Marshall Steam Station (5)

Comments from MRO regarding new draft permits for Allen, Marshall, and Riverbend
Comments from Wes and Donna following inspections at Allen and Marshall Steam stations
on 6/7 and 6/8 (clarification given by Marcia):
They need a stormwater permit. (None of the Duke facilities have individual stormwater
permits. Since stormwater is mentioned in two of the permits already should the permit
become a combined wastewater/stormwater permit for all discharges of stormwater?)
o Marshall — no mention of stormwater discharges in NC0004987
o Allen — Stormwater is mentioned as a discharge through Outfall 002 in
NC0004979)
o Riverbend — Tormwater is mentioned as a discharge through Outfall 002 in
NC0004961
Sampling should be more than quarterly, ideally weekly.
c (This is sampling at Outfall 002 [final effluent] and applies to both facilities that
were inspected)
Sampling should be composite, if it can't be flow proportional, then at least time based.
o , (This is sampling at Outfall 002 [final effluent] and applies to both facilities that
were inspected- this comment would also apply to Riverbend (M. Allocco
comment). From inception of permit (1977 copy available at MRO) until 1989
samples except for Oil & grease were composite samples. No information in
permit files (fact sheets, staff reports, etc.) detailing why the change was made.
In the 2001 version of the permit all parameters except Oil & Grease and TSS,
and sulfate are composite samples. 2002 permit notes that the monitoring has
been changed from composite to grab due to the large size and consistent
effluent out of the ash basin, grab sampling is considered to be equally
representative of the discharge (how was this determination made?).
Sumps outfalls (2a/b) should be sealed off, but if not they should be sampled regardless
of the length of the discharge event (no hour limitation) and, yes, they can be easily
sampled. (Sampling was conducted using the telescoping sampling pole owned by
MRO)
o Depending on the analysis results for samples collected by MRO staff there may
be a need to add more analytes to the sampling requirements. MRO will forward
to permitting the results of the analyses at Marshall and Allen.
Facilities should have dual classification.
o Marshall is currently classified as PC -1; should be PC -1 and WW -1 as per D.
Hood communication to M. Allocco
o Allen is currently classified as PC -1; should be PC -2 and WW -2 as per D. Hood
communication to M. Allocco
o Classification of Riverbend was not reviewed; currently PC -1
Use TPH, not oil and grease, if petroleum is a cause of concern.
Comments from Marcia
Riverbend
• Section A. (5.) Biocide Condition — Line 3 "any" is misspelled as "nay".
• Section A. (5.) Biocide Condition - This section states that a biocide worksheet is not
needed when introducing a new biocide to an outfall being currently tested for toxicity. Is
this an adequate test of toxicity? The quarterly toxicity testing is a grab sample once a

quarter and would not correspond to the detailed review by DWQ personnel a biocide
sheet submission would afford.
Section (6.) Special Conditions bullet #1 states, "There shall be no discharge of
olychlorinated bi phenyl compounds." From a compliance standpoint how do we
ssure this? Is it through the one analysis completed for permit renewal? What is the
nspector to review?
Section (6.) Special Conditions bullet #3 states, "If the permittee, after monitoring for at
least six months, determines that he/she is consistently meeting the effluent limits
contained herein, the permittee may request of the Director that the monitoring
requirement be reduced to a lesser frequency." While this text has appeared in the
permit since 1977 (oldest permit at MRO) I question whether 6 months of data is enough
to determine if a constituent is absent from a discharge. Is this the timeframe given to all
permittees or something special to power plants? If it is not consistent with DWQ
procedures and other permits then it should be changed. Should there be a caveat that
any changes to a treatment system or chemicals used in a treatment system the
frequency will be increased.
Section (6.) Special Condition"s bullet #5 "waters" is misspelled as "wasters"
Section (6.) Special Conditions bullet #5 states, "Discharge of chlorine from the use of
chlorine gas, sodium hypochlorite, or other similar chlorination compounds for
disinfection in the plant potable and service water systems and in sewage treatment is
authorized." At what level is the chlorine discharge authorized? We are making all other
permittees meet a 50 µg/L TRC compliance level with permit limits of either 17 µg/L or
28 Etg/L. This includes Water Treatment Plants that chlorinate the water they provide
and then dechlorinate or otherwise strip chlorine before discharge.
Section (6.) Special Conditions bullet #5 states, "Use of restricted use pesticides for lake
management purposes by applicators licensed by the NC Pesticide Board is allowed."
The EPA has just promulgated regulations that require a permit when pesticides are
applied to waters of the US. I assume this requirement may be permitted by DWQ but it
might also be given to the NC Pesticide Board. Need to ensure we are not providing
conflicting authorizations and we may not know for —2 years.
Section (7.) Permit Terms bullet #2 states, "Chemical metal cleaning will be conducted
according to Duke Power approved equivalency demonstration." The Duke Power
approved equivalency demonstration was submitted at some point in the past and is
stored in the permit files. This does not give the inspector anything to verify when
inspecting the plant.
Section (7.) Permit Terms bullet #3 states, "It has been determined from information
submitted that the plans and procedures in place at Riverbend Steam Station are
equivalent to that of a BMP." What does this statement refer to? Somewhere between
1980 and 1984 the following caveat was removed from the permit general text and may
be what this statement refers to. If so, the language in this bullet needs to be tightened
to require the plans and procedure be updated on a specific schedule and available for
review by DWQ inspectors or is this something that is more appropriate in a stormwater
permit? To me it implies that this is currently a wastewater/stormwater permit. "The
Permittee shall develop and implement a Best management practices (BMP) Plan to
identify and control the discharge of oils and the Hazardous and toxic substances listed
in 40 CFR, part 117 and Tables II and II of Appendix D to 40 CFR, Part 122. The plan
shall include a listing of all potential sources of spills or leaks of these materials, a
method for containment, a description of training, inspection and security procedures,
and emergency response measures to be taken in the event of a discharge to surface
waters. Sources of such discharges may include but are not limited to, materials storage

