NCG500594_Approval_20110502

NPDES DOCUMENT !MCANNINO COVER !MEET
NPDES
Permit:
NCG500594
Richmond County Combustion
Turbine Plant
Document
Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Approval
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
May 2, 2011
This document is printed on reuse paper -ignore any
content on the reYerse side

- Guerra, Bob
From: Guerra, Bob
Sent: Monday, May 02, 2011 1:54 PM
To: 'Bryson, Robin R.'
Cc: Kashmer, Kimberly
Subject: RE: Richmond County Application Modification NCG500594
,V¢r review (flour submittal it has been determined that (l\jo Turtk¢r fiction (UM
is required from dour faci[itI to warrant the directing of flows from the east cooling
tower basin maintenance 6[owdown to either Outfall 003 or ool.
From: Bryson, Robin R. jmailto:robin.bryson(apgnmail.com1
Sent: Friday, April 15, 2011 12:14 PM
To: Guerra, Bob
Cc: Kashmer, Kimberly
Subject: Richmond County Application Modification NCG500594
Thank you for your timeildiscussing the Richmond County Combustion Turbine Plant Coverage under General Permit
NCG500000. Based on our phone call earlier this week, I have attached a brief flow diagram for the Richmond County
site illustrating the change to our application (in red). Also attached is the submittal for the application modification we
submitted in January 2098 to add the new combined cycle powerblock that you indicated that you were missing in your
file.
While the your letter dated April 6, 2011, refers to a permit modification, our submittal dated March 30, 2011, was an
update our general permit application to reflect the option of directing flow from the east cooling tower basin
maintenance drawdowri', to either Outfall 003 or 001. The discharges at the Richmond County site are currently covered
by General Permit NCG500594. We believe that no further action is necessary on your part before we may implement
this change. We plan to drain the cooling tower basin to Outfall 001 next week as presented in the application
modification submitted March 30, 2011.
Please respond to this email, including Kim Kashmer, indicating your concurrence with this understanding and that our
activity may commence. Thank you.
Thank you for your time.
Robin R. Bryson
Environmental, Health & Safety
Progress Energy Carolinas, Inc.
Bell 919-546-3962
Vnet 770-3962
1

Guerra, Bob
From: Bryson, Robin R. [[e-mail]]
Sent: Friday, April 15, 2011 12:14 PM
To: Guerra, Bob
Cc: Kashmer, Kimberly
Subject: Richmond County Application Modification NCG500594
Attachments: abrieviated diagram.pptx; NPDES application amendment request.pdf
Thank you for your time discussing the Richmond County Combustion Turbine Plant Coverage under General Permit
NCG500000. Based on our phone call earlier this week, I have attached a brief flow diagram for the Richmond County
site illustrating the change to our application (in red). Also attached is the submittal for the application modification we
submitted in January 2008 to add the new combined cycle powerblock that you indicated that you were missing in your
file.
While the your letter dated April 6, 2011, refers to a permit modification, our submittal dated March 30, 2011, was an
update our general permit application to reflect the option of directing flow from the east cooling tower basin
maintenance drawdown to either Outfall 003 or 001. The discharges at the Richmond County site are currently covered
by General Permit NCG500594.`We believe that no further action is necessary on your part before we may implement
this change. We plan to grain the cooling tower basin to Outfall 001 next week as presented in the application
modification submitted March 30, 2011.
Please respond to this email, including Kim Kashmer, indicating your concurrence with this understanding and that our
activity may commence. Thank you.
Thank you for your time.
Robin R. Bryson
Environmental, Health & Safety
Progress Energy Carolinas, Inc.
Bell 919-546-3962
Vnet 770-3962
1

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
Apri16, 2011
CECIL T GURGANUS, PLANT MANAGER
PROGRESS ENERGY CAROLINAS INC
RICHMOND COUNTY ENERGY COMPLEX
SUITE 198 ENERGY WAY
HAMLET NC 28345
Subject: Acknowledgement of Permit Modification Request for NCG500594
Progress Energy Carolinas, Inc.
Richmond County Combustion Turbine Plant
Richmond County
Dear Mr. Gurganus:
DENR-FRO
APR 0 7 2011
D O
The Division of Water Quality acknowledges receipt of your permit modification request on April 6, 2011. Your request
has been assigned to Bob Guerra for review.
The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To
ensure the maximum efficiency in processing permit applications, the Division requests your assistance in providing a
timely and complete response to any additional information requests.
Please note at this time, processing permit applications can take as long as 60 — 90 days after receipt of a complete
application.
If you have any questions, please contact Bob Guerra at 919-807-6387, or via email at [e-mail]. If the
reviewer is unavailable, you may leave a message, and they will respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincerely,
Dina Sprinkle
Cc: Central Files
Eayetteviile Regfddna1 Office Surface Water Protection Section
Permit application file NCG500594
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
-Phone: [phone] FAX: [phone] \ Customer Service: 1-877-623-6748
Internet: www,ncwaterquality.org
One
NorthCarolina

