NCG500582_Owner (Name Change)_20060906

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
E. Scott Dial
Southern Power Company
5755 North Carolina 801 Hwy.
Salisbury, NC 28147
Subject NPDES Permit Modification
Permit NCG500582
Plant Rowan County
formerly CP&L - Rowan County
Rowan County
Dear Mr. Dial:
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.
cc: Central Files
Mooresville Regional Office, Surface Water Protection
NPDES Unit File
Sincerely,
9(1) 0A,J
6/1„.'Alan W. Klimek, P.E.
No e tCarolina
at«raij
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal opportunity/Affirmative Action Employer— 50% Recycledlt 0°% 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 compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
SOUTHERN POWER COMPANY
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 certificate of coverage shall become effective September 7, 2006.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day September 7, 2006.
6(140______—
(7041Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Re: Rowan County Power Plant
Subject: Re: Rowan County Power Plant
From: Dennis Ramsey <[e-mail]>
Date: Fri, 21 Oct 2005 12:33:33 -0400
To: "Tuite, Patricia \(US - Pittsburgh\)" <[e-mail]>
CC: [e-mail], "Tronsberg, Kathryn 1(US - Pittsburgh\)"
<[e-mail]>, Charles Weaver <[e-mail]>
Patty
Thank you very much for your response. Unfortunately although the facility's
permit application for coverage under the General Permit did identify the oil
storage containment facilities and the steam generation facilities, these are not
considered as "other similar wastewaters" for the purpose of the GP. In fact, the
GP specifically states on the cover page and page 5 of 15 that "Steam generating
facilities are not eligible for coverage under this General Permit". Likewise
discharges from oil storage containment facilities are not considered similar to
cooling waters, boiler blowdown or condensate. This is not only my interpretation
of the GP but also that of staff in our NPDES Program.
Since NPDES permitting is not by area of responsibility, please continue to work
with Samar to resolve the NPDES issues with this facility. He will also continue
to be your primary contact on the tax certification request.
Thank you very much and hopefully all these issue can be resolved quickly.
Dennis
Tuite, Patricia (US - Pittsburgh) wrote:
Dennis,
Thanks for all your efforts regarding this tax certification.
The General permit under which this facility operates (NCG500000) DOES
include "Other similar watewaters which may qualify for coverage under
this General Permit." This section covers the discharges from oil
storage containment facilities and waste water from electric generating
facilities.
As shown in the application for the General Permit (I have attached an
excerpt to limit file size), Progress Energy has included an Attachment
2 to describe their wastewater streams. Under Phase II Combined Cycle
Wastewater / Stormwater, bullet seven, the application attachment
states:
"As with the simple cycle, other wastewaters such as fuel oil/water
interface condensate, false start materials, and compressor wash water
will be collected and hauled off site."
Furthermore, bullet 11 of the same attachment states:
"Various storage areas, equipment, and process modules such as
transformers, lube oil filters, fuel oil modules, ammonia storage, water
conditioning products,etc. will have containment areas around them which
will collect rain water. These containment areas will have manually
controlled valves at their outlets. The rainwater 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 in the rain water the rain water will
be pumped and hauled or the rain water will be treated by various
methods including a portable oil/water separator prior to release to the
ground."
As an additional point of clarification, the North Carolina General
Statute that offers the property tax exemption (105-275) offers a
property tax exemption for:
1 of 5 10/24/2005 8:37 AM

