY INFORMATION TSCA: All components of this product are listed in the TSCA inventory. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): 6,694 gallons due to SODIUM -HYDROXIDE (CAUSTIC SODA); USDA FOOD PLANT APPROVALS: This product contains ingredients that have.been determined as eerie for ii_e -- for CCCnln^ Cr cooling containers of , meat and/or poultry and in systems with no food contact. (G5, G7) SARA SECTION 312 HAZARD CLASS: . Immediate(acute);Delayed(Chronic) SARA SECTION 302 CHEMICALS: No regulated constituent present at OSHA thresholds SARA SECTION 313 CHEMICALS: .No regulated constituent present at OSHA thresholds CALIFORNIA REGULATORY INFORMATION CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65) CHEMICALS PRESENT: No regulated constituents present MICHIGAN REGULATORY INFORMATION No regulated constituent present at OSHA thresholds 16 OTHER INFORMATION NFPA/HMIS Health 1 Fire 1 Reactivity 0 Special ALK ,(1) Protective Equipment B CODE TRANSLATION Slight -Hazard Slight Hazard Minimal Hazard pH above 12.0 Goggles,Gloves (1) refer to section 8 of.MSDS for additional protective equipment recommendations. CHANGE LOG EFFECTIVE DATE REVISIONS tO SECTION: SUPERCEDES MSDS status: 30-JAN-199.7 ** NEW ** 11-NOV-1997 30-JAM-1997 03-JAN-2002 2,3,4,8 11-NOV-1997 197MAR-2002 12 03-JAN-2002 10-APR-2002 12 19-MAR-2002 06-MAY-2002 12 10-APR-2002 '10-JUN-2002 15 06-MAY-2002 24-MAR-2005 2 10-JUN-2002 SODIUM HYPOCHLORITE MATERIAL SAFETY DATA SHEET BLEACH,10-16% /(wt.) Page I of TRINITY MANUFACTURING, INC. PO Box 1519 11 E.V. Hogan Drive Hamlet, NC 28345 EMERGENCY PHONE: (800) 632-6228 (8:00 am - 5:00 pm EST) Chemtrec: 1-800-424-9300 "(24 Hours) Effective Date: 01-01-92 Revised Date:.._01-12-05 1. PRODUCT IDENTIFICATION Product Name: Sodium Hypochlorite, 10-16% by wt. Tri-Lite 150 (15% min. Vol, trade %) Tri-Lite 100 (12% min. vol, trade %) Chemical Name: Sodium Hypochlorite Chemical Family: Hypochlorite (Oxidizing Agent) HAZARD RATINGS I-T.EP.'. TH: 3 C. = : east FLAMMABILITY: 0 1= Slight REACTIVITY: 2 2 = Moderate PERSONAL PROTECTION: C 3 = High 4 = Extreme 2. HAZARDOUS INGREDIENTS Name CAS Percent Exposure Limits by weight OSHA ACGIH PEL TLV Sodium Hypochlorite 7681-52-9 10.0-16.0 N/E N/E M V&3 cor ��� I� Specific Gravity (H20 =1): 1.158 - 1.260 @ 90° F. Vapor Pressure (min Hg): 17.5 mmHg @ 70.'F. Vapor Density (Air =1): > 1.0 Percent Volatile (by volume): 100.0 Solubility In Water: Complete Boiling Point: 110 *C. in soln. (230 T.) Melting Point: N/A . Evaporation Rate: N/A Appearance: Greenish yellow liquid Odor: Pungent like chlorine pH > 11.0 4. FIRE AND EXPLOSION HAZARD DATA Flash Point ('C.): Not flammable Flammable Limits: N/A Extinguishing Media: Water spray, dry chemical, COZ Special Fire Fighting, Precautions: Wear self-contained breathing apparatus (SCBA). Unusual Fire and Explosion Hazards: When heated, bleach decomposes and may cause containers to rupture or explode. Contact with oxidizing agents or organic materials may cause fire. Fire generates chlorine gas. 5. REACTIVITY DATA: Stabili : Stable Instability Becomes unstable after 40'C. (104'F.) Incompatibility (Materials to Avoid): Acids, organic material, ammonia, reducing agents, amines, ultraviolet light. Hazardous Decomposition or Bvproducts:' Reacts with acid to release chlorine gas. Hazardous Polymerization: Will not occur. Conditions to Avoid: High heat, sunlight exposure. 6. HEALTH HAZARD DATA Routes Of Entry: Inhalation? Yes Skin? Yes Ingestion? No Eyes? Yes Health Hazards (Acute & Chronic): Corrosive to skin, eyes and mucous membranes. Lung damage, dermatitis. Carcinogenicity: NTP? No IARC Monographs? No OSHA Regulated? No Signs and Symptoms Of Exposure: Inhalation: Irritation, coughing; may cause lung damage. Skin Contact: Irritation; may cause dermatitis or, ulceration. Ingestion: Irritation, nausea, vomiting. Eve Contact: Irritation; may cause burns. Medical Conditions Generallv Aggravated By Exposure: Respiratory problems. SODIUM HYPOCHLORITE BLEACH, 10-16% /wt Emergency and First Aid Procedures: Inhalation: Remove to fresh air. If breathing is difficult, call a physician. Skin Contact: Flush affected area immediately with water for 15 minutes, call a physician. Ingestion: If conscious, give water to drink, followed by milk. Do not induce vomiting. Call a physician. Eve Contact: Flush immediately with water for 15 minutes, call a physician. 7. PRECAUTIONS - Handling and Use Steps To Be -Taken If Material Is Released or Spilled: Ventilate spill or leak area. Wear personal protective equipment as needed to prevent contact such as goggles, gloves, neoprene or rubber coveralls, rubber boots, and the appropriate level of respiratory protection. Small Spills: Contain spilled material. Transfer to secure containers. Where necessary, collect using absorbent media like clay or sand. Large Spills: Wear SCBA. Dike to minimize area of contamination. Dilute with large amounts of water. Pump or vacuum liquid to container. Absorb remaining liquid with inert material such as sand or clay and collect into containers. Avoid contact with organic materials. Avoid direct discharge to sewers or surface waters. Waste Disposal Method: Consult federal, state, and local regulations. Precautions To Be Taken In Handling and Storing: Store in cool, dry, and well ventilated area away from organics and strong reducing agents. Do not freeze. Keep container closed when not in use. Avoid direct sunlight. 8. CONTROL MEASURES Respiratory Protection: Use NIOSH approved respirators if above PEL/TLV Ventilation: Local exhaust if enclosed area Protective Gloves: Rubber, neoprene Eve Protection: Chemical goggles; use face shield for additional protection Other Protective Clothing or Equipment: Proper clothing (such as rubber apron) and boots in accordance with 29CFR1910.133 as needed to protect, against contact. Work/Hygienic Practices: Wash hands and face before eating, drinking, or smoking after handling material. Eye wash station and safety shower must be available in area. MATERIAL SAFETY DATA SHEET 2 of 2 9. REGULATORY INFORMATION For Sodium Hypochlorite as NaOCI, CAS 7681-52-9 SARA Title III: Yes SARA 311/312: Acute; mixture/liquid Section 313 Form R: No Reportable Quantity: 100 lbs. CERCLA RCRA Hazardous Waste: Not listed Clean Water Act: 100 lbs. TSCA Inventory: Yes TSCA 8(d): No TSCA 12(b): No TSCA Flags:. XU - State Lists: Massachusetts Haz. Substance: F8 Pennsylvania Haz. Substance: E Minnesota Haz. Substance: I New York Hazardous Substances RQ Air - 100 lbs RQ Land - 100 lbs CAS Number Chemical Name % by Weight 7681-52-9 Sodium Hypochlorite 10-16 10. TRANSPORTATION INFORMATION Basic Shipping Description: RQ, Hypochlorite solutions, Class 8 (Corrosive), UN1791, PG III (Sodium Hypochlorite 10-16% by weight) Reportable Quantity 100 lbs (DOT) IL REFERENCES The information accumulated herein is believed to be accurate but is not warranted to be whether originating with Trinity Manufacturing, Inc. or not. Recipients are advised to confirm in advance that the information is. current and applicable to their situation. No warranty is implied. Since conditions of use are beyond Trinity Manufacturing's control, user assumes all risk. N/E - Not established N/A - Not available Mr. Charles H. Weaver, Jr. February 1, 2007 Page 7 Attachment 5 _ _ ... .... ._ .- -- :...... ... . .... . . . . . Authorization for Representatives ENSR I AECOM Southern Company Sanrices, Jim 5755 NG 801 Hwy. Rnli,hgry, Nnrth Nrolina 28147 SOUTHERN COMPANY bito-1;0I to Serve Your World-" Robert P Hare January 30, 2007 Project Manager ENSR 4701 Cox Road, Suite 200 Glenn Alen, Virginia 23060 --- _.... ......... Mt dare, Please sign for me, the Plant Rowan NPDES Permit Application so not to delay the timely application and meeting the deadline. Z will be available for any future correspondence if needed. Thanks for your cooperation. Regards, Terry D. Syverson Compliance Team Leader IA Southern Power Company. 5755 NC 801 14wy Salisbury, NC 28147 NCDENR North Carolina Department of Environment and Natural Resources Division of .Water Quality Michael F. Easley, Governor William G. Ross; Jr., Secretary Alan W. Klimek; P.E., Director November 15, 2006 Terry V. Syverson Southern Power. Company .5755 NC Hwy 801 Salisbury, NC 28147 Subject: NPDES Permit NCG500000 renewal Certificate:of Coverage (CoC) NCG500582 Rowan County Plant Rowan County Dear Permittee: The facility listed above is covered under NPDES General Permit NCG500000. NCG500000 expires on July 31, 2007. Federal (40 CFR 122.41).and North Carolina (15A NCAC 2H.0105(e)) regulations require that•permit renewal, applications must be filed at least 180 days prior to expiration of the current .permit. If you have already mailed a renewal request, you. may disregard this notice. To satisfy, this requirement, the Divisionmust receive a renewal request postmarked no later than February 1. 2007. Failure to request renewal by this date may result: in a civil.penalty. assessment. Larger penalties may be assessed depending upon the delinquency of the request: This renewal notice is being sent well in.advance of the due date. so that you have adequate time to prepare your application. If any discharge previously covered under NC6500000 will occur after July 31, 2007, the CoC must be renewed. Discharge of wastewater without a valid permit would violate North Carolina" General Statute 143-215.1; unpermitted discharges of wastewater may be assessed civil penalties of up to $25,000 per day. If all discharge has ceased at your facility and you wish to rescind.this CoC [or if you have other questions], contact me at the telephone number or e-mail address listed below. Sincerely, C,ML ®FFPCE Charles H. Weaver, Jr.. NPDES Unit . cc: Central Files NPDES File 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 512 North Salisbury Street, Raleigh, North Carolina 27604 Phone: 919 733-5083, extension 511. / FAX 919 733-0719'/ charles.weaver@ncmail.net Nov 1 6 200r Nne orthCawlina ,U&rGi, An -Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper 5755 North Carolina 801 Hwy Salisbury, NC 21847 VIA CERTIFIED MAIL/RETURN RECEIPT REQUESTED North Carolina Department of Environment and Natural Resources Division of Water Quality Surface Water Protection Section Attn: Charles Weaver, Jr. 1617 Mail Service Center Raleigh, North Carolina 27699-1617 North Carolina Department of Environment and Natural Resources Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, North Carolina 28115 September 1, 2006 SOWERN COMPANY Enrr rxvS - 1patr World' D LE Q; Eud[E D SEP - 5 2006 RE: Change in Ownership of the Rowan County Power, LLC Combustion Turbine Facility; General NPDES Permit No. NCG500000; Certification of Coverage No. NCG500582 for Discharge of Non -contact Cooling Water / Condensate To Whom It May Concern: This letter is intended to inform you that Southern Power Company will be purchasing the Rowan County Power, LLC Combustion Turbine Facility ("the Facility") on September 1, 2006. As part of this transaction, the name of the facility will be changed to "Plant Rowan County," and the new responsible official for the Facility will be Scott Dial. No other modification is being made to the originally permitted source at this time. In accordance with the North Carolina water quality rules, Southern Power Company hereby notifies you of the above changes and submits the attached Permit Name / Ownership Change Form, as well as a copy of the Purchase and Sale Agreement, Dated as of May 8, 2006, which provides legal documentation of the transfer of ownership. In addition, Southern Power Company seeks to continue coverage of the Facility under Certificate of Registration of Oil Terminal Facility 804020040. 0 Should you require any additional information, or have any questions regarding this correspondence, please notify me at your earliest convenience. Thank you. cc: Scott Dial Terry Syverson Brian Toth Chris Lane Randy Brogdon Representative for Southern Power Company -, /a— � z� Larry Small Plant Manager Representative for Rowan County Power, LLC PPFPP' O 'mot Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality I. Please enter the permit number for which the change is requested. NPDES Permit (or) Certificate of Coverage N, SC G 1 510 10 10 0 0 U. Permit status prior to status change. a. Permit issued to (company name): Carolina Power and Light b. Person legally responsible for permit: Larry P . Small First / MI / Last Plant Manager Title 5755 North Carolina 801 Highway Permit Holder Mailing Address Salisbury NC 28147 City State Zip (704 ) 278-6603 (704) 278-6620 Phone Fax c. Facility name (discharge): C,P, &L Rowan County Combustion Turbine Gen. Facility d. Facility address: 5755 North Carolina 801 Highway Address Salisbury NC 28147 City State Zip e. Facility contact person: Richard V. Carroll ( 704 ) 27B-6607 First / MI / Last Phone III. Please provide the following for the requested change (revised permit). a. Request for change is a result of: ® Change in ownership of the facility ® Name change of the facility or owner I f other please explain: b. Permit issued to (company name): c. Person legally responsible for permit: d. Facility name (discharge): e. Facility address: f. Facility contact person: Southern Power Company E. Scott Dial First / MI / Last Plant Manager Title 5755 North Carolina 801 Highway Permit Holder Mailing Address Salisbury NC 28147 City State Zip (704 )278-6603 esdial@southernco.com Phone E-mail Address Plant Rowan County 5755 North Carolina 801 Highway Address Salisbury NC 28147 City State Zip Terry D. Syverson First / MI / Last (704 )278-6607 tdsyvers@southernco.com Phone E-mail Address Revised 7/2005 PERMIT NAME/OWNERSHIP CHANGE FORM Page 2 of 2 IV. Permit contact information: (if different from the person legally responsible for the permit) Permit contact: Terry D. Syverson First / Mt / Last Compliance Team Leader 5755 North Carolina 801 Highway Mailing Address Salisbury NC 28147 City State Zip (704) 278-6607 tdsyvers@southernco.com Phone E-mail Address V. Will the permitted facility continue to conduct the same industrial activities conducted prior to this ownership or name change? 9 Yes ❑ No (please explain) IT. Required Items: THIS APPLICATION WILL RE RETURNED. UNPROCESSED IF ITEMS ARE INCOMPLETE.OR MISSING: ❑ This completed application is required for both name change and/or ownership change requests. ❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill of sale) is required for an ownership change request. Articles of incorporation are not sufficient for an ownership change. ............................ ...................................e.............. ...................... The certifications below must be completed and signed by both the permit holder prior to the change, and the new applicant in the case of an ownership change request. For a name change request, the signed Applicant's Certification is sufficient. PERMITTEE CERTIFICATION (Permit holder prior to ownership change): I, Larry P . Small , attest that this application for a name/ownership change has been reviewed 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 information is not included, this applicatioihack711 be seta ed as incomplete. Fi LO Signature Date APPLICANT CERTIFICATION: 1, E. Sc tt Dial , attest that this application for a name/ownership change has beh reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this licat are not pleted and that if all required supporting information is not included, this applic lion p c age w 11 a returne a incomplete. ),06 tgnature Date ......... 0....... 0.0 PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO: Division of Water Quality Surface Water Protection Section 1617 Mail. Service Center Raleigh, North Carolina 27699-1617 Revised 7/2005 E. Scott Dial Southern Power Company 5755 North Carolina 801 Hwy. Salisbury, NC 28147 Dear Mr. Dial: Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality .September 6, 2006 De �oVJI t, Soa%epw POt Subject: NPDES Permit Modification Permit NCG500582 Plant Rowan County formerly CP&L - Rowan County Rowan County Division personnel.have reviewed and approved your change of address request of the subject permit, received on September 5, 2006. This permit modification documents the change in ownership. Please find enclosed the revised Certificate of Coverage, General Wastewater Discharge Permit, Fact Sheet and a copy of a Technical Bulletin. All other terms and conditions contained in the original permit remain unchanged and in full effect This permit modification is issued under the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency. If you have any questions concerning this permit modification, please contact the Point Source Branch at (919) 733-5083 extension 363 or 350. . Sincerely, Alan W. Klimek, P.E. cMooresville,Regronal�Office; Siuface Water -Protection �llu .bRJR°�iR�l� j $bo NPDES Unit Filet- t . Et AND NATURAL RESOURCES MOOREtVILLE pEO2CNAL OFFICE i SEP 1 2 204 RATER 0 UALITY SECTION ne NoaCarolina �Eurally North Carolina Division of Water Quality . 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service Intemet h2o.enrstate.nc.us 512 N. Salisbury St Raleigh, NC 27604 FAX (919) 733-2496 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY . GENERAL PERMIT NO. NCG500000 CERTIFICATE OF COVERAGE No. NCG500582 TO DISCHARGE NON -CONTACT COOLING WATER, COOLING TOWER AND BOILER BLOWDOWN, CONDENSATE AND SIMILAR WASTEWATERS UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM — In-con-.pliance wi,h-tlie pry, ision of -North -Carolina General-Statute-143=2-1t`:l, other iawful-standards-and- -- regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, is hereby authorized to discharge NON -CONTACT COOLING WATER / CONDENSATE water or similar wastewater from a facility located at PLANT ROWAN COUNTY 5755 NORTH CAROLINA 801 HIGHWAY SALISBURY ROWAN COUNTY to receiving waters designated as a ut North Second Creek, a class C water, in the Yadkin — Pee Dee River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV of General Permit No. NCG500000 as attached. — ____-This_certifir,ate-of-soverage-shall-become a tf eciive September 7, 2006. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day September 7, 2006. F.aAlan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission State of .North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor. William G. Ross Jr., Secretary Alan W. Klimek, P.E., Director TAWNYA BURDA CP&L-ROWAN COUNTY PO BOX 1551 PEB 7 RALEIGH, NC 276021551 Dear Permittee: ,Ai�rA, �1 I L NCDENR NORTH CARout" DEPARTMENT of e4viRONmew AND NAruRAL RESOURCES July 26, 2002 Subject: Reissue - NPDES Wastewater Discharge Permit Cp&L-Rowan County COC Number NCG500582 Rowan County In response to your renewal application for continued coverage under general permit NCG500000, the Division of Water Quality (DWQ) is forwarding herewith the reissued wastewater general permit Certificate of Coverage (COC). This COC is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated May 9,1994 (or as subsquently amended). The following information is included with your permit package: * A copy of the Certificate of Coverage for your treatment facility * A copy of General Wastewater Discharge Permit NCG500000 • A copy of a Technical Bulletin for General Wastewater Discharge Permit NCG50000D Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext. 578 Sincerely, for Alan W. Klimek, P.E. cc: Central Files Stormwater & General Permits Unit Files Mooresville Regional Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper State of North Carolina. Department of Environment and Natural Resources Division of Water Quality Michael F. Easley-, Governor ,William G. Ross Jr., Secretary Alan W. Klimek, P.E., Director July 26, 2002 TAWNYA BURDA CP&L-ROWAN COUNTY PO BOX 155 f PEB 7 RALEIGH, NC 276021-551 NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: Reissue - NPDES Wastewater Discharge Permit Cp&L-Rowan County COC NumberNCG500582 Rowan County Dear Permittee: In response to your renewal application for continued coverage under general permit NCG500000, the Division of Water Quality (DWQ) is forwarding herewith the reissued wastewater general permit Certificate of Coverage (COC). This COC is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated May 9., 1994 (or as subsquently amended). The following information is included with your permit package: * A copy of the Certificate of Coverage for your treatment facility * A copy of General Wastewater Discharge Permit NCG500060 * A copy of a Technical Bulletin for General Wastewater Discharge Permit NCG500000 Your coverage under this general permit is not transferable except after notice to DWQ. The Division may/require modification or revocation and reissuance.of the Certificate of Coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext. 578 Sincerely, for Alan W. Klimek, P.E. cc: Central Files Stormwater & General Permits Unit Files Mooresville Regional Office 1617 Mail service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-0719 An Equal'Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper C, Progress Energy March 8, 2006 Mr. Rex Gleason Water Quality Supervisor North Carolina Department of Environment and Natural Resources Mooresville .Region. Division of Water Quality' 610 East Center Avenue,'.Suite 3 0 1. Mooresville, NC. 28115 VIV FRICE V'11A 7f _1A, WAR 1 3 2006 Subject: Resubmittal - Application. Letter for Tax Exemption Certification of Qualifying Water Pollution Control. Equipment at Rowan County Power, LLC's Power Generation Facility Located in Rowan, County, North Carolina Dear Mr. Gleason: Only July. 29, 2005, pursuant to North Carolina General Statute ("NCGS") §105-275(8), Progress Energy. Service Company , LLC ("Progress Energy) requested* tax. exemption certification. for qualifying water pollution control equipment. currently installed at the Rowan County Power Generating Facility (the "Platf '), located in Sdlisbury" Rowan County, North Carolina. The Plant is owned and operated by Progress Energy's affiliate, Rowan County Power; LLC. On August 30, 2005, you sent a letter to me, Ms. Penney Develle, Manager, Corporate Tax, Progress Energy, stating, "The certificate of coverage (COC) under the general permit (No. NCG500592) for the subject company is not detailed enough to identify specific equipment f6r which the tax certification is being requested." On November 28, 2005; you sent a letter to Mr. Larry Small, Plant Manager of the Plant. In this letter you stated, "After reviewing the information submitted to this office, via your letter dated November 3, 2005, it was. decided that the Rowan County, Power, LLC facility can still be covered under the existing General Permit NCG500582. Also, since this issue regarding the need for -a General , Permit versus Individual 'Permit has been resolved, the Tax Certification .application for the facility can be resubmitted." ...In discussionsbetweenKathryn Tronsberg, Senior Manager, Deloitte Tax LLPJ'.'Deloitte Tax"), Ms. Patricia, Tuite, Senior Associate, . Deloitte- Financial Advisory Services LLP ("Deloitte FAS7), and Mr. Samar Bou-Ghazale, - NCDENR, Mr; Bou-Ghazale indicated that the application resubmittal should include all the water pollution system including the -systems that have already been . informally certified. . That Way, the NCDENR can issue one. tax certification for all the pollution control property they are certifying including the property informally, certified. The NCDENR informally certified, the Storm Water Collection & Segregation System in an e-mail message dated October 24, 2005. in this e-mail, Mr. SamarBou-Ghazale stated, "Regarding tax certificdtion,..we can only certify at this time the storm water ponds and associated pipes and the treatment of the discharge..." It is our understanding that we are including the storm water, system as a formality to be included in the single water tax certification that will be issued after review of the applications. Progress Energy Tax Services Dept, CX1 G: • P.O. Box 14042 • St Petersburg • Florida 33733 • (727) 820-5375 Street Address: 100 Central Avenue * St. Petersburg eFlodda 3370 Progress Energy Services Company, LLC: A Progress Energy Company The qualifying water pollution. control equipment, operating in accordance with the terms and conditions of National Pollutant Discharge Elimination System Permit No. NCG500000, . is detailed in the following Exhibits: 1. Exhibit I — Units 1 through,5 - Water Pollution Control. Equipment Descriptions 2. Exhibit II - Information Required For Water Pollution Control Property Tax Exemption Request - Units 1 through 3 Simple Cycle Plant. 3. Exhibit III Information Required For Water Pollution Control Property Tax Exemption Request - Units4 and 5 Combined Cycle Plant. NCGS §105-275(8).states the following: "(8)a: Real. and personal property .that is used or, if under construction, is to be used exclusively for air cleaning or waste disposal or to abate, reduce or prevent the pollution of air or water (including, _ but not limited to, waste lagoons and facilities owned by public or .private . utilities 'built and installed primarily for. the purpose of providing sewer service .to areas that are predominantly residential in character or areas that lie outside territory .already having sewer service), if the Department of Natural Resources and Community Development or a local air pollution control program for air - cleaning devices located in an area where the Environmental Management Commission has certified a local air pollution control program pursuant to G.S. 143-215.112 furnishes a certificate to the tax supervisor of the county in which the property -is situated or to be situated stating that the Environmental Management Commission or local air pollution control program has found that the describedproperty: (Emphasis added.) 1. Has been or will be constructed or installed; 2. Complies -.with or -that plans therefore which have been .submitted to . the Environmental Management Commission or local air. pollution control program indicate that- it will comply with the .requirements of the Environmental Management. Commission or local air pollution control program; 3. Is being effectively operated or will, when completed, be required to operate in accordance with the . terms .and conditions of the permit, certificate of approval, or other document of approval issued by the Environmental Management Commission or local air pollution control program; and . 4. Has or, whencompleted, will have as its primary rather than incidental purpose the reduction of water pollution resulting from the. discharge of sewage and waste_ or the reduction of air pollution resulting from theemission of air contaminants. " For the tax exemption .certification .of water .pollution control equipment, it is important for the ..:reviewing authority to : note the water pollution control. property , does. NOT have to treat the wastewater- as a prerequisite to qualification as water pollution control property. Rather, in accordance with NCGS § 105-275(8), water . pollution .property is "Real. and personal property ..used exclusively ...to. abate, reduce or prevent the pollution of ...water. In accordance with NCGS § 105-275(8), Exhibits I, II, and III detail the Plant's .water pollution control .devices and appurtenances, .which are "[R]eal and, personal, property that is used... exclusively for ... waste disposal or to abate, reduce or prevent the pollution of water ...". Exhibit II and III include the following columns of information for each water pollution control equipment item: Progress Energy Tax Services Dept., CX1G: • P.O. Box 14042 • SL Petersburg • Florida 33733 • (727) 820-5375 Street Address: 100 Central Avenue • St. Petersburg • Florida 33701 Progress Energy Services Company, LLC: A Progress Energy Company • Application item number, • Equipment or system name,, • Reference to a ,water permit 'section or North Carolina Administrative code section that necessitates the use of the water pollution control equipment, • The primary purpose of the water pollution control equipment; .and • A detailed description of the water pollution control equipment. Submission of this application letter is, required as a process step in the State of North Carolina . Department of Revenue's pollution control certification process for real and: personal property tax exemption of certain assets used in pollution control capacities within the Plant. Please send one copy of the completed tax exemption certification to the following addresses: Ms: Penney Develle MAC: CX2G Manager,.. Corporate Tax Progress Energy Service Company, LLC. . 100 Central Avenue - - St. Petersburg, FL 33.701 Ms. Kathryn Ttonsberg Senior Manager Deloitte Tax LLP. 2500 One PPG -Place Pittsburgh, PA 15222-5401 If you have any questions. regarding this request for tax exemption certification, .please contact me at (727) 820-5375 or.Ms: Kathryn-Tronsberg of Deloitte Tax.LLP.at (412) 338-7822. Sincerely, Penney Dev le Manager; Corporate Tax, Progress Energy Service .Company, LLC- Attachments cc: Jeffery Binkley. (Deloitte Tax — Atlanta) Kathryn Tronsberg (Deloitte Tax - Pittsburgh) -Patricia Tuite (Deloitte FAS — Pittsburgh) Progress Energy Tax Services Dept, CX1 G: • P.O. Box 14042 • St. Petersburg •Florida 33733 • (727) 820 5375 Street Address 100 Central Avenue • St Petersburg • Florida 33701 Progress Energy Services Company, LLC: A -Progress Energy Company Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 I. GENERAL PLANT DESCRIPTION — ROWAN COUNTY FACILITY The Progress Energy Service Company LLC's ("Progress Energy's") Rowan County power generation facility (the "Plant") is located in Salisbury, Rowan County, North Carolina. The Plant is owned and operated by Progress Energy's affiliate, Rowan County Power, LLC. The Plant is a nominal 925 megawatts ("MWs"), including a combined cycle block rated at 466 MWs and three simple -cycle units rate at 459 MWs. The Plant was constructed in Phases with the three simple -cycle units commencing operations in 2001 (Phase I) and the combined -cycle block commencing operations in 2003 (Phase II). There are a total of five gas turbine generators ("GTGs") on site. Three of the GTGs (Units 1 through Unit 3) are simple -cycle. They use natural gas ("NG") or fuel oil to generate electricity but there are no heat recovery steam generators ("HRSGs") for these three units. The remaining two GTGs (Units 4 and Unit 5) are combined -cycle. They use NG or fuel oil (Unit 5 is NG only) to generate electricity and the heat is recovered in the HRSG and used in the steam turbine generator ("STG") to generate additional electricity. II. TAX CERTIFICATION OF POLLUTION CONTROL EQUIPMENT This tax exemption certification application is being presented pursuant to North Carolina General Statute ("NCGS") §105-275(8). NCGS §105-275(8) states the following: "(8)a. Real and personal property that is used or, if under construction, is to be used exclusively for air cleaning or waste disposal OR to abate, reduce or prevent the pollution of air or water (including, but not limited to, waste lagoons and facilities owned by public or private utilities built and installed primarily for the purpose of providing sewer service to areas that are predominantly residential in character or areas that lie outside territory already having sewer service), if the Department of Natural Resources and Community Development or a local air pollution control program for air - cleaning devices located in an area where the Environmental Management Commission has certified a local air pollution control program pursuant to G.S. 143-215.112 furnishes a certificate to the tax supervisor of the county in which the property is situated or to be situated stating that the Environmental Management Commission or local air pollution control program has found that the described property: (Emphasis added.) 1. Has been or will be constructed or installed; 2. Complies with or that plans therefore which have been submitted to the Environmental Management Commission or local air pollution control program indicate that it will comply with the requirements of the Environmental Management Commission or local air pollution control program; 3. Is being effectively operated or will, when completed, be required to operate in accordance with the terms and conditions of the permit, certificate of approval, or other document of approval issued by the Environmental Management Commission or local air pollution control program; and 4. Has or, when completed, will have as its primary rather than incidental purpose the reduction of water pollution resulting from the discharge of sewage and Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 2 of 10 waste or the reduction of air pollution resulting from the emission of air contaminants. " III. SYSTEM DESCRIPTIONS System descriptions for the tax certification of the water pollution control exemption for qualifying water pollution control facilities (the "Facilities") at the Plant have been prepared for the following Plant Facilities: 1. Wastewater Collection and Treatment System 2. Boiler Blowdown Collection System 3. Cooling Tower System 4. Storm Water Collection & Segregation System 5. Secondary Containment - (Oil and Chemical Spill Control Containment) 6. Cathodic Protection System Each of the Facilities above is described herein. 1. Wastewater Collection and Treatment System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). Furthermore, NCGS § 130A-334 includes the following definitions: (2a) "Industrial process wastewater" means any water -carried waste resulting from any process of industry manufacture, trade, or business. (14) "Wastewater" means any sewage or industrial process wastewater discharged, transmitted, or collected from a residence, place of business, place of public assembly, or other places into a wastewater system. (15) "Wastewater system" means a system of wastewater collection, treatment, and disposal in single or multiple components, including a privy, septic tank system, public or community wastewater, wastewater reuse or recycle system, mechanical or biological wastewater treatment system, and other similar system... " The Wastewater Collection & Treatment System at the Plant collects drains and processes industrial process wastewater for eventual discharge to the waters of the state. Specifically, components of the Wastewater Collection and Treatment System include: Phase I • GTG Drains Tank (500 Gallons) (5) • GTG Drains Tanks Foundations & Containments (3) • GTG Drains Tank Containment Pumps (3) - 50 gpm and 1.5 hp • GTG Water Wash Drains Tank (4,000 Gallons) (3) • GTG Water Wash Drains Tank Foundations (3) Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 3 of 10 Phase II • GTG Water Wash Drains Tank (4,000 Gallons) (2) • GTG Water Wash Drains Tank Foundations (2) • GTG Drains Tank (500 Gallons) (2) • GTG Drains Tank Containment Pumps (2) - 50 gpm and 1.5 hp • GTG Drains Tanks Foundations & Containment (2) • STG Oily Drain Tank (650 gallons) (1) • STG Oily Drains Tank Containment (1) • STG Lube Oil Containment Area Sump Pump (1) • Cooling Tower - Blowdown Pi in — • Circulating a er emical Feed Sump Pump (1) • Effluent Line • as e ater Dechlorination Equipment Each Phase I and Phase II GTG is equipped with a false start drains tank and a water wash drains tank, with associated tank foundations. The false start drains tanks are located aboveground and the water wash tanks are located underground. Each false start tank is equipped with concrete curb containment and associated piping. The underground water wash drain tanks are not provided with complete secondary containment. The STG Unit is equipped with an STG oily drains tank. Similarly, this equipment is equipped with concrete curb containment and sump pump. Accumulated wastewater and storm water is examined to be sure no oil will be discharged from these containments. Drainage from the containment areas is then released to the ground where it drains via sheet flow into storm water drains, through the associated drainage culverts, and into one of the four detention ponds. Ultimately, runoff will reach North Second Creek. Drainage stored within the false start drains tanks and the water wash drains tanks will be pumped from the tanks and removed from the site by a waste management firm.' The false start drains tanks and lube oil reservoir containments are equipped with containment pumps that are locally controlled from a start/stop push button located at the pump. The pumps for these containments are operated manually and locked in the closed position when not in use. The remaining tanks are gravity drained using drain valves that are locked in a closed position when the containment is empty. The primary discharge from Phase II (the combined cycle process) is the cooling tower blowdown. The cooling tower blowdown contains sodium hypochlorite, corrosion inhibitors, scale inhibitors, and acid/caustic for pH control. The blowdown receives dechlorination treatment prior to the discharge. This water application includes only the downstream cooling tower blowdown piping and the dechlorination system. As per NCGS §105-275(8), the Wastewater Collection and Treatment System is property used exclusively ... "to abate, reduce or prevent the pollution of water.." Furthermore, its primary, rather than incidental purpose is the reduction of water pollution resulting from the discharge of sewage and waste. ' Rowan County Power, LLC, Application for Coverage, General Permit NCG500000, April 11, 2002, Attachment 2, Page 2. Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 4of10 2. Boiler Blowdown Collection System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee)." Furthermore, Certificate of Coverage, Section C, page 5 of 15 states that the permit is applicable to the following types of discharges: 3. Blowdown wastewaters. Blowdown is defined as the minimum discharge of recirculating water for the purpose of discharging materials contained in the water, the further buildup of which would cause concentrations in amounts exceeding limits established by best engineering practice. Furthermore, NCGS § 130A-334 includes the following definitions: (2a) "Industrial process wastewater" means any water -carried waste resulting from any process of industry manufacture, trade, or business. (14) "Wastewater" means any sewage or industrial process wastewater discharged, transmitted, or collected from a residence, place of business, place of public assembly, or other places into a wastewater system. (15) "Wastewater system" means a system of wastewater collection, treatment, and disposal in singe or multiple components, including a privy, septic tank system, public or community wastewater, wastewater reuse or recycle system, mechanical or biological wastewater treatment system, and other similar system... " Therefore, under these definitions, boiler blowdown should be classified as blowdown wastewaters constituting an industrial process wastewater stream. The management of such wastewater via the Plant's Phase II Cooling Tower System, acting as a Wastewater system, is performed via the blowdown's treatment, reuse and recycling of the boiler blowdown back into Plant process cooling water system for cooling water needs for the STG condenser(s). The Boiler Blowdown Collection System includes the following major equipment: Phase II (Only • Blowdown Collection Tanks (2) • HRSG Blowdown Tank Foundations (2) • HRSG Blowdown Sump & Sump Foundations (2) • HRSG Blowdown Sump Pumps (4) The Boiler Blowdown Collection System collects industrial process wastewater via steam and condensate drains originating from the Plant's two HRSGs within Phase II. For each unit, drains from sections of the HRSG are directed to one of two HRSG Blowdown Collection Tanks (one for each HRSG) where the fluid separates into steam and condensate. Steam is vented to the Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 5 of 10 atmosphere and condensate drains to one of two Boiler Blowdown Sumps (one for each HRSG). Boiler Blowdown Sump Pumps (2 each) within each Boiler Blowdown Sump, convey the collected industrial process wastewater to the Plant's Cooling Tower basin. Ultimately, this waste stream becomes part of the larger Cooling Tower Blowdown process wastewater. Since the Blowdown Wastewater discharged from the Boiler Blowdown Collection System is defined as the minimum discharge of recirculating water for the purpose of discharging materials contained in the water, the further buildup of which would cause concentrations in amounts exceeding limits established by best engineering practice, as per NCGS § 105-275(8), the Boiler Blowdown Collection System is property used exclusively ... "for waste disposal." Furthermore, its primary, rather than incidental purpose, is the reduction of water pollution resulting from the discharge of sewage and waste. 3. Cooling Tower System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee)." Furthermore, NCGS § 130A-334 includes the following definitions: (2a) "Industrial process wastewater" means any water -carried waste resulting from any process of industry manufacture, trade, or business. (14) "Wastewater" means any sewage or industrial process wastewater discharged, transmitted, or collected from a residence, place of business, place of public assembly, or other places into a wastewater system. (1 S) "Wastewater system" means a system of wastewater collection, treatment, and disposal in singe or multiple components, including a privy, septic tank system, public or community wastewater, wastewater reuse or recycle system, mechanical or biological wastewater treatment system, and other similar system... " Therefore, under these definitions, the Plant's Phase II Cooling Tower System acts in the capacity of a Wastewater reuse or recycle system. It provides for the treatment, reuse and recycling of the STG condenser cooling water, after thermal discharge to the atmosphere of the heat transferred during circulation within the condensers, as well as the reuse and recycling of boiler blowdown, back into Plant process cooling water needs for the STG condenser(s). Should an alternative, once -through cooling system design have been employed by the Plant, the discharge of these process industrial wastewater streams would ultimately have been to the surface waters of the state. Secondarily, the Cooling Tower System eliminates potential thermal pollutant emissions to surface waters of the state that would be created by the discharge of high - temperature condenser cooling water directly to North Second Creek in the Yadkin Pee -Dee River Basin. Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 6 of 10 The exclusive purpose of the Cooling Tower System is the reuse and recycling of Plant process industrial wastewater streams, in the form of cooling water and boiler blowdown. Therefore, as per NCGS §105-275(8), the Cooling Tower System is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, the Cooling Tower System's primary, rather than incidental purpose, is the reduction of water pollution resulting from the discharge of sewage and waste since it is sole purpose is the reuse and recycling of such wastewater streams after the removal of heat (thermal discharge) that would otherwise be discharged to the waters of the state in the form of industrial process wastewater. The Cooling Tower System includes the following major equipment: Phase II (Onlyl • Cooling Tower, Basin, Foundation, Grating, Piping, Valves, and Electrical • Circulating Water Pumps, Piping, and Valves • Cooling Tower - Circulating Water Chemical Feed System and Containment The Cooling Tower System is an 8-cell, induced mechanical -draft, fiberglass, counter -flow cooling tower. Each cell is equipped with a single speed motor driven fan. The fans are reversible for cold weather operation. Each fan has vibration switches that automatically stop the fan on high vibration and annunciate DCS alarms. Water is sprayed above the cooling tower fill with a "down -spray" system and cascades down through the fill. The cooling tower fans draw air upward through the fill, cooling the water by evaporation. Drift eliminators, installed above the cooling tower inlet distribution system, minimize the amount of water loss due to carryover of unevaporated water droplets. The Cooling Tower System Chemical Injection System controls biological growth and maintains the cooling water chemistry within specifications to ensure proper operation of the Cooling Tower System. The Cooling Tower System Chemical Injection System includes chemical storage tanks and chemical feed pumps. 4. Storm Water Collection & Segregation System The Department of Water Quality Certificate of Coverage Number NCG500582, Section C, page 5 of 15 states that the permit is applicable to the following types of discharges: 4. Exempt stormwater, which is defined as discharges of stormwater which do not require permits under the state of Federal NPDES programs. Exempt stormwater includes stormwater which accumulates in outdoor basins or ponds designed for cooling water or other waters covered by this permit. Storm Water Collection & Segregation System is basically comprised of catch basins, manholes, rip rap channels, and detention ponds. The detention ponds collect drainage from the gravity drained containment areas, released water from secondary containment structures, and storm water from the fuel oil areas. Once the condition of the accumulated storm water is examined to be sure no oil will be discharged, drainage from the containment areas is released to the ground where it drains via sheet flow into storm water drains, through the associated drainage culverts, and into one of the four detention ponds. Ultimately, runoff will reach North Second Creek. If a catastrophic spill Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 7 of 10 occurred, oil would flow to the southwest detention pond. A 10" containment boom has been installed in this pond as a precautionary measure. Inspection of the effluent from the southeast plant detention pond is a requirement of the Plant's permit. 2 The Storm Water Collection & Segregation System includes the following major equipment: Phase I • Stormwater Piping • Catch Basins • Concrete Headwalls • Manholes • Rip Rap Channels • Detention Ponds Phase II • Stormwater Piping • Catch Basins • Concrete Headwall • Manhole • Rip Rap Channel As shown above, the Storm Water Collection & Segregation System is property used exclusively to prevent water pollution. Therefore, as per NCGS §105-275(8), the Storm Water Collection & Segregation System is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental purpose, is the reduction of water pollution resulting from the discharge of sewage and waste. 5. Secondary Containment - (Oil and Chemical Spill Control Containment) The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). Such discharges shall be limited and monitored by the Permittee as specified below: In this table, Oil and Grease limits are as follows: EFFLUENT LMTS MONITORING RE. UIRMENTS CHARACTERISTICS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location Oil & Grease see note 3 15.0 m l 20.0 m l Semi-annually Grab Effluent The Code of Federal Regulations Title -40 Part 112 sets forth the requirements for the Plant's Spill Prevention, Control and Countermeasures Plan ("SPCC Plan"). On -site petroleum product storage areas and chemical storage areas have secondary containment in the form of concrete- 2 Spill Prevention Control and Countermeasures ("SPCC") Plan Rowan County Power, LLC, Updated September 24, 2004 Revision No. 3 Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 8of10 wall dikes, sumps, containment pallets or steel trays. In the event of oil or chemical leakage, the containment areas prevent the release of industrial waste to the waters of the state. The exclusive purpose of the Secondary Containment - (Oil and Chemical Spill Control Containment) is the prevention of an accidental discharge of oils and hazardous materials to the waters of the state by the use of concrete containment structures. As per NCGS §105-275(8), Secondary Containment - (Oil and Chemical Spill Control Containment) is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental, purpose is the reduction of water pollution resulting from the discharge of sewage and waste. The Secondary Containment - (Oil and Chemical Spill Control Containment) includes the following,major equipment: Phase I Accessory & LF / AA Module Containment (3) • Isolation Transformer Containment'(2) • LCI / EX2000 Transformer Containment (2) • Station Service Transformer Containment (1) • Fuel Oil Unloading Area Containment • Fuel Oil Unloading Area Containment Grating • Fuel Oil Forwarding Skid Containment (1) Main Step-up Transformerl Containment (3) • Excitation Transformer Containment (3) • 480V Secondary Unit Substation Transformer Containment (3) • Fuel Oil Area 480V SUS & MCC Containment (1) 4.16 KV MCC,,Switchgear, & Transformer Containment (1) Administration Building Transformer Containment (2) • Fire Pump Transformer Containment (1) • Fuel Oil Unloading Area Canopy Fuel Oil Piping Double Wall Portion of Pipe Fuel Oil Tanks Double Wall `Cost Phase II Accessory & ,LF / AA Module Containment (2) Isolation Transformer Contamment\(1) • LCI / EX2000 Transformer Containment (1) Main Step-up Transformer Containment (2) • Excitation Transformer Containment �2) • STG Main Oil Tank, Coolers, Strainers; & Conditioner Containment (1) • Cycle Chemical Feed Area Containment-11 1) • Fuel Oil Forwarding Skid Containment (1) • STG #2 GSU Transformer Containment (1) • STG ,13.8 KV Unit Auxiliary Transformer Containment (1) • 4.16 KV Unit Auxiliary Transformer Containment (1) • Circulating Water Pump Transformer Containment (1) • Station Service Transformer Containment (2)`, 0 Balance of Plant Station Service Transformer Containment (1) Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 9 of 10 Each gas turbine is equipped with a lube oil reservoir, fuel oil pump skid, and false start drain tank. The false start drain tanks are located aboveground. Each tank is equipped with concrete curb containment. The Steam Turbine (ST) Unit in association with CT Unit 5 is equipped with an EHC Oil Unit, EHC Main Oil Tank, ST Oily Drains Tank, and Seal Oil Unit. Similarly, each piece of equipment is equipped with concrete curb containment. Several transformers containing mineral oil are located in the combustion turbines, steam turbine and substation areas at the Plant, including six main step-up transformers. Secondary containment for each of these units is provided by concrete curb containment structures. Additional containment for the site is provided through the use of on -site sandbags and booms and the four site detention ponds. The false start drain tank and lube oil reservoir containments are equipped with containment pumps that are locally controlled from a start/stop push button located at the pump. The pumps for these containments are operated manually and locked in the closed position when not in use. The remaining tanks and transformers are gravity drained using drain valves that are locked in a closed position when the containment is empty. The detention ponds collect drainage from the gravity drained containment areas, released water from secondary containment structures, and storm water from the fuel oil areas. An uncontained oil release from the site would flow by way of the storm water collection system into one of the four detention ponds. Discharge from the detention ponds could flow through natural drainage features into one of the tributaries to North Second Creek.3 As shown above, the Secondary Containment - (Oil and Chemical Spill Control Containment) is property used exclusively to prevent water pollution. As per NCGS §105-275(8), Secondary Containment is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental, purpose is the reduction of water pollution resulting from the discharge of sewage and waste. 6. Cathodic Protection System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). The Plant uses the Cathodic Protection System for underground piping as a proactive method to prevent corrosion of piping so that there is no unauthorized discharge of pollutants to the waters of the state. Corrosion is an electrochemical reaction based on universal laws of nature. All metallic structures corrode when immersed in an electrolyte such as soil, water or concrete. The only thing that varies is the time involved in the corrosion. When placed in the ground, metals produce a current, which causes ions to leave their surface. The rate of current flow determines the life of the structure. 3 Spill Prevention Control and Countermeasures ("SPCC") Plan Rowan County Power, LLC, Updated September 24, 2004 Revision No. 3 Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 10 of 10 By connecting a metal of higher potential to a metallic structure it is possible to create an electrochemical cell in which the metal with lower potential becomes a cathode and is protected. This technique is called cathodic protection. Selected underground piping has been installed with cathodic protection to protect the pipe from corrosion and subsequent inadvertent leakage to the surface waters or groundwaters in the vicinity of the Plant. Since the exclusive purpose of the Cathodic Protection System is to prevent inadvertent pipe leakage due to corrosion, as per NCGS §105-275(8), the Cathodic Protection System is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental, purpose is the reduction of water pollution resulting from the discharge of sewage and waste. E%IIBIT H. INFORMATION REQUIRED FOR WATER POLLUTION CONTROL PROPERTY TAR PMEMPTION REQUEST OWNERS: . ROWAN COUNTY POWER, LLC PLANT NAME: ROWAN COUNTY. ADDRESS: 5755 NORTH CAROLINA 801 HIGHWAY - - - CITY: SALISBURY, NORTH CAROLINA 28144 PLANT: UNITS 1-3 SIMPLE CYCLE PLANT - - NPDES PERMIT: CERTIFICATE OF COVERAGE NUMBER NCG500582 Application Item Number Equipment / System Name Eligibility -Permit Section / Regiilntioas Primary Purpose/ Operalloa Detailed Description WATER POLLUTION REDUCTION SYSTEMS - WASTE DISPOSAL SYSTEMS - W-1 Wastewater Collection & Treatment Divi n of Water Quality ('DWQ") Certificate of Exclusive purpose ofwaste disposal by preventing The Wastewater Collection System collects the wastewater from the fuel oil / water interface Coverage Number NCG500582, Part A(1) page 2 of "unauthorized discharges to the groundwater and condensate, secondary containment area drains, and other wastewater drains in the plant. The. - 15 and PartC(I to 31 page 5 of 15. North Carolina surface waters of the state. Wastewater Collection System includes but is not limited to three (3) CT Water Wash Tanks, three' General Statutes ("NCGS') Section 130A-335. (3) CT Drains Tanks, three (3) CT Drains Tank Containment Pumps, various sump pumps, piping, - - and associated instrumentation. WATER POLLUTION PREVENTION SYSTEMS - SPILL PREVENTION W-2 Storm Water Collection & Segregation DWQ Certificate of Coverage Number NCG500582, Exclusive purpose ofcollecting and segregating The Storm Water Collection & Segregation System segregates storm water from process System PartC(4) page 5 of 15. - stormwater thereby preventing unauthorized wastewater and directs the Now of storm water runoff for discharge from the Facility site. The - discharges to the groundwater and surface waters Storm Water Collection and Segregation System includes but is not limited to catch basins, . . of the state. underground drain pipes, surface drainage ditches, and storm water detention ponds. W-3 Cathodic Protection DWQ Certificate of Coverage Number NCG500582, . -Exclusive purpose of preventing leakage of fluids A cathodic protection system is installed to mitigate corrosion and reduce the likelihood of Part A(1) page 2 of 15. NCGS Section 130A-335. and discharges into the ground. hazardous materials contaminating the environment. The cathodic protection installation consists of an electrical system that sends current through aninsulated wire to anodes, which are special metal bare buried in the soil near the underground piping. W-4 Secondary Containment- (Oil and DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing the accidental Containment and diversionary structures arc mandated by the CFR to prevent a discharge to the Chemical Spill Control Containment) Part A(1) page 2 of 15. CFR Title 40 Parts 112.20, discharge of oils and hazardous materials by the groundwatem of the state. All containers (including transformers) used to store oils and other 112.21, and 112.1-7. Spill Prevention Control and use of concrete containment structures. such potentially harmful liquids have a form of secondary containment. The secondary " Countermeasures ("SPCC") Plan Rowan County containment provides additional storage capacity for any materials which may leak due to the Power, LLC. failure, overfilling or improper draining of the primary storage container. Secondary containment structures at the plant include but are not limited to non -leaching concrete containment. -installed under or around the primary storage containers. In addition to the concrete secondary - oritainments, the, plant includes a fuel oil unloading canopy area that shields the fuel oil - " unloading components from stomawater thereby containing any spills or leaks and preverttipg the pollution of the groundwaters of the state. The plant also includes secondary containment steel . - - walls for the plant's fuel oil storage tanks. Page t of t EXI=IT III: INFORMATION REQUIRED FOR WATER POLLUTION CONTROL PROPERTY TAX EXEMPTION REQUEST - OWNERS: ROWAN COUNTY POWER, LLC . _PLANT NAME: ROWAN COUNTY ADDRESS: 5755 NORTH CAROLINA 801 HIGHWAY - - • - - - CITY: • SALISBURY, NORTH CAROLINA, 28144 - PLANT: UNITS 4-5 COMBINED CYCLE PLANT - - - NPDES PERMIT: CERTIFICATE OF COVERAGE NUMBER NCG500582" - - Application Item Number Equipment / System Name Eli fbflity - Permit Section / Regulations Primary Purpose / Operation Detailed Description WATER POLLUTION REDUCTION SYSTEMS - WASTE DISPOSAL SYSTEMS - - . W-1} , Wastewater Collection & Treatment - Division of Water Quality ("DWQ") Certificate of Exclusive purpose ofwaste disposal by preventing The Wastewater Collection System collects the wastewater from the cooling tower blowdown, Coverage Number NCG500582, Part A(1) page 2 of unauthorized discharges to the groundwater. and HRSG blowdown, cooling tower drains, fuel oil / water interface condensate, secondary. -- - - - - 15 and PartC(I to 3) page 5 of 15.. North Carolina surface waters of the state: - containment area drains, and other wastewater drains in the plant. Prior to discharge to the General Statutes ("NCGS") Section 130A-335. permitted discharge point, outfall 002 (North) Second Creek, the cooling tower drains stream is treated with a'de-chlorination System. The Wastewater Collection System includes but is not - limited to two (2) CT Water Wash Tanks, two (2) CT Drains Tanks, two (2) CT Drains Tank - Containment Pumps, one.(1) Oily Drains Tank, a dechlorination system; various sump pumps, piping, and associated instrumentation. W-2 Boiler Blowdown Wastewater Collection DWQ Certificate of Coverage Number NCG500582, Exclusive purpose ofwaste disposal by preventing The Boiler Slowdown Wastewater System delivers blowdown wastewater to the cooling tower Part A(1). page 2 of 15 and PartC(1 to 3) page 5 of unauthorimd discharges to the groundwater and basin. The Boiler Blowdown Wastewater System includes but is not limited to two (2) boiler ' 15. NCGS Section 130A-335. surface waters of thestate. blowdown tanks, two (2) blowdown water sump, four (4) blowdown water sump pumps, piping, . - and instrumentation. . - - -- - WATER POLLUTION REDUCTION SYSTEMS - THERMAL POLLUTION REDUCTION SYSTEMS W-3 Cooling Tower System ("CTS") DWQ Certificate of Coverage Number NCG500582, - Exclusive purpose of reducing thermal discharges The CTS serves to reduce the amount ofwater pollution in thaform of heat by cooling the Part A(1) page 2 of 15 and PartC(I to 3) page 5 of, to surface waters of the state. condenser cooling water and transferring the heat to the atmosphere rather than discharging heat 15. NCGS Section 130A-335. to the waters of the state. By using a cooling tower, a combined -cycle electric generating facility -. .. . eliminates the use of once -through cooling as the method of cooling SIG condensers. -The cooling - tower is an 8-cell, mechanical -draft tower. The.CTS includes but is not limited f the cooling - - tower basin, foundation, equipment; all associated water piping and pumps; and chemical injection equipment. .. WATER POLLUTION PREVENTION SYSTEMS - SPILL PREVENTION W-4 Storm Water Collection & Segregation DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of collecting and segregating The Sierra Water Collection & Segregation System segregates storm water from process System PartC(4) page:5 of 15. stormwater thereby preventing unauthorized wastewater and directs the flow of storm water runoff for discharge from the Facility Bite. The . discharges to the groundwater and surface waters Storm Water Collection and Segregation System includes blit is not lir ' catch basins, - - - - of the state. underground drain pipes, surface drainage ditches, and rm water detention ponds. W-5 .Cathodic Protection DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing leakage of fluids A cathodic protection system is installed to mitigate corrosionand reduce the likelihood of Part A(1) page 2 of 15. NCGS Section 130A-335: and discharges into the ground.' hazardous materials contaminating the environment The cathodic protection installation - . . . . . .consists ofari electrical system that sends current through an insulated wire to anodes, which are special metal bars buried in the soil near the underground piping: W-6 Secondary Containment - (Oil and DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing the accidental Containment and diversionary structures are mandated by the CFR to prevent a discharge to the Chemical Spill Control Containment) Part A(1) page 2 of 15. CFR Title 40 Parts 112.20, discharge of oils and hazardous materials by the groundwaters of the state. All containers (including transformers) used to store oils and other - - 112.21, and 112.1-7. Spill Prevention Control and - use of conerete.containment structures. such potentially harmful liquids have a form of secondary containment. The secondary . - Countermeasures ("SPCC") Plan Rowan County containment provides additional storage capacity for any materials which mayleak due to the Power, LLC. - failure, overfilling or improper draining ofthe primary storage container. Secondary containment - - structures'atthe plant include but are not limited to non -leaching concrete: containment. installed under or.around the primary storage containers. .- ----" Page t of 1 . ��� Progress Energy March 8, 2006 Mr. Rex Gleason Water Quality Supervisor North Carolina Department of Environment and Natural Resources Mooresville Region Division of Water Quality 610 East Center Avenue, Suite 301 Mooresville, NC 28115 Subject: Resubmittal - Application Letter for Tax Exemption Certification of Qualifying Water Pollution Control Equipment at Rowan County Power, LLC's Power Generation Facility Located in Rowan County, North Carolina Dear Mr. Gleason: Only July 29, 2005, pursuant .to North Carolina General Statute ("NCGS") § 105-275(8), Progress Energy Service Company LLC ("Progress Energy) requested tax exemption certification for qualifying water pollution control equipment currently installed at the Rowan County Power Generating Facility (the "Plant"), located in Salisbury, Rowan. County, North Carolina. The Plant is owned and operated by Progress Energy's affiliate, Rowan County Power, LLC. On August 30:, 2005, you sent a letter to me, Ms. Penney Develle, Manager, Corporate Tax, Progress Energy, stating, "The certificate of coverage (COC) under the general permit (No. NCG500582) for the subject company is not detailed enough to identify specific equipment for which the tax certification is being requested." On November 28, 2005, you sent a letter to Mr. Larry Small, Plant Manager of the Plant. In this letter you stated, "After reviewing the information submitted to this office, via your letter dated November 3, 2005, it was decided that the Rowan County Power, LLC facility can still be covered under the existing General Permit NCG500582. Also, since this issue regarding the need for a General Permit versus Individual Permit has been resolved, the Tax Certification application for the facility can be resubmitted." In discussions between Kathryn Tronsberg, Senior Manager, Deloitte Tax LLP ("Deloitte Tax"), Ms. Patricia Tuite, Senior Associate, Deloitte Financial Advisory Services LLP ("Deloitte FAS"), and Mr. Samar Bou-Ghazale, NCDENR, Mr. Bou-Ghazale indicated that the application resubmittal should include all the water pollution system including the systems that have already been informally certified. That way, the NCDENR can issue one tax certification for all the pollution control property they are certifying including the property informally certified. The NCDENR informally certified the Storm Water Collection & Segregation System in an e-mail message dated October 24, 2005. In this e-mail, Mr. Samar Bou-Ghazale stated, "Regarding tax certification, we can only certify at this time the storm water ponds and associated pipes and the treatment of the discharge..." It is our understanding that we are including the storm water system as a formality to be included in the single water tax certification that will be issued after review of the applications. Progress Energy Tax Services Dept, CX1G: • P.O. Box 14042 • St. Petersburg • Florida 33733 • (727) 820-5375 Street Address: 100 Central Avenue • St. Petersburg • Florida 33701 Progress Energy Services Company, LLC: A Progress Energy Company The qualifying water pollution control equipment, operating in accordance with the terms and conditions of National Pollutant Discharge Elimination System Permit No. NCG500000, is detailed in the following Exhibits: 1. Exhibit I — Units 1 through 5 - Water Pollution Control Equipment Descriptions 2. Exhibit II - Information Required For Water Pollution Control Property Tax Exemption Request - Units 1 through 3 Simple Cycle Plant. 