HomeMy WebLinkAboutNC0001422_Issuance of Permit_20061214OF W ArF9
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Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
December 14, 2006
Mr. Harry Sideris, Plant Manager
Carolina Power and Light d /b /a/ Progress Energy Carolinas, Inc.
Sutton Steam Plant
801 Sutton Steam Plant Road
Wilmington, North Carolina 28401
Subject: Issuance of NPDES Permit
Permit NC0001422
L.V. Sutton Electric Plant
New Hanover County
Dear Mr. Sideris:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. 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 U.S. Environmental Protection Agency dated May 9, 1994 (or as
subsequently amended).
This final permit includes the following major changes from the draft permit sent to you on
October 11, 2006.
• Monitoring for TN and TP has been increased to Monthly for Outfall 001 in response to EPA
comment and to be consistent with the new Cape Fear Permitting Strategy. The Division cannot
grant your request to reduce monitoring to Quarterly. This segment of the Cape Fear River is
impaired and additional monitoring is necessary to support water quality modeling efforts within the
Cape Fear River Basin.
• Monthly monitoring for DO has been added in response to EPA's comment and to evaluate the
impact of the facility's discharge on the receiving stream. The Division cannot grant your request to
remove this monitoring from the permit. This segment of Cape Fear River is impaired due to low
DO concentrations and the Division has to evaluate the impact of individual dischargers. In
addition, the DO analysis is very simple, quick, and inexpensive.
• Selenium Monitoring for Outfall 004 has been reduced to Quarterly in response to your request and
to be consistent with the requirements for Outfall 002.
• The following text was added to Section A. (12) to reflect new requirements of the Environmental
Sciences Section: "Fish tissue monitoring will only be completed if the ash pond discharges to the
river for 120 days in a calendar year ". The Division will also allow you to submit fish monitoring
data 4 month after the calendar year in which the samples are taken.
• Groundwater monitoring wells 17, 18, and 19 were added to the list of monitoring wells in response
to your request.
N. C. Division of Water Quality I NPDES Unit Phone: (919) 733 -5083
1617 Mail Service Center, Raleigh, NC 27699 -1617 fax: (919) 733 -0719
Internet: h2o.enr.state.nc.us DENR Customer Service Center: 1 800 623 -7748
r
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Carolina Power & Light d/b/a/Progress Energy Carolinas, Inc
is hereby authorized to:
1. Continue to discharge cooling pond blowdown, recirculated cooling
water, noncontact cooling water, and treated wastewater from internal
outfalls 002, 003, and 004 (via external Outfall 001); coal pile runoff,
low volume wastes, ash sluice water (including wastewater generated
from the Rotomix system), and stormwater runoff ( Outfall 002);
chemical metal cleaning waste ( Outfall 003); and ash sluice water
(including wastewater generated from the Rotomix system), coal pile
runoff, low volume wastes, and stormwater runoff ( Outfall 004) at a
facility located at Sutton Steam Electric Plant, 801 Sutton Steam
Plant Road, Wilmington, New Hanover County, and
2. Discharge wastewater (via Outfall 001) from said treatment works at
the location specified on the attached map into the Cape Fear River,
classified C -Swamp waters in the Cape Fear River Basin.
Permit NC0001422
a
't
NORTH CAR MA
Sutton Lake
New
Ash Pond
Outfall
r 002
Old
Ash Pond
Discharge
-Canal
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (002)
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to the Cooling Pond from Outfall 002 (Old Ash Pond - coal pile
runoff, low volume wastes, ash sluice water, chemical metal cleaning wastes ( Outfall 003), and
stormwater runoff). Such discharges shall be limited and monitored by the Permittee as specified
below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Measurement
I Sample Type
Sample
Average
Maximum
Frequency
Monthly
Daily
Measurement
Sample
Sample Location
Pump Logs or
Average
Maximum
Frequency
Type
similar
Flow
1 mg/ L
1 mg/ L
Weekly
Pump Logs
Effluent
1 mg/ L
1 mg/ L
2/ Month
Grab
or similar
Oil and Grease
15 mg /L
20 mg /L
Monthly
Grab
Effluent
Total Suspended
30 mg/ L
100 mg/ L
Monthly
Grab
Effluent
Solids
Total Arsenic
NL (µg/ L)
Quarterly
Grab
Effluent
Total Selenium
NL (µg/ L)
Quarterly
Grab
Effluent
Ammonia - Nitrogen'
Weekly
Grab
Effluent
1. Monitoring is only required when ash sluicing occurs.
Samples taken in compliance with the monitoring requirements specified above shall be taken prior to
mixing with other waste streams.
A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (003)
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to the Old Ash Pond from Outfall 003 (Chemical metal cleaning
wastes). Such discharges shall be limited and monitored by the Permittee as specified below *:
EFFLUENT
CHARACTERISTICS
Flow
Total Copper
Total Iron
LIMITS
MONITORING REQUIREMENTS
Monthly
I Daily
Measurement
I Sample Type
Sample
Average
Maximum
Frequency
Location
Weekly
Pump Logs or
Effluent
similar
1 mg/ L
1 mg/ L
2/ Month
Grab
Effluent
1 mg/ L
1 mg/ L
2/ Month
Grab
Effluent
* Effluent requirements for Outfall 003 have been suspended due to the changes in disposal method
for chemical metal cleaning wastes. If the plant needs to discharge these wastes through Outfall 003,
you shall notify the Division 1 week in advance of such discharge. Upon commencement of the
discharge, all the requirements for this outfall become active. Following the discharge of metal cleaning
waste, effluent requirements
Permit NC0001422
.t
Y
A. (4) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (004)
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to the Cooling Pond and /or to Outfall 001 from Outfall 004 (New
Ash Pond - ash sluice water, coal pile runoff, low volume wastes, chemical metal cleaning wastes
( Outfall 003), and stormwater runoff). Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly
Daily
Measurement
I Sample
Sample
Average
Maximum
Frequency
Type
Location
Flow
Weekly
Pump Logs
Effluent
or similar
Oil and Grease
15 mg /L
20 mg /L
Monthly
Grab
Effluent
Total Suspended
30 mg /L
100 mg /L
Monthly
Grab
Effluent
Solids
Total Arsenic
NL (µg /L)
Quarterly
Grab
Effluent
Total Selenium
NL (µg/ L)
Quarterly
Grab
Effluent
Ammonia- Nitrogen
Weekly
Grab
Effluent
Samples taken in compliance with the monitoring requirements specified above shall be taken prior to
mixing with other waste streams.
A. (5) ACUTE TOXICITY MONITORING (QRTRLY)
The permittee shall conduct acute toxicity tests on a guarterlq basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/ Fail Methodology For Determining Acute Toxicity
In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions). The monