NC0076775_Permit (Issuance)_19991223

NPDES DOCU BENT !MCANNINO COVER SHEET
NPDES Permit:
NC0076775
Falls Powerhouse
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Staff Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
December 23, 1999
This document is printed on reuse paper - ignore arty
content on the reYerae 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
NCDENR
Subject: Permit No. NC0076775
Falls Powerhouse
Stanly 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,
NC0076775, 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, 003, 004, and 005 and the quarterly monitoring of outfall 007, 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.usl

Yadkin, Inc.
Permit No. NC0076775
Falls 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. NC0076775
Falls 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 perrmittee. 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. NC0076775 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.
S" ur grnal Signed By
David A. Goodrich
Kerr T. Stevens
cc: Mooresville Regional Office - Water Quality Section
Central Files
NPDES Files 4
Point Source Compliance/Enforcement Unit

Permit No. NC0076775
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
Falls Powerhouse
at the end of NCSR 1727
souteast of Badin, NC
Stanly 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

SUPPLEMENT TO PERMIT COVER SHEET
Yadkin, Inc.
is hereby authorized to:
Permit No. NC0076775
1. Continue to discharge once -through cooling water from outfalls 001, 002, 003, 004, and 005 and water
from a sump drain (Outfall 007) located at Falls Powerhouse, at the end of NCSR 1727, southeast of
Badin, Stanly County, and
1.
Discharge from said treatment works at the location specified on the attached map into the Yadkin
River which is classified as class WS-IV and B CA waters in the Yadkin -Pee Dee River Basin.

Facility Information
latitude: .2.3. 44 Sub-13:vin:
8044'34"
Quad tt: F1SNE
Stnnunt WS- IV int I
IttveivingStivain:
Permitted Mow: N, .1
03-07-08
Facility
Location
x
North
'01171 ;77.1
`,A.

r
A (I ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
During the period beginning on the effective date of the permit and lasting until expiration, the Permitter is authorized to discharge once -through cooling water from outfall(s)
serial number 001, 002, 003, 004, and 005. Such discharges shall be limited and monitored by the Permittee as specified below:
Permit No. NC0076775
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING
Effluent Measurement
Fre uenc
REQUIREMENTS
Sample Type
Sample
Location*
Monthly Average
Weekl Avera a
Dail Maximum
Semi -Annually
Estimate
E
Flow (MGD)
I
1
Semi-annually
Grab
1
Temperature'
pH2
2
2
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 be 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 clue to the facility's operation. Temperature of the effluent may be obtained anywhere
downstream of the heat exchanger effluent that is representative of the discharge.
The pH of the effluent shall not be less than 6.0 standard units nor greater than 9.0 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 obtained during the previous semi-annual period shall he recorded and reported on a Discharge Monitoring Report (DMR) form and postmarked no later
than the 30t day following the completed reporting period. The first DMR is due on the 30'' 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.