3. Exhibit III - Information Required For Water Pollution Control Property Tax Exemption Request - Units 4 and 5 Combined Cycle Plant. NCGS §105-275(8) states the following: "(8)a. Real and personal property that is used or, if under construction, is to be used exclusively for air cleaning or waste disposal or to abate, reduce or prevent the pollution of air or water (including, but not limited to, waste lagoons and facilities owned by public or private utilities built and installed primarily for the purpose of providing sewer service to areas that are predominantly residential in character or areas that lie outside territory already having sewer service), if the Department of Natural Resources and Community Development or a local air pollution control program for air - cleaning devices located in an area where the. Environmental Management Commission has certified a local air pollution control program pursuant to G.S. 143-215.112 furnishes a certificate to the tax supervisor of the county in which the property is situated or to be situated stating that the Environmental Management Commission or local air pollution control program has found that the described property: (Emphasis added.) 1. Has been or will be constructed or installed; 2. Complies with or that plans therefore which have been submitted to the Environmental Management Commission or local air pollution control program indicate that it will comply with the requirements of the Environmental Management Commission or local air pollution control program; 3. Is being effectively operated or will, when completed, be required to operate in accordance with the terms and conditions of the permit, certificate of approval, or other document of approval issued by the Environmental Management Commission or local air pollution control program; and 4. Has or, when completed, will have as its primary rather than incidental purpose the reduction of water pollution resulting from the discharge of sewage and waste or the reduction of air pollution resulting from the emission of air contaminants. " For the tax exemption certification of water pollution control equipment, it is important for the reviewing authority to note the water pollution control property does NOT have to treat the wastewater as a prerequisite to qualification as water pollution control property. Rather, in accordance with NCGS §105-275(8), water pollution property is "Real and personal property ...used exclusively ...to abate, reduce or prevent the pollution of ...water. In accordance with NCGS § 105-275(8), Exhibits I, II, and III detail the Plant's water pollution control devices and appurtenances, which are "[R]eal and personal property that is used... exclusively for ... waste disposal or to abate, reduce or prevent the pollution of ... water ...". Exhibit II and III include the following columns of information for each water pollution control equipment item: Progress Energy Tax Services Dept., CX1 G:. P.O. Box 14042 . St Petersburg . Florida 33733 • (727) 820-5375 Street Address: 100 Central Avenue • St Petersburg . Florida 33701 Progress Energy Services Company, LLC: A Progress Energy Company • Application item number, • Equipment or system name, • Reference to a water permit section or North Carolina Administrative code section that necessitates the use of the water pollution control equipment, • The primary purpose of the water pollution control equipment, and • A detailed description of the water pollution control equipment. Submission of this application letter is required as a process step in the State of North Carolina Department of Revenue's pollution control certification process for real and personal property tax exemption of certain assets used in pollution control capacities within the Plant. Please send one copy of the completed tax exemption certification to the following addresses: Ms. Penney Develle MAC: CX2G Manager, Corporate Tax Progress Energy Service Company, LLC 100 Central Avenue St. Petersburg, FL 33701 Ms. Kathryn Tronsberg Senior Manager Deloitte Tax LLP 2500 One PPG Place Pittsburgh, PA 15222-5401 If you have any questions regarding this request for tax exemption certification, please contact me at (727) 820-5375 or Ms. Kathryn Tronsberg of Deloitte Tax LLP at (412) 338-7822. Sincerely, Penney Dev le Manager, Corporate Tax, Progress Energy Service Company, LLC Attachments cc: Jeffery Binkley Kathryn Tronsberg Patricia Tuite (Deloitte Tax — Atlanta) (Deloitte Tax — Pittsburgh) (Deloitte FAS — Pittsburgh) Progress Energy Tax Services Dept, CX1 G:. P.O. Box 14042 . St. Petersburg . Florida 33733 • (727) 820-5375 Street Address: 100 Central Avenue • St. Petersburg . Florida 33701 Progress Energy Services Company, LLC: A Progress Energy Company Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 I. GENERAL PLANT DESCRIPTION — ROWAN COUNTY FACILITY The Progress Energy Service Company LLC's ("Progress Energy's") Rowan County power generation facility (the "Plant") is located in Salisbury, Rowan County, North Carolina. The Plant is owned and operated by Progress Energy's affiliate, Rowan County Power, LLC. The Plant is a nominal 925 megawatts ("MWs"), including a combined cycle block rated at 466 MWs and three simple -cycle units rate at 459 MWs. The Plant was constructed in Phases with the three simple -cycle units commencing operations in 2001 (Phase I) and the combined -cycle block commencing operations in 2003 (Phase II). There are a total of five gas turbine generators ("GTGs") on site. Three of the GTGs (Units 1 through Unit 3) are simple -cycle. They use natural gas ("NG") or fuel oil to generate electricity but there are no heat recovery steam generators ("HRSGs") for these three units. The remaining two GTGs (Units 4 and Unit 5) are combined -cycle. They use NG or fuel, oil (Unit 5 is NG only) to generate electricity and the heat is recovered in the HRSG and used in the steam turbine generator ("STG") to generate additional electricity. II. TAX CERTIFICATION OF POLLUTION CONTROL EQUIPMENT This tax exemption certification application is being presented pursuant to North Carolina General Statute ("NCGS") §105-275(8). NCGS §105-275(8) states the following: "(8)a. Real and personal property that is used or, if under construction, is to be used exclusively for air cleaning or waste disposal OR to abate, reduce or prevent the pollution of air or water (including, but not limited to, waste lagoons and facilities owned by public or private utilities built and installed primarily for the purpose of providing sewer service to areas that are predominantly residential in character or areas that lie outside territory already having sewer service), if the Department of Natural Resources and Community Development or a local air pollution control program for air - cleaning devices located in an area where the Environmental Management Commission has certified a local air pollution control program pursuant to G.S. 143-215.112 furnishes a certificate to the tax supervisor of the county in which the property is situated or to be situated stating that the Environmental Management Commission or local air pollution control program has found that the described property: (Emphasis added.) 1. Has been or will be constructed or installed; 2. Complies with or that plans therefore which have been submitted to the Environmental Management Commission or local air pollution control program indicate that it will comply with the requirements of the Environmental Management Commission or local air pollution control program; 3. Is being effectively operated or will, when completed, be required to operate in accordance with the terms and conditions of the permit, certificate of approval, or other document of approval issued by the Environmental Management Commission or local air pollution control program; and 4. Has or, when completed, will have as its primary rather than incidental purpose the reduction of water pollution resulting from the discharge of sewage and Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 2 of 10 waste or the reduction of air pollution resulting from the emission of air contaminants. " III. SYSTEM DESCRIPTIONS System descriptions for the tax . certification of the water pollution control exemption for qualifying water pollution control facilities (the "Facilities") at the Plant have been prepared for the following Plant Facilities: 1. Wastewater Collection and Treatment System 2. Boiler Blowdown Collection System 3. Cooling Tower System 4. Storm Water Collection & Segregation System 5. Secondary Containment - (Oil and Chemical Spill Control Containment) 6. Cathodic Protection System Each of the Facilities above is described herein. 1. Wastewater Collection and Treatment System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). Furthermore, NCGS § 130A-334 includes the following definitions: (2a) "Industrial process wastewater" means any water -carried waste resulting from any process of industry manufacture, trade, or business. (14) "Wastewater" means any sewage or industrial process wastewater discharged, transmitted, or collected from a residence, place of business, place of public assembly, or other places into a wastewater system. (15) "Wastewater system" means a system of wastewater collection, treatment, and disposal in single or multiple components, including a privy, septic tank system, public or community wastewater, wastewater reuse or recycle system, mechanical or biological wastewater treatment system, and other similar system... " The Wastewater Collection & Treatment System at the Plant collects drains and processes industrial process wastewater for eventual discharge to the waters of the state. Specifically, components of the Wastewater Collection and Treatment System include: Phase I • GTG Drains Tank (500 Gallons) (3) • GTG Drains Tanks Foundations & Containments (3) • GTG Drains Tank Containment Pumps (3) - 50 gpm and 1.5 hp • GTG Water Wash Drains Tank (4,000 Gallons) (3) • GTG Water Wash Drains Tank Foundations (3) Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 3 of 10 Phase II • GTG Water Wash Drains Tank (4,000 Gallons) (2) • GTG Water Wash Drains Tank Foundations (2) • GTG Drains Tank (500 Gallons) (2) • GTG Drains Tank Containment Pumps (2) - 50 gpm and 1.5 hp • GTG Drains Tanks Foundations & Containment (2) • STG Oily Drain Tank (650 gallons) (1) • STG Oily Drains Tank Containment (1) • STG Lube Oil Containment Area Sump Pump (1) • Cooling Tower - Blowdown Piping • Circulating Water Chemical Feed Sump Pump (1) • Effluent Line • Waste Water Dechlorination Equipment Each Phase I and Phase II GTG is equipped with a false start drains tank and a water wash drains tank, with associated tank foundations. The false start drains tanks are located aboveground and the water wash tanks are located underground. Each false start tank is equipped with concrete curb containment and associated piping. The underground water wash drain tanks are not provided with complete secondary containment. The STG Unit is equipped with an STG oily drains tank. Similarly, this equipment is equipped with concrete curb containment and sump pump. Accumulated wastewater and storm water is examined to be sure no oil will be discharged from these containments. Drainage from the containment areas is then released to the ground where it drains via sheet flow into storm water drains, through the associated drainage culverts, and into one of the four detention ponds. Ultimately, runoff will reach North Second Creek. Drainage stored within the false start drains tanks and the water wash drains tanks will be pumped from the tanks and removed from the site by a waste management firm.' The false start drains tanks and lube oil reservoir containments are equipped with containment pumps that are locally controlled from a start/stop push button located at the pump. The pumps for these containments are operated manually and locked in the closed position when not in use. The remaining tanks are gravity drained using drain valves that are locked in a closed position when the containment is empty. The primary discharge from Phase II (the combined cycle process) is the cooling tower blowdown. The cooling tower blowdown contains sodium hypochlorite, corrosion inhibitors, scale inhibitors, and acid/caustic ' for pH control. The blowdown receives dechlorination treatment prior to the discharge. This water application includes only the downstream cooling tower blowdown piping and the dechlorination system. As per NCGS §105-275(8), the Wastewater Collection and Treatment System is property used exclusively ... "to abate, reduce or prevent the pollution of water.." Furthermore, its primary, rather than incidental purpose is the reduction of water pollution resulting from the discharge of sewage and waste. ' Rowan County Power, LLC, Application for Coverage, General Permit NCG500000, April 11, 2002, Attachment 2, Page 2. Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 4 of 10 2. Boiler Blowdown Collection System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee)." Furthermore, Certificate of Coverage, Section C, page 5 of 15 states that the permit is applicable to the following types of discharges: 3. Blowdown wastewaters. Blowdown is defined as the minimum discharge of recirculating water for the purpose of discharging materials contained in the water, the further buildup of which would cause concentrations in amounts exceeding limits established by best engineering practice. Furthermore, NCGS § 130A-334 includes the following definitions: (2a) "Industrial process wastewater" means any water -carried waste resulting from any process of industry manufacture, trade, or business. (14) "Wastewater" means any sewage or industrial process wastewater discharged, transmitted, or collected from a residence, place of business, place of public assembly, or other places into a wastewater system. (15) "Wastewater system" means a system of wastewater collection, treatment, and disposal in singe or multiple components, including a privy, septic tank system, public or community wastewater, wastewater reuse or recycle system, mechanical or biological wastewater treatment system, and other similar system... " Therefore, under these definitions, boiler blowdown should be classified as blowdown wastewaters constituting an industrial process wastewater stream. The management of such wastewater via the Plant's Phase II Cooling Tower System, acting as a Wastewater system, is performed via the blowdown's treatment, reuse and recycling of the boiler blowdown back into Plant process cooling water system for cooling water needs for the STG condenser(s). The Boiler Blowdown Collection System includes the following major equipment: Phase II (Only • Blowdown Collection Tanks (2) • HRSG Blowdown Tank Foundations (2) • HRSG Blowdown Sump & Sump Foundations (2) • HRSG Blowdown Sump Pumps (4) The Boiler Blowdown Collection System collects industrial process wastewater via steam and condensate drains originating from the Plant's two HRSGs within Phase II. For each unit, drains from sections of the HRSG are directed to one of two HRSG Blowdown Collection Tanks (one for each HRSG) where the fluid separates into steam and condensate. Steam is vented to the Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 5 of 10 atmosphere and condensate drains to one of two Boiler Blowdown Sumps (one for each HRSG). Boiler Blowdown Sump Pumps (2 each) within each Boiler Blowdown Sump, convey the collected industrial process wastewater to the Plant's Cooling Tower basin. Ultimately, this waste stream becomes part of the larger Cooling Tower Blowdown process wastewater. Since the Blowdown Wastewater discharged from the Boiler Blowdown Collection System is defined as the minimum discharge of recirculating water for the purpose of discharging materials contained in the water, the further buildup of which would cause concentrations in amounts exceeding limits established by best engineering practice, as per NCGS §105-275(8), the Boiler Blowdown Collection System is property used exclusively ... "for waste disposal." Furthermore, its primary, rather than incidental purpose, is the reduction of water pollution resulting from the discharge of sewage and waste. 3. Cooling Tower System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee)." Furthermore, NCGS § 130A-334 includes the following definitions: (2a) "Industrial process wastewater" means any water -carried waste resulting from any process of industry manufacture, trade, or business. (14) "Wastewater" means any sewage or industrial process wastewater discharged, transmitted, or collected from a residence, place of business, place ofpublic assembly, or other places into a wastewater system. (15) "Wastewater system" means a system of wastewater collection, treatment, and disposal in singe or multiple components, including a privy, septic tank system, public or community wastewater, wastewater reuse or recycle system, mechanical or biological wastewater treatment system, and other similar system... " Therefore, under these definitions, the Plant's Phase II Cooling Tower System acts in the capacity of a Wastewater reuse or recycle system. It provides for the treatment, reuse and recycling of the STG condenser cooling water, after thermal discharge to the atmosphere of the heat transferred during circulation within the condensers, as well as the reuse and recycling of boiler blowdown, back into Plant process cooling water needs for the STG condenser(s). Should an alternative, once -through cooling system design have been employed by the Plant, the discharge of these process industrial wastewater streams would ultimately have been to the surface waters of the state. Secondarily, the Cooling Tower System eliminates potential thermal pollutant emissions to surface waters of the state that would be created by the discharge of high - temperature condenser cooling water directly to North Second Creek in the Yadkin Pee -Dee River Basin. Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 6of10 The exclusive purpose of the Cooling Tower System is the reuse and recycling of Plant process industrial wastewater streams, in the form of cooling water and boiler blowdown. Therefore, as per NCGS §105-275(8), the Cooling Tower System is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, the Cooling Tower System's primary, rather than incidental purpose, is the reduction of water pollution resulting from the discharge of sewage and waste since it is sole purpose is the reuse and recycling of such wastewater streams after the removal of heat (thermal discharge) that would otherwise be discharged to the waters of the state in the form of industrial process wastewater. The Cooling Tower System includes the following major equipment: Phase II (Only • Cooling Tower, Basin, Foundation, Grating, Piping, Valves, and Electrical • Circulating Water Pumps, Piping, and Valves • Cooling Tower - Circulating Water Chemical Feed System and Containment The Cooling Tower System is an 8-cell, induced mechanical -draft, fiberglass, counter -flow cooling tower. Each cell is equipped with a single speed motor driven fan. The fans are reversible for cold weather operation. Each fan has vibration switches that automatically stop the fan on high vibration and annunciate DCS alarms. Water is sprayed above the cooling tower fill with a "down -spray" system and cascades down through the fill. The cooling tower fans draw air upward through the fill, cooling the water by evaporation. Drift eliminators, installed above the cooling tower inlet distribution system, minimize the amount of water loss due to carryover of unevaporated water droplets. The Cooling Tower System Chemical Injection System controls biological growth and maintains the cooling water chemistry within specifications to ensure proper operation of the Cooling Tower System. The Cooling Tower System Chemical Injection System includes chemical storage tanks and chemical feed pumps. 4. Storm Water Collection & Segregation System The Department of Water Quality Certificate of Coverage Number NCG500582, Section C, page 5 of 15 states that the permit is applicable to the following types of discharges: 4. Exempt stormwater, which is defined as discharges of stormwater which do not require permits under the state of Federal NPDES programs. Exempt stormwater includes stormwater which accumulates in outdoor basins or ponds designed for cooling water or other waters covered by this permit. Storm Water Collection & Segregation System is basically comprised of catch basins, manholes, rip rap channels, and detention ponds. The detention ponds collect drainage from the gravity drained containment areas, released water from secondary containment structures, and storm water from the fuel oil areas. Once the condition of the accumulated storm water is examined to be sure no oil will be discharged, drainage from the containment areas is released to the ground where it drains via sheet flow into storm water drains, through the associated drainage culverts, and into one of the four detention ponds. Ultimately, runoff will reach North Second Creek. If a catastrophic spill Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 7of10 occurred, oil would flow to the southwest detention pond. A 10" containment boom has been installed in this pond as a precautionary measure. Inspection of the effluent from the southeast plant detention pond is a requirement of the Plant's permit. 2 The Storm Water Collection & Segregation System includes the following major equipment: Phase I • Stormwater Piping • Catch Basins • Concrete Headwalls • Manholes • Rip Rap Channels • Detention Ponds Phase II • Stormwater Piping • Catch Basins • Concrete Headwall • Manhole • Rip Rap Channel As shown above, the Storm Water Collection & Segregation System is property used exclusively to prevent water pollution. Therefore, as per NCGS § 105-275(8), the Storm Water Collection & Segregation System is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental purpose, is the reduction of water pollution resulting from the discharge of sewage and waste. 