Cape Fear Steam Station (14)

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NCDEN
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H Sullins Dee Freeman
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name
NPDES Permit Number -
Facility Location:
Type of Activity.
SIC Code (if applicable)•
Receiving Streams
River Basin
Stream Classification -
Proposed Permit Requirements
Monitoring Data
Progress Energy Carolinas, Inc - Cape Fear Steam Electric Plant
NCS000550
500 CP&L Road, Moncure, NC (Chatham County)
Steam Electric Generation
4911
See Figure 1
( EI
Cape Fear River Basin, Sub -basin 03-06-07 � EEC ;
WS -Iv JUN 2 9 2011
See attached draft permit u -
G�� r� rc`tn,
See Table 1
Response Requested by (Date). July 25, 2011
Central Office Staff Contact: Return to: B
Special Issues:
ias, [phone]
Issue
a �om e a ;
a Rating Scale:=1(easy)�to mm
X10 aliaird �.�
Compliance history
5
Benchmark exceedance
5
Location (TMDL, T&E
species, etc
3
Other Challenges-
• Power Plant -
New SW Permit
8
Difficulty Rating:
21/40
SEPU
2 3 2011
DENR. WATER QUALITY
"MIDSANDSTo"WA"E BRANCH
Special Issues Explanation•
• Previously this facility only had an NPDES WW permit for its discharges (NC0003433)
Description of Onsite Activities:
The Cape Fear Steam Electric Plant is a coal-fired electric generation plant The station includes two coal-
fired heat recovery boilers and four combined cycle combustion turbines The site has four stormwater
outfalls: SW -1 (inactive ash pond, rarely discharges), SW -2 (railroad track between plant entrance road and
plant site, to Shaddox Crk), SW -3 (roadside beside plant entrance, to Shaddox Crk), and SW -8 (inactive ash
pond, rarely discharges)
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Documents Reviewed:
• NPDES Stormwater Permit Application Materials (EPA Forms 1 & 2F)*
*Note SPU's add info letter said a larger -scale site map was preferable to the 85"x 11"aerial map, but
the response letterjust included a narrative response and two aerial maps with more detail instead
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU and NPDES Wastewater Permit Files
• Central Files
• 303(d) List (2010 Assessment)
• 2005 Catawba Basmw!de Plan and consultation with Basmwide Planning Staff
History:
Until now, the Cape Fear Steam Plant has had only a wastewater permit and sampled some stormwater
outfalls for the NPDES WW renewal application. The Division initiated an effort this past year to segregate
stormwater management requirements into a separate NPDES SW permit, rather than combine WW and SW
under one NPDES permit, for power plants. The decision for that strategy is based on the accumulating
complexities in power plant wastewater permits, and our need to better manage stormwater data records for
these sites The attached permit was drafted to reflect the permitting strategy for all coal-fired power plants
set by the Stormwater Permitting Unit (SPU) in 2009
Figure 1: Map of Facility
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Central Office Review Summary:
1. Owner's Other Permits
• NPDES Wastewater Permit NC0003433
Air Permit 01057T28 [Not noted on EPA Form 1]
Others?
2 General Observations -
In 2009 the SPU established a strategy for all coal-fired power plant stormwater permits The approach
includes a standard suite of parameters for analytical monitoring (see attached discussion) Since then, at
least four power plants have been monitoring stormwater discharges for those parameters
Elizabethtown Power LLC (NCS000352), Lumberton Power LLC (NCS000349), Progress Energy's Mayo
Steam Electric Power Plant (NPDES WW + SW NC0038377), and Progress Energy's Weatherspoon Steam
Electric Plan (NPDES WW + SW NC0005363).
Data from those facilities in Central Files (12 samples total) show Zn and Cu benchmarks exceeded most
often Those sites also have mercury levels in stormwater discharges that range up to 10 ng/1 Earlier
mercury data from Weatherspoon showed higher levels Mercury levels in both sampled outfalls at the
Cape Fear Steam Plantfor this application ranged 2 4-55 ng/1
This plant site was included in the Environmental Integrity Project and Earthjustice report called "Out of
Control. Mounting Damages From Coal Ash Waste Sites" (February 2010), attached The report noted
groundwater monitoring at the Cape Fear Steam Plant found concentrations of lead, chromium, boron,
iron, manganese, and sulfate above NC groundwater standards, at wells within 125' of ash pond
impoundments. The plant site operates four unlined ash impoundments, one active and three inactive.
The draft stormwater permit proposes monitoring for all of these constituents except iron and
manganese
According to Progress Energy contact discussions with NPDES wastewater staff, this facility is
scheduled to be decommissioned in 2017
3. Impairments and Basinwide Planning Recommendations- The segment of the Cape Fear River
downstream of where this facility discharges stormwater is impaired for chlorophyll a, indicative of
excessive nutrient loading in this river system (both nitrogen and phosphorus) The segment begins just
above Buckhorn Dam [AU #18-(4.5)]. The last current Basinwide Plan (2005) mentions nutrient -laden
runoff from urban and agricultural land uses as a contributor The Middle Cape Fear River Basin
Association (MCFRB) continues to monitor water quality in this segment, this Progress Energy facility is a
member of the MCFRB.