A (2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Permit No. NC0076775
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 007 — Sump
Drain. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING
Effluent Measurement
Frequency
REQUIREMENTS
Sample Type
Sample
Location*
Monthly Average
Weekly Average
Daily Maximum
Flow
Quarterly
Estimate
E
Oil and Grease'
15 mg/1
20 mg/I
Quarterly
Grab
E
pH2
Quarterly
Grab
E
NOTES:
a: Sample Locations: E — Effluent or at the point closest to discharge where a representative sample of the discharge can feasibly he obtained.
I The tailrace shall he 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.
2. The pH of the effluent shall not he less than 6.0 standard units or greater than 9.0 standard units, unless ambient river conditions prevent compliance with this range.
Best Management Practices (BMPs) must be employed to ensure that excessive pollutants are not discharged to the surface water of the state. These practices
should include as a minimum, routine maintenance of the rope skimmer type oil/water separator and cleaning accumulated sediment in the bottom of the sump
annually.
Chemical wheel pit cleaning is permitted on a monthly basis. When wheel pit cleaning occurs, the tailrace shall he inspected visually for foam and oil. Cleaning shall be
conducted only with pre -approved solvents. Should the Permittee wish to change solvents, a written request should be made to the Division including the MSDS for the
proposed solvent.
Mechanical cleaning operations, which do not contribute any wastewater to the discharge are not limited by this permit. Non -discharging cleaning operations may he
conducted as often as necessary to ensure safety and proper facility operation.
The Permittee shall obtain authorization from the Division prior to the use of any chemical additive (i.e. biocides) 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 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 obtained during the previous calendar quarter shall he recorded and reported on a Discharge Monitoring Report (DMR) form and postmarked no later than
the 3011' day following the completed reporting period. The first DMR is due on the 30t day of the month following the calendar quarter in which the permit was issued. The
permittee shall confirm in writing that BMPs have been employed as specified in this permit with DMR submitted.
There shall be no discharge of floating solids or visible loam (other than trace amounts) in the effluent. unless ambient river conditions prevent compliance.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0076775
Facility Information
Applicant/Facility Name:
Yadkin, Inc. /Falls Powerhouse
Applicant Address:
PO Box 576, Badin, NC 28009-0576
Facility Address:
End of NCSR 1727 southeast of Badin, NC
Permitted Flow
N/A — Daily Average —1,383,120 gpd
Type of Waste:
Once though cooling water and sump discharges.
Facility/Permit Status:
Renewal
County:
Stanly
Miscellaneous
Receiving Stream:
Yadkin River
Regional Office:
Mooresville
Stream Classification:
WS-IV & B CA
USGS Topo Quad:
F 18 NE
303(d) Listed?:
NO -
Permit Writer:
Michael Myers
Subbasin:
03-07-08
Date:
August 26,1999
Drainage Area (mi2):
4125
„;;;,
0
Summer 7Q10 (cfs)
1400
Winter 7Q10 (cfs):
1400
Average Flow (cfs):
1400
IWC (%):
Primary SIC Code:
4911
SUMMARY
This facility maintains 6 outfalls (001, 002, 003, 004, 005 and 007) With the exception of outfall 007 (sump
drain) the source of water for the other outfalls is once through cooling water. The old permit stipulates that
outfalls 001 through 005 monitor (with no limits) flow, temperature and total residual chlorine with no
discharge monitoring report is required because of the use of BMP's.
Yadkin Inc. has requested that monitoring be replace by implementation of BMP's. 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 NCG50000, however, they choose to use 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.
DWQ's goal for those hydroelectric facilities that request an individual permit instead of an asking for
coverage under the general permit is consistency. Therefore, permit NC0027332 and general permit
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 Badin Dam to a point 0.5
miles upstream of Falls 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. — Falls Hydroelectric Powerhouse Fact Sheet
NPDES Renewal
Paste 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:
Outfall 007 - Permit limits will be applied to the sump drain outfall 007 for oil and grease. Additionally,
monitoring will be required for flow, oil and grease, and pH, with quarterly reporting requirements, as
outlined on the Effluent Limitations page.
Outfalls 001, 002, 003, 004, and 005 — Monitoring and/or limits have been set for flow and temperature as
outlined on the Effluents Limitations page.
DMR submittal - DMRs will need to be submitted quarterly for all outfalls.
Total Residual Chloride (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.
Tailrace clause — The tailrace clause requiring inspection has been reworded to ensure inspection at least
quarterly and after lubrication activities at the facility.
Chemical and Mechanical Sump Cleaning Clauses — Though this may not be applicable to this facility it has
been included to ensure that this facility is consistent with other hydroelectric facilities across the state.
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 by:
Signatu
•
7/8 7
Date
Yadkin.Inc. — Falls Hydroelectric Powerhouse Fact Sheet
NPDES Renewal
Page 2