5. Secondary Containment - (Oil and Chemical Spill Control Containment) The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). Such discharges shall be limited and monitored by the Permittee as specified below: In this table, Oil and Grease limits are as follows: EFFLUENT LIMITS MONITORING REQUIRMENTS CHARACTERISTICS Monthly Avera e Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location Oil & Grease see note 3 15.0 mg/1 20.0 m l Semi-annually Grab Effluent The Code of Federal Regulations Title 40 Part 112 sets forth the requirements for the Plant's Spill Prevention, Control and Countermeasures Plan ("SPCC Plan"). On -site petroleum product storage areas and chemical storage areas have secondary containment in the form of concrete- 2 Spill Prevention Control and Countermeasures ("SPCC") Plan Rowan County Power, LLC, Updated September 24, 2004 Revision No. 3 Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 8 of 10 wall dikes, sumps, containment pallets or steel trays. In the event of oil or chemical leakage, the containment areas prevent the release of industrial waste to the waters of the state. The exclusive purpose of the Secondary Containment - (Oil and Chemical Spill Control Containment) is the prevention of an accidental discharge of oils and hazardous materials to the waters of the state by the use of concrete containment structures. As per NCGS §105-275(8), Secondary Containment - (Oil and Chemical Spill Control Containment) is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental, purpose is the reduction of water pollution resulting from the discharge of sewage and waste. The Secondary Containment - (Oil and Chemical Spill . Control Containment) includes the following major equipment: Phase T • Accessory & LF / AA Module Containment (3) • Isolation Transformer Containment (2) • LCI / EX2000 Transformer Containment (2) • Station Service Transformer Containment (1) • Fuel Oil Unloading Area Containment • Fuel Oil Unloading Area Containment Grating • Fuel Oil Forwarding Skid Containment (1) • Main Step-up Transformer Containment (3) • Excitation Transformer Containment (3) • 480V Secondary Unit Substation Transformer Containment (3) • Fuel Oil Area 480V SUS & MCC Containment (1) • 4.16 KV MCC, Switchgear, & Transformer Containment (1) • Administration Building Transformer Containment (2) • Fire Pump Transformer Containment (1) • Fuel Oil Unloading Area Canopy • Fuel Oil Piping Double Wall Portion of Pipe • Fuel Oil Tanks Double Wall Cost Phase II • Accessory & LF / AA Module Containment (2) • Isolation Transformer Containment (1) • LCI / EX2000 Transformer Containment (1) • Main Step-up Transformer Containment (2) • Excitation Transformer Containment (2) • STG Main Oil Tank, Coolers, Strainers, & Conditioner Containment (1) • Cycle Chemical Feed Area Containment (1) • Fuel Oil Forwarding Skid Containment (1) • STG #2 GSU Transformer Containment (1) • STG 13.8 KV Unit Auxiliary Transformer Containment (1) • 4.16 KV Unit Auxiliary Transformer Containment (1) • Circulating Water Pump Transformer Containment (1) • Station Service Transformer Containment (2) 0 Balance of Plant Station Service Transformer Containment (1) Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 9 of 10 Each gas turbine is equipped with a lube oil reservoir, fuel oil pump skid, and false start drain tank. The false start drain tanks are located aboveground. Each tank is equipped with concrete curb containment. The Steam Turbine (ST) Unit in association with CT Unit 5 is equipped with an EHC Oil Unit, EHC Main Oil Tank, ST Oily Drains Tank, and Seal Oil Unit. Similarly, each piece of equipment is equipped with concrete curb containment. Several transformers containing mineral oil are located in the combustion turbines, steam turbine and substation areas at the Plant, including six main step-up transformers. Secondary containment for each of these units is provided by concrete curb containment structures. Additional containment for the site is provided through the use of on -site sandbags and booms and the four site detention ponds. The false start drain tank and lube oil reservoir containments are equipped with containment pumps that are locally controlled from a start/stop push button located at the pump. The pumps for these containments are operated manually and locked in the closed position when not in use. The remaining tanks and transformers are gravity drained using drain valves that are locked in a closed position when the containment is empty. The detention ponds collect drainage from the gravity drained containment areas, released water from secondary containment structures, and storm water from the fuel oil areas. An uncontained oil release from the site would flow by way of the storm water collection system into one of the four detention ponds. Discharge from the detention ponds could flow through natural drainage features into one of the tributaries to North Second Creek.3 As shown above, the Secondary Containment - (Oil and Chemical Spill Control Containment) is property used exclusively to prevent water pollution. As per NCGS §105-275(8), Secondary Containment is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental, purpose is the reduction of water pollution resulting from the discharge of sewage and waste. 6. Cathodic Protection System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). The Plant uses the Cathodic Protection System for underground piping as a proactive method to prevent corrosion of piping so that there is no unauthorized discharge of pollutants to the waters of the state. Corrosion is an electrochemical reaction based on universal laws of nature. All metallic structures corrode when immersed in an electrolyte such as soil, water or concrete. The only thing that varies is the time involved in the corrosion. When placed in the ground, metals produce a current, which causes ions to leave their surface. The rate of current flow determines the life of the structure. 3 Spill Prevention Control and Countermeasures ("SPCC") Plan Rowan County Power, LLC, Updated September 24, 2004 Revision No. 3 Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 10 of 10 By connecting a metal of higher potential to a metallic structure it is possible to create an electrochemical cell in which the metal with lower potential becomes a cathode and is protected. This technique is called cathodic protection. Selected underground piping has been installed with cathodic protection to protect the pipe from corrosion and subsequent inadvertent leakage to the surface waters or groundwaters in the vicinity of the Plant. Since the exclusive purpose of the Cathodic Protection System is to prevent inadvertent pipe leakage due to corrosion, as per NCGS §105-275(8), the Cathodic Protection System is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental, purpose is the reduction of water pollution resulting from the discharge of sewage and waste. EXHIBIT A: INFORMATIONREQUIRED FOR WATER POLLUTION CONTROL PROPERTY TAX EXEMPTION REQUEST OWNERS: ROWAN COUNTY POWER, LLC PLANT NAME: ROWAN COUNTY ADDRESS: 5755 NORTH CAROLINA 801 HIGHWAY CITY: SALISBURY, NORTH CAROLINA 28144 PLANT. UNITS 1-3 SIMPLE CYCLE PLANT NPOES PERMIT. CERTIFICATE OF COVERAGE NUMBER NCGS00582 Application Item Number Equipment / System Name Eligibility - Permit Section / Regulations Primary Purpose / Operation Detailed Description WATER POLLUTION REDUCTION SYSTEMS - WASTE DISPOSAL SYSTEMS W-1 Wastewater Collection & Treatment Division of Water Quality ('DWQ') Certificate of Exclusive purpose ofwaste disposal by preventing The Wastewater Collection System collects the wastewater from the fuel oil / water interface Coverage Number NCG500582, Part A(1) page 2 of unauthorized discharges to the groundwater and condensate, secondary containment area drains, and other wastewater drains in the plant. The 15 and PartC(I to 3) page 5 of 15. North Carolina surface waters of the state. Wastewater Collection System includes but is not limited to three (3) CT Water Wash Tanks, three General Statutes ('NCGS') Section 130A-335. (3) CT Drains Tanks, three (3) CT Drains Tank Containment Pumps, various sump pumps, piping, and associated instrumentation. WATER POLLUTION PREVENTION SYSTEMS • SPILL PREVENTION W-2 Storm Water Collection & Segregation DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of collecting and segregating The Storm Water Collection & Segregation System segregates storm water from process System PartC(4) page 5 of 15. atormwater thereby preventing unauthorized wastewater and directs the flow of storm water runoff for discharge from the Facility site. The discharges to the groundwater and surface waters Storm Water Collection and Segregation System includes but is not limited to catch basins, of the state. underground drain pipes, surface drainage ditches, and storm water detention ponds. W-3 Cathodic Protection DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing leakage of fluids A cathodic protection system is installed to mitigate corrosion and reduce the likelihood of Pan A(1) page 2 of 15. NCGS Section 130A-335. and discharges into the ground. hazardous materials contaminating the environment. The cathodic protection installation consists of an electrical system that sends current through an insulated wire to anodes, which are special metal bars buried in the soil near the underground piping. W-4 Secondary Containment - (Oil and DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing the accidental Containment and diversionary structures are mandated by the CFR to prevent a discharge to the Chemical Spill Control Containment) Part A(1) page 2 of 15. CFRTitle 40 Pans 112.20, discharge of oils and hazardous materials by the groundwaters of the state. All containers (including transformers) used to store oils and other 112.21, and 112.1-7. Spill Prevention Control and use of concrete containment structures. such potentially harmful liquids have a form of secondary containment. The secondary ' Countermeasures ('SPCC') Plan Rowan County containment provides additional storage capacity for any materials which may leak due to the Power, LLC. failure, overfilling or improper draining of the primary storage container. Secondary containment structures at the plant include but are not limited to non -leaching concrete containments installed under or around the primary storage containers. In addition to the concrete secondary containments, the plant includes a fuel oil unloading canopy area that shields the fuel oil - unloading components from stormwater thereby containing any spills or leaks and preventing the pollution of the groundwater, of the state. The plant also includes secondary containment steel walls for the plant', fuel oil storage tanks. Page t of t EXHIBIT Hr. INFORMATION REQUIRED FOR WATER POLLUTION CONTROL PROPERTY TAR EXEMPTION REQUEST OWNERS: ROWAN COUNTY POWER, LLC PLANT NAME: ROWAN COUNTY ADDRESS: 5755 NORTH CAROLINA 801 HIGHWAY CITY: SALISBURY, NORTH CAROLINA 28144 PLANT. UNITS 4-5 COMBINED CYCLE PLANT NPDES PERMIT. CERTIFICATE OF COVERAGE NUMBER NCG500582 Application Item Number Equipment /System Nmmc Eligibility Permit Section / Regulations g Y- N Prim Purpose / Operation °*y P P°�° DetaOed Description P WATER POLLUTION REDUCTION SYSTEMS - WASTE DISPOSAL SYSTEMS W-1 Wastewater Collection & Treatment Division of Water Quality ('DWQ') Certificate of Exclusive purpose ofwasts disposal by preventing The Wastewater Collection System collects the wastewater from the cooling tower blowdown, Coverage Number NCG500582, Part A(1) page 2 of unauthorized discharges to the groundwater and HRSG blowdown, waling tower drains, fuel oil / water interface condensate, secondary 15 and PartC(1 to 31 page 5 of 15. North Carolina surface waters of the state. containment area drains, and other wastewater drains in the plant. Prior to discharge to the General Statutes ('NCGS') Section 130A-335. permitted discharge point, outfall 002 (North) Second Creek, the cooling tower drains stream is treated with a de -chlorination System. The Wastewater Collection System include. but is not limited to two (2) CT Water Wash Tanks, two (2) CT Drains Tanks, two (2) CT Drains Tank Containment Pumps, one (1) Oily Drains Tank, a dechlorination system, various sump pumps, piping, and associated instrumentation. W-2 Boiler Slowdown Wastewater Collection DWQ Certificate of Coverage Number NCG500582, Exclusive purpose ofwaste disposal by preventing The Boiler Slowdown Wastewater System delivers blowdown wastewater to the cooling tower Part A(1) page 2 of 15 and PartC(1 to 3) page 5 of unauthorized discharges to the groundwater and basin. The Boiler Slowdown Wastewater System includes but is not limited to two (2) boiler 15. NCGS Section 130A-335. surface waters of the state. blowdown tanks, two (2) blowdown water sump, four (4) blowdown water sump pumps, piping, and instrumentation. WATER POLLUTION REDUCTION SYSTEMS - THERMAL POLLUTION REDUCTION SYSTEMS W-3 Cooling Tower System ('CfS') DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of reducing thermal discharges The CTS serves to reduce the amount ofwater pollution in the form of heat by cooling the Part A(1) page 2 of 15 and PartC(1 to 31 page 5 of to surface waters of the state. condenser cooling water and transferring the heat to the atmosphere rather than discharging heat 15. NCGS Section 130A-335. to the waters of the state. By using a cooling tower, a combined -cycle electric generating facility eliminates the use of once -through cooling as the method of cooling STG condenser.. The cooling tower is an 8-cell, mechanical -draft tower. The CTS includes but is not limited to the cooling tower basin, foundation, equipment; all associated water piping and pumps; and chemical injection equipment. WATER POLLUTION PREVENTION SYSTEMS - SPILL PREVENTION W-4 Storm Water Collection & Segregation DWQ Certificate of Coverage Number NCG500582, Exclusive purpose ofcollecting and segregating The Storm Water Collection & Segregation System segregates storm water from process System PartC(4) page 5 of 15. stormwater thereby preventing unauthorized wastewater and directs the flow, of storm water runoff for discharge from the Facility site. The discharges to the groundwater and surface waters Storm Water Collection and Segregation System includes but is not limited to catch basins, of the state. underground drain pipes, surface drainage ditches, and storm water detention ponds. W-5 Cathodic Protection DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing leakage of fluids A cathodic protection system is installed to mitigate corrosion and reduce the likelihood of Pare All) page 2 of 15. NCGS Section 130A-335. and discharges into the ground. hazardous materials contaminating the environment. The cathodic protection installation consists of an electrical system that sends current through an insulated wire to anodes, which am special metal bars buried in the soil near the underground piping. W-6 Secondary Containment - (Oil and DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing the accidental Containment and diversionary structures are mandated by the CFR to prevent a discharge to the Chemical Spill Control Containment) Part A(1) page 2 of 15. CFR Title 40 Parts 112.20, discharge of oils and hazardous materials by the groundwaters of the state. All containers (including transformers) used to store oils and other 112.21, and 112.1-7. Spill Prevention Control and use of concrete containment structures. such potentially harmful liquids have a form of secondary containment. The secondary Countermeasures (°SPCC') Plan Rowan County containment provides additional storage capacity for any materials which may leak due to the Power. LLC. failure, overfilling or improper draining of the primary storage container. Secondary containment structures at the plant include but are not limited to non -leaching concrete containments installed under or around the primary storage container°. A Progress Energy March 8, 2006 Mr. Rex Gleason Water Quality Supervisor North Carolina Department of Environment and Natural Resources Mooresville Region Division of Water Quality 610 East Center Avenue, Suite 301 Mooresville, NC 28115 Subject: Resubmittal - Application Letter for Tax Exemption Certification of Qualifying Water Pollution Control Equipment at Rowan County Power, LLC's Power Generation Facility Located in Rowan County, North Carolina Dear Mr. Gleason: Only July 29, 2005, pursuant . to North Carolina General Statute ("NCGS") § 105-275(8), Progress Energy Service Company LLC ("Progress Energy) requested tax exemption certification for qualifying water pollution control equipment currently installed at the Rowan County Power Generating Facility (the "Plant"), located in Salisbury, Rowan County, North Carolina. The Plant is owned and operated by Progress Energy's affiliate, Rowan County Power, LLC. On August 30, 2005, you sent a letter to me, Ms. Penney Develle, Manager, Corporate Tax, Progress Energy, stating, "The certificate of ' coverage (COC) under the general permit (No. NCG500582) for the subject company is not detailed enough to identify specific equipment for which the tax certification is being requested." On November 28, 2005, you sent a letter to Mr. Larry Small, Plant Manager of the Plant. In this letter you stated, "After reviewing the information submitted to this office, via your letter dated November 3, 2005, it was decided that the Rowan County Power, LLC facility can still be covered under the existing General Permit NCG500582. Also, since this issue regarding the need for a General Permit versus Individual Permit has been resolved, the Tax Certification application for the facility can be resubmitted." In discussions between Kathryn Tronsberg, Senior Manager, Deloitte Tax LLP ("Deloitte Tax"), Ms. Patricia Tuite, Senior Associate, Deloitte Financial Advisory Services LLP ("Deloitte FAS"), and Mr. Samar Bou-Ghazale, NCDENR, Mr. Bou-Ghazale indicated that the application resubmittal should include all the water pollution system including the systems that have already been informally certified. That way, the NCDENR can issue one tax certification for all the pollution control property they are certifying including the property informally certified. The NCDENR informally certified the Storm Water Collection & Segregation System in an e-mail message dated October 24, 2005. In this e-mail, Mr. Samar Bou-Ghazale stated, "Regarding tax certification, we can only certify at this time the storm water ponds and associated pipes and the treatment of the discharge..." It is our understanding that we are including the storm water system as a formality to be included in the single water tax certification that will be issued after review of the applications. Progress Energy Tax Services Dept., CX1G: • P.O. Box 14042 • St Petersburg • Florida 33733 • (727) 820-5375 Street Address: 100 Central Avenue • St Petersburg *Florida 33701 Progress Energy Services Company, LLC: A Progress Energy Company The qualifying water pollution control equipment, operating in accordance with the terms and conditions of National Pollutant Discharge Elimination System Permit No. NCG500000, is detailed in the following Exhibits: 1. Exhibit I — Units 1 through 5 - Water Pollution Control Equipment Descriptions 2. Exhibit II - Information Required For Water Pollution Control Property Tax Exemption Request - Units 1 through 3 Simple Cycle Plant. 3. Exhibit III - Information Required For Water Pollution Control Property Tax Exemption Request - Units 4 and 5 Combined Cycle Plant. NCGS §105-275(8) states the following: "(8)a. Real and personal property that is used or, if under construction, is to be used exclusively for air cleaning or waste disposal or to abate, reduce or prevent the pollution of air or water (including, but not limited to, waste lagoons and facilities owned by public or private utilities built and installed primarily for the purpose of providing sewer service to areas that are predominantly residential in character or areas that lie outside territory already having sewer service), if the Department of Natural Resources and Community Development or a local air pollution control program for air - cleaning devices located in an area where the Environmental Management Commission has certified a local air pollution control program pursuant to G.S. 143-215.112 furnishes a certificate to the tax supervisor of the county in which the property is situated or to be situated stating that the Environmental Management Commission or local air pollution control program has found that the described property: (Emphasis added.) 