Excessive nutrient loading continues to be a concern for the Cape Fear River system. Basinwide Planning
Staff (N Deamer, 6/21/2011) advised of the need for reducing nutrients to this segment of the river At
some point in the future, a TMDL or nutrient management strategy will be needed from below Jordan
Lake Dam and Randleman Reservoir to the Buckhorn Dam
Sampling results from two of the stormwater outfalls submitted with the application (SW -002 and SW -
003) indicate nutrient levels are relatively low (TN = 1.62 mg/l, 199 mg/l, TP = 0.17 mg/1, 0 69 mg/1)
Because of the need to better characterize sources in this area, the draft permit proposes nutrient
monitoring for this permit term. The reviewer recommends removing TN and TP monitoring at the
next renewal if results confirm there is minimal concern.
4. Threatened and Endangered. None identified in the vicinity of this site (NHP Virtual Workroom, accessed
6/23/2011)
5. Location: No issues with locating this facility.
6 Industrial Changes Since Previous Permit. N/A, new stormwater permit.
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7 Analytical Monitoring Notes Two outfalls were sampled as part of the NPDES stormwater application
These outfalls (SW -002 and SW -003) were sampled in September 2010 for the NPDES wastewater permit
renewal application (submitted May 2011) The other outfalls (SW -001 and SW -008) discharge
stormwater from ash ponds that have been inactive for 35 years, and discharge is rare See application
documents (Form 2F)
SW -002 [Drains area along railroad between entrance road and plant site, as well as open field, to Shaddox
Creek] • COD levels were under the 120 mg/1 benchmark (48.6 mg/1), and BOD levels were low (3 6 mg/1),
suggesting a larger amount of non-biodegradeable organic material TSS, 0&G, pH and nutrients were all
well below or within range of current stormwater benchmarks The copper concentration (0 007 mg/1)
was the same as the current benchmark Arsenic, mercury, selenium, chromium, and nickel
concentrations levels were all below benchmarks No results were reported for aluminum, antimony,
beryllium, boron, bromide, cadmium, lead, magnesium, manganese, molybdenum, silver, thallium,
tin and zinc, but all were reported as pollutants "that may be present in coal along the rail " Total
residual chlorine (TRC), ammonia, nitrate -nitrite, TKN, and fecal coliform were also reported ("natural
environmental processes" were cited as a potential source), but these would not likely be associated with
industrial activities at this plant site Although fecal values were noted over the 1000 CPU/100 ml
benchmark, monitoring is not recommended
SW -003 [Drains plant entrance roadside swale] COD (67 mg/1) and BOD (9.3 mg/1) were slightly higher
than the other outfall but still below benchmarks (120 mg/1, 30 mg/l, respectively) TSS (35 2 mg/1) was
higher but also below the 100 mg/l benchmark TN and TP were similar to SW -002 levels. All metals
measured (see above) were below benchmarks Again, no results were reported for aluminum,
antimony, beryllium, boron, bromide, cadmium, lead, magnesium, manganese, molybdenum,
silver, thallium, tin and zinc, but all were reported as pollutants "that may be present in coal along the
rail " Likewise TRC, ammonia, nitrate -nitrite, TKN, and fecal coliform were reported but not likely
attributable to industrial activities Although fecal values were noted over the 1000 CPU/100 ml
benchmark, monitoring is not recommended
8 Qualitative Monitoring Notes- N/A, new permit.
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Permit Recommendations:
Analytical Monitoring:
Proposed analytical monitoring is consistent with the Stormwater Permitting Unit's strategy for all power
plant permits established in 2009. For more information, see attached discussion. The draft includes
a Semi-annual monitoring for 13 priority metals (Ag, As, Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb, Se, Tl, Zn) + Al
& B, with benchmarks where available
b Semi-annual mercury (Hg) monitoring with more sensitive method 1631E but no benchmark (or
obligation to monitor monthly in Tier 2).
c Semi-annual monitoring for COD, TSS, pH, sulfates, and 0&G
d Requirement to submit annual data summary to DWQ regional office
2. In addition, the draft permit proposes nutrient monitoring for this permit term because of the chlorophyll
a standard violations lust downstream in the Cape Fear River (should be removed at renewal if there is no
concern)
3 Coal pile runoff discharge (subject to stormwater effluent guidelines limitations) is covered under the
plant's wastewater permit (NC0003433); coal yard runoff is directed through the West Ash Pond to
NPDES WW outfall 007(UT to Cape Fear River).
