NC0000396_Dust Suppression Chemicals 2001_20010321

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tlit
CCP&L
A Progress Energy Company
March 21, 2001
Mr. David Goodrich
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center I 0 ', PI�
Raleigh, NC 27699-1617
Subject: Carolina Power& Light, a Progress Energy Company VAR 2 6 2001
Asheville Steam Electric Plant J _�
NPDES Permit No. NC0000396 ®Eta_q�Afft QUALITY
Dust Suppression Chemicals ;BRANCH
Dear Mr. Goodrich:
This letter is to notify you that Asheville Steam Electric Plant will be changing the chemicals it
uses for dust suppression. The chemicals, BetzDearborn Dustreat DC9123 and DC9140, will
be used to control coal dust at both the stackout area and the unload area. The MSDSs for
these chemicals are enclosed.
Please replace the enclosed sheet with the appropriate sheet in the NPDES permit application
submitted April 3, 2000. Please also amend the NPDES permit application on file. CP&L
believes that the use of these chemicals will not require a permit modification. Use of these
chemicals will begin in approximately 30 days.
Please contact Louise England at [phone] with any questions.
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons, who mange the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.
Sincerely yours,
W. T. Tr.4lor
Plant Manager—Asheville Plant
Enclosures
cc: Asheville Regional Office— DWQ
MAILED
Asheville Steam Plant
200 CP&L Dove
Arden,NC 28704 MAR 2 2 2001

' • Carolina Power& Light Company
Asheville Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0000396
Attachment 4
Form 2C - Item VI - Potential Discharges Not Covered By Analysis
Chemical Estimated Quantity Frequency Purpose
Used (per year)
Hydrazine (35%) 400 gallons Continuous Oxygen scavenger in
boiler
Ammonium hydroxide 500 gallons Continuous pH control of boiler
water
Sodium hydroxide 24,000 gallons Continuous pH control of ash pond
Sodium hydroxide 30 gallons As required pH control of boiler
(50%) water
Sodium hypochlorite 10,000 gallons Daily during warm Control of biological
(15%) months fouling on heat
exchangers
Sodium molybdate 100 pounds As required Corrosion control in
closed cooling water
system
Sodium chloride 25,000 pounds As required Water softener
regeneration
Urea 150,000 gallons Continuous during NOx control
high ozone months
Molten Sulfur 120 tons Continuous Particulate matter
control
BetzDearbom 11,400 pounds - Continuous when Coal dust suppression -
Dustreat DC9123 estimated plant is operating proprietary chemical
BetzDearborn 360 gallons - Continuous when Coal dust suppression -
Dustreat DC9140 estimated unloading coal proprietary chemical
Fyrewash (detergent) 200 gallons As needed Combustion turbine
blade washing
Detergents/cleaning Variable As needed Housekeeping
agents
1

Afiletail I1060.
CP&L Util
Mr. Charles Weaver March 30, 2000
North Carolina Department of Environment and Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Asheville Steam Electric Plant
National Pollutant Discharge Elimination System Permit No. NC0000396
Renewal Application
Dear Mr. Weaver:
The current NPDES permit for Carolina Power & Light Company's Asheville Steam Electric
Plant located in Buncombe County expires on September 30, 2000. CP&L hereby requests
that the NPDES permit for the facility be reissued. Enclosed are the EPA Application Form 1 -
General Information and EPA Application Form 2C - Wastewater Discharge Information, both in
triplicate.
With reissuance of the NPDES permit,.CP&L requests the following:
• Eliminate the requirement to monitor copper for once-through cooling water (Outfall 002).
Monitoring data over the past years has demonstrated that copper is below the reporting
limit for this discharge. Copper monitoring was originally required due to suspected erosion
of the Unit 1 condenser tubes. These copper condenser tubes were replaced with stainless
steel tubes in 1994. Currently, CP&L monitors copper monthly.
• The current permit expresses the maximum limitation for Total Residual Chlorine as an
instantaneous maximum for the once through cooling water discharge [Part I page A.(2).].
The Steam Electric Effluent Limitation Guidelines at 40 CFR Part 423 express this value as
a maximum concentration. At 47 FR 52293 of the preamble to these guidelines EPA
describes this maximum concentration as a "daily maximum limitation." Consequently,
CP&L requests that the Total Residual Chlorine limitation be expressed in the permit as a
Daily Maximum Limitation rather than an instantaneous maximum limitation. Additionally,
CP&L requests that the phrase "or sequential" be inserted after"Simultaneous" in the last
line in the double asterisked paragraph that appears on the current permit page A.(2). This
addition will reflect the fact that we are allowed to chlorinate each unit sequentially as well
as simultaneously.
• Part III, Condition K, of the present NPDES permit for the Asheville Steam Electric Plant,
requires CP&L request a continuation of its 316(a) variance beyond the term of the present
permit. Enclosed is an EPA Guidance Letter dated August 11, 1988 outlining the general
procedure to be followed in requesting the continuance of a 316(a) variance. The following
is CP&L's response to the pertinent factors contained in the EPA General Procedure for the
reissuance of the 316(a) variance:

1. The permittee must request that the variance be continued
Response: CP&L hereby requests continuation of the 316(a) variance
reflected in it's present NPDES permit for the Asheville Steam
Electric Plant.
2. Plant operating conditions and load factors are unchanged and are expected to
remain so for the term of the reissued permit.
Response: The plant operating conditions and load factors are unchanged
and are expected to remain so for the term of the reissued permit.
3. There are no changes to the permittee's knowledge to plant discharges or other
discharges in the plant site area which could interact with thermal discharges.
Response: To CP&L's knowledge there have been no changes to the
Asheville Plant discharges or other discharges to Lake Julian
which could interact with the thermal discharges.
4. There are no changes to the permittee's knowledge to the biotic community of the
receiving water body which could impact the previous 316 determinations.
Response: As demonstrated by CP&L's annual Environmental Monitoring
Reports, which are routinely submitted to the Director of the
Division of Water Quality, since issuance of the current NPDES
permit there have been no changes to the biotic community of
Lake Julian which would impact the previous 316(a)
determination.
Descriptions of sludge disposal for the different waste streams are included in Attachment 3 of
the EPA Application Form 2C.
It has been recently discovered that there are three stormwater outfalls on the access road to
the Asheville Plant which discharge to surface water. Two of these outfalls discharge to Lake
Julian and the third is directed into the spillway of the lake. The access road is used as a 9
transportation route for coal and oil delivery trucks. This road will be replaced with a new
access road in the next few months. The new access road, which is still in the planning stages, ...141(P—
will
3 Pwill be the primary plant access for coal and oil truck deliveries. Stormwater from the new
access road will be routed to the ash pond and to Lake Julian. As soon as plans for the road
are finalized, the Asheville Plant will submit EPA Form 3510-2F for the stormwater that will be
discharged to Lake Julian. Additionally, as soon as practical Asheville Plant will sample the
stormwater outfalls on the existing access road and submit the EPA Form 3510-2F when
analysis data has been received. CP&L would like the reissued NPDES permit to reflect these
stormwater discharges.

r t
9
If there are any questions regarding the enclosed information, please contact Louise England at
[phone].
Sincerely,
tedr±
i2,1„7
W.T. Taylor
Plant Manager-Asheville Plant
Endosures
cc: Asheville Regional Office DWG

Carolina Power & Light Company
Asheville Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0000396
Attachment 2
Form 2C - Item II -A Flows, Sources of Pollution, and Treatment Technologies

French Broad ), Make-Up
River Water Intake Stormwater * Old
Ash Pond
`I
D Settling
Units 1 &2 S Lake Julian
Zone Condensers Outfall 002
B
Lake N d Intake F
Julian Structure Circulating Water _� Ash Sump
to Heat Exchanger
1
Uv
DieselChemical Metal L Evaporation
Fire T Cleaning Waste 0.
in Boilers
Fire Preheater
O Pump Protection Cleaning Sluice L
System Water Water
Ir 1 Y
y Treatment
Service Water Vendor supplied O R Basin
water treatment G ,
1
Combustion M 'V r t
I Turbine Site 4-- ;
New 4. J
— i111. Low Volume E Ash Pond French Broad
Waste Sources *, —0. Secondary A River
A Settling Basin Outfall 001
Storm Water K J H
•
y Dam Seepage
Coal Pile
Public Potable and C Public Runoff Attachment 2-form 2C-Item HA Flows,Sources of
Water 0 Sanitary .Sewage Pollution,and Treatment Technologies
Supply System System Carolina Power&Light Company
Asheville Steam Electric Plant
Buncombe County Page 1 of 2

