NC0081931_Permit (Issuance)_19991223

NPDES DOCUMENT SCANNING COVER :SHEET
NPDES Permit:
NC0081931
High Rock Powerhouse
t1. 'q6Y 5644bigSt 4,.
Document Type:
ermit Issuance)
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Inspection
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
December 23, 1999
Thug document is printed on reuse paper - ignore any
content on the rezrerse side

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
December 23, 1999
Mr. William L. McCaskill
c/o Yadkin, Inc.
P.O. Box 576
Badin, North Carolina 28009
A7;f7A
NCDENR
Subject: NPDES Permit Issuance
Permit No. NC0081931
High Rock Powerhouse
Rowan County
Dear Mr. McCaskill:
The Division has reviewed the Yadkin Inc. comments of October 17, 1999 in response to their draft
NPDES permit. The Division has considered the concerns raised and has modified the permit in
accordance with current Division policy, all responses to concerns and revisions made to draft permit,
NC0081931, are explained below:
Comment #1: Clarification of the pH monitoring requirement, since Yadkin Inc. does not add any
chemical additives to the source water.
Response: The hydrogen ion content of water is considered a generic measurement of water quality and
as such is included as a condition of the general permit for hydroelectric facilities. Since the conditions of
the general permit are considered minimum requirements, the semi-annual monitoring of pH, for outfalls
001, 002 and 003 will remain as a condition for this permit.
Comment #2: Clarification of the temperature monitoring requirement. The maximum temperature
change across the generator is 25 °C with a the ratio of cooling water discharge to generator discharge of
1:30,000. Therefore, the worst case temperature rise of the Yadkin River due to cooling water discharge
would be 0.0083 °C, assuming an ambient water temperature of 20 °C.
Response: As with pH, temperature is considered a generic measurement of water quality and as such is
included as a condition of the general permit for hydroelectric facilities. Since the conditions of the
general permit are considered minimum requirements, the semi-annual monitoring of temperature will
remain as a condition for this permit.
Comment #3: Yadkin Inc. request that Discharge Monitoring Reports (DMR) submittal be waived.
Response: Since Yadkin, Inc. request coverage under an individual NPDES permit, DMR reporting is
required.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Internet: http://h2o.enr.state.nc.us/

Yadkin, Inc.
Permit No. NC0081931
High Rock Powerhouse
Page 2
Comment #4: Since it is impractical to obtain samples at the point of discharge, Yadkin Inc. request
approval for sampling at the closest point to discharge where a representative sample can practically be
obtained.
Response: The Division agrees that this is a reasonable request and has included the phrase, "E —
Effluent or the point closest to discharge where a representative sample of the discharge can feasibly be
obtained." to allow for sampling at the sump upstream of the discharge.
Comment #5: The cover letter states that the pH limitation will include the phrase "unless ambient river
conditions prevent compliance with this range", however this phrase does not appear in the pH footnote.
Response: The phrase "unless ambient river conditions prevent compliance with this range" has been
inserted into Note 2 on the Effluent Limitations and Monitoring Requirement page.
Comment #6: The fact sheet notes that the "facility is not required to perform any instream monitoring".
If the boiler plate language relating to increases in stream temperature cannot be removed from the
Effluent Limitations and Monitoring Requirements page, then this same statement needs to be reflected
on the Effluent Limitations and Monitoring page as a footnote.
Response: The temperature footnote contained in the permit is reflective of the water quality standard for
temperature as contained in the 02B .0200 rules. Therefore, a discharge cannot raise the temperature of
the receiving stream by more than 2.8 °C or cause the receiving stream to exceed 32°C (for lower
piedmont and coastal plain waters) even if temperature is not specifically addressed in the conditions of
the permit. Though the temperature footnote will remain in the permit, the intent of this limitation is not
to require instream monitoring of temperature for reporting purposes.
Comment #7: Clarification of BMPs related to the changing of oil absorbent pads on a quarterly basis.
Yadkin Inc. does not utilitize oil absorbent pads for the sumps. Instead Yadkin Inc. uses a rope skimmer
type oil water separator.
Response: Since oil absorbent pads are not utilized at this facility the BMP language has been altered to
better reflect the current operations at this facility. BMPs for the rope skimmer type oil/water separator
will remain as a condition of the permit.
Comment #8 and #9: Yadkin Inc. request that note #1 on the A(2) Effluent Limitations and Monitoring
Requirement page be changed to "The tailrace shall be visually inspected for oil sheen attributed to
facility operations on a weekly basis in conjunction with inspections of the floor sump and rope
skimmer." Additionally, Yadkin Inc. request that note #1 on the A(2) Effluent Limitations and
Monitoring Requirement page be replaced with language that requires the tailrace inspections to be
logged in the operating log instead of on the DMRs.
Response: The Division recognizes Yadkin Inc.'s concern with the liability of the language contained in
the draft permit and has no objection to the proposed language, however in order to assure the availability
of data, the footnote has been modified as follows:
"The tailrace shall be visually inspected for oil sheen attributed to facility operations on a weekly basis in
conjunction with inspections of the floor sump and rope skimmer. Confirmation that a visual inspection
was conducted shall be recorded in the operating log for the facility and provided to the Division upon
request."

Yadkin, Inc.
Permit No. NC0081931
High Rock Powerhouse
Page 3
Comment #10: Yadkin request that the "Boiler Plate" language related to the discharge of floating solids
or visible foam be removed from the Effluent Limitations and Monitoring Requirements page. Foam is
not uncommon on the downstream side of the hydroelectric plant, however this foam is due to turbulence
and surfactants or other foam causing agents present in the ambient river water.
Response: The Division agrees that Yadkin Inc. cannot control the characteristics of the influent ambient
river water, therefore the phrase "unless ambient river conditions prevent compliance" has been added to
the language.
Comment #11: Effluent Limitations and Monitoring Requirements page for outfalls 001, 002, 003, 004,
and 005: The monitoring frequency for these outfalls is semi-annual, however the reporting frequency is
quarterly. Yadkin Inc. request that the reporting frequency mirror the monitoring frequency for these
outfalls.
Response: The quarterly monitoring frequencies for these outfalls were placed in the draft permit in
order to maintain consistency throughout the permit. This was done as a matter of convenience to the
Division and the permittee. However, the Division recognizes the permittee's concerns over the liability
of this requirement and has changed the reporting requirement to mirror the monitoring frequencies.
Attached is the NPDES permit No NC0081931 issued December 23, 1999. This permit is issued pursuant
to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the US Environmental Protection Agency dated December 6, 1983.
Please take notice that this permit is not transferable. Part II, E.4. addresses the requirements to be
followed in case of change in ownership or control of this discharge. This permit does not affect the legal
requirement 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
government permit that may be required.
If any parts , measurement frequencies or sampling requirements contained in this permit modification are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be a written petition conforming to chapter 150B
of the North Carolina General Statutes, filed with the Office of Administrative Hearings, Post Office
Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such demand is made, this decision shall be
final and binding.
If you have any questions concerning this permit, please contact Mr. Michael Myers at telephone number
[phone], extension 508.
Sincerely,
Original Signed By
David A. Goodrich
Kerr T. Stevens
cc: Mooresville Regional Office - Water Quality Section
Central Files
NPDES Files
Point Source Compliance/Enforcement Unit

Permit No. NC0081931
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER 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,
Yadkin, Inc.
is hereby authorized to discharge wastewater from a facility located at
High Rock Powerhouse
Northwest of intersection at
NCSR 1002 and NCSR 2501
Davidson County
to receiving waters designated as Yadkin River in the Yadkin -Pee Dee River Basin in accordance
with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III
and IV hereof.
This permit shall become effective February 1, 2000.
This permit and authorization to discharge shall expire at midnight on January 31, 2004.
Signed this day December 23, 1999.
Original Signed By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0081931
SUPPLEMENT TO PERMIT COVER SHEET
Yadkin, Inc.
is hereby authorized to:
1. Continue to discharge once -through cooling water from outfalls 001, 002 and 003 located at High
Rock Powerhouse, at the intersection of NCSR 1002 and NCSR 2501, in Davidson County, and
Discharge from said treatment works at the location specified on the attached map into Yadkin
River, which is classified as a Class WS-IV, and B CA waters in the Yadkin River Basin.

Facility Information
Latitude:
Longitude:
Quad #:
Strewn Class:
Receiving Stream
Pemutted Flow:
35'36' 03"
80"14'03"
E18SW
WS-IV and B
Yadkin River
N/A
Sub -Basin:
03-07-08
Yadkin Inc.
NO00S1931
High Rock Powerinwe

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Permit No. NC0081931
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge once -through cooling water from
outfall(s) serial number 001, 002 and 003. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Effluent Measurement
Frequency
Sample
Type
Sample
Location*
Monthly
Average
Weekly Average
Daily Maximum
Flow (MGD)
Semi -Annually
Estimate
E
Temperature'
1
1
Semi-annually
Grab
E
pl-12
Semi-annually
Grab
E
NOTES:
Sample Location: E — Effluent or at the point closest to discharge where a representative sample of the discharge can feasibly he obtained.
The temperature of the effluent will he regulated so that the temperature of the receiving stream does not increase by more than 2.8 °C above the natural water
temperature. In no case should the receiving stream temperature exceed 32 °C due to the facility's operation. Temperature of the effluent may be ohtained anywhere
downstream of the heat exchanger effluent that is representative of the discharge.
2 The pH of the effluent shall not be less than 6.0 standard units nor greater than 9.(} standard units. unless ambient river conditions prevent compliance with this range.
The Permittee shall obtain authorization from the Division prior to the use of any chemical additive in the discharge. the permittee shall notify the Director in
writing at least ninety (90) days prior to instituting the use of any additional additive in the discharge which may be toxic to aquatic life (other than additives
previously approved by the division). Such notification shall include the completion of a Biocide Worksheet Form 101 (if applicable), a copy of the MSDS for the
additive, and a map indicating the discharge point and receiving stream.
Monitoring results ohtained during the previous semi-annual period shall he recorded and reported on a Discharge Monitoring Report (DMR) form and postmarked no later
than the 30`1' day following the completed reporting period. The first DMR is due on the 301' day of the month following the calendar semi-annual period in which this permit
was issued.
There shall he no discharge of floating solids or visible foam (other than trace amounts) in the effluent, unless ambient river conditions prevent compliance.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0081931
Facility Information
Applicant/Facility Name:
Yadkin, Inc. /High Rock Powerhouse
Applicant Address:
PO Box 576, Badin, NC 28009-0576
Facility Address:
Northwest of the intersection for NCSR 1002 and NCSR 2501
Permitted Flow
N/A — Daily Average — 51,840 gpd
Type of Waste:
Once -through cooling water.
Facility/Permit Status:
Renewal
County:
Davidsan. 1-?0,..A>4,3
Miscellaneous
Receiving Stream:
Yadkin River
Regional Office:
Mooresville
Stream Classification:
WS-IV & B CA
USGS Topo Quad:
E 18 SW
303(d) Listed?:
NO
Permit Writer:
Michael Myers
Subbasin:
03-07-08
Date:
August 27,1999
Drainage Area (m12):
adaillir
Summer 7Q10 (cfs)
Winter 7Q10 (cfs):
Average Flow (cfs):
IWC (%):
Primary SIC Code:
4911
SUMMARY
This facility maintains 3 outfalls (001, 002 and 003). The source of wastewater for the outfalls is once through
cooling water. The old permit stipulates that outfalls 001 through 003 be monitored (with no limits) for flow,
temperature and total residual chlorine. No discharge monitoring reports have been required because of the
use of BMPs.
Yadkin Inc. has requested that monitoring be replaced by implementation of BMPs. Additionally, Yadkin
Inc. requested that the pH and temperature "Boiler Plate" language be excluded from the permit. This plant
is eligible for coverage under general permit NCGS0000, however, they prefer the individual permit because
the general permit does not provide a provision for BMP practices in lieu of monitoring. In the next renewal
of the general permit the viability of providing such a provision into the permit should be examined. For all
hydroelectric facilities that request individual permits in lieu of the general permit, it is the Division's position
that these facilities should be permitted consistently statewide. Therefore, permit NC0027332 and general
permits NCG500000 were used in developing this draft permit for the hydroelectric plants owned by Yadkin,
Inc. in the Yadkin River basin.
The receiving stream (Yadkin River) is classified as WS-IV and B CA waters from a point 0.6 mile upstream
of High Rock Lake dam to Badin Dam. This reach is not listed on the 303(d) list as impaired water.
According to the May 1998 Yadkin -Pee Dee River Basinwide Water Quality management Plan this reach has
been classed as supporting its designated uses.
TOXICITY TESTING:
Current Requirement: N/A
Recommended Requirement: N/A
COMPLIANCE SUMMARY:
To date this facility has not been required to submit Discharge Monitoring Reports (DMR) because of the
implementation of Best Management Practices. However a historical review of inspection reports was
Yadkin. Inc. — High Rock Hydroelectric Powerhouse Fact Sheet
NPDES Renewal
Pave 1

conducted and Mike Parker (Mooresville Regional Office) was contacted regarding compliance issues. With
the available information it was concluded that this facility has no compliance issues.
INSTREAM MONITORING:
This facility is not required to perform any instream monitoring.
PROPOSED CHANGES:
Outfalls 001, 002 and 003 — Monitoring and/or permit limits have been set for flow and temperature as
outlined on the Effluent Limitations page.
DMR submittal - DMRs will need to be submitted quarterly for all outfalls.
Total Residual Chlorine (TRC) - Total residual chlorine monitoring will be removed from the permit, since
chlorine is not utilities at this facility.
Chromium, zinc, and cooper restriction - The chromium, zinc, and copper excerpt will be excluded since this is
adequately addressed in the notification requirement if any toxicants are to be added.
Temperature - Temperature requirement will reflect the situation if natural conditions raise the ambient temp
above 32°C.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice:
Permit Scheduled to Issue:
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please contact Michael
Myers at [phone] ext. 508.
REGIONAL OFFICE COMMENT: This is a minor permit renewal therefore the regional office comments
will be solicited during the public comment period.
Copies of the following are attached to provide further information on the permit development:
• Reasonable Potential Analysis (majors only)
• Existing permit effluent sheets with changes noted (existing facilities only)
• Draft Permit
NPDES Recommendation bv:
Signature
0/6 20 - v eater�---
Date
Yadkin. Inc. — I-Iigh Rock Hydroelectric Powerhouse Fact Sheet
NPDES Renewal
Page 2

Regional Office Comments
Regional Recommendation by:
Signature
Date
Reviewed and accepted by:
Regional Supervisor:
/�
//
j (`44
'
-..,
Signature
Date
/v
NPDES Unit Supervisor:
Signature
Date
Yadkin. Inc. - Hieh Rock Hydroelectric Powerhouse Fact Sheet
NPDES Renewal
Page 3

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0081931
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001, 002 and 003. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Flow
Temperature
Total Residual Chlorine
Discharge Limitations Monitoring Requirements
Lbs/day 4i
Units (specify)Measurement Sample Sample
Mon. Avg, Daily Max Mon. Avg. Daily Max. Frequency Tyke Location
dr
,'
THERE L HALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE TREATMENT SYSTEM EXCEPT AS PRE -APPROVED
ADDITIVES TO BIOCIDAL COMPOUNDS.
* E - Effluent
** The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 2.8° C and
in no case cause the ambient water temperature to exceed 32°C.
The permittee shall obtain authorization from the Division of Environmental Management prior to utilizing any biocide in the cooling water (See
Part III of this Permit).
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Aluminum Company of America
ALCOA
1999 October 21
N. C. Department of Environment
and Natural Resources
Division of Water Quality
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Attn: Michael J. Myers
FEDERAL EXPRESS
NEXT DAY AIR
TRACKING #811315345151
RE: COMMENTS ON DRAFT NPDES PERMITS - YADKIN, INC
Falls Powerhouse — NC0O76775
Tuckertown Powerhouse — NC0O81949
High Rock Powerhous% — NCOO81931
Dear Mr. Myers:
Alcoa is providing the following written comments to the above referenced documents on
behalf of Yadkin, Inc. It was a pleasure meeting with you on 9/20/99 to review our
operations and the comments we had on the draft permits. On behalf of Alcoa and
Yadkin, I would like to thank you for your time and consideration of the issues and
comments which follow.
If you should have any questions regarding these matters, please don't hesitate to contact
me.
Yours Very Truly,
William L. McCaskill
Senior Environmental Specialist
Alcoa - Badin Works
Cc:email
S. H. Myers
B. A. Cox
H. J. van der Meyden
J. D. Morton - PGH - NAEHS
J. J. Lettrich - PGH - Legal
ACT 2 5
()CT 5
DENR - WATER DUALITY
POINT SOURCE BRANCH
B. J. Polk - Yadkin
G. J. Ott - Yadkin
K. G. Hunsucker - Yadkin
M. L. Hinson - Yadkin
P:\WINWORD\ENVIRON\WATER\NC-DEM\YADKIN DRAFT PERMIT COMMENTS.DOC
P.O. Box 576 Badin, North Carolina 28009 USA