`v Progress Energy
Mr. Charles Weaver
NCDENR/DWQ/NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
March 30, 201 I
Subject: Carolina Power & Light Co. d/b/a Progress Energy Carolinas, Inc. (Progress Energy)
Richmond County Combustion Turbine Plant —Certificate of Coverage NCG500594
NPDES General Permit NCG500000 Notice of Intent Application Modification
Dear Mr. Weaver:
Progress Energy is hereby modifying the National Pollution Discharge Elimination System
(NPDES) General Permit NCG500000 Notice of Intent application submitted in January 2007
for the above referenced facility. This NOI was modified on January 23, 2008, to add an
additional combined cycle powerblock, with an accompanying cooling tower.
The Richmond County Combustion Turbine Plant requests that during cooling tower
maintenance activities, when the new powerblock basin may have to be drained to various
levels including emptied, the water release may be directed to a sediment pond for discharge to
an unnamed tributary to Marks Creek via permitted Outfall 001 in addition to the currently -
permitted destination to an unnamed tributary to Marks Creek via Outfall 003. Enclosed are
Attachments 2 and 3 submitted during the renewal process that have been modified to reflect
this modification (changes in bold).
We thank you in advance for your attention to our permitting needs. If there are any questions
about this information please contact Ms. Robin Bryson by telephone at [phone] or by
email at [e-mail].
I certffr, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief true, accurate, and complete. 1 am aware that there are significant penalties for
submitting false information, including the possibility offines and imprisonment for knowing violations.
Sincerely,
Cecil T. Gurganus
Plant Manager
CTG/rb
c: Ms. Robin Bryson
bc: Kim Kashmer, Richmond EHS
Progress Energy Carolinas, Inc.
Richmond County Eneigy Complex
Suite 198 Energy Way
Hamlet, NC 28345
?PROWLED,
APR 06�01
POINT SOURCE BURANCH

Richmond County Combustion Turbine Plant NCG500594 NOI Application Modification
Attachment 2. Description of Wastewater Discharged
The Richmond County Combustion Turbine Plant consists of five simple cycle combustion
turbine units, two combined cycle combustion turbine units and two units that can be operated
in either simple cycle or combined cycle mode. Wastewaters from various processes are
discharged into three permitted outfalls. Outfall 001, which flows into an unnamed tributary to
Marks Creek, primarily receives wastewater from non -contact cooling water (evaporative
coolers) from simple cycle and combined cycle units. Outfall 002, which flows into Marks
Creek, receives wastewater from the combined cycle units, primarily from the cooling tower
blowdown. Outfall 003, which also flows into an unnamed tributary to Marks Creek,
infrequently receives wastewater primarily from stormwater runoff and cooling tower drains.
Simple Cycle Wastewater Processes
The simple cycle combustion turbine units produce wastewater from the evaporative cooler
process (non -contact cooling water). More than half of the wastewater from the evaporative
coolers is lost to consumption and evaporation; the remainingoverflow is routed along the site
P p
stormwater dr *nage system with leads to the stormwater retention basin and released to an
unnamed tribu , ary to Marks Creek (Outfall 001).
Other wastewaters such as fuel oil/water condensate, false start materials, equipment drains
containing potential oil, and compressor wash water is collected and disposed of offsite (pump
and haul) for proper disposal.
Likewise, discharges from the water demineralizer process, in portable treatment units, are
removed off site for disposal. There is a "rinse in" period when processed water is released to
the ground for a few minutes before directing it into the storage tanks. Also, after process
completion anIamount may be released to the ground before the portable tanks departs. The
water quality released to the ground from these two brief time periods has been determined to
be between potable and demineralized.
Various equipment, including fuel oil storage tanks, is double -walled or has containment areas
for spill containment. Stormwater collected in these areas are visually inspected for the presence
of oil or other regulated substances prior to release to the ground. If oil or other regulated
A2-2