•
Carolina Power & Light Company
Asheville Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0O00396
Attachment 2
Form 2C - Item Il-A Flow, Sources of Pollution, and Treatment Technologies
Stream Name Average Flow Comments
A Ash Pond Discharge 2.55 MGD Outfall 001
B Intake to Once-through Cooling& 250.1 MGD
Circulating Water to Heat Exchangers
C Plant Potable and Sanitary Uses 0.002 MGD To POTW
D Makeup to Lake from River 5000 gpm Maximum Flow-Utilized
During Dry Weather
E Low Volume Wastes
• Ash Hopper Seals 0.05 MGD
• Sandbed Filter Backwash 2600 GaUevent Rare Usage
• Water Softener Regeneration and 3100 GaUevent Rare Usage
Washing
• Boiler Blowdown 0.006 MGD Startup-Estimated
F Circulating Water from Heat Exchangers 19.3 MGD Estimated
G Ash Sluice Water 2.0 MGD Estimated
H Dam Seepage 0.09 MGD Calculated
I City Water Supply to Boiler Makeup 0 MGD Rare Usage
J Coal Pile Runoff 0.01 MGD Based on Average
Annual Rainfall of 47"and
50%Runoff
K Storm Water 0.052 MGD Estimated
L Chemical Metal Cleaning Wastes 0-90,000 Gallons Normal Practice is
(0 gallons anticipated) Evaporation
M Water From Combustion Turbine Facility 0-0.02 MGD Intermittent
Operation
N From Lake to Intake 250.15 MGD Estimated
O Intake to Service Water 0.05 MGD Estimated
O Fire Protection Water 0.010 MGD Estimated
R Air Preheater Cleaning 10,000 gallons/event Estimated
S Discharge to Lake Julian 248.4 MGD Outfall 002-Estimated
T Emergency Fire Protection Water 0 Used for fire fighting
U Diesel Fire Pump to Lake Julian 0.128 MG/week Estimate-pump testing
2

Carolina Power & Light Company
_ Asheville Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0000396
Attachment 3
Form 2C - Item Il-B Flows, Sources of Pollution, and Treatment Technologies

• Carolina Power & Light Company
' Asheville Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0000396
Attachment 3
Form 2C - Item II-B Flow, Sources of Pollution, and Treatment Technologies
The Asheville Steam Electric Plant is located in Arden, North Carolina south of Asheville, North
Carolina. The Asheville Steam Electric Plant is a coal-fired, steam cycle electric generating
plant with two generating units. Two Internal Combustion (IC)Turbines are also located on the
plant site. The plant has a 320-acre cooling lake (Lake Julian) on the east side of the French
Broad River in Buncombe County, North Carolina.
Chemical constituents contained in the discharges from this plant will, in part be representative
of the naturally occurring chemical quality of the intake water and will also have chemical
constituents of such quality and quantity associated with similar discharges for fossil generating
facilities of this size, type and in this geographical location. Either all or part of the elements
listed on the Periodic Table, either singularly or in any combination, may from time to time be
contained in the discharge.
Outfall 001 - Discharge from Ash Pond to French Broad River
The Plant's ash pond, which is located east of the French Broad River and south of the plant,
discharges into the French Broad River. The ash pond receives ash sluice water, low volume
wastes, coal pile runoff, air preheater cleaning water, fire protection system drainage, chemical
metal cleaning wastes (potentially), storm water and other waters from the Combustion Turbine
Facility constructed on the Plant's site. The proposed wheel wash and weigh stations will also
discharge to the Ash Pond. The Pond provides treatment by sedimentation and neutralization
to the above-referenced individual waste streams. Water leaves the ash pond via a standpipe
with skimmer and flows by pipe and lined ditch to a secondary basin, where it is discharged by
overflow to a ditch that coveys it to the French Broad River. Detailed descriptions of the
individual waste streams are below.
Ash Sluice Water
Fly ash and bottom ash from both units are hydraulically conveyed by an ash sluice pipeline to
the ash pond. An Amine Enhanced Fuel Lean Gas Rebum (AEFLGR) process will be installed
on Unit 1 in the spring of 2000. This process utilizes urea to reduce NOx emissions and will be
1