NPDES Draft Permit Comments
Yadkin, Inc
General Comments
Yadkin, Inc has applied for coverage under individual NPDES permits for these facilities
rather than general permits because of conditions in the general permits which they feel
are unwarranted for their operations.
The following summarizes the comments, as well as, our understanding of the agencies
position based on our discussions during the 10/19/99 meeting.
1. Yadkin requests clarification regarding the requirements to monitor the pH of cooling
water and sump water. Since there are no chemical additives added to these sources,
what is the basis for requesting that the pH of non -contact cooling water and/or sump
water be monitored?
• It is our understanding that the division understands our position on the above
issue and does not necessarily see the need for monitoring the pH of these
discharges.
2. Yadkin requests clarification regarding the basis of requirements to monitor the
temperature of the cooling water discharges. In the schematic diagrams which were
submitted as part of the application, there is data which indicates that the volume of
generator discharge water relative to the cooling water discharge is proportionally, at
a minimum, a 3000:1 ratio. Operating data indicates there is only an average increase
of 4° - 5° C across the heat exchangers. The maximum increase before a genearator
will trip off-line due to insufficient cooling capacity is 20° — 25°C.
The following thermodynamic equation related to temperature & volume can be used
to show what the resulting temperature would be from combining the cooling water
discharge with the generator discharge.
T(3) = (V(1) x T(1) + V(2) x T(2) ) / (V(1) + V(2) )
For Yadkin's case, assuming a water temperature of 20°C, and a cooling water rise of
worst case 25°C, then the resulting water temperature would be:
T(3) _ (3000 x 20) + (1 x 45)) / (3000 + 1 )
_ (60000 + 45) / 3001
= 20.0083
The resulting increase in the receiving water of .0083 degrees is well below the 2.8
degree threshold of allowable temperature rise above background.
• It is our understanding that the division understands our position on the above
issue and does not necessarily see the need for monitoring the temperature of
these discharges.

NPDES Draft Permit Comments
Yadkin, Inc
General Comments (cont)
3. Yadkin requests that DMR reporting as specified in the Effluent Limitations and
Monitoring Requirements page be waived. It is our understanding that hydroelectric
facilities permitted under the N. C. general permit NC500000 are collecting similar
data and are not required to submit these reports.
• It is our understanding that the division understands the above issue and will
consider our request, but, may expect that we provide the DMR as a part of
facilitating the divisions needs for acquisition of data regarding these discharges.
4. Yadkin requests approval that any required sampling is allowed to be performed at
the closest point to the discharge, which is representative of such discharge, as is
feasible based on the design and accessibility of the particular discharge. In a lot of
cases, it is impracticable to collect samples from the end of the pipe for a particular
discharge due to it being submerged, elevated, or located in a hazardous or
inaccessible area on the downstream side of the facilities.
• It is our understanding that the division understands our position on the above
issue and does not see any problems associated with this request.
5. Effluent Limitations and Monitoring Requirements Page: In the cover letter, there is a
note stating that the pH limitations are to include the words "unless ambient river
conditions prevent compliance with this range." Note 2 on the Effluent Limitations
and Monitoring Requirements Pages does not contain this language and needs to be
amended.
• It is our understanding that the division understands our position on the above issue,
and will modify the language on the Effluent Limitations and Monitoring
Requirements Page to be consistent with the language in the cover letter.
6. On the fact sheet under "instream monitoring", it is noted that the "facility is not
required to perform any instream monitoring." If the boiler plate language relating to
increases in stream temperature cannot be removed from the Effluent Limitations and
Monitoring Requirements page, then this same statement needs to be reflected on the
Effluent Limitations and Monitoring Requirements page as a footnote.
• It is our understanding that the division understands our position on this issue,
and since the boiler plate language related to instream temperature increases
cannot be removed, the agency is willing to modify the language on the Effluent
Limitations and Monitoring Requirements Page to be consistent with the
language in the fact sheet regarding "no requirements" to perform instream
monitoring.

NPDES Draft Permit Comments
Yadkin, Inc
General Comments (cont)
7. Yadkin requests clarification in the cover letter regarding BMP's related to the
changing of oil absorbent pads on a quarterly basis and cleaning of the sumps.
The sumps are currently serviced by a rope skimmer type oil/water separator with
BMP language in the current permit to maintain these devices. While there are no oil
absorbent pads used on a routine basis, the intermittent use, if necessary, and
subsequent removal would best be managed on an as needed basis.
8. Yadkin requests that note #1 on the Effluent Limitations and Monitoring
Requirements pages (A2) relating to inspections of the tailrace be amended to read as
follows: " The tailrace shall be visually inspected for oil sheens attributable to facility
operations on a weekly basis in conjunction with inspections of the floor sump and
rope skimmer."
Lubrication of the wicket gates is currently performed on a daily basis by an
automated system which uses a very small amount of grease. Based on the type of
grease being used and the minimal quantity, Yadkin does not feel that daily
inspections would be warranted as a result of this activity.
• It is our understanding that the division understands our position on the above
issue and considers this to be a reasonable request
9. Yadkin requests that note 1 on the Effluent Limitations and Monitoring Requirements
.7 pages (A2) regarding the requirement to document inspections of the tailrace on the
DMR be replaced with language which requires these inspections to be recorded in
the operating log of the facility, as opposed to, documenting them on the DMR. Since
the permittee would be required by law to immediately report to the agency any
visible sheens attributable to our operations as a result of these inspections, it
precludes the necessity of making a note on the DMR that inspections were
conducted.
• While this issue was not specifically addressed during our meeting, if DMR reporting
will be required on a quarterly or semi-annual basis, it would not be logical to
document these inspections on the DMR on a weekly basis if they are already being
documented in the facility operating log, and we are required by law to report visible
sheens attributable to our operations as a result of these inspections