4 During the warmer months of the year when cooling towers are used, stormwater contributes a very
small percentage of flow compared to the much larger, continuous cooling water and other wastewater
flows (0 18 MGD of a total of over 250 MGD, or 0.07%, based on flows reported in Form 2C Part II.). In
cooler months when the towers are not used, stormwater flow percentage drops to 0 9% (or 0 3% if the
estimate is based on once -through cooling flows of 58 8 MGD reported in the NPDES WW permit fact
sheet, rather than Form 2C). In either case, the potential for stormwater contaminants to reach
concentrations of concern is extremely small throughout the year In addition, the draft NPDES WW
permit includes monitoring for Cr, As, Se, Hg (low level method 1631), Ni, and Cu at outfall 007. The
reviewer does not recommend any additional stormwater-related monitoring for this outfall like in the
draft permit for Duke Energy's Plant Allen Steam Station (where stormwater combines with smaller
wastewater flows)
Permittee contact: Robin Bryson, [phone]
No questions for contact at the time of permit drafting
1 Q• question?
a ANSWER answer.
2 Q• question?
a ANSWER answer
3. Q question?
a ANSWER answer.
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SPU Power Plant Permit Strategy (Beginning 2009)
In recent years, the Stormwater Permitting Unit has recognized the complex issues associated with coal -
burning power plants and the increased attention on coal ash storage, use, and disposal at these sites Data on
stormwater discharges from these plant sites is limited because the focus has traditionally been on
wastewater Regions have also voiced concern about potential contamination from metals in stormwater
discharges associated with the activities at these sites After researching constituents these activities or
materials may introduce to the power plant property (and with them potential for stormwater pollution), the
Unit formulated a strategy for these renewal permits
Basis. Draft RTI Study ('Human and Ecological Risk Assessment of Coal Combustion Wastes; RTI, August
2007) and discussions with Robert Schreusdale of RTI suggest these metals may signal contamination
problems SPU also discussed contaminants with Duke University researcher, Dr Avner Vengosh, who
researched the TVA ash pond spill in Dec 2008 in Kingston, TN (Mtg with SPU on May 4, 2009). In
addition, RRO/DWQ has sampled discharges from cogeneration plants in the FRO area and flagged
metals of concern Overall, we have very little data with which to characterize stormwater discharges
from this industry, but we know there is a concern and need for better understanding about possible
stormwater pollution from activities here.
(FYI - Cost of clean mercury method around $100.)
Basis. Power plants area potential major source of mercury, and although some Hg maybe regional,
there is a risk that significant quantities come from the activities at the plant itself While wastewater
permit limits are calculated based on low stream flow and high wastewater effluent f.'ow conditions --
and sometimes do not warrant the lower -detection method—stormwater contributions vary broadly
and do not change the bio -accumulative nature of methyl -mercury. SPU recognizes the complexity of
regional air transport and deposition, as well as the cost and resources involved in clean mercury
sampling protocol, and therefore will exempt Hg from monthly monitoring in the tier structure
However, if mercury data suggest a problem driven by sources or activities at the plant, DWQ should
investigate further and could require additional monitoring in the future
Basis: conventional pollutants associated with types of activities here Note -include provision to allow
pH values below benchmark if facility can document rainfall pH is as low or lower at time of sampling.
Basis Consistency with current draft General Permits and to facilitate prompter awareness of
monitoring results at the regional office level.
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example, plants might consider installing bioretention cells for drainage areas where metals are a
problem and monitor for effectiveness, in exchange for decreased monitoring frequency and/or no
benchmark trigger We -will also consider relieving monitoring if the facility can demonstrate levels
are not attributable to, or else not able to be separated from, industrial activities SPU will work with
the regional offices to address situations on a case-by-case basis
Basis- SPU recognizes the ubiquitousness of copper and zinc, and the low benchmark concentrations for
metals like Cd, but we also know activities at power plants can be contributors of these pollutants. SPU
feels alternatives to more monitoring can facilitate solutions and that the permit tier structure isflexible
enough to relieve the permittee of monitoring when appropriate
under a
permit, examine for need to apply storwmater effluent limits.) Federal effluent guidelines apply
specifically to the Steam Electric Generating industry, which excludes cogeneration facilities.
However, cogeneration plants are similar in many respects, and coal storage and handling activities
may even be identical. SPU will consider a tailored approach for certain SDOs based on proximity to
coal sources, storage area size, etc Depending on the size and similarity of the coal storage and
handling (and perhaps other factors), the permit writer could decide to (a) apply limits initially, or (b)
an arrangement where benchmarks mirroring BPT requirements for coal pile leachate in 40 CFR §423
(TSS of 50 mg/1 and pH 6-9 SU) would become limits after two exceedences (i.e., Tier 2 action), or (c)
lust impose benchmarks.
Basis Federal stormwater effluent limits apply to coal piles at steam electric generating facilities,
similarity of cogeneration plants (and even elsewhere) warrant similar scrutiny Other states such as
Virginia, Ohio, and Georgia have already imposed the same BPT limits on coal pile runoff and leachate at
facilities where coal burning for steam electric generation is not necessarily the primary industrial
activity. The flexibility for North Carolina to do the same follows that lead and acknowledges the
potential for the same pollution problems
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Recommendations: Based on the documents reviewed, the application information submitted on May 4, 2011 (fee
submitted June 15, 201 1) is sufficient to issuq an Individual Stormwater Permit
Prepared by (
Stormwater Permitting Unit
for
Concurrence by Regional
RO Water Quality S
Regional Office Staff Comments (attach
` Date (0
Date
pages as necessary)
Date
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