Re: Rowan County Power Plant
"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".
Therefore, the criteria for water pollution control equipment includes
equipment that is used exclusively for the prevention of water
pollution. In order to qualify, the water pollution control equipment
does not have to TREAT the water but rather PREVENT the pollution of the
waters of the state.
I hope you find this information pertinent and useful.
Regards,
Patty
Patricia G. Tuite
Deloitte Financial Advisory Services LLP
Direct: [phone]
Fax: [phone]
ptuiteedeloitte.com
www.deloitte.com
2500 One PPG Place
Pittsburgh, PA 15222-5401
Original Message
From: Dennis Ramsey(mailto:dennis.ramsey®ncmail.net] Sent: Wednesday, October
19, 2005 3:50 PM
To: Tuite, Patricia (US - Pittsburgh)
Cc: Samar Bou-Ghazale; Tom Belnick
Subject: Re: FW: Rowan County Power, LLC - 2nd of 2 e-mails
Patty
Unfortunately your request gets more complicated the more I try to understand
it.
The General permit under which this facility operates (NCG500000) only covers
specific activities. Two of the activities that are not covered are discharges
from oil storage containment facilities and waste water from steam generating
facilities. From the information that you sent me, it appears that this
facility has both of these waste streams.
That being the case, these two waste streams will need to be covered by an
individual permit.
From conversations with our NPDES permitting staff, Rowan County Power has the
option of applying for a single individual permit to cover all the discharges
from the site or retaining the coverage under the GP for the activities allowed
coverage under the GP and applying for a separate
permit for the steam generation and the discharge from the oil storage facility.
It is my understanding that Samar will be conducting a site visit of the
facility in the near future. While he is on site, it would be very helpful if
you or someone could discuss with him the processes on site and how Rowan Power
would like to proceed.
Discussions should also be held on the issue of the tax certification.
I am sorry that your request has gotten more complicated that either of us would
have liked but we will do all we can to work with you to resolve these issues as
quickly as we can.
Thanks
Dennis
2 of 5 10/24/2005 8:37 AM

Re: Rowan County Power Plant
•
Tuite, Patricia (US - Pittsburgh) wrote:
Patricia G. Tuite
Deloitte Financial Advisory Services LLP
Direct: [phone]
Fax: [phone]
[e-mail]
www.deloitte.com
2500 One PPG Place
Pittsburgh, PA 15222-5401
Original Message
From: Tuite, Patricia (US - Pittsburgh) Sent: Thursday, October 13, 2005 4:11
PM
To: 'dennis.ramseyencmail.net'
Cc: Tronsberg, Kathryn (US - Pittsburgh)
Subject: Rowan County Power, LLC
Dennis,
Here are the answers to your questions:
1. From what I understand it appears that the facility uses mostly gas/fuel
oil turbines to generate electricity. However some of the information that
you sent me indicates that heat recovery steam generators power a steam
turbine generator to produce additional electric power. Is this correct?
ANSWER: That is correct. There are five Combustion Turbines on site.
Three of the combustion turbines (Units 1 through 3) are simple cycle.
That means that 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 combustion turbines (Units 4 and
5) are combined cycle. That means that 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 to generate additional electricity.
If
2. Are there stormwater treatment facilities or ponds on the site?
so, does all of the stormwater go through these ponds or does some of the
stormwater discharge directly from the collection system to surface
waters without treatment? Do you have a site plan that you can e-mail
me.
ANSWER: There are four stormwater detention ponds, Pond CT-1,Pond
CT-2,Pond SY-1, and Pond SY-2. I have attached drawings that show the
stormwater system and the ponds. It is my understanding that the
stormwater is routed to these ponds and there is no discharge directly
from the collection system.
3 of 5 10/24/2005 8:37 AM

Re: Rowan County Power Plant
'r
3. What happens to the stormwater that is captured in the oil storage
facility containment system? Is there any type of oil water separator?
Is the stormwater discharged to surface waters or transported off site?
ANSWER: I have also attached a copy of the Plant's Spill Prevention
Control and Countermeasures Plan. As you will see in this plan, "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."
There is no oil water separator permanently installed at the Rowan
County Plant.
4. Do you have an e-copy of the NOI that was submitted by Rowan County Power
for coverage under NCG50000 that you can send me.
ANSWER: I have attached a copy of the Phase II NOI.
Thanks so much for your time and consideration of this matter. I hope
that you find this information to be useful. Please let me know if you
have any additional questions or concerns.
Regards,
Patty
Patricia G. Tuite
Deloitte Financial Advisory Services LLP
Direct : [phone]
Fax: [phone]
[e-mail]
www.deloitte.com
2500 One PPG Place
Pittsburgh, PA 15222-5401
Original Message
From: Dennis Ramsey[mailto:[e-mail]] Sent: Wednesday,
October 12, 2005 4:19 PM
To: Tuite, Patricia (US - Pittsburgh)
Subject: Rowan County Power, LLC
Patty
I need your help again in better understanding the situation at Rowen County
Power. Can you please help me with the following questions.
1. From what I understand it appears that the facility uses mostly gas/fuel
oil turbines to generate electricity. However some of the information that
you sent me indicates that heat recovery steam generators power a steam
turbine generator to produce additional electric power. Is this correct?
2. Are there stormwater treatment facilities or ponds on the site?
If
4 of 5 10/24/2005 8:37 AM