Regional Office Comments
Peg- ! - LqA- cu/ Pot
)44614,- (40/ too
4-() PAC 4.4 C1/4_ p-e-v^pvt-i / 7/0 /4-
12--caa-v—e—e—d I CI zi)
Regional Recommendation bv:
Signature
Date
1�
ZZ
Reviewed and accepted by:
Regional Supervisor:
Signature
Date
NPDES Unit Supervisor:
Signature
Date
Yadkin.Inc. — Falls hydroelectric Powerhouse Fact Sheet
NPDES Renewal
Palle 3

A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0076775
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge cooling
waters from outfall(s) serial number 001, 002, 003, 004 and 005. Such discharges shall be limited and monitored by the permittee as specified
below: '
Effluent Characteristics
Flow
Temperature
Total Residual Chlorine
Discharge Limitations Monitoring Requirements
Lbslday Units (specify) Measurement Sample *Sample
Mon. Avgi Daily Max Mon. Avg. Daily Max. Frequency Type Location
THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE TREATMENT SYSTEM EXCEPT AS PRE -APPROVED
ADDITIVES TO I3IOCIDAL COMPOUNDS.
** 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.
116 SZla0
S311I 'IVtti! N 3 AEI OJ=1tf

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0076775
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 007 - Sump Drain. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations Monitoring Requirements
Lbslday Units (specifvl Measurement Sample *Sample
Mon. Avg. Daily Max Mon. Avg, Daily Max. Frequency Type Location
*Sample locations: E - Effluent, I - Influent
BMP Conditions:
1. Check weekly the rope skimmer oil/water separator to insure proper operation.
2. Clean out the accumulated sediment in bottom of sumps at a minimum on an annual basis.
Documentation shall be kept on record for a period of three years of the activities maintanance taken and the date upon which such action was
taken.
There shall be no discharge of floating solids or visible foam in other than tract amounts.
h6 S 2130
STIIJ WW.1.11:0 40 aD311.

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
nE, MOR Al �TTLTM
j� 1Tt 1\L L i
To:
Britt Setzer
NC DENR / DEH / Regional Eng
Mooresville Regional Office
•
1�\
November 9, 1999
From: Michael J. Myers
NPDES Unit
TriicgrA
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
�1 00076 '7 7
Subject: Review of Draft NPDES Permit- _
Yadkin Inc. — 4 ((SsUW✓C}'�-t
Stanly County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
December 17, 1999. If you have any questions on the draft permit, please contact me at the
telephone number or e-mail address listed at the bottom of this page.
RESPONSE: (Check one)
FrConcur with the issuance of this permit provided the facility is operated and maintained
properly, the stated effluent limits are met prior to discharge, and the discharge does not
contravene the designated water quality standards.
Concurs with issuance of the above permit, provided the following conditions are met:
Opposes the issuance of the above permit, based on reasons stated below, or attached:
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 508 (fax) 919 733-0719
VISIT US ON THE INTERNET @ http:JJh2o.enr.state.nc.us/NPDES Mike.myers@ ncmail.net

Aluminum Company of America
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
OCT2 5 i?99
OCT 2 5 1999
DENR - WATER QUALITY
POINT SOURCE BRANCH
B. J. Polk - Yadkin
G. J. Ott - Yadkin
K. G. Hunsucker - Yadkin
M. L. Hinson - Yadkin
P \WIN WORD\ENVIRON\WATERWC-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. •v, .b.z•.-_
r•rli�"' a .)(u;. ?ri fXvL �"y'e�-� L,.e.. ia. (-0,1s,C14.sL'a" 0. t, 2� 4snd.7r..c"ti. G:re z
2. Yadkin requests clarification regarding the basis of requirements to monitor the 91 1..5 {y y
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)xT(i)+V(2)XT(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
r discharges. "1•,ti(.4-
c
/G -A• r "1
✓ ;� ( •h
F 1.0 4 y..• �., 12-r S�r�-iei.' -� Sum. /10 i T1'61- cw r}(

c-
• .
to' ,,<`
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. , 40
G j
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 modem the language on the Effluent Limitations and Monitoring
Requirements Page to be consistent with the language in the cover letter.
c)
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 modem 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.
►.tot Re-yua4!--,4 -cl I2 L4 C•`.0 (� nc4