Carolina Power & Light Company
• Asheville Steam Electric Plant
_ National Pollutant Discharge Elimination System Permit Number NC0000396
used in high ozone months (approximately May through September). A byproduct of this
process is ammonia which will be carried to the ash pond via ash sluice water.
Coal Pile Runoff
Storm water runoff from the coal pile is collected in drainage ditches that surround the coal pile.
The drainage ditches are routed to the ash pond for treatment. During maintenance activities,
sludges removed from catch basins, sumps, etc. may be transported to the old and/or the new
ash pond for disposal.
Storm Water
Storm water runoff from the plant area, parking lots, combustion turbine area, oil storage and
handling facility and the plant's 115 KV substation is routed to the ash pond for treatment.
During maintenance activities, sludges removed from catch basins, sumps, etc. may be
transported to the old and/or the new ash pond for disposal.
Low Volume Wastes
Boiler water make up is withdrawn from Lake Julian and purified utilizing vendor supplied
equipment. A second option is to perform these activities using plant equipment to filter, soften,
and evaporate make up water with the filter backwash, softener regeneration, and softener
rinses discharged to the ash pond. The water softeners are regenerated using salt. Boiler
water is treated with ammonia, hydrazine, and sodium hydroxide. Boiler and evaporator
blowdown and drainage is sent to the ash pond and may contain small quantities of the
chemicals. Some molybdate waste from the closed cooling water system is created through
valve leakage and maintenance activities and is discharged to the ash pond. A furnace ash
hopper seal is maintained by using plant service water. A standard operation water level is
maintained in a seal trough for the ash hopper seal. Overflow from this trough is discharged to
the ash pond. A sodium hydroxide solution is fed into this flow stream as necessary for ash
pond pH adjustment. Coal dust suppression is achieved by spraying a proprietary chemical on
coal at different stages of coal use. This chemical will be replaced in the summer of 2000 by
two proprietary chemicals. Small amounts of excess dust suppression chemical(s) have the
potential to be discharged to the ash pond via plant drains or coal pile runoff. Small amounts of
urea waste from bulk urea unloading operations is discharged to the ash pond. All plant area
floor drains are routed to the ash pond and include equipment drainage and wash down along
2

Carolina Power & Light Company
' Asheville Steam Electric Plant
_ National Pollutant Discharge Elimination System Permit Number NC0000396
with rainfall runoff. During maintenance activities, sludges removed from catch basins, sumps,
etc. may be transported to the old and/or the new ash pond for disposal.
In many cases, added chemicals are consumed or chemically altered during the plant
processes. Only trace amounts might be recoverable in water entering the ash pond.
Detectable levels of these chemicals would not be expected to occur in ash pond discharges.
Chemical Metal Cleaning Wastes
The boilers are chemically cleaned every five-to-eight years using a weak citric acid solution.
This cleaning solution and its rinses are stored on site for disposal by evaporation in an
operating unit's furnace. Typical cleanings would result in a waste of approximately 80,000
gallons. Should evaporation not be used, the waste can be routed to a treatment basin for
neutralization and precipitation prior to being conveyed to the old ash pond with permission of
the DWQ, to the newer ash pond, or other means of disposal. Cleaning of other heat
exchanger surfaces may produce 5,000-10,000 gallons every three-to-five years.
Other Wastes
Operation of the combustion turbine (CT) generation facility may produce turbine blade wash
water, inlet filter cooling water, various condensate waters, and water from equipment and tank
drains. These wastewaters will be collected in the storm water collection system of the CT site
and routed to the ash pond. During maintenance activities, sludges removed from catch
basins, sumps, etc. may be transported to the old and/or the new ash pond for disposal.
- Plant Potable and Sanitary System -
The supply of water for plant potable and sanitary use is obtained from the Asheville/Buncombe
Water Authority system and waste from this system is discharged to the Metropolitan Sewage
District System.
-230 KV Substation Storm Water-
Storm water runoff from the substation located adjacent to the plant is conveyed to the old ash
pond.
3

Carolina Power & Light Company
Asheville Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0000396
-Air Preheater Cleaning -
After the Amine Enhanced Fuel Lean Gas Reburn (AEFLGR) system is operational, the air
preheater will be water washed on a more frequent basis. It is expected to require cleaning
once per year or more frequently as needed. The wastewater from this activity will be
discharged to the ash pond.
Outfall 002 - Discharge to Lake Julian
Once-Through Cooling Water
This flow provides condenser cooling water for the generating units 1 and 2. Maximum
condenser flows for units 1 and 2 are 124 MGD and 162 MGD, respectively.
Once-through cooling water is used to supply non-contact cooling water for the component
closed cooling water system. The component closed cooling water system flows combine with
unit 1 and 2 condenser flows prior to discharge to Lake Julian. Maximum component closed
cooling water system flows for unit 1 and 2 are 9.1 MGD and 10.2 MGD, respectively.
Discharge flow to Lake Julian is calculated at the intake to units1 and 2 condensers and to the
circulating water to the heat exchanger. The discharge of water from the heat exchangers is
routed to an ash sump. The majority of this water is further routed to the discharge of units 1
and 2 condensers. Less than one per cent of the flow to the ash sump is used to supply ash
sluice water, preheater cleaning water, and fire protection water.
Control of biological fouling on heat-exchanger surfaces is accomplished by addition of sodium
hypochlorite as required, which is usually less that 2 hours per day per unit, with a net total
residual chlorine of less than 0.2 ppm discharged during that period. Cooling is accomplished
by evaporation from the surface of Lake Julian and mixing and convection with lake waters.
Make up for Lake Julian is from the French Broad River, natural runoff and creek flows. Water
is pumped from the French Broad River during dry periods to supplement the flow. Although
discharge from Lake Julian to the river is extremely rare, any occurrence would be during
periods of heavy rainfall.
4