1. Has been or will be constructed or installed; 2. Complies with or that plans therefore which have been submitted to the Environmental Management Commission or local air pollution control program indicate that it will comply with the requirements of the Environmental Management Commission or local air pollution control program; 3. Is being effectively operated or will, when completed, be required to operate in accordance with the terms and conditions of the permit, certificate of approval, or other document of approval issued by the Environmental Management Commission or local air pollution control program; and 4. Has or, when completed, will have as its primary rather than incidental purpose the reduction of water pollution resulting from the discharge of sewage and waste or the reduction of air pollution resulting from the emission of air contaminants. " For the tax exemption certification of water pollution control equipment, it is important for the reviewing authority to note the water pollution control property does NOT have to treat the wastewater as a prerequisite to qualification as water pollution control property. Rather, in accordance with NCGS §105-275(8), water pollution property is "Real and personal property ...used exclusively ...to abate, reduce or prevent the pollution of ...water. In accordance with NCGS §105-275(8), Exhibits I, II, and III detail the Plant's water pollution control devices and appurtenances, which are "[R]eal and personal property that is used... exclusively for ... waste disposal or to abate, reduce or prevent the pollution of ... water ...". Exhibit II and III include the following columns of information for each water pollution control equipment item: Progress Energy Tax Services Dept., CX1G:. P.O. Box 14042 .St. Petersburg • Florida 33733 • (727) 820-5375 Street Address: 100 Central Avenue • St. Petersburg • Florida 33701 Progress Energy Services Company, LLC: A Progress Energy Company • Application item number, • Equipment or system name, • Reference to a water permit section or North Carolina Administrative code section that necessitates the use of the water pollution control equipment, • The primary purpose of the water pollution control equipment, and • A detailed description of the water pollution control equipment. Submission of this application letter is required as a process step in the State of North Carolina Department of Revenue's pollution control certification process for real and personal property tax exemption of certain assets used in pollution control capacities within the Plant. Please send one copy of the completed tax exemption certification to the following addresses: Ms. Penney Develle MAC: CX2G Manager, Corporate Tax Progress Energy Service Company, LLC 100 Central Avenue St. Petersburg, FL 33701 Ms. Kathryn Tronsberg Senior Manager Deloitte Tax LLP 2500 One PPG Place Pittsburgh, PA 15222-5401 If you have any questions regarding this request for tax exemption certification, please contact me at (727) 820-5375 or Ms. Kathryn Tronsberg of Deloitte Tax LLP at (412) 338-7822. Sincerely, Penney Dev le Manager, Corporate Tax, Progress Energy Service Company, LLC Attachments cc: Jeffery Binkley (Deloitte Tax — Atlanta) Kathryn Tronsberg (Deloitte Tax — Pittsburgh) Patricia Tuite (Deloitte FAS — Pittsburgh) Progress Energy Tax Services Dept., CX1G: • P.O. Box 14042 . St. Petersburg • Florida 33733 . (727) 820-5375 Street Address: 100 Central Avenue • St. Petersburg • Florida 33701 Progress Energy Services Company, LLC: A Progress Energy Company Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 I. GENERAL PLANT DESCRIPTION — ROWAN COUNTY FACILITY The Progress Energy Service Company LLC's ("Progress Energy's") Rowan County power generation facility (the "Plant") is located in Salisbury, Rowan County, North Carolina. The Plant is owned and operated by Progress Energy's affiliate, Rowan County Power, LLC. The Plant is a nominal 925 megawatts ("MWs"), including a combined cycle block rated at 466 MWs and three simple -cycle units rate at 459 MWs. The Plant was constructed in Phases with the three simple -cycle units commencing operations in 2001 (Phase I) and the combined -cycle block commencing operations in 2003 (Phase II). There are a total of five gas turbine generators ("GTGs") on site. Three of the GTGs (Units 1 through Unit 3) are simple -cycle. They use natural gas ("NG") or fuel oil to generate electricity but there are no heat recovery steam generators ("HRSGs") for these three units. The remaining two GTGs (Units 4 and Unit 5) are combined -cycle. They use NG or fuel oil (Unit 5 is NG only) to generate electricity and the heat is recovered in the HRSG and used in the steam turbine generator ("STG") to generate additional electricity. II. TAX CERTIFICATION OF POLLUTION CONTROL EQUIPMENT This tax exemption certification application is being presented pursuant to North Carolina General Statute ("NCGS") §105-275(8). NCGS §105-275(8) states the following: "(8)a. Real and personal property that is used or, if under construction, is to be used exclusively for air cleaning or waste disposal OR to abate, reduce or prevent the pollution of air or water (including, but not limited to, waste lagoons and facilities owned by public or private utilities built and installed primarily for the purpose of providing sewer service to areas that are predominantly residential in character or areas that lie outside territory already having sewer service), if the Department of Natural Resources and Community Development or a local air pollution control program for air - cleaning devices located in an area where the Environmental Management Commission has certified a local air pollution control program pursuant to G.S. 143-215.112 furnishes a certificate to the tax supervisor of the county in which the property is situated or to be situated stating that the Environmental Management Commission or local air pollution control program has found that the described property: (Emphasis added.) 1. Has been or will be constructed or installed; 2. Complies with or that plans therefore which have been submitted to the Environmental Management Commission or local air pollution control program indicate that it will comply with the requirements of the Environmental Management Commission or local air pollution control program; 3. Is being effectively operated or will, when completed, be required to operate in accordance with the terms and conditions of the permit, certificate of approval, or other document of approval issued by the Environmental Management Commission or local air pollution control program; and 4. Has or, when completed, will have as its primary rather than incidental purpose the reduction of water pollution resulting from the discharge of sewage and Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 2 of 10 waste or the reduction of air pollution resulting from the emission of air contaminants. " III. SYSTEM DESCRIPTIONS System descriptions for the tax certification of the water pollution control exemption for qualifying water pollution control facilities (the "Facilities") at the Plant have been prepared for the following Plant Facilities: 1. Wastewater Collection and Treatment System 2. Boiler Blowdown Collection System 3. Cooling Tower System 4. Storm Water Collection & Segregation System 5. Secondary Containment - (Oil and Chemical Spill Control Containment) 6. Cathodic Protection System Each of the Facilities above is described herein. 1. Wastewater Collection and Treatment System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). Furthermore, NCGS § 130A-334 includes the following definitions: (2a) "Industrial process wastewater" means any water -carried waste resulting from any process of industry manufacture, trade, or business. (14) "Wastewater" means any sewage or industrial process wastewater discharged, transmitted, or collected from a residence, place of business, place ofpublic assembly, or other places into a wastewater system. (15) "Wastewater system" means a system of wastewater collection, treatment, and disposal in single or multiple components, including a privy, septic tank system, public or community wastewater, wastewater reuse or recycle system, mechanical or biological wastewater treatment system, and other similar system... " The Wastewater Collection & Treatment System at the Plant collects drains and processes industrial process wastewater for eventual discharge to the waters of the state. Specifically, components of the Wastewater Collection and Treatment System include: Phase I • GTG Drains Tank (500 Gallons) (3) • GTG Drains Tanks Foundations & Containments (3) • GTG Drains Tank Containment Pumps (3) - 50 gpm and 1.5 hp • GTG Water Wash Drains Tank (4,000 Gallons) (3) • GTG Water Wash Drains Tank Foundations (3) Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 3 of 10 Phase II • GTG Water Wash Drains Tank (4,000 Gallons) (2) • GTG Water Wash Drains Tank Foundations (2) • GTG Drains Tank (500 Gallons) (2) • GTG Drains Tank Containment Pumps (2) - 50 gpm and 1.5 hp • GTG Drains Tanks Foundations & Containment (2) • STG Oily Drain Tank (650 gallons) (1) • STG Oily Drains Tank Containment (1) • STG Lube Oil Containment Area Sump Pump (1) • Cooling Tower - Blowdown Piping • Circulating Water Chemical Feed Sump Pump (1) • Effluent Line • Waste Water Dechlorination Equipment Each Phase I and Phase II GTG is equipped with a false start drains tank and a water wash drains tank, with associated tank foundations. The false start drains tanks are located aboveground and the water wash tanks are located underground. Each false start tank is equipped with concrete curb containment and associated piping. The underground water wash drain tanks are not provided with complete secondary containment. The STG Unit is equipped with an STG oily drains tank. Similarly, this equipment is equipped with concrete curb containment and sump pump. Accumulated wastewater and storm water is examined to be sure no oil will be discharged from these containments. Drainage from the containment areas is then released to the ground where it drains via sheet flow into storm water drains, through the associated drainage culverts, and into one of the four detention ponds. Ultimately, runoff will reach North Second Creek. Drainage stored within the false start drains tanks and the water wash drains tanks will be pumped from the tanks and removed from the site by a waste management firm.l The false start drains tanks and lube oil reservoir containments are equipped with containment pumps that are locally controlled from a start/stop push button located at the pump. The pumps for these containments are operated manually and locked in the closed position when not in use. The remaining tanks are gravity drained using drain valves that are locked in a closed position when the containment is empty. The primary discharge from Phase II (the combined cycle process) is the cooling tower blowdown. The cooling tower blowdown contains sodium hypochlorite, corrosion inhibitors, scale inhibitors, and acid/caustic for pH control. The blowdown receives dechlorination treatment prior to the discharge. This water application includes only the downstream cooling tower blowdown piping and the dechlorination system. As per NCGS § 105-275(8), the Wastewater Collection and Treatment System is property used exclusively ... "to abate, reduce or prevent the pollution of water.." Furthermore, its primary, rather than incidental purpose is the reduction of water pollution resulting from the discharge of sewage and waste. ' Rowan County Power, LLC, Application for Coverage, General Permit NCG500000, April 11, 2002, Attachment 2, Page 2. Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 4 of 10 2. Boiler Blowdown Collection System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee)." Furthermore, Certificate of Coverage, Section C, page 5 of 15 states that the permit is applicable to the following types of discharges: 'l 3. Blowdown wastewaters. Blowdown is defined as the minimum discharge of recirculating water for the purpose of discharging materials contained in the water, the further buildup of which would cause concentrations in amounts exceeding limits established by best engineeringpractice. Furthermore, NCGS § 130A-334 includes the following definitions: (2a) "Industrial process wastewater" means any water -carried waste resulting from any process of industry manufacture, trade, or business. (14) "Wastewater" means any sewage or industrial process wastewater discharged, transmitted, or collected from a residence, place of business, place ofpublic assembly, or other places into a wastewater system. (15) "Wastewater system" means a system of wastewater collection, treatment, and disposal in singe or multiple components, including a privy, septic tank system, public or community wastewater, wastewater reuse or recycle system, mechanical or biological wastewater treatment system, and other similar system... " Therefore, under these definitions, boiler blowdown should be classified as blowdown wastewaters constituting an industrial process wastewater stream. The management of such wastewater via the Plant's Phase II Cooling Tower System, acting as a Wastewater system, is performed via the blowdown's treatment, reuse and recycling of the boiler blowdown back into Plant process cooling water system for cooling water needs for the STG condenser(s). The Boiler Blowdown Collection System includes the following major equipment: Phase II (Only) • Blowdown Collection Tanks (2) • HRSG Blowdown Tank Foundations (2) • HRSG Blowdown Sump & Sump Foundations (2) • HRSG Blowdown Sump Pumps (4) The Boiler Blowdown Collection System collects industrial process wastewater via steam and condensate drains originating from the Plant's two HRSGs within Phase II. For each unit, drains from sections of the HRSG are directed to one of two HRSG Blowdown Collection Tanks (one for each HRSG) where the fluid separates into steam and condensate. Steam is vented to the Rowan County Power, LLC Exhibit 1— System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 5 of 10 atmosphere and condensate drains to one of two Boiler Blowdown Sumps (one for each HRSG). Boiler Blowdown Sump Pumps (2 each) within each Boiler Blowdown Sump, convey the collected industrial process wastewater to the Plant's Cooling Tower basin. Ultimately, this waste stream becomes part of the larger Cooling Tower Blowdown process wastewater. Since the Blowdown Wastewater discharged from the Boiler Blowdown Collection System is defined as the minimum discharge of recirculating water for the purpose of discharging materials contained in the water, the further buildup of which would cause concentrations in amounts exceeding limits established by best engineering practice, as per NCGS § 105-275(8), the Boiler Blowdown Collection System is property used exclusively ... "for waste disposal." Furthermore, its primary, rather than incidental purpose, is the reduction of water pollution resulting from the discharge of sewage and waste. 3. Cooling Tower System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee)." Furthermore, NCGS § 130A-334 includes the following defmitions: (2a) "Industrial process wastewater" means any water -carried waste resulting from any process of industry manufacture, trade, or business. (14) "Wastewater" means any sewage or industrial process wastewater discharged, transmitted, or collected from a residence, place of business, place of public assembly, or other places into a wastewater system. (15) "Wastewater system" means a system of wastewater collection, treatment, and disposal in singe or multiple components, including a privy, septic tank system, public or community wastewater, wastewater reuse or recycle system, mechanical or biological wastewater treatment system, and other similar system... " Therefore, under these definitions, the Plant's Phase II Cooling Tower System acts in the capacity of a Wastewater reuse or recycle system. It provides for the treatment, reuse and recycling of the STG condenser cooling water, after thermal discharge to the atmosphere of the heat transferred during circulation within the condensers, as well as the reuse and recycling of boiler blowdown, back into Plant process cooling water needs for the STG condenser(s). Should an alternative, once -through cooling system design have been employed by the Plant, the discharge of these process industrial wastewater streams would ultimately have been to the surface waters of the state. Secondarily, the Cooling Tower System eliminates potential thermal pollutant emissions to surface waters of the state that would be created by the discharge of high - temperature condenser cooling water directly to North Second Creek in the Yadkin Pee -Dee River Basin. Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 6 of 10 The exclusive purpose of the Cooling Tower System is the reuse and recycling of Plant process industrial wastewater streams, in the form of cooling water and boiler blowdown. Therefore, as per NCGS §105-275(8), the Cooling Tower System is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, the Cooling Tower System's primary, rather than incidental purpose, is the reduction of water pollution resulting from the discharge of sewage and waste since it is sole purpose is the reuse and recycling of such wastewater streams after the removal of heat (thermal discharge) that would otherwise be discharged to the waters of the state in the form of industrial process wastewater. The Cooling Tower System includes the following major equipment: Phase II (Only) • Cooling Tower, Basin, Foundation, Grating, Piping, Valves, and Electrical • Circulating Water Pumps, Piping, and Valves • Cooling Tower - Circulating Water Chemical Feed System and Containment The Cooling Tower System is an 8-cell, induced mechanical -draft, fiberglass, counter -flow cooling tower. Each cell is equipped with a single speed motor driven fan. The fans are reversible for cold weather operation. Each fan has vibration switches that automatically stop the fan on high vibration and annunciate DCS alarms. Water is sprayed above the cooling tower fill with a "down -spray" system and cascades down through the fill. The cooling tower fans draw air upward through the fill, cooling the water by evaporation. Drift eliminators, installed above the cooling tower inlet distribution system, minimize the amount of water loss due to carryover of unevaporated water droplets. The Cooling Tower System Chemical Injection System controls biological growth and maintains the cooling water chemistry within specifications to ensure proper operation of the Cooling Tower System. The Cooling Tower System Chemical Injection System includes chemical storage tanks and chemical feed. pumps. 4. Storm Water Collection & Segregation Svstem The Department of Water Quality Certificate of Coverage Number NCG500582, Section C, page 5 of 15 states that the permit is applicable to the following types of discharges: 4. Exempt stormwater, which is defined as discharges of stormwater which do not require permits under the state of Federal NPDES programs. Exempt stormwater includes stormwater which accumulates in outdoor basins or ponds designed for cooling water or other waters covered by this permit. Storm Water Collection & Segregation System is basically comprised of catch basins, manholes, rip rap channels, and detention ponds. The detention ponds collect drainage from the gravity drained containment areas, released water from secondary containment structures, and storm water from the fuel oil areas. Once the condition of the accumulated storm water is examined to be sure no oil will be discharged, drainage from the containment areas is released to the ground where it drains via sheet flow into storm water drains, through the associated drainage culverts, and into one of the four detention ponds. Ultimately, runoff will reach North Second Creek. If a catastrophic spill Rowan County Power, LLC Exhibit I — System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 7 of 10 occurred, oil would flow to the southwest detention pond. A 10" containment boom has been installed in this pond as a precautionary measure. Inspection of the effluent from the southeast plant detention pond is a requirement of the Plant's permit. 2 The Storm Water Collection & Segregation System includes the following major equipment: Phase I • Stormwater Piping • Catch Basins • Concrete Headwalls • Manholes • Rip Rap Channels • Detention Ponds Phase II • Stormwater Piping • Catch Basins • Concrete Headwall • Manhole • Rip Rap Channel As shown above, the Storm Water Collection & Segregation System is property used exclusively to prevent water pollution. Therefore, as per NCGS § 105-275(8), the Storm Water Collection & Segregation System is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental purpose, is the reduction of water pollution resulting from the discharge of sewage and waste. 5. Secondary Containment - (Oil and Chemical Spill Control Containment) The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). Such discharges shall be limited and monitored by the Permittee as specified below: In this table, Oil and Grease limits are as follows: EFFLUENT LIMITS MONITORING RE UIRMENTS CHARACTERISTICS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location Oil & Grease see note 3 15.0 mg/1 20.0 mg/1 Semi-annually Grab Effluent The Code of Federal Regulations Title 40 Part 112 sets forth the requirements for the Plant's Spill Prevention, Control and Countermeasures Plan ("SPCC Plan"). On -site petroleum product storage areas and chemical storage areas have secondary containment in the form of concrete- 2 Spill Prevention Control and Countermeasures ("SPCC") Plan Rowan County Power, LLC, Updated September 24, 2004 Revision No. 3 Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 8 of 10 wall dikes, sumps, containment pallets or steel trays. In the event of oil or chemical leakage, the containment areas prevent the release of industrial waste to the waters of the state. The exclusive purpose of the Secondary Containment - (Oil and Chemical Spill Control Containment) is the prevention of an accidental discharge of oils and hazardous materials to the waters of the state by the use of concrete containment structures. As per NCGS § 105-275(8), Secondary Containment - (Oil and Chemical Spill Control Containment) is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental, purpose is the reduction of water pollution resulting from the discharge of sewage and waste. The Secondary Containment - (Oil and Chemical Spill Control Containment) includes the following major equipment: Phase I • Accessory & LF / AA Module Containment (3) • Isolation Transformer Containment (2) • LCI / EX2000 Transformer Containment (2) • Station Service Transformer Containment (1) • Fuel Oil Unloading Area Containment • Fuel Oil Unloading Area Containment Grating • Fuel Oil Forwarding Skid Containment (1) • Main Step-up Transformer Containment (3) • Excitation Transformer Containment (3) • 480V Secondary Unit Substation Transformer Containment (3) • Fuel Oil Area 480V SUS & MCC Containment (1) • 4.16 KV MCC, Switchgear, & Transformer Containment (1) • Administration Building Transformer Containment (2) • Fire Pump Transformer Containment (1) • Fuel Oil Unloading Area Canopy • Fuel Oil Piping Double Wall Portion of Pipe • Fuel Oil Tanks Double Wall Cost Phase II • Accessory & LF / AA Module Containment (2) • Isolation Transformer Containment (1) • LCI / EX2000 Transformer Containment (1) • Main Step-up Transformer Containment (2) • Excitation Transformer Containment (2) • STG Main Oil Tank, Coolers, Strainers, & Conditioner Containment (1) • Cycle Chemical Feed Area Containment (1) • Fuel Oil Forwarding Skid Containment (1) • STG #2 GSU Transformer Containment (1) • STG 13.8 KV Unit Auxiliary Transformer Containment (1) • 4.16 KV Unit Auxiliary Transformer Containment (1) • Circulating Water Pump Transformer Containment (1) • Station Service Transformer Containment (2) 0 Balance of Plant Station Service Transformer Containment (1) Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 9 of 10 Each gas turbine is equipped with a lube oil reservoir, fuel oil pump skid, and false start drain tank. The false start drain tanks are located aboveground. Each tank is equipped with concrete curb containment. The Steam Turbine (ST) Unit in association with CT Unit 5 is equipped with an EHC Oil Unit, EHC Main Oil Tank, ST Oily Drains Tank, and Seal Oil Unit. Similarly, each piece of equipment is equipped with concrete curb containment. Several transformers containing mineral oil are located in the combustion turbines, steam turbine and substation areas at the Plant, including six main step-up transformers. Secondary containment for each of these units is provided by concrete curb containment structures. Additional containment for the site is provided through the use of on -site sandbags and booms and the four site detention ponds. The false start drain tank and lube oil reservoir containments are equipped with containment pumps that are locally. controlled from a start/stop push button located at the pump. The pumps for these containments are operated manually and locked in the closed position when not in use. The remaining tanks and transformers are gravity drained using drain valves that are locked in a closed position when the containment is empty. The detention ponds collect drainage from the gravity drained containment areas, released water from secondary containment structures, and storm water from the fuel oil areas. An uncontained oil release from the site would flow by way of the storm water collection system into one of the four detention ponds. Discharge from the detention ponds could flow through natural drainage features into one of the tributaries to North Second Creek.3 As shown above, the Secondary Containment - (Oil and Chemical Spill Control Containment) is property used exclusively to prevent water pollution. As per NCGS § 105-275(8), Secondary Containment is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, -its primary, rather than incidental, purpose is the reduction of water pollution - resulting from the discharge of sewage and waste. 