Re:,Rowan County Power Plant
so, does all of the stormwater go through these ponds or does some of the
stormwater discharge directly from the collection system to surface
waters without treatment? Do you have a site plan that you can e-mail
me.
3. What happens to the stormwater that is captured in the oil storage
facility containment system? Is there any type of oil water separator?
Is the stormwater discharged to surface waters or transported off site?
4. Do you have an e-copy of the NOI that was submitted by Rowan County Power
for coverage under NCG50000 that you can send me.
Thanks
Dennis
*****Any tax advice included in this written or electronic
communication was not intended or written to be used, and it cannot be
used by the taxpayer, for the purpose of avoiding any penalties that may
be imposed on the taxpayer by any governmental taxing authority or
agency*****
This message (including any attachments) contains confidential
information intended for a specific individual and purpose, and is
protected by law. If you are not the intended recipient, you should
delete this message. Any disclosure, copying, or distribution of this
message, or the taking of any action based on it, is strictly
prohibited. [v.T.1]
5 of 5 10/24/2005 8:37 AM

I e:..N G500582
Subject: Re: NCG500582
From: Dennis Ramsey <[e-mail]>
Date: Wed, 19 Oct 2005 11:15:39 -0400
To: Charles Weaver <[e-mail]>
CC: [e-mail], Bradley Bennett <[e-mail]>, Samar Bou-Ghazale
<S [e-mail]>
Charles
I spoke with Mike Parker and he said that he did do an inspection of the site but
it was before the facility was constructed. Therefore as far as I can determine no
one from DWQ has conducted an inspection of the facility since its construction.
According to information supplied by the facility, two of the five turbines are .
combined cycle. They use natural gas or fuel oil to generate electricity and:..the
heat is recovered and used in a steam turbine to generate additional electricity.
Although this is not a typical steam turbine facility, would this fact preclude._::.
these turbines from being covered under NCG500000. Is there a definition of_what
is considered a steam turbine for the purpose of coverage under NCG500000.
Also from information supplied by the facility, stormwater from the oil storage,
areas is either pumped or flows by gravity to the stormwater detention ponds._!,
Therefore as per your earlier message, it would appear that this stormwater should..
not be covered by the GP.
Since either one or two waste streams do not qualify for coverage under the GP.,.
should we issue a new individual permit for the entire facility or have some_:bf=the
facility covered by the GP and other parts of the facility covered by the GP:
Thank you for your help
Dennis
Charles Weaver wrote:
Dennis:
Mike Parker did a thorough inspection of this site when the General Permit.
coverage was first issued. Unless things have drastically changed, the steam
generation question does not apply.
The GP says that the NOI shall include Final plans and specifications for
the treatment system and all major components. Do we keep these plans and
specifications either in your offices or central files.
No - the facility is required to keep approved plans and specs on site. If the
Division didn't ahve to approve any plans or specs, this question is N/A.
2. Does this GP cover the discharge from the containment system for their
oil storage tanks or must that be covered by a different permit.
Mike's inspection notes state that these wastewaters are hauled offsite for
disposal. This question is N/A, unless they are now discharging any such
wastewater. If they are, they need an individual permit.
3. They are asking for tax certification for their catholitic protection
system for their piping. They contend that this system was installed to
mitigate and reduce the likelihood of hazardous materials contaminating
the environment. I would have thought that it was installed mainly to
prolonging the life of their piping. Am I missing something.
1 of 2 10/20/2005 9:49 AMI

Re: NCG500582
I'd recommend asking Mike. I have no idea what the justification is for tax
certifications.
CHW
2 of 2 10/20/2005 9:49 AM