Carolina Power & Light Company
Asheville Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0000396
Attachment 4
Form 2C - Item VI - Potential Discharges Not Covered By Analysis

Carolina Power & Light Company
Asheville Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0000396
Attachment 4
Form 2C - Item VI - Potential Discharges Not Covered By Analysis
Chemical Estimated Quantity Frequency Purpose
Used (per year)
Hydrazine (35%) 400 gallons Continuous Oxygen scavenger in
boiler
Ammonium hydroxide 500 gallons Continuous pH control of boiler
water
Sodium hydroxide 24,000 gallons Continuous pH control of ash pond
Sodium hydroxide 30 gallons As required pH control of boiler
(50%) water
Sodium hypochlorite 10,000 gallons Daily during warm Control of biological
(15%) months fouling on heat
exchangers
Sodium molybdate 100 pounds As required Corrosion control in
closed cooling water
system
Sodium chloride 25,000 pounds As required Water softener
regeneration
Urea 150,000 gallons Continuous during NOx control
high ozone months
Molten Sulfur 120 tons Continuous Particulate matter
control
Benetech - BT415 1200 gallons Continuous when Coal dust suppression -
Aqueous Binder unloading coal and/or proprietary chemical
Blend ,plant is operating
Benetech - BT404 14,000 gallons - Continuous when Coal dust suppression -
Binder/Anionic estimated unloading coal and/or proprietary chemical to
Surfactant Blend plant is operating replace BT415
Benetech - BT205W 900 gallons - Continuous when Coal dust suppression -
Anionic/Nonionic estimated unloading coal and/or proprietary chemical to
Surfactant Blend plant is operating replace BT415
Fyrewash (detergent) 200 gallons As needed Combustion turbine
blade washing
Detergents/cleaning Variable As needed Housekeeping
agents
1

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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
0-M
'' CDENR DIVISION OF WATER QUALITY
t .„;_� ASHEVILLE REGIONAL OFFICE
: fil •. r i `. WATER QUALITY SECTION
yl ri
0
�p` { March 9, 2000
r,,. RfRNOR '- -- - .-_..
-'+... Ing, IR} T —}
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-:,f, H Mr. Winston T. Traylor
- t r L OLMAN' ,
I I' �
' . R�TARY Manager
yy��' Carolina Power & Light Company MAR 1 6 2000
>u` 200 CP&L Drive
ti,t3 Arden, North Carolina 28704
.f 5 ;;•I ,.. DENR WATER QUALITY
POINT SOURCE BRANCH
� 1. H
`."' 1"` Subject : Proposed Ash Restacking Project
',',N r`" ��.� NPDES Permit No NC0000396
,ti.r z;1 CP&L - Skyland Steam Station
t ---.Lt-1-4, Buncombe County, North Carolina
1..
i6 ` r -4
t1 l Dear Mr. Traylor:
s?, : E," 'b' This letter is in regards to the proposed Ash
xg '. Restacking Project at your Skyland Steam Electric
� , �$i`4. i :- Generating Station. The project is an effort to return
`,r,0 storage and settling capacity to the new ash settling
i.: ;',- basin which has seen its available settling capacity
t:, t e. 4 .'_�4 steadily decrease since coming online in 1982 . It
r ' .["? "'•' involves removal of approximately 1, 000, 000 tons of
L - dewatered ash from the new basin with placement of this
;s I;. ash in an area of the old ash settling basin. The old
` ' •
- =W basin is dry; having been taken out of operation shortly
�� r`= , : - after the new basin became operational . As result of this
s': - , , ' 4 project, there will be no dis . - • - -•. • ' - basin
,' !'f`�,` c',1, to surface waters of North Carolina. Wastewater resulting
-»-_ ;. - from the dewatering operation will be continually
F returned to the new ash basin. The project is scheduled
" ,1 -:....04-1-:- ...:`' ; - to begin in the second quarter of 2000 and has a target
', , - , completion date of September 1, 2002 .
ii ` CIA.. 44..�r.
• l: ; � ::. In reviewing this proposal, I find that this
' ,,,_ project should have no adverse effect on the treatment
' +..: capability of the new ash settling basin or the
- . compliance requirements of NPDES Permit Number NC0000396 .
,, "`;l ',` The effective operation of the new ash settling basin
,r a i0T-7w, ; should be uninterrupted. As result, no additional
' fT . 1.. regulatory approval from this Division is needed for CP&L
W. y to proceed with this project . A copy of this letter will
' " '' ' be included with the NPDES permit file. ,,
-$1- FIFST
Vtr.0 . INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 28801-2414
r +' aa: �
PHONE [phone] FAX [phone]
i`'��'i AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1O% POST-CONSUMER PAPER