6. Cathodic Protection System The Department of Water Quality Certificate of Coverage Number NCG500582, Part A(1) page 2 of 15 states, "The Permittee is authorized to discharge non -contact cooling water, cooling tower boiler blowdown, air compressor condensate and similar wastewaters from outfalis numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). The Plant uses the Cathodic Protection System for underground piping as a proactive method to prevent corrosion of piping so that there is no unauthorized discharge of pollutants to the waters of the state. Corrosion is an electrochemical reaction based on universal laws of nature. All metallic structures corrode when immersed in an electrolyte such as soil, water or concrete. The only thing that varies is the time involved in the corrosion. When placed in the ground, metals produce a current, which causes ions to leave their surface. The rate of current flow determines the life of the structure. Spill Prevention Control and Countermeasures (" SPCC") Plan Rowan County Power, LLC, Updated September 24, 2004 Revision No. 3 Rowan County Power, LLC Exhibit I —System Descriptions Application for Water Pollution Control Certificate March 8, 2006 Page 10 of 10 By connecting a metal of higher potential to a metallic structure it is possible to create an electrochemical cell in which the metal with lower potential becomes a cathode and is protected. This technique is called cathodic protection. Selected underground piping has been installed with cathodic protection to protect the pipe from corrosion and subsequent inadvertent leakage to the surface waters or groundwaters in the vicinity of the Plant. Since the exclusive purpose of the Cathodic Protection System is to prevent inadvertent pipe leakage due to corrosion, as per NCGS §105-275(8), the Cathodic Protection System is property used exclusively ... to abate, reduce or prevent the pollution of water. Furthermore, its primary, rather than incidental, purpose is the reduction of water pollution resulting from the discharge of sewage and waste. EXfIIBIT H. INFORMATIONREQUIRED FOR WATER POLLUTION CONTROL PROPERTY TAX EXEMPTION REQUEST OWNERS: ROWAN COUNTY POWER, LLC PLANT NAME: ROWAN COUNTY ADDRESS: 5755 NORTH CAROLINA 801 HIGHWAY CITY. SALISBURY, NORTH CAROLINA 28144 PLANT: UNITS 1-3 SIMPLE CYCLE PLANT NPDES PERMIT: CERTIFICATE OF COVERAGE NUMBE NCG5005S2 Application Item Number( Equipment / System Name Eligibility - Permit Section / Regulations Primary Purpose / Operation Detailed Description WATE OLL TION REDUCTION SYSTEMS •WASTE DISPOSAL.SYSTEMS -1 Wastewater Collection & Treatment Division of Water Quality ('DWQ') Certificate of Exclusive purpose ofwaste disposal by preventing The Wastewater Collection System collects the wastewater from the fuel oil / water interface Coverage Number NCG500582, Part A(1) page 2 of unauthorised discharges to the groundwater and condensate, secondary containment area drains, and other wastewater drains in the plant. The 15 and PartC(1 to 31 page 5 of 15. North Carolina surface waters of the state. Wastewater Collection System includes but is not limited to three (3) CT Water Wash Tanks, three General Statutes ('NCGS') Section 130A-335. (3) CT Drains Tanks, three (3) CT Drains Tank Containment Pumps, various sump pumps, piping, and associated instrumentation. WATER POL UTION PREVENTION SYSTEMS - SPILL PREVENTION W-2 Storm Water Collection & Segregation DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of collecting and segregating The Storm Water Collection & Segregation System segregates storm water from process System - PartC(41 page 5 of 15r' stormwater thereby preventing unauthorized wastewater and directs the flow of storm water runoff for discharge from the Facility site. The discharges to the groundwater and surface waters Storm Water Collection and Segregation System includes but is not limited to catch basins, of the state. underground drain pipes, surface drainage ditches, and storm water detention ponds. w-3 Cathodic Protection DWQ Certificate of Coverage Number NCG500582,. Exclusive purpose of preventing leakage of fluids A cathodic protection system is installed to mitigate corrosion and reduce the likelihood of Par A(1) page 2 of 15. NCGS Section 130A-335. and discharges into the ground. hazardous materials contaminating the environment. The cathodic protection installation \�consists of an electrical system that sends current through an insulated wire to anodes, which are special metal bare buried in the soil near the underground piping. W-4 Secondary Containment - (Oil and DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing the accidental Containment and diversionary structures are mandated by the CFR to prevent a discharge to the Chemical Spill Control Containment) Part A(1) page 2 of 15. CFR Title 40 Parts 112.20, discharge of oils and hazardous materials by the groundwaters of the state. All containers (including transformers) used to stare oil. and other ' 112.21, and 112.1-7. Spill Prevention Control and use of concrete containment structures. such potentially harmful liquids have a form of secondary containment. The secondary Countermeasures ('SPCC') Plan Rowan County containment provides additional storage capacity for any materials which may leak due to the - Power, LLC. failure, overfilling or improper draining of the primary storage container. Secondary containment structures at the plant include but are not limited to non -leaching concrete containments installed under or around the primary storage containers. In addition to the concrete secondary containments, the plant includes a fuel oil unloading canopy area that shields the fuel oil unloading components from stormwater thereby containing any spills or leaks and preventing the pollution of the groundwaters of the state. The plant also includes secondary containment steel walls for the plant's fuel oil storage tanks. P.O.1 of t EXHIBIT III. INFORMATION REQURED FOR WATER POLLUTION CONTROL PROPERTY TAX EXEMPTION REQUEST OWNERS: ROWAN COUNTY POWER, LLC PLANT NAME: ROWAN COUNTY ADDRESS: 5755 NORTH CAROLINA 801 HIGHWAY CITY. SALISBURY, NORTH CAROLINA 28144 PLANT: UNITS 4-5 COMBINED CYCLE PLANT �~\ NPDES PERMIT: CERTIFICATE OF COVERAGE NUMB NCU Application Equipment / System Name Eligibility - Permit Section / Regulations Primary Purpose / Operation DetaOed De.cription Item Number WATER -POLLUTION REDUCTION SYSTEMS - WASTE DISPOSAL SYSTEMS W-1 Wastewater Collection & Treatment Division of Water Quality ('DWQ') Certificate of Exclusive purpose of waste disposal by preventing The Wastewater Collection System collects the wastewater from the cooling tower blowdown, Coverage Number NCG500582, Part A(1) page 2 of unauthorized discharges to the groundwater and HRSG blowdown, cooling tower drains, fuel ail / water interface condensate, secondary 15 and PartC(I to 3) page 5 of 15. North Carolina surface waters of the state. containment area drains, and other wastewater drains in the plant. Prior to discharge to the General Statutes (-NCGS') Section 130A-335. permitted discharge point, outfall 002 (North) Second Creek, the cooling tower drains stream is treated with a de -chlorination System. The Wastewater Collection System includes but is not limited to two (2) CT Water Wash Tanks, two (2) CT Drains Tanks, two (2) CT Drains Tank Containment Pumps, one (11 Oily Drains Tank, a dechlorination system, various sump pumps, piping, and associated instrumentation. W-2 Boiler Slowdown Wastewater Collection DWQ Certificate of Coverage Number NCG500582, Exclusive purpose ofwaste disposal by preventing The Boiler Blowdown Wastewater System delivers blowdown wastewater to the cooling tower Part A(1) page 2 of 15 and PartC(1 to 3) page 5 of unauthorized discharges to the groundwater and basin. The Boiler Blowdown Wastewater System includes but is not limited to two (2) boiler 15. NCGS Section 130A-335. surface waters of the state. blowdown tanks, two (2) blowdown water sump, four (4) blowdown water sump pumps, piping, and instrumentation. WATER POLLUTION REDUCTION SYSTEMS - THERMAL POLLUTION REDUCTION SYSTEMS W-3 Cooling Tower System (-CTS') DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of reducing thermal discharges The CTS serves to reduce the amount of water pollution in the form of heat by cooling the Part A(I) page 2 of 15 and PartC(1 to 3) page 5 of to surface waters of the state. condenser cooling water and transferring the heat to the atmosphere rather than discharging heat 15. NCGS Section 130A-335. to the waters of the state. By using a cooling tower, a combined -cycle electric generating facility eliminates the use of once -through cooling as the method of coaling STG condensers. The cooling tower is an 8-cell, mechanical -draft tower. The CTS includes but is not limited to the cooling tower basin, foundation, equipment; all associated water piping and pumps; and chemical injection equipment. WATER POLLUTION PREVENTION SYSTEMS - SPILL PREVENTION W-4 Storm Water Collection & Segregation DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of collecting and segregating The Storm Water Collection & Segregation System segregates storm water from process System PartC(4) page 5 of 15. stormwater thereby preventing unauthorized wastewater and directs the flow of storm water runoff for discharge from the Facility site. The discharges to the groundwater and surface waters Storm Water Collection and Segregation System includes but is not limited to catch basins, of the state. underground drain pipes, surface drainage ditches, and storm water detention pond.. W-5 Cathodic Protection DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing leakage of fluids A cathodic protection system is installed to mitigate corrosion and reduce the likelihood of Part A(1) page 2 of 15. NCGS Section 130A-335. and discharges into the ground. hazardous materials contaminating the environment. The cathodic protection installation consists of an electrical system that sends current through an insulated wire to anodes, which are special metal bars buried in the soil near the underground piping. W.6 / Secondary Containment - (Oil and DWQ Certificate of Coverage Number NCG500582, Exclusive purpose of preventing the accidental Containment and diversionary structures are mandated by the CFR to prevent a discharge to the � __e, Chemical Spill Control Containment) Part A(1) page 2 of 15. CFR Title 40 Parts 112.20, discharge of oils and hazardous materials by the groundwaters of the state. All containers (including transformers) used to store oils and other 112.21, and 112.1-7. Spill Prevention Control and use of concrete containment structures. such potentially harmful liquids have a form of secondary containment. The secondary Countermeasures (-SPCC-) Plan Rowan County containment provides additional storage capacity for any materials which may leak due to the Power, LLC. failure, overfilling or improper draining of the primary storage container. Secondary containment structures at the plant include but are not limited to non -leaching concrete containments installed under or around the primary storage containers. Page 1 of 1 r o � October 25, 2005 Mr. Larry Small, Plant Manager Rowan County Power, LLC 5755 NC 801 Hwy Salisbury, NC 28147 Michael F. Easley, Govern 'rb&— William G. Ross Jr., Secretdry North Carolina Department of Environment and Natural Resources Subject: Rowan County Power, LLC General Permit No. NCG500582 & Tax Certification Rowan County, N.C. Dear Mr. Small: Alan W. Klimek, P.E. Director Division of Water Quality After further review of the storm water permit for the subject facility, it has been decided that the facility should be covered by an individual permit. Rowan County Power, LLC is subject to the Federal Effluent Guidelines and needs to apply for an individual permit and complete EPA Form 1 and EPA Form 2E. These forms and instructions can be downloaded from our website: httn-//h2o.enr.state.nc_nsNPDES/ciocnm nt, h ml#individnalapps Regarding tax certification, we can only certify at this time the storm water ponds and associated piping and the treatment facilities at the discharge, excluding the boiler blowdown and the cooling tower. After review of the individual permit, this office will be able to give you a definitive answer regarding the other components that were submitted for tax certification. Since the original tax certification submitted to this office was returned, it is necessary for Rowan County Power, LLC to resubmit the application to this office in order to process the tax certification for the wastewater treatment facilities mentioned above. If you have any questions concerning this matter, please do not hesitate .to contact Mr. Samar Bou-Ghazale or me at (704) 663-1699. Sincerely, D. Rex Gleason, P. E. Surface Water Protection Regional Supervisor No0&' Carolivna T nt/ •-------- North Carolina Division of Water Quality 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone (704) 663-1699 Customer Service Internet: h2o.enr.state.nc.us FAX (704) 663-6040 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper p�pF �ATFRQG Michael F. Eemo Uj r William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources O 'C Alan W. Klimek, P.E. Director Division of Water Quality August 8, 2003 Mr. Larry Small Rowan County Power, LLC 5755 NC 801 Hwy. Salisbury , NC 28147 Subject: NPDES COC # NCG500582 Rowan County Power, LLC Amendment to permit application Rowan County Dear Mr. Small: The Division has amended your NCG500582 application with the information submitted in a letter received from you on May 22, 2003. The toxicity of the splash/drift discharge from the cooling system water was examined by the Division's toxicity unit and found to be discharging at acceptable levels. If you have any questions about this matter please contact Ms. Aisha Lau at (919)733-5083 ext. 578. Sincerely, cc: Stormwater and General Permits Unit Moore s-vil-le-Regional-0ffice Central Files NCDENR Customer Service Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 1 800 623-7748 O o i` �i Q�""`''o e C I • �qy° �/ f � � � � �ii�/I r �✓� I. � 1� !`-,.�` '� • , •� i . ' 1. wl � : �``,.�, ` �'�'�/ ,' P•. _ f)t� / `.J�l Site` Boundary t `( 1It ` Property t ; Boundary -� 3 O Cooling Tower _ f 11 �Sd* ° Storm Water Pond ^� ` 9 ,, -� •.1�' �� ; _s� I Outfall 001 -- ��-- 7-W Outfall 002 - Outfall I _� :4� ( Underm1Lground ( Sampling Point) % / i Discharge Pipe) i Wu all 002 �- l t� �,.� (Temperature y .1 Sampling Point) (� �� - ---� of �:� .� � �� � � •'�_��- USGS 7-1/2 MINUTE SERIES MAP FIGURE NUMBER: ENSR I AECOM�4 Rowan Mills, NC Topographic Site Map 1987 TOPOGRAPHIC QUADRANGLE Plant Rowan County 5755 Highway 801 ENSR CONSULTING AND ENGINEERING (NC), INC. Salisbury RALEIGH, NORTH CAROLINA 27616 Rowan County, North Carolina PHONE (919) 872-6600 FAX: (919) 872-7996 1 DRAWN BY: I DATE PROJECT NUMBER DRAWWG NUMBER: WEB: HTTP://WWW.ENSR.AECOM.COM SCALE 1:24000 1 KLR 1 1/26/07 06204-018 1 A60644A Mr. Joel Y. Kamya President, Rowan County Bower, LLC P.O. Box 1551— Mail Stop 333-4 Raleigh, NC 27602-1551 Dear Mr. Kamya: Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources HC DEPT. LAdan,W. i.Ll��sr�Qk��.E. ANID;J,`\Ttin .t c:- iIOr_yf5 for iMC1DRE,,,,.Division'of Wd er-U-i9lity October 29, 2002 NOV 0 7 2002 Subject: NPDES Permit # NCG500582 Rowan County Power, LLC NCG500582 modification and A to C Rowan County On April 12, 2002 the Division of Water Quality received your Notice of Intent (NOI) requesting a modification to the treatment system covered by the existing Certificate of Coverage number NCG500582. Based on the information provided with this permit modification authorization is hereby granted for the construction and operation of a cooling water dechlorination system with a'maximum discharge of 0.24 MGD of treated wastewater to Second Creek, a Class C stream in the Yadkin -Pee Dee River Basin. However, the use of the water conditioners described in this modification are limited to the conditions outlined in the enclosed memorandum from Mr. Todd Christenson, dated September 16, 2002, and enclosed. The Authorization to Construct is issued in accordance with Part III, Paragraph 2 of NPDES Permit No. NCG500000, and shall be subject to revocation unless the wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in Permit No. NC6500000. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take immediate corrective action, including those as may be required by this Division, such as the construction of additional or replacement wastewater treatment or disposal facilities. The Mooresville Regional Office, telephone number (704) 663-1699, shall be notified at least forty-eight (48) hours in advance of operation of the installed facilities so that an in -place inspection can be made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. - Upon completion of construction and prior to operation of this permitted facility a certification must be received from a professional engineer certifying that -the permitted facility has been installed in accordance with the NPDES Permit, the Certificate of Coverage, this Authorization to Construct and the approved plans and specifications. Mail the Certification to the Stormwater and General Permits Unit, NCDENR, DWQ, 1617 Mail Service Center, Raleigh, NC 27699-1617. A copy of the approved plans and specifications shall be maintained on file by the Permittee for the life of the facility. NCDENR N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service 1 800 623-7748 Permit No. NCG500582 Permit Modification/Authorization to Construct Rowan County Power, LLC October 29, 2002 Page 2 Failure to abide by the requirements contained in this Authorization to Construct may subject the Permittee to an enforcement action by the Division of Water Quality in accordance with North Carolina General Statute 143-215.6A to 143-215.6C. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning this matter please contact Aisha Lau at (919) 733-5083, ext. 578. Sincerely, Alan W. Klimek, P.E. Enclosure _ cc: -Mooresville Reg nanal-Of e Stormwater and General Permits Unit . Central Files V o. NCG500582 odification/Authorization to Construct County Power, LLC October 29, 2002 Page 2 Engineer's Certification` as a duly registered Professional Engineer in the State of North Carolina, having - been authorized to observe (periodically, weekly, full time) the construction of the project, for the Project Name Location Permittee, hereby state that, to the best of my abilities, due care and diligence was used in the observation of the construction of a cooling water dechlorination system such that the construction was observed to be built within substantial compliance and intent of the approved plans and specifications. Signature Date Registration No. Upon completion of construction and prior to operation of this permitted facility a certification must be received from a professional engineer certifying that the permitted facility has been installed in accordance with the NPDES Permit, the Certificate of Coverage, this Authorization to Construct and the approved plans and specifications. Mail the Certification to Aisha Lau, Stormwater and General Permits Unit, NCDENR, DWO, 1617 Mail Service Center, Raleigh, NC 27699-1617. To: Permits and'Engineering Unit Water Quality Section Attention: Tony Evans SOC PRIORITY PROJECT: No Date: June 5, 2000 NPDES STAFF REPORT AND RECOMMENDATIONS -County: Rowan NPDES Permit No.: NCG500582 MRO No.: 00-51 PART I - GENERAL INFORMATION 1. Facility and Address: CP&L - Rowan Combustion Turbine Generation Facility 575.5 NC Hwy. 801 Salisbury, N.C. 28144 2. Date of Investigation: June 2, 2000 3. Report Prepared By: Michael L. Parker, Environ. Engr. II 4. Person Contacted and Telephone Number: Bill Hickman, (919)215-4529 5. Directions to Site: From the jet. of US Hwy. 70 and NC Hwy. 801 in western Rowan County, travel north on NC Hwy. 801 z 1.0 mile. The entrance to the site is on the right (east) side of Hwy 801. 