NPDES Draft Permit Comments
Yadkin, Inc
General Comments (cont)
10. Yadkin requests that the boiler plate language related to the discharge of floating
solids or visible foam be removed from the Effluent Limitations and Monitoring
Requirements pages. While the discharges from these operations do not contain
floating solids or visible foam, it is not uncommon for there to be foam on the
downstream side of any hydroelectric facilitiy as a result of turbulence and the
presence of surfactants or other foam causing substances present in the river
attributable to other sources.
• It is our understanding that the division understands our position on this issue,
and since the boiler plate language related to the discharge of floating solids or
visible foam cannot be removed, the permittee is requesting that additional
language be added to the Effluent Limitations and Monitoring Requirements Page
to clarify that this only applies to floating solids or foam causing agents added by
the pemittee and does not apply to floating solids or foam causing agents present
in the intake water.
Facility Specific Comments
Pemit No. NC0081931 - High Rock Powerhouse
11. In the third bullet of the cover letter, as well as, on the fact sheet there is reference to
DMR reporting on a quarterly basis, however, the prosposed frequency of monitoring
and reporting indicated in the effluent limitations and monitoring requirements page
for this facility are on a semi-annual basis. The cover letter and fact sheet need to be
consistent with the effluent limitations and monitoring requirements page regarding
semi-annual reporting.
• It is our understanding that the division understands our position on the above
issue and considers this to be a reasonable request
Permit No. NC0076775 - Falls Powerhouse
12. Effluent Limitations and Monitoring Requirements Page for Outfalls 001, 002, 003,
004, and 005: The monitoring frequency on this page is semi-annual, and the
reporting frequency at the bottom of the page requires quarterly reporting. DMR
submittal should be dependent on what the monitoring frequency is for the outfall in
question, not on the most restrictive frequency in the whole permit. If the agency
requires monitoring and reporting for these outfalls, the monitoring and reporting
frequency should be consistent on a semi-annual basis.
• It is our understanding that the division understands our position on the above
issue and considers this to be a reasonable request

NPDES Draft Permit Comments
Yadkin, Inc
Facility Specific Comments (cont)
Permit No. NC0081949 - Tuckertown Powerhouse
13. Effluent Limitations and Monitoring Requirements Page for Outfalls 001, 002, 003:
The monitoring frequency on this page is semi-annual, and the reporting frequency at
the bottom of the page requires quarterly reporting. DMR submittal should be
dependent on what the monitoring frequency is for the outfall in question, not on the
most restrictive frequency in the whole permit. If the agency requires monitoring and
reporting for these outfalls, the monitoring and reporting frequency should be
consistent on a semi-annual basis.
• It is our understanding that the division understands our position on the above
issue and considers this to be a reasonable request

PUBLIC NOTICE
STATE OF
NORTH CAROLINA
ENVIRONMENTAL
MANAGEMENT
COMMISSION
POST OFFICE
BOX 29535
RALEIGH,
NORTH CAROLINA
27626-0535
NOTIFICATION OF
INTENT TO ISSUE A
STATE NPDES PERMIT
determinations regarding the
proposed permit. A public
meeting may be held where
the Director of the Division
of Environmental Manage-
ment finds a significant de-
gree of public interest in a
proposed permit.
A copy of the draft permit is
available by writing or call-
ing the Division of Environ-
mental Management, P.O.
Box 29535, Raleigh, North
Carolina 27626-0535, (919)
733-7015.
The application and other in-
formation may be inspected
at these locations during nor-
mal office hours. Copies of
the information on file are
available upon request and
payment of the costs of re-
production. All such com-
ments or requests regarding
a proposed permit should
make reference to the
NPDES permit number list-
ed below.
On the basis of thorough
staff review and application
of Article 21 of Chapter 143,
General Statutes of North
Carolina. Public Law 92-500
and other lawful standards
and regulations. the North
Carolina Environmental
Management Commission
proposes to issue a permit to
discharge to the persons list-
ed below effective 11/8/99
and subject to special condi-
tions.
Persons wishing to comment
upon or object to the pro-
posed determinations are
invited to submit same in
writing to the above address
no later than 10/22/99. All
comments received prior to
that date will be considered
in the formulation of final
o. v� L-c%r ) J �^ Y<\
Date 9/15/99
David A. Goodrich
for Ken T. Stevens, Director
Division of Environmental
Management
Public notice of intent to is-
sue a State NPDES permit to
the following:
1. NPDES No.
Yadkin, Inc., P.O. Box 576
Badin, NC 28009 has ap-
plied for a permit renewal
for a facility located at High
Rock Powerhouse, North
West of the Intersection of
NCSR 1002 and NCSR 2501
in Rowan County. The fa-
cility discharges cooling wa-
ter from three outfalls into
the Yadkin River. a Class
\VS -IV and B CA stream in
the Yadkin -Pee Dee River
Basin. No parameters are
water quality limited, but
this discharge may affect fu-
ture allocations.
AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA Lcxinizton,N.C.
DAVIDSON COUNTY
Sept. 22, 1999
m.Ateire) 19
of THE DISPATCH, a newspaper published
Lexington, County and State aforesaid, being duly sworn, says the foregoing
which the
day of
attached is maa true copy,
was published
19 IS.
in said
in the city of
of
newspaper once the
Publication Fee $ 10(,0
. 3
Sworn to and subscribed before me, this

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•1
c4MMEWfS ON DRAFT NPDES PERMITS - YADKIN, INC
Subject: COMMENTS ON DRAFT NPDES PERMITS - YADKIN, INC
Date: Wed, 20 Oct 1999 19:58:39 -0400
From: "McCaskill, William L." <[e-mail]>
To: 'Mike Myers' <[e-mail]>
CC: "Cox, Bruce A." <[e-mail]>, "Myers, Steve H." <[e-mail]>,
"Polk, Julian" <[e-mail]>,
"Van Der Meyden, Henk" <[e-mail]>,
"Ott, Gregory J." <[e-mail]>,
"Hunsucker, Kenneth G." <[e-mail]>,
"Hinson, Macy L." <Macy.Hinson @ alcoa.com>,
"Morton, John D." <[e-mail]>,
"Lettrich, Jeffrey J." <Jeffrey.Lettrich @ alcoa.com>
Mike,
Attached are the final comments on the referenced documents. For your
reference, I have highlighted any final revisions which were not included in
the draft document we reviewed on Tuesday. You will note that I have added a
comment (#9) regarding the necessity of documenting tailrace inspections on
the DMR.
I will get a hard copy in the mail to you tomorrow via FedEx.
If you have any questions after reviewing the comments, please don't
hesitate to contact me.
«YADKIN DRAFT PERMIT COMMENTS.doc»
Larry McCaskill
Senior Environmental Specialist
B - BADIN WORKS
FAX [phone]
VOICE 704-422-5639
ACTNET 230-5639
INTERNET Larry . McCaskill @ Alcoa . corn
MYADKIN DRAFT PERMIT COMMENTS.doc
Name: YADKIN DRAFT PERMIT
COMMENTS.doc
Type: Microsoft Word Document
(application/msword)
Encoding: base64
Download Status: Not downloaded with message
1 of I 10/21/99 9:23 AM