Page 2
March 9, 2000
Thank you for the opportunity to review this proposal .
Should you have questions or wish to discuss this letter in more
detail, please contact me; telephone (828) 251-6208 .
Y.I. tru ,
i i
j
M- . Haner
Environmental Chemist
I/
cc: David Goodrich
Forrest R. Westall 4
i

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'-,i- ' ,' .'14,.. Nef
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NORTH CAROLINA DEPARTMENT OF
R AlF7r ENVIRONMENT AND NATURAL RESOURCES
cDENRDIVISION OF WATER QUALITY
t; ASHEVILLE REGIONAL OFFICE
," WATER QUALITY SECTION
1.:5 ,;
y, fI _>. February 29, 2000 '- ,
` 14.1CS' HUat JR:
!T'.�yO€RNOR M r Jr
sec/ Mr. Winston T. Traylor o �.�
> V Manager
>_ HOLn1AN Carolina Power & Light Company I c
1 .. <,ETARY 200 CP&L Drive ~'
_s
Arden, North Carolina 28704 - r^
i l ci:‘..,,,L
K ..
,.4 - , ,,,, 4: . ._, , _
._:.„ ,,,: . .71.2„7„ ,4
` Ig Subject : Evaluation of Inno - • _Technology
c Relative to NPDES Permit 'o---&0000396
��y4 Amine Enhanced Reburn System & Urea
?'tL 3 ;,-,:' ,T4- M" ill '
�` > "` Based Non Catalytic Reduction Process
. ^' PW L. .r, . CP&L - Skyland Steam Electric Station
C4 .�: „-� " : Buncombe County, North Carolina your
l• i:S „'' � . .�
y x 3V�y,+*��R.
.tib K1 X4/- L E "..
'
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Dear Mr. Traylor:
2f i.:
This letter is in regards to your letter of November
12, 1999, concerning the proposed NOx emission reduction
+
: ti. process to be employed at your Skyland Steam Electric
!, Generating Station . The NOx reduction process will make
use of innovative technology called the Amine Enhanced
Fuel Lean Gas Reburn (AEFLGR) and urea-based selective
{ noncatalytic reduction (SNCR) process. Use of this process
will result in ammonia nitrogen being discharged to the
- ash settling basin with discharge under NPDES permit no.
F NC0000396 to the French Broad River. Worst case
. • i projection of unreacted ammonia would correlate to an
addition of 7 . 3 #/hour to ash settling basin which
-... -..'-' `--� converts to approximately 10 .2 m /1
pp y g per day of ammonia
nitrogen being added to the basin. The discharge from this
,... M s� w ash settling basin to the French Broad River should be
--,, " k `°.� ., „, reduced from this concentration.
ffi1 ', ,za: Review of this innovative process indicates that the
�-•� �' - projected worst case ammonia nitrogen discharge to the
French Broad River should have minimal impact on water
°', . w quality of the French Broad River. No additional
` , ` regulatory approval from this Division is needed for use
� _ of this process . A copy of this letter will be included
, '' with the NPDES permit file.
"`" .. FI'I cST
i* uk •'YPKA'ai FN At.".RIt..
.111.111.3111
k (�.KK�VYy _�
1�'�''~Yr R ,n,�yry. i. INTERCHANGE BUILDING, 58 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 28801-2414
' b ' ' �*w p PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST-CONSUMER PAPER

Page 2
February 29, 2000
Thank you for the opportunity to review this proposal .
Should you have questions or wish to discuss this letter in more
detail, please contact me; telephone (828) 251-6208 .
Yo s truly,
/
-� . aner
En ironmental Chemist
cc: David Goodrich
Forrest R. Westall