Richmond County Combustion Turbine Plant NCG500594 NOI Application Modification
substances are, observed they will be removed prior to release or the stormwater will be pumped
and hauled.
Exempt stormwater that drains from the overall site is discharged along the drainage system to
either the stormwater retention pond or the sediment pond and released to unnamed tributaries
to Marks Creek (Outfalls 001 and 003).
Combined Cycle Wastewater Processes
The combined cycle combustion turbine units process the heat remaining in the turbine exhaust
by directing it to a boiler called a Heat -Recovery Steam Generator (HRSG). The recovered heat
is used to generate steam in a closed cycle system which increases electricity production. The
condenser tubes within the steam generator are cooled by water. The heated cooling water is
directed to cooling towers in a closed cycle system (not once -through cooling water) where heat
is dissipated. This process produces wastewater primarily as cooling water blowdown which is
directed to Marks Creek (Outfall 002). The HRSG blowdown wastewater is introduced into the
condenser cooling system as makeup water.
During cooling tower maintenance activities, the basins (south basin volume is 850,000 gallons
and new east basin volume is 1,115,156 gallons) may have to be drained to various levels,
including emptied. Depending on activity, the basin water may be partially or fully routed (1)
through the dechlorination process and discharged via Outfall 002 to Marks Creek, (2) back to
the cooling closed cycle, (3) to a future cooling loop, or (4) to a sediment pond for possible
discharge an unnamed tributary to Marks Creek (Outfalls 001 and 003) after dechlorination is
provided. Other infrequent draining and cleaning of various process units during operation and
maintenance activities may generate wastewater that are within the boundaries of those
wastewaters acdressed by NCG500000.
Wastewaters from routine HRSG cleaning, fuel oil/water condensate, false start materials,
equipment drains containing potential oil, and compressor wash water is collected and hauled
off site (pump and haul) for proper disposal. For a more extensive cleaning, the HRSGs may
require flushing with a large volume of water. The wastewater from this flushing would be
discharged via' Outfall 002 or released into a sediment pond prior to discharge via Outfall 001
or Outfall 003.
A2-3

•
Richmond County Combustion Turbine Plant NCG500594 NO1 Application Modification
Likewise, disc arges from the water demineralizer process, in portable treatment units, are
removed offsite for disposal. There is a "rinse in" period when processed water is released to the
ground for a few minutes before directing it into the storage tanks. Also, after process
completion an amount may be released to the ground before the portable tanks departs. The
water quality released to the ground from these two brief time periods has been determined to
be between potable and demineralized.
Various equipment, including fuel oil storage tanks, transformers, lube oil filters, etc., have
containment areas for spill containment. Stormwater collected in these areas are visually
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
stormwater will be pumped and hauled.
Laboratory processes produce small amounts of wastewater. Laboratory drains are routed to
HRSG blowdown sumps which flow to one of the cooling tower basins and discharged to
Outfall 002.
Exempt stormwater that drains from the overall site is discharged along the drainage system to
either the stormwater retention pond or the sediment pond and released to unnamed tributaries
to Marks Creek (Outfalls 001 and 003).
There is potential for a small volume of cooling water (estimated maximum 3,000 GPD) to
splash/drift to the ground around the outside of the basin after making contact with the cooling
water fill. Similarly, incidental leaks (estimated maximum 1,000 GPD) associated with the
routine operation of the combustion turbine heat recovery steam generators may occur and get
to the ground surface. The variable amounts of this splash/drift and leakage has the potential to
be washed with stormwater that flows overland (greater than 2,500 feet) to the drainage system
and into a retention pond. The chemical nature of this potential discharge is equivalent to the
permitted cooling tower blowdown discharge (Outfall 002).

Richmond County Combustion Turbine Plant NCG500594 NOI Application Modification
Attachment 3
Type of Chemicals Added to the Wastewater for Treatment
There are three discharge points permitted at the Richmond County Combustion Turbine Plant.
Chemicals are added for treatment in wastewater discharged to one and potentially to all three
outfalls.
(1) Outfall 001 — There is potential for a small volume of cooling water to splash/drift to the
ground around the outside of the east basin after making contact with the cooling water fill.
Similarly, incidental leaks associated with the routine operation of the combustion turbine
heat recovery steam generators may occur and get to the ground surface. These potential
discharges may contain any of the chemicals listed for Outfall 002. Potential discharges
directed t the sediment pond from the cooling tower basin water drawdown during
non-routi a maintenance or during a high -volume flushing of HRSG would contain the
same potential chemical additives listed for Outfall 002.
(2) Outfall 002 — Cooling tower blowdown discharge (including substances found in boiler
blowdown) contains certain amounts of biocides, corrosion/scale inhibitors, and other types
of chemicals (dechlorination) as additives for wastewater treatment. Sulfuric acid and
caustic may also be added to balance pH values between 6 to 9 SU; the NPDES permit range
for freshwater systems.
(3) Outfall 00
— There is potential for a small volume of cooling water to splash/drift to the
ground around the outside of the south basin after making contact with the cooling
water fill
Similarly, incidental leaks associated with the routine operation of the
combustion turbine heat recovery steam generators may occur and get to the ground
surface. T ese potential discharges may contain any of the chemicals listed for Outfall
002. Potential discharges directed to the sediment pond from the cooling tower basin water
drawdown during non -routine maintenance or during a high -volume flushing of HRSG
would contain the same potential chemical additives listed for Outfall 002.