1999 October 21
N. C. Department of Environment
and Natural Resources
Division of Water Quality
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Attn: Michael J. Myers
FEDERAL EXPRESS
NEXT DAY AIR
TRACKING #811315345151
RE: COMMENTS ON DRAFT NPDES PERMITS - YADKIN, INC
Falls Powerhouse — NC0076775
Tuckertown Powerhouse — NC0081949
High Rock Powerhouse — NC0081931
Dear Mr. Myers:
Alcoa is providing the following written comments to the above referenced documents on
behalf of Yadkin, Inc. It was a pleasure meeting with you on 9/20/99 to review our
operations and the comments we had on the draft permits. On behalf of Alcoa and
Yadkin, I would like to thank you for your time and consideration of the issues and
comments which follow.
If you should have any questions regarding these matters, please don't hesitate to contact
me.
Yours Very Truly,
William L. McCaskill
Senior Environmental Specialist
Alcoa - Badin Works
Cc:email
S. H. Myers
B. A. Cox
H. J. van der Meyden
J. D. Morton - PGH - NAEHS
J. J. Lettrich - PGH - Legal
B. J. Polk - Yadkin
G. J. Ott - Yadkin
K. G. Hunsucker - Yadkin
M. L. Hinson - Yadkin
C:ITEMPIYADKIN DRAFT PERMIT COMMENTS.DOC

NPDES Draft Permit Comments
Yadkin, Inc
General Comments
Yadkin, Inc has applied for coverage under individual NPDES permits for these facilities
rather than general permits because of conditions in the general permits which they feel
are unwarranted for their operations.
1. Yadkin requests clarification regarding the requirements to monitor the pH of cooling
water and sump water. Since there are no chemical additives added to these sources,
what is the basis for requesting that the pH of non -contact cooling water and/or sump
water be monitored?
2. Yadkin requests clarification regarding the basis of requirements to monitor the
temperature of the cooling water discharges. In the schematic diagrams which were
submitted as part of the application, there is data which indicates that the volume of
generator discharge water relative to the cooling water discharge is proportionally, at
a minimum, a 3000:1 ratio. Operating data indicates there is only an average increase
of 4° - 5° C across the heat exchangers. The maximum increase before a genearator
will trip off-line due to insufficient cooling capacity is 20° — 25°C.
The following thermodynamic equation related to temperature & volume can be used
to show what the resulting temperature would be from combining the cooling water
discharge with the generator discharge.
T(3) = (V(1) x T(1) + V(2) x T(2) ) / (V(1) + V(2) )
For Yadkin's case, assuming a water temperature of 20°C, and a cooling water rise of
worst case 25°C, then the resulting water temperature would be:
T(3)=(3000x20)+(1 x45))/(3000+1)
=( 60000 + 45) / 3001
= 20.0083
The resulting increase in the receiving water of .0083 degrees is well below the 2.8
degree threshold of allowable temperature rise above background.

NPDES Draft Permit Comments
Yadkin, Inc
General Comments (cont)
3. Yadkin requests that DMR reporting as specified in the Effluent Limitations and
Monitoring Requirements page be waived. It is our understanding that hydroelectric
facilities permitted under the N. C. general permit NC500000 are collecting similar
data and are not required to submit these reports.
• It is our understanding that the division understands the above issue and will
consider our request, but, may expect that we provide the DMR as a part of
facilitating the divisions needs for acquisition of data regarding these discharges.
4. Yadkin requests approval that any required sampling is allowed to be performed at
the closest point to the discharge, which is representative of such discharge, as is
feasible based on the design and accessibility of the particular discharge. In a lot of
cases, it is impracticable to collect samples from the end of the pipe for a particular
discharge due to it being submerged, elevated, or located in a hazardous or
inaccessible area on the downstream side of the facilities.
• It is our understanding that the division understands our position on the above
issue and does not see any problems associated with this request.
5. Effluent Limitations and Monitoring Requirements Page: In the cover letter, there is a
note stating that the pH limitations are to include the words "unless ambient river
conditions prevent compliance with this range." Note 2 on the Effluent Limitations
and Monitoring Requirements Pages does not contain this language and needs to be
amended.
• It is our understanding that the division understands our position on the above issue,
and will modify the language on the Effluent Limitations and Monitoring
Requirements Page to be consistent with the language in the cover_letter.
6. On the fact sheet under "instream monitoring", it is noted that the "facility is not
required to perform any instream monitoring." If the boiler plate language relating to
increases in stream temperature cannot be removed from the Effluent Limitations and
Monitoring Requirements page, then this same statement needs to be reflected on the
Effluent Limitations and Monitoring Requirements page as a footnote.
• It is our understanding that the division understands our position an this issue,
and since the boiler plate language related to instream temperature increases
cannot be removed, the agency is willing to modify the language on the Effluent
Limitations and Monitoring Requirements Page to be consistent with the
language in the fact sheet regarding "no requirements" to perform instream
monitoring.