State of North Carolina
. • Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary NCDENR
Kerr T. Stevens, Director
August 17, 1999
Mr. Winston T. Traylor, Plant Manager
Carolina Powerd`?Light Company
Asheville Plant
200 CP?L Drive
Arden, North Carolina 28704
Subject: Site Drainage Concurrence
Permit No. NC0000396
Asheville Steam Electric Plant
Buncombe County
Dear Mr. Traylor:
This letter is in response to your correspondence, received August 4, 1999. regarding site drainage
modifications at the above referenced facility.
Based on information presented to Division staff in a July 7, 1999 meeting with Fred Holt, Joanie
Cooke, and Louise England of CP&L's Environmental Services Section, the Division concurs that no further
regulatory approvals are necessary to proceed with the proposed addition to the site drainage system. The
proposed work is not within the scope of the Authorization to Construct process and no further permit
modifications are necessary. The Water Quality Section of the Asheville Regional Office should be contacted
upon completion of all work associated with this project. It is the Division's expectation that CP 2L staff will
exercise care to minimize impacts associated with this site work.
If you have any questions concerning this matter, please contact Mr. Mark McIntire at telephone
number [phone]. extension 553.
Sincerely,
•
CCl/David A. Goodrich
NPDES Supervisor
Cc: Central Files
Asheville Regional Office /Water Quality Section
NPDES Unit Files
1617 Mail Service Center. Raleigh. North Carolina 27699-1617-Telephone [phone] FAX[phone]
An Equal Opportunity Affirmative Action Employer- 50% Recycled / 10% Post-consumer paper

•
CP&L
z.vismemmenosii
RtiEOW
Carolina Power& Light Company
Asheville Plant
200 CP&L Drive JUL 3 0 1999 ._i
Arden, NC 28704
DENR -WATER OUAUTn►1 2 9 1999
POINT SOURCE BRAN
File: 12520A
Mr.David Goodrich
North Carolina Department of Environment and Natural Resources
Division of Water Quality
PO Box 29535
Raleigh,North Carolina 27626
Subject: Carolina Power&Light
Asheville Steam Electric Plant
NPDES Permit No.N .:i 11 9. 2IY►^ 4. (2
Unit 4 modified site it • • -
Dear Mr.Goodrich:
By letters of August 6 and October 22, 1998,and April 6, 1999,Carolina Power&Light Company(CP&L)
submitted certain information to the Division of Water Quality(DWQ)to update and amend the current NPDES
application to reflect the addition of storm water and other water associated with the construction and operation
of a proposed combustion turbine(CT)generator project and to request an authorization to construct(ATC)for
certain treatment and conveyance systems associated with the CT project.With the addition of the second CT
unit as referenced in the October 22, 1998 and April 6, 1999 submittals,CP&L is planning on an addition to the
site drainage plan. This addition will consist of miscellaneous drain piping from the unit,two catch basins,and
approximately 250 feet of 15 inch and 18 inch reinforced concrete drain line which will tie into existing
conveyances.These additions will result in only an expansion of the conveyance system piping within the
project site and will not result in any volumes or sources of water additional to those presented in the August 6,
1998 and April 6, 1999 submittals.
This project was discussed in a July 7, 1999 meeting among Mark McIntire and Tom Belnick of your unit and
Fred Holt,Joanie Cooke and Louise England of CP&L's Environmental Services Section.
Construction of these additions will not disrupt the operation of the ash pond which will provide treatment for
water conveyed by these additions.
By this letter CP&L is seeking your concurrence that no further regulatory approvals are necessary to proceed
with this addition to the site drainage system.
We appreciate your expeditious attention to these matters and if there are any questions,please contact Fred Holt
at(919)362-3558 or Garry Whisnant at(828)687-5210.

• .•
•
1 •
Sincerely,
; fr4Q
Winston T.Traylor
Manager-Asheville Plant
c: DWQ-Max Hauer,Asheville Regional Office
DWQ-Mark Mclntire
DWQ-Tom Belnick
Louise England
Fred Holt
Garry Whisnant

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I •
•
CP&L
Carolina Power& Light Company
Asheville Plant
200 CP&L Drive
Arden, NC 28704
October 5, 2000
Mr. Max Haner
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801 (; —I
)
Subject: Asheville Steam Electric Plant "9111rth OCT 1 0 2000
NPDES Permit No. NC0000396
Ash Pond
DBE( - WATER QUALITY
Dear Mr. Haner: POINT SOURCE BRANCH
As per the October 4, 2000, conversation between you and Louise England, CP&L's Asheville
Plant has observed that the Total Suspended Solids (TSS) results for the ash pond effluent
(Outfall 002) are increasing. In an effort to address the TSS issues, plant personnel will be
relocating the ash sluice lines in an effort to maximize the residence time in the ash pond.
In addition, a request has been made of the NPDES permitting unit to allow the Asheville Plant
to the increase the height of the ash pond weir, which would also increase the residence time of
the ash pond. Due to the increase in water level in the ash pond, a force main that discharges
water from the Combustion Turbine site into the ash pond would also need to be extended
approximately 6 feet at a 45 degree angle to allow the end of the discharge pipe to be above the
ash pond water level. This request was made via email to Susan Wilson by Louise England on
October 5, 2000.
If any further information is needed please contact Ms. Louise England at [phone].
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.
Sincerely,
- 9��^
W. T. Tra
Plant Manager–Asheville Plant