NPDES Draft Permit Comments
Yadkin, Inc
General Comments (cont)
7.
cY
‘;pcifr
8.
4-to c
reAu
S A)cfr un/•"fie
i
Yadkin requests clarification in the cover letter regarding BMP's related to the •-,y` %
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 ''`�' 5i`
c%v.-t:--.t.
BMP language in the current permit to maintain these devices. While there are no oil
44.-
p2
absorbent pads used on a routine basis, the intermittent use, if necessary, and
subsequent removal would best be managed on an as needed basis.
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
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 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 p
its-gi-ck
�(`
1t&r
at`V,5zti. °a
6Q¢J ✓, `d e d

NPDES Draft Permit Comments
Yadkin, Inc
General Comments (cont) � - ��P, a .
tom~
1
pr-x
0. 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 offloating 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
i- 'fps \ - tJ w� (L g _ b wf-(•S J . A e u t Ail ewet Ole 16414
12. Effluent Limitations and Monitoring Requirements Page or Outfalls 001, 002, 003, ``" °` 4
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
fat'' 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

The Stanly News and Press
P.O. Box 488
Albemarle, NC 28002
[phone]
AFFIDAVIT OF INSERTION
Date: 9/27/99
STARTDATE CLASS DESCRIPTION
WORDS INS CHG
MURPHY, KIM
NCDENR/DWQ/BUDGET OFFICE
RALEIGH,NC 27626-0535
PO BOX 29535
09/21/99 300 PUBLIC NOTICE STATE 398
NORTH CAROLINA, STANLY COUNTY
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary
Public of said County and State, duly
commissioned, qualified, and authorized by
law to administer oaths, personally appeared:
LaJeune Waggoner, who being first duly sworn,
deposes and says: that he is Publisher of a
newspaper known as THE STANLY NEWS AND PRESS,
published, issued, and entered as second class mail
in the City of Albemarle, in said County and State;
that he is authorized to make this affidavit and sworn
statement; that the notice or other legal advertisement,
a true copy of which is attached hereto, was published
in THE STANLY NEWS AND PRESS on the dates
specified on the copy attached and that the said
newspaper in which such notice, paper, document, or
legal advertisement was published was, at the time of
each and every such publication, a newspaper meeting
all of the requirements and qualifications of Section 1-597
of the General Statures of North Carolina and was a
qualified newspaper within the meaning of Section 1-597
of the General Statures of North Carolina.
83.58
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION
POST OFFICE BOX 29535
RALEIGH, NORTH CAROLINA
27626-0535
NOTIFICATION OF INTENT To ISSUEA
STATE NPDES PERMIT
On the basis of thorough staff review and appli-
cation 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 dis-
charge to persons listed below on 11/8/99, and
subject to special conditions.
Persons wishing to comment upon or object to
the proposed determinations are invited to sub-
mit 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 determinations regarding the proposed per-
mit. A public meeting may be held where the
Director of the Division of Environmental Man-
agement finds a significant degree of public inter-
est in a proposed Permit.
A copy of the draft permit is available by writing
or calling the Division of Environmental Manage-
ment, Post Office Box 29535, Raleigh, North Car-
olina 27626-0535, telephone number (919) 733-
7015.
The application and other information may be
inspected at these locations during normal office
hours. Copies of the information on file are avail-
able upon request and payment of the costs of
reproduction. All such comments ur requests
regarding a proposed Order should make refer-
ence to the NPDES permit number listed below.
1. NPDES Permit NC0076775. Yadkin, Inc., PO
Box 576 Badin, NC 28009 has applied for a per-
mit renewal for a facility located at Falls Power-
house, at the end of NCSR 1727 southeast of
Sworn to an
this 2,5 day of
before me,
, 19gq
fm,
Ndthry P blic
My Commission expires rn\, )12, au)