areas; in -plant transfer, process and material handling areas; loading and unloading
operations; plant site runoff; and sludge and waste disposal areas. The BMP plan shall
be developed in accordance with good engineering practices, shall be documented in
narrative form; and shall include any necessary plot, plans, drawings, and maps. The
BMP Plan shall be developed no later than six months after issuance of the final permit
(or modification), and shall be implemented no later than one year after issuance of the
final permit (or modifications). The BMP Plan shall be maintained at the plant site and
shall be available for inspection by EPA and DEM personnel."
Section (8.) Special Condition for Discharge of Wastewater discusses the need for Duke
to ensure there is adequate room in the ash basin for the solids and associated water
generated at the plant along with stormwater runoff. It requires annual reporting to DWQ
unless Duke can certify before issuance of the permit they have adequate room for the
life of the permit. However, the following statement in this section is unclear or
confusing. "Present information indicates a needed volume of 86.2 acre-feet in addition
to solids that will be deposited to the ash pond; any change to plant operations affecting
such certification shall be reported to the Director within five days." Does this statement
mean that Duke needs to clear out 86.2 acre-feet before the permit is issued; need to
clarify language? They must notify us within 5 days of what; first knowledge of the
change in the plant operations? Since the ash basins are now high -hazard dams
inspected by DLR does DLR have a say in how much solids and water are maintained in
the pond?
Section (9.) Special Condition — Boiler Cleaning Wastes third paragraph "at" is
misspelled as "oat" and in Item #4 "has" has been misspelled as "ahs".
Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 001 — Note
#1 states, "Downstream sampling point: down stream at Mountain Island lake." This
does not describe where in Mountain Island Lake the downstream sample should be
collected. Should this be worded "downstream at Mountain Island Lake dam"?
Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 002 - Note
#2 under the table states, "Total metals are defined by 40 CFR 136. Any method
specified by 40 CFR is considered acceptable for analysis." This is too vague of a
statement. 40 CFR 136 allows for atomic absorption analysis of metals that will only
obtain a detection limit in the mg/L range. Although Duke is analyzing via ICP -MS this
statement allows them to backtrack and use a method with a lower detection limit.
Although I doubt this will happen we should tighten up our requirements; either require a
specific method such as ICP -MS or require that they detect below the applicable water
quality standard.
Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 002 - there is
no monitoring for mercury at Outfall 002. Since all waters within North Carolina are
impaired for mercury due to fish tissue concentrations (not noted in the fact sheet) Duke
should have to monitor for mercury especially since coal-fired power plants are a major
source of mercury in the environment. They should be required to use Method 1631 E
with a detection limit of 12 ng/L.
Due to the recent release of monitoring data for Mountain Island Lake from the Catawba
Riverkeeper the permit should not be released until the data has been reviewed. It is
unclear whether the Duke data collected during the 316(a) variance request can be
compared to the Riverkeeper's data. Duke is only performing sediment analyses on
sediment fines and it appears the Riverkeepr's results are for all sediment within a
sediment core. We need to be able to compare. The 2004 study by Duke appears to
show an increase in arsenic in sediment directly down stream of the cove where Outfall
002 discharges (their statement). No data in MRO files regarding 316(a) data since

2004. In addition, no data has ever been collected by Duke in the discharge cove. It
may be appropriate to request additional sampling by Duke in this cove for water quality
(including metals), sediment, and fish in light of the recent Mecklenburg County arsenic
data. Original permit in 1977 required metals sampling in mountain Island Lake
downstream of the discharge which had to meet water quality standards.
New Comments added - Marcia
Marshall
• Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 002 — DWQ
asks permittee to monitor and report multiple metals. We should provide the level to
which we require Duke to analyze and with respect to mercury we should note we want it
analyzed via Method 1631 E which obtains a detection limit of 12 ng/L.