NPDES Draft Permit Comments
Yadkin, Inc
General Comments (cont)
7. Yadkin requests clarification in the cover letter regarding BMP's related to the
changing of oil absorbent pads on a quarterly basis and cleaning of the sumps.
The sumps are currently serviced by a rope skimmer type oil/water separator with
BMP language in the current permit to maintain these devices. While there are no oil
absorbent pads used on a routine basis, the intermittent use, if necessary, and
subsequent removal would best be managed on an as needed basis.
8. Yadkin requests that note #1 on the Effluent Limitations and Monitoring
Requirements pages (A2) relating to inspections of the tailrace be amended to read as
follows: " The tailrace shall be visually inspected for oil sheens attributable to facility
operations on a weekly basis in conjunction with inspections of the floor sump and
rope skimmer."
Lubrication of the wicket gates is currently performed on a daily basis by an
automated system which uses a very small amount of grease. Based on the type of
grease being used and the minimal quantity, Yadkin does not feel that daily
inspections would be warranted as a result of this activity.
• It is our understanding that the division understands our position on the above
issue and considers this to be a reasonable.request
9. Yadkin requests that note 1 on the Effluent Limitations and Monitoring Requirements
pages (A2) regarding the requirement to document inspections of the tailrace on the
DMR be replaced with language which requires these inspections to be recorded in
the operating log of the facility, as opposed to, documenting them on the DMR. Since
the permittee would he required by law to immediately report to the agency any
visible sheens attributable to our operations as a result of these inspections, it
precludes the necessity of making a. note on the DMR that inspections were
conducted.
• While this issue was not specifically addressed during our meeting, if DMR reporting
will be required on a quarterly or semi-annual basis, it would not be logical to
document these inspections on the DMR on a weekly basis if they are already being
documented in the facility operating log, and we are required by law to report visible
sheens attributable to our operations as a result of these inspections

NPDES Draft Permit Comments
Yadkin, Inc
General Comments (cont)
10. Yadkin requests that the boiler plate language related to the discharge of floating
solids or visible foam be removed from the Effluent Limitations and Monitoring
Requirements pages. While the discharges from these operations do not contain
floating solids or visible foam, it is not uncommon for there to be foam on the
downstream side of any hydroelectric facilitiy as a result of turbulence and the
presence of surfactants or other foam causing substances present in the river
attributable to other sources.
• It is our understanding that the division understands our position on this issue,
and since the boiler plate language related to the discharge of floating solids or
visible foam cannot he removed, the permittee is requesting that additional
language be added to the Effluent Limitations and Monitoring Requirements Page
to clarify that this only applies to floating solids or foam causing agents added by
the pemittee and does not apply to floating solids or foam causing agents present
in the intake water.
Facility Specific Comments
Pemit No. NC0081931 - High Rock Powerhouse
11 In the third bullet of the cover letter, as well as, on the fact sheet there is reference to
DMR reporting on a quarterly basis, however, the prosposed frequency of monitoring
and reporting indicated in the effluent limitations and monitoring requirements page
for this facility are on a semi-annual basis. The cover letter and fact sheet need to be
consistent with the effluent limitations and monitoring requirements page regarding
semi-annual reporting.
• It is our understanding that the, division understands our position on the above
issue and considers this to be a reasonable request
Permit No. NC0076775 - Falls Powerhouse
12. Effluent Limitations and Monitoring Requirements Page for Outfalls 001, 002, 003,
004, and 005: The monitoring frequency on this page is semi-annual, and the
reporting frequency at the bottom of the page requires quarterly reporting. DMR
submittal should be dependent on what the monitoring frequency is for the outfall in
question, not on the most restrictive frequency in the whole permit. If the agency
requires monitoring and reporting for these outfalls, the monitoring and reporting
frequency should be consistent on a semi-annual basis.
• It is our understanding that the division understands our position on the above
issue and considers this to be a reasonable request

NPDES Draft Permit Comments
Yadkin, Inc
Facility Specific Comments (cont)
Permit No. NC0081949 - Tuckertown Powerhouse
13. Effluent Limitations and Monitoring Requirements Page for Outfalls 001, 002, 003:
The monitoring frequency on this page is semi-annual, and the reporting frequency at
the bottom of the page requires quarterly reporting. DMR submittal should be
dependent on what the monitoring frequency is for the outfall in question, not on the
most restrictive frequency in the whole permit. If the agency requires monitoring and
reporting for these outfalls, the monitoring and reporting frequency should be
consistent on a semi-annual basis.
.1.#1 irositkA

RE: -Water Tsmp
Subject: RE: Water Temp
Date: Wed, 20 Oct 1999 08:58:08 -0400
From: "Hunsucker, Kenneth G." <[e-mail]>
To: "Ott, Gregory J." <[e-mail]>,
"McCaskill, William L." <Larry.McCaskill @ alcoa.conv,
"' Mike.Myers @ ncmail.net"" <Mike.Myers @ ncmail. net>
Myers.
Larry
Have included water temperature readings for 1999 and copied Mike
Ken
From:
Sent:
To: Ott,
Subject:
McCaskill, William L.
Tuesday, October 19, 1999 3:37 PM
Gregory J.; Hunsucker, Kenneth G.
FW: Water Temp
Attached is the data which Ken sent me regarding the cooling water
temperatures. Six data points. As I recall, Mike requested a minimum of 8
data points. Any chance we could expand this list. The more, the better.
We need to email it to him ASAP because they will be finalizing the
permit.
His email address is [e-mail]
Larry McCaskill
Senior Environmental Specialist
B - BADIN WORKS
FAX
VOICE
ACTNET
INTERNET
704-422-5776
704-422-5639
230-5639
Larry . McCaskill @ Alcoa . com
From: Hunsucker, Kenneth G.
Sent: Tuesday, October 05, 1999 12:12 PM
To: McCaskill, William L.
Subject: FW: Water Temp
From: Hunsucker, Kenneth G.
Sent: Friday, January 08, 1999 11:08 AM
To: McCaskill, W. Larry
Subject: Water Temp
Larry
the following water temperture reading from # 2 generator cooling water
were recorded in the the station operation log book.
water in water out
1 of 2 10/21/99 9:23 AM

RE -Water Temp
A R
> 98/02/21 42deg F 57deg F
> 98/04/20 63 77
> 98/06/15 78 82
> 98/08/24 83 89
> 98/10/19 73 78 # 3 Gen.
> 98/12/14 56 63
> 99/02/16 47 60
> 99/04/12 57 68
> 99/06/15 Not Generating
> 99/08/16 Not Generating
> 99/10/11 70 82
>
2 of 2
10/21/99 9:23 AM