North Carolina } ss
Mecklenburg County}
The Knight Publishing Co., Inc.
Charlotte, NC
Affidavit of Publication
THE CHARLOTTE OBSERVER
NCDENR AIR QUALITY DIVISION
TOM REEDER
PO BOX 29580
RALEIGH NC 27626-0580
REFERENCE: 30010433
3379691 Intent Notification
Before the undersigned, a Notary Public of said
County and State, duly authorized to administer
oaths affirmations, etc., personally appeared,
being duly sworn or affirmed according to law,
doth depose and say that he/she is a
representative of the Knight Publishing Company a
corporation organized and doing business under the
laws of the State of Delaware, and publishing a
newspaper known as The Charlotte Observer in the
city of Charlotte, County of Mecklenburg and State
of North Carolina and that as such he/she is
familiar with the books, records, files and
business of said Corporation and by reference to
the files of said publication
the attached advertisement was inserted. The
following is correctly copied from the books and
files of the aforesaid Corporation and
Publication.
PUBLISHED ON: 09/22
AD SPACE:
FILED ON:
114 LINE
09/26/99
•
NAME:
TITLE:
DATE:
In Testimony Whereof I have hereunto set my
day and year aforesaid.
Notary:
PUBLIC NOTICE
STATE OF NORTH CAROUNA
ENVIRONMENTAL MANAGEMENT COMMISSION
POST OFFICE BOX 29535
RALEIGH, NORTH CAROLINA 27826.0535
NOTIFICATION OF INTENT TO ISSUE A STATE NPDES PERMIT
On the basis of thorough staff review and application of Article 21 o1 Chapter
143, General Statutes of North Carolina, Public Law 92-500 and other lawful
ement
standards and ro regulations,
otosissue North
Carolina
to the persons listed
Commission proposes
below, effective 11/0199 and subject to special conditions.
are invited dst insubmt sametinpwriting to tn or he above to the r address determinations
latter than
10122/99. All date will be considered in the
formulation al final determinations l
regarding the proposd permit. A public
Manmay be haled degree of publirector of ic interest Divisionhe a 1 Environmental
permt.
Management copyofthe draft
a significant
Enviiro�nmamtal Management, P.O. Box 295y35, AeleiQh, or calling
Carolithe na 27n of
626-
0535, [phone].
The application and other information may be Inspected at, these locations
during normal office pa hrrnen o1 the casts oes of feinformation rep oduclon �Alltisuch comments
le are available
upon rrquest st and day
NPDES Permit Number listed belowtl permit should make reference to the
Date: 9l15199 David Goodrich
for Ken T. 5levens, Director ement •
- �/ n . Division a1 Flwironmental Manag
P
I�WI.; a State NPOES permit to the following:
1. NPDES
rmotite of in :,� -..
1. NPDES .''a',,:'.a- ' dkm, Inc., PO Box 576, Batlln, NC 28009 has
applied for a-• , enewal for a facility located at Falls Powerhouse. at the
end of NCSR 1727 southeast of Badln In Stanly County. rams -
charges cooling and sump dram water from sit outfalls into the YadkinRiver,
a Class water and Bstream in Me lirnited. but this tltlkiischarrge may affect future alloc-Pee Dee River BaSin. No ations.
tars are water qual use
kin. Inc., PO Box 576. Badin, NC 28009 has
2. NPDES No.o"-;r a facility located at Tuckertownn PPoowerhor. of
on NCSR for a • The facility discharges
treated 1164 m Montgomery m tour
I Into the Yadkin River.. a Class
WB.CAindustrial wastewater the er ham n-Pr ouzel kin -Pee DeeFiver Basin. No param
water
& li CA stream
but this diedschargs may affect future allocations.
water quality .- , Shurtape Technologies. Inc., Box 1530. Hickory.
3.NC NPOES ha'. . - Ibr a permit renewal fora facility located at Shuna0e
Technologies. 28- Stony Highway90. Stony Point,
Alexander
County.
Teacility discharges 0.010 GD f treated domestic
wastewater
County.
Pee Dee River
aria ouNss into Third Creek, is waequal quality limited. in Far she ame
Yadkin -
Pee Dee River Basin.nDissolved capacity cg of the immediate receiving water will
beramater end. hIs ma a ffec utunebased effluent limitations ,
be addiional This may within this p ro�on 0l t watershed.
for additional discharges within this portion LP3379691
hand and affixed my seal,
My Commission Expires: 05/12/01
the
9a"e t`oe 4o rc,�
1"/ t['Fr?