I ..
• I
' g '
Cc: NPDES Unit
• r. North Carolina Department of Environment and Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

RE:Asheville Plant Ash Pond
Ce e t. 64(L
f
Subject: RE: Asheville Plant Ash Pond
Date:Thu, 5 Oct 2000 09:41:31 -0400
From: "England,Louise" <[e-mail]
a To: 'Susan Wilson' <[e-mail]>
v
Susan,
I wanted to let you know that I spoke with Max Haner of the Asheville
Regional Office yesterday (October 4, 2000) about increasing the height of
the ash pond over/under weir and extending the force main. Mr. Haner saw no
problems with Asheville Plant making these changes.
Thanks for your quick response.
Louise England
Original Message
From: Susan Wilson [mailto:[e-mail]]
Sent: Thursday, October 05, 2000 8:53 AM
To: England, Louise
Cc: '[e-mail]'
Subject: Re: Asheville Plant Ash Pond
Louise,
The NPDES Unit/ Water Quality Section (contingent on the AROs concurrence)
can
see no reason that this project needs an Authorization to Construct permit
from
this office. As always with any construction activities, all NPDES permit
limits must be maintained.
"England, Louise" wrote:
> Susan,
> The Asheville Steam Electric Plant (NPDES Permit No. NC0000396) would like
> to increase the height of its weir to an elevation of 2162 feet. The
> original design documents (- 1980) listed the design maximum elevation of
> the weir as 2160 feet. The design elevation of the ash pond dike is 2165
> feet. Currently the elevation of the weir is - 2158.5 feet. In 1999 Law
> Engineering performed a dam stability analysis of the ash pond dike which
> considered stability, seepage, and storm storage. This analysis found
that
> the design maximum elevation of the weir was 2162 feet which would provide
3
> feet storage needed for a design storm. We would like to increase the
> elevation of the weir to 2162 feet.
> In addition, a forced main which discharges water from the Combustion
> Turbine site into the ash pond would need to be extended by 6 feet at a 45
> degree angle to ensure that the pipe would remain above the increased
water
> level in the ash pond. This increase in pipe length will not have any
> effect on the amount of treatment the discharge from the CT site receives.
> Asheville Plant is interested in performing this work next week. I would
> appreciate it if you could respond to these requests by Friday October 6,
> 2000. Please give me a call with any questions.
> Thanks,
> Louise England
> (919) 362-3522
1 of 1 10/5/00 9:46 AM

Re:Asheville Plant
f •
Subject: Re: Asheville Plant
•
Date: Mon, 22 Jan 2001.14:39:35 -0500
• From:Tom Belnick<[e-mail]>
To: "England,Louise" <[e-mail]>
Louise- I don't see a problem with this. No permit is needed to raise the
weir.
"England, Louise" wrote:
> On October 5, 2000, I requested that Asheville Plant be allowed to raise
> their ash pond discharge weir up to 2162 feet. You were away from the
> office so I made the request of Susan Wilson. With DWQ's approval the
> height extension was completed. Unfortunately I specified that the design
> maximum elevation was 2162 feet. Upon further review of a 1999 Law
> Engineering dam stability analysis, it was found that the actual design
> maximum elevation is 2163 feet. Therefore the Asheville Steam Electric
> Plant (NPDES Permit No. NC0000396) would like to increase the height of its
> ash pond discharge weir to an elevation of 2163 feet. The design elevation
> of the ash pond dike is 2165 feet. Raising the weir from 2162 to 2163 feet
> would still provide 2 feet storage needed for a design storm. Plant
> personnel would like to begin the work to raise the height of the weir on
> Wednesday, January 24th. Thanks for your time.
> Louise England
> Carolina Power & Light
> Environmental Services Section
> (919) 362-3522
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: (919) 733-5083 ext. 543
Fax: (919) 733-0719
l of 1 1/22/01 2:39 PM