Yadkin, Inc.
Post Office Box 576
Badin, North Carolina 28009-0576
yaDKln Inc
March 01, 1999
North Carolina Department of
Environment, and Natural Resources
Division of Water Quality
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Attn: Mr. Charles H. Weaver, Jr.
Re: NPDES Permit Applications — Yadkin, Inc.
Falls Powerhouse — NC0076775
Narrows Powerhouse —NC0081957
Tuckertown Powerhouse — NC0081949
High Rock Powerhouse —NC0081931
Gentlemen:
Enclosed are permit applications for the four Yadkin, Inc. hydro -generation plants.
We request consideration of a best management practice (BMP) provision for all permitted outfalls.
Since our discharges consist primarily of non -contact cooling water and the volume of water used to cool
the turbines relative to the total discharge volume is so small, we question the necessity of boiler plate
language in the current permits related to instream temperature rise. Also, since we are not adding
anything to the cooling water which would alter the pH, we question the necessity of boiler plate
language in the current permits related to pH.
You will no« that we have added an additional outfall at the Narrows Powerhouse (004). We are
currently in the process of sampling the discharge and will be forwarding the data to you as an
amendment to this application.
Also, .please note that High Rock Powerhouse is actually located in Davidson County; however, during
previous permit renewals, for consistency sake, permitting oversight has been provided from one regional
office. Yadkin requests that this approach to permitting oversight be continued from one regional office.
We do not produce sludge in our process; therefore, a sludge management plan is not included in the
submittal.
Please call me at [phone] should you have questions or comments concerning
this submittal.
Sincer
valiari Polk, P.E.
Vice President

HIGH ROCK POWERHOUSE
NPDES PERMIT NO. NC0081931
Yadkin River
HIGH ROCK HIGH ROCK
Unit One Unit Two
Scroll Case Scroll Case
Unit One
Thrust Bearing
Cooling Water
17,280 Gal/Day
Outfall # 001
Into Yadkin
River
Unit Two
Thrust Bearing
Cooling Water
17_Gal/Day__
_♦
Outfall # 002
Into Yadkin
River
HIGH ROCK
Unit Three
Scroll Case
Unit Three
Thrust Bearing
Cooling Water
17,280 Gal/Day
Outfall # 003
Into Yadkin
River
Unit One Generator Unit Two Generator Unit Three Generator
Discharge/24 Hrs. Discharge/24 Hrs. Discharge/24 Hrs.
1,861,263,360 Gals. 1,825,718,400 Gals. 1,851,569,280 Gals.

To: NPDES Unit
Water Quality Section
Attention: Charles Weaver
SOC Priority Project: No
Date: June 4, 1999
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Rowan
NPDES Permit No.: NC0081931
MRO No.: 99-63
PART I - GENERAL INFORMATION
1. Facility and Address: High Rock Powerhouse
c/o Yadkin, Inc.
Post Office Box 576
Badin, N.C. 28009
2. Date of Investigation: May 27, 1999
3. Report Prepared By: Michael L. Parker, Environ. Engr. II
4. Person Contacted and Telephone Number: Mr. Ronnie Pickier, [phone].
5. Directions to Site: The High Rock Powerhouse is accessed via a private dirt road on the left
(north) side of SR 1002, immediately after crossing the Yadkin River from Stanly County
into Davidson County.
6. Discharge Point(s), List for all discharge Points: -
Latitude: 35° 36' 03"
Longitude: 80° 14' 03"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: E 18 SW
7. Size (land available for expansion and upgrading): There is little, if any, area available for
the construction of wastewater treatment facilities.
8. Topography (relationship to flood plain included): The Powerhouse is located on the main
segment of the Yadkin River; however, the hydroelectric generation facilities are not subject
to flooding.
9. Location of Nearest Dwelling: The nearest dwelling is at least 1000 feet from the site.

Page Two
10. Receiving Stream or Affected Surface Waters: Yadkin River
a. Classification: WS-IV and B, CA
b. River Basin and Subbasin No.: Yadkin 03-07-08
c. Describe receiving stream features and pertinent downstream uses: The Yadkin River
is used for primary and secondary recreation and electricity generation. There are no
known water intakes several miles below this Powerhouse.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater: 0.01728 MGD*
* Intermittent depending on powerhouse usage and electrical needs.
b. Current permitted capacity: N/A
c. Actual treatment capacity: N/A
d. Description of existing or substantially constructed treatment works: There are no
existing treatment works nor are any proposed. For domestic wastewater disposal,
employees have an on -site subsurface disposal system.
e. Possible toxic impacts to surface waters: None. There are no biocides added to the
cooling water at this facility.
d. Pretreatment Program (POTWs only): N/A
2. Residuals handling and disposal scheme: There are no residuals generated.
3. Treatment Plant Classification: This facility does not meet the minimum criteria for a class I
rating.
4. SIC Code(s): 4911
Wastewater Code(s): 48
MTU Code(s): N/A
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grants Funds (municipals only)? No
2. Special monitoring requests: None at this time.
3. Additional effluent limits requests: None at this time.

Page Three
4. Air Quality and/or Groundwater concerns or hazardous materials utilized at this facility that
may impact water quality, air quality or groundwater? No AQ or GW concerns nor are
hazardous materials utilized at this facility.
PART IV - EVALUATION AND RECOMMENDATIONS
The applicant, Yadkin, Inc. (a subsidiary of ALCOA), operates a powerhouse (dam) on the
Yadkin River known as the High Rock Powerhouse, which generates hydroelectric power. A portion
of the electricity generated by the powerhouse is used in ALCOA's aluminum manufacturing process.
Complex electrical generation machinery exists at this facility that requires cooling water during
operation.
issued.
There have been no changes and/or modifications to this facility since the Permit was last
It is recommended that the NPDES Permit be renewed as requested.
�ignature of Report Preparer Date
Water Quality Regional Sup or
h:ldsr1dsr99U»ghrock.dsr
a -
Date