To: Permits and Engineering Unit
Water Quality Section
Attention: Sean Goris
SOC Priority Project: No
Date: June 4, 1999
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Stanly
NPDES Permit No.: NC0076775
MRO No.: 99-62
PART I - GENERAL INFORMATION
1. Facility and Address: Falls 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. 11
4. Person Contacted and Telephone Number: Mr. Ronnie Pickier, [phone]
5. Directions to Site: From the jct. of Hwy. 740 and SR 1719 (Falls Road) in the Town of
Badin, travel east on SR 1719 to the end of the road (the road changes to SR 1727). The
Falls Powerhouse is located at the end of SR 1727.
6. Discharge Point(s), List for all discharge Points: -
Latitude: 35° 23' 44"
Longitude: 80° 04' 34"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: E 18 NE
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.

Page Two
9. Location of Nearest Dwelling: The nearest dwelling is at least 1000 feet from the
Powerhouse site.
10. Receiving Stream or Affected Surface Waters: Yadkin River
a. Classification: WS-IV and B
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: (MGD)
Outfalls
001, 003, and 005 002 & 004 007
0.432 0.0432 0.00072
Outfall 001, 003, and 005:
Outfall 002 and 004:
Outfall 007:
Generator cooling water.
Thrust bearing cooling water.
Powerhouse floor drains, wheelpit drains, oil & sludge
skimmer.
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

Page Three
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.
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 Falls Powerhouse, which generates hydroelectric power 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 an NPDES Permit be renewed as requested.
Signature of Report Preparer Date
Water Quality Regional Supe:'or
h:ldsr\dsr99\fallsdam.dsr
D� 6 �99
Date

RE: Water Temp
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.com>,
"'[e-mail]"" <[e-mail]>
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 [phone]
VOICE 704-422-5639
ACTNET 230-5639
INTERNET 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:Neater Temp
> 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

,COMMENTS 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" <Julian.Polk@ alcoa.com>,
"Van Der Meyden, Henk" <[e-mail]>;
"Ott, Gregory J." <[e-mail]>,
"Hunsucker, Kenneth G." <[e-mail]>,
"Hinson, Macy L." <[e-mail]>
"Morton, John D." <John.Morton @ alcoa.com>,
"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 . com
E1YADKIN 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 1 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.
The followingsummarizes 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 necessarilysee 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(0) x T(o) + 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 ghat the :division understands .the above issue and will
consider our request,,
facilitating the divisions need1
ect that we provide the DMR as a part o
oracquisition 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.
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.
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 understa
and since -the boil
cannot be removed: th jag psis wii
Limitations and Monitoring'Requrre.
language in the fact__ s h eet regarding
monitoring.
acts, understands our position;
elatedxto anstream temperate
ling to rnodify the languageron tki f, Z
vents Page to be consi•stent with the
"no requirements: to perform instream
r Issue,
e°m ores
uen

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, necessary and
._._ may,
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:zs our understar
issue and considers
dkiu •
requests..
vim
prec
conducte
ess.
z04604. nderstands our positron on .the above.
e ac` reasonable request
uentLimitations an
ei 1 entstok ocuimient inspect.
which requires these wisp
ocumenti
atelyej
aces
:at lnsp
•orin
Jeo
nit.. omen
:fince

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.
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.
rs
zbove
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 ` ove
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.