6. Discharge Point(s), List for all discharge Points: - Latitude: 350 43' 10" Longitude: 80' 35' 40" Attach a USGS Map Extract and indicate treatment plant site and discharge point on map. USGS Quad No.: E 16 NE 7. Site size and expansion area consistent with application: Yes. There is ample room for WWTP construction, if necessary. 8. Topography (relationship to flood plain included): The site is gently rolling with slopes ranging from, 3-12%. The plant site is not located in a flood plain. 9. Location of Nearest Dwelling: Approx. 500+ feet from the plant site. Page Two 10. Receiving Stream or Affected Surface Waters: Second Creek a. Classification: WS-IV, C b. River Basin and Subbasin No.: Yadkin 030706 C. Describe receiving stream features and pertinent downstream uses: The area both upstream and downstream is generally rural in nature with agriculture being the primary use, however, there is one large industrial discharger z 2/3 mile upstream (Koss - NC0004944). PART H - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS a. Volume of Wastewater: 0.058 MGD (Design Capacity) b. What is the current permitted capacity: N/A G. Actual treatment capacity of current facility (current design capacity): N/A d. Date(s) and construction activities allowed by previous ATCs issued in the previous two years: N/A e. Description of existing or substantially constructed WWT facilities: There are no existing WWT facilities. f. Description of proposed WWT facilities: The applicant does not propose any WWT facilities at this time. The discharge will consist primarily of non -contact cooling water (see Part IV). g. Possible toxic impacts to surface waters: There are no toxic impacts expected. Any biocidal additives to the cooling water system will have to be approved by the Aquatic Toxicology Unit prior to use. h. Pretreatment Program (POTWs only): Not Needed. 2. Residual handling and utilization/disposal scheme: Residuals generation is not expected. 3. Treatment Plant Classification: N/A 4. SIC Code(s): 4911 Wastewater Code(s): 14 5. MTU Code(s): N/A Page Three PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? No 2. Special monitoring or limitations (including toxicity) requests: None at this time. 3. Important SOC/JOC or Compliance Schedule dates: N/A 4. Alternative Analysis Evaluation a. Spray Irrigation: Not pursued for the first phase of this project since the applicant plans to utilize reuse in later phases of this project. b. Connect to regional sewer system: There is a package WWTP within the service area of this proposed facility, however, an expansion of this plant would be necessary before it could accept the proposed waste stream. Also the cooling water may be detrimental to the operation of the WWTP since the cooling water waste stream would dominate the plant's influent resulting in an unfavorable F/M ratio. C. Subsurface: Not pursued for the first phase of this project since the applicant plans to utilize reuse in later phases of this project. d. Other disposal options: None evaluated. PART IV - EVALUATION AND RECOMMENDATIONS CP&L is proposing to construct a combustion turbine generation facility in western Rowan County. Wastewater generated at this facility will come from an evaporative cooling process for the combustion turbines. Although there are no additives to the cooling water proposed at this time, any additives (such as biocides) will require Division approval prior to their use. Domestic wastewater will be disposed of on -site through subsurface disposal permitted through the Division of Environmental Health. Other wastewater sources that may have pollutants such as oil/grease will be collected for disposal (pumped and hauled) off -site at a waste oil reclamation facility. Pending receipt d approval of the draft permit, it is recommended that an NPDES Permit be issued. Signature of ReportPreparer Date Water Quality Re nal Supervisor Date hAdsr\dsr00\cp&1.dsr A 1� State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Bill Holman, Secretary Kerr T. Stevens, Director by March 20, 2000 CAROLINA POWER AND LIGHT COMPANY ATTN: BILL HICKMAN 411 FAYETTEVILE STREET (CPB 9A) RALEIGH, NORTH CAROLINA 27605 Dear Mr. Hickman: IT .. L'TIWA 1 0 • NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Ma WPM 40V v NATURAL RESO RC:L- �Q 2p, '2000 ,�st7yytdd p ,1 .i�;,.y�.:rl r;•• r^rrpEH'I ' �7 VYJCQi1 Uh Ea�7�u:..1k.Lr!I :� In:11:.1..L1] Uslil[IESVILLE HRIO!IL 7FFVr Subject: NPDES General Permit Application Application Number NCG500582 Carolina Power and Light Company Rowan County This is to acknowledge receipt of the following documents on 03H03100 ,f Completed Notice of Intent (Application Form), Engineering Proposal (for proposed control facilities), Request for permit renewal, Application processing fee of $80.00 Engineering Economics Alternatives Analysis, Engineering Plans and Specifications Local Government Signoff, Source Reduction and Recycling; Interbasin Transfer, Other: The items checked below are needed before review can begin: Completed Notice of Intent (Application Form), Engineering proposal (see attachment), Application Processing Fee of $, Delegation of Authority (see attached), Biocide Sheet (see attached), Engineering Economics Alternatives Analysis, Engineering Plans and Specifications Local Government Signoff, Source Reduction and,Recycling, Interbasin Transfer, Other: If the application is not made complete within thirty (30) days, it will be returned:to you and may be resubmitted when complete. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action.Employer 50% recycled/ 10% post -consumer paper NCG500582 Page 2 This application has been assigned to Antonio Evans (919/733-5083) Ext. 584 of our Stormwater and General Permits Unit for review. You will be advised of any comments, recommendations, questions or other information necessary for the review of the application. Sincerely, r Y2 Z:D Antonio V. Evans, P.E. Stormwater and General Permits Unit cc: `-_a_Mooresvilhl_eReggrial-Office Permit Application File A,LTT4 Division of Water Quality / Water Quality Section NCDENR National Pollutant Discharge Elimination System NORTH CAROLW DEPARTMENT OF ENVIRONMENT ANC NATURAL Res ul ces NCG500000 NOTICE OF INTENT National Pollutant Discharge Elimination System application for coverage un NCG500000: Non -contact cooling water, boiler blowdown, cooling tower T similar point source discharges (Please print or type) 1) Mailing address of owner/operator: Company Name FOR AGENCY USE ONLY Date Received Year Month Da Certificate "Coverage NFCTG17 Check # Amount Permit Assigned to e Inreralr-Perjmi l l9 deg �'' n, on n ate, -and'_ _ i MAR 3 1 l3ENR! Owner Name Carolina Power and Light Company -__ ----- Street Address 411 Fayetteville Street Q _(CPB9A) __ City Raleigh State NC ZIP Code �7605 w z -- ---- —___-- _— Telephone No. (919) 546-7428 p - -- ------ ---- Fax: ------- ---- --- —=- N? Address to which all permit correspondence will be mailed,3 C 2) Location of facility producing discharge: Pi c 00 Fi i:? Facility Name CP&L Rowan County Combustion Turbine Generation Facility T 0 :1 Facility Contact Bi�� lii c�man--__—_-_-------_--_- -9 = -- w' C Street Address 5755 NC 801 Highway U c� Salisbury-----------------�-----------�r�+4-- City - State ---___ ZIP Code --_-_ County Rowan —_____— ----------------------------- Telephone No. 919) _ 215-4529—___—_— Fax: ------ 3) Physical location information: Please provide a narrative description of how to get to the facility (use street names, state road numbers, and distance and direction from a roadway intersection). See Attachment_ 1 __---_—_ — (A copy of a county map or USGS quad sheet with facility clearly located on the map is required to be submitted with this application) 4) This NPDES permit application applies to which of the following: 4� New or Proposed ❑ Modification Please describe the modification: -- ----- ---------------- ❑ Renewal Please specify existing permit number and original issue date: ___________ 5) Does this facility have any other NPDES permits? ❑ No AR Yes If yes, list the permit numbers for all current NPDES permits for this facility: NCGO 10000 For any discharge of storm water associated with construction 6) What is the nature of the business applying, for this permit? ElectricityGeneration See attachment 2 Page 1 of 4 SWU-212-062199 NCG500000 N.O.I. 7) Description of Discharge: a) Is the discharge directly to the receiving water? U Yes ❑ No If no, submit a site map with the pathway to the potential receiving waters clearly marked. This includes tracing the pathway of the storm sewer to the discharge point, if the storm sewer is the only viable means of discharge. b) Number of discharge points (ditches, pipes, channels, etc. that convey wastewater from the property): 1 (001) c) What type of wastewater is discharged? Indicate which discharge points, if more than one. XJ0 Non -contact cooling water Discharge point(s) #: 001___ ❑ Boiler Blowdown Discharge point(s) M ----------- ___ ❑ Cooling Tower Blowdown Discharge point(s) #: ❑ Condensate Discharge point(s) #: ❑ Other Discharge point(s) #: (Please describe "Other") d) Volume of discharge per each discharge point (in GPD): 60;000 GPD #1: XX #2: #3: #4 e) Please describe the type of process (i.e., compressor, A/C unit, chiller, boiler, etc.) the wastewater is being discharged from, per each separate discharge point (if applicable, use separate sheet): --- See attachment 2 8) Please check the type of chemical added to the wastewater for treatment , per each separate discharge point (if applicable, use separate sheet): ❑ Biocides Name: Manuf.: ❑ Corrosion inhibitors Name: Manuf.: ❑ Chlorine Name: Manuf.: ❑ Algaecide Name: _ Manuf.: ❑ Other Name: Manuf.: XKI None 9) If any box in item (8) above, other than none, was checked, a completed Biocide 101 Form and manufacturers' information on the additive is required to be submitted with the application for the Division's review. 10) Is there any type of treatment being provided to the wastewater before discharge (i.e., retention ponds, settling ponds, etc.)? ❑ Yes NN No If yes, please include design specifics (i.e., design volume, retention time, surface area, etc.) with submittal package. Existing treatment facilities should be described in detail. Design criteria and operational data (including calculations) should be provided to ensure that the facility can comply with the requirements of the General Permit. The treatment shall be sufficient to meet the limits set by the general permits. Note: Construction of any wastewater treatment facilities requires submission of three (3) sets of plans and specifications along with the application. Design of treatment facilities must comply with the requirements of 15A NCAC 2H .0138. If construction applies to this discharge, include the three sets of plans and specifications with this application. Page 2 of 4 SW U-212-062199 NCG500000 N.O.I. 11) Discharge Frequency: a) The discharge is: ❑ Continuous :9 Intermittent 19: Seasonal• i) If the discharge is intermittent, describe when the discharge will occur: Up to 16 hours - -perday --------- ----- ----- ---- ii) If seasonal check the month(s) the discharge occurs: ❑ Jan. ❑ Feb. ❑ Mar. ❑ Apr. May Jun. Jul. Au Sept.Oct. ❑Nov. El mo t ss har in other y g• • cdepeeding on need b) How many days per week is there a discharge? U 2__1LcL 7days /week________ c) Please check the days discharge occurs: Sat. � Sun.X7 Mon. )�6 Tue.X] Wed. -ice Thu. Fri. 12) Pollutants: Please list any known pollutants that are present in the discharge, per each separate discharge point (if Pollutants in discharge would consist of those substances aprplicable, use s�parate sheet): _—___ p esent in t e water source in addition to particulates not removecTTrom the air 13) Receiving waters: stream by the filters.. a) What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility wastewater discharges end up in? If the site wastewater discharges to a separate storm sewer system (4S), name the operator of the 4S (e.g. City of Raleigh). Second creek b) Stream Classification: C , WS IV ----- 14) Alternatives to Direct Discharge: See attachment 3 Address the feasibility of implementing each of the following non -discharge alternatives a) Connection to a Regional Sewer Collection System b) Subsurface disposal (including nitrification field, infiltration gallery, injection wells, etc.) c) Spray irrigation The alternatives to discharge analysis should include boring logs and/or other information indicating that a subsurface system is neither feasible nor practical as well as written confirmation indicating that connection to a POTW is not an option. It should also include a present value of costs analysis as outlined in the Division's "Guidance For the Evaluation of Wastewater Disposal Alternatives': 15) Additional Application Requirements: For new or proposed discharges, the following information must be included in triplicate with this application or it will be returned as incomplete. a) 7.5 minute series USGS topographic map (or a photocopied portion thereof) with discharge location clearly indicated. b) Site map, if the discharge is not directly to a stream, the pathway to the receiving stream must be clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point. c) If this application is being submitted by a consulting engineer (or engineering firm), include documentation from the applicant showing that the engineer (Or firm) submitting the application has been designated an authorized Representative of the applicant. d) Final plans for the treatment system (if applicable). The plans must be signed and sealed by a North Carolina registered Professional Engineer and stamped -"Final Design -Not released for construction". Page 3 of 4 SWU-212-062199 NCG500000 N.O.I. e) Final specifications for all major treatment components (if applicable). The specifications must be signed and sealed by a North Carolina registered Professional Engineer and shall include a narrative description of the treatment system to be constructed. I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: Joel Y_Kamma__ Title: Vice President of Power Plant Development & Construction Department (CP&L) 2/17/00 ------ — ------------------ ---- -- --- ------- (Signature of Applicant) (Date Signed) North Carolina General Statute 143-215.6 b (i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.) Notice of Intent must be accompanied by a check or money order for $80.00 made payable to: NCDENR Mail three (3) copies of the entire package to: Stormwater and General Permits Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Final Checklist This application will be returned as incomplete unless all of the following items have been included: ❑ Check for $80 made payable to NCDENR ❑ 3 copies of county map or USGS quad sheet with location of facility clearly marked on map ❑ 3 copies of this completed application and all supporting documents ❑ 3 sets of plans and specifications signed and sealed by a North Carolina P.E. ❑ Thorough responses to items 1-7 on this application ❑ Alternatives analysis including present value of costs for all alternatives Note The submission of this document does not guarantee the issuance of an NPDES permit Page 4 of 4 SWU-212-062199 ATTACHMENT 1 NCG500000 NOI CP&L Rowan County Combustion Turbine Generation Facility - Physical Location Information - From Salisbury, NC, travel west on US Route 70 to intersection of US Route 70 and State Road 801. Turn right (north) on State Road 801, travel approximately one mile and turn right (east) onto the access road to site. /_V 111I_ G101u111"'I �a NCG500000 NOI CP&L Rowan County Combustion Turbine Generation Facility Description of Simple Cycle Simple Cycle Combustion Turbine Generators operate by introducing outside ambient air to the process through inlet air filters. The ambient air is cleaned by the inlet filters and cooled by an evaporative cooling process which utilizes a sheet flow of water over a fabric media. The clean, cool air is then compressed by a multi -stage axial -flow compressor. The compressed air then flows to the combustion chamber where it is combined with fuel (natural gas or fuel oil) and ignited. The hot combustion gases are expanded through a multi -stage turbine, then directed to the exhaust stack. The turbine, driven by the expanding gases, turns both the compressor and the electricity generator. Please refer to later pages of this attachment for a water flow schematic and a water flow description. Wastewaters/Storm Water • The discharge from the project will consist of overflow from the evaporative cooling process. • Other wastewaters such as fuel oil/water interface condensate, false start materials and compressor wash water will be collected and pumped and hauled off site. • The water demineralization process will occur in portable treatment units owned by a contractor. Once a treatment unit requires regeneration it will be taken offsite and replaced with a fresh unit. No water treatment wastes will be discharged from the site. • The fuel oil storage tanks will be double walled for spill containment thereby eliminating open containment areas where storm water would be collected and discharged therewith. Also the fuel oil handling pump areas will be roofed to minimize exposure to storm water. • Exempt storm water that drains from the overall site will also be discharged. • Various equipment such as transformers and lube oil filters will have small containment areas around them which will collect storm water. These containment areas will have manually controlled valves. The storm water collected in these containment areas will be inspected for the presence of oil or other regulated substances prior to release to the ground. If oil or other regulated substances are observed they will be removed prior to release or the storm water will be pumped and hauled. Description of Flows for Simple Cycle Process Assume 16 hours per day operation. All flow values are approximate and are related to type of fuel used, and frequency and duration of electrical generation need. The discharge line is proposed to be constructed in the right of way corridor of the potential natural gas route which is depicted on the attached map. Label Source Description Flow (GPD) A County Potable Water System 1,008,000 B Potable Water to Demineralization Trailer 864,000 C Potable Water to Inlet Evaporative Coolers 144,000 D Demineralized Water to NOx Control Injectors 864,000 E Evaporative / Consumptive Losses 86,400 F False Start Contentsl Pump and Haul G Compressor Wash Water 2 Approximately 1500 gallons per unit when washed (Pump and Haul) H Eva orative Cooler Drains 57,600 I Condensate from Oil / Water interface dependent upon use of oil; (Pump and Haul) J Exempt storm water from site Rainfall dependent K Domestic sewage to septic tank/drain field 1 Oil and perhaps oil/water mixture; results infrequently when fuel mixture fails to ignite and drains to bottom of unit. 2 Flow is dependent upon use of unit and mode (during operation or not) of wash Attachment 2 Page 2 Septic Tank System K Potable Use Plant Fire 1.9 County System A C L Evaporative Coolers F Waste taken offsite f Demin. .""."... Trailer Storage False Start Drain Tank - Pump & Haul Pump & Haul I oil/water interface condensate NOx injection water D onsumptive / CTs Evaporative losses (three E simple cycle Evap. Cooler Drains units) q H It Compressor Wash Water Drain Tank - Pump & Haul Fuel Oil Storage Double Walled Tank F O Forward F O Unload Pump Sump Sump J Site Storm Water Discharge Discharge 001 Attachment 2 CP&L Rowan County Simple Cycle CT Site ATTACHMENT 3 NCG500000 NOI CP&L Rowan County Combustion Turbine Generation Facility - Alternatives to Direct Discharge - a) Connection to a Regional Sewer Collection System - a connection to a small package POTW owned by Rowan County was investigated. This package plant is called the Rowan County Second Creek WWTP #1. Permit No. NC0078361. It is located south of the junction of state road 1951 and US Route 70. The discharge from this facility is into Second Creek. This POTW is currently permitted to discharge up to 0.09 MGD although the existing facility has a design of 0.03 MGD. The facility currently discharges approximately 0.004 to 0.006 MGD. The CP&L Rowan County CT facility Phase I would generate approximately 0.058 MGD of mainly evaporative cooling water. In order to connect to this POTW, CP&L would have to construct a flow equalization structure and a conveyance line to the POTW site. Additionally, the POTW would have to undergo a significant physical expansion to be able to hydraulically accept the evaporative cooling water. After an evaluation of this alternative, CP&L believes that this alternative is not practical for phase I of the project because of the following reasons: • The evaporative cooling water is benign and should not result in any detriment to the beneficial uses of the receiving waters if discharged directly to Second Creek (where it would be discharged should it be routed to the POTW). • Later phases of the project may allow reuse of the evaporative cooling water. Consequently, the line to the POTW may not have a use later in the project and the cost of the POTW expansion and conveyance line to the POTW may be wasted. • The volume of evaporative cooling water would potentially wash out the biomass of the` POTW or create an unfavorable F/M ratio since the cooling water contains minimum organic material. • Hydraulic capacity of the POTW would have to be increased significantly. The POTW funding, procurement process and timing of this construction activity may hinder CP&L's schedule for their facility. b) Subsurface Disposal - It is anticipated that the evaporative cooling water will be reused in later phases of the project. Consequently, this alternative was not pursued for phase I. c) Spra,} Irrigation - It is anticipated that the evaporative cooling water will be reused in later phases of the project. Consequently, this alternative was not pursued for phase 1. Additionally, as a result of the evaluation of alternatives to discharge, CP&L will construct double walled fuel oil storage tanks and roof the fuel oil unloading and transfer pump facilities. This will minimize the exposure of storm water to fuel oil leaks. Consequently, the discharge of storm water from these containment areas will be eliminated.