110-1-c
Pc.9-,--AJ
e. (2 5 oo / pc, >, oc.)_s„.0 c -.7,
)416- . L.2
-,--
2e6 c-st-t
/\. 0 Q.)-1,-12-0-evt
-,-
> z. g" e
4-y-it. 1,....h.A.4, r , ._„.,_-,- .,..„____ i f' , .,----
4 r)1.7/ '5,o
,
ct.,219/-
^Jo
Acid, ;40-__
/dr) 50 /h
/TS 4 _5Qp
7(.k-k4
sltu-e4 t," bup
- 1,),/ Zo--7
IL-9(V
di?
e ALidi741--
15)'
e - airri2 _
-2- . C.,`-4.)
_
Aix)! Trie
Fr- k_ 30-4-ud
in(
s

Krt/, Ion A6,3e
P oa
A -"P - 67z6/7/
C.A-r-c c,„ (o.4s c /1- - S �� e� c ,¢ t� u T-p.
r l e o / o g ge,
.--scC`c"- , - P3,Cw a 3 ' 4/4/
gv`
.5 63 --0g
c 44-o �-�' Ana—rifigt v,J.5 - .Y L 3 .
�("Lr Q-0
/' - f9
dal, 003) (wry
' 7 = Su w-p
QPA-1p5 a6-7
l�ec� Cam, LS; vl Q i'4r'n cs 6. BA,L
/L,/ s rrz 17 Z

WL4
[9,&. 730)c i6
l -ci J1� J.0 C z `(c)c9
TsC. Toy- q27-SG3>
Src ! -419 //
> 3 g 7 M 14-) - I� 3 x /LP (�'� ��7- 15 2
i3 3 rac., b_f _ J. 3 gSlz 04
(r/ �t /9
BS c s p.Lc/4.! d,
o0 ) ) 0 0 3) f- Do S" _ 0. L/ 3 z vril C~ D
ooa U_ 0 y3 2 G D
00-7 7. CooC'?2 /uG-b.
'`7'/Z 5
F[c5„, = /-/Q0 c .� /7e fu �ce� b 1—� iz C
L IL
C~vk/
zoo xti Q
hi!

"-) 1`- —5, (-05 _Ci2 • v- C
niern.j-tP/, s.
-tps.
1Ji

Yadkin, Inc.
Post Office Box 576
Badin, North Carolina 28009-0576
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.
yaDI In Inc
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 note 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.
Si�l
. Julian Polk, P.E.
Vice President

Powerhouse
Floor
Drains
FALLS POWERHOUSE
NPDES PERMIT NO. NC0076775
Yadkin River
y
FALLS
Unit One
Scroll Case
v
FALLS
Unit Two
Scroll Case
y
FALLS
Unit Three
Scroll Case
Units 1,2, and 3
Unit One
Unit Two
Unit Two
Unit Three
Unit Three
Wheelpits
Generator
Thrust Bearing
Generator
Thrust Bearing
Generator
Drainage
Cooling Water
Cooling Water
Cooling Water
Cooling Water
Cooling Water
432,000 Gal/Day
43,200 GaVDay
432,000 Gal/Day
43,200 Gal/Day
_ 432,000 GaVDay
7
Oil and Sludge
Skimmer
720 GaVDay
Outfall # 007
Outfall # 005
Outfall # 004
Outfall # 003
Outfall # 002
Outfall # 001
Into Yadkin
Into Yadkin
Into Yadkin
Into Yadkin
Into Yadkin
Into Yadkin
River
River
River
River
River
River
Unit One Generator
Discharge per 24 Hrs.
1,551,225,600 Gals.
Unit Two Generator
Discharge per 24 Hrs.
1,712,880,000 Gals.
Unit Three Generator
Discharge per 24 Hrs.
1,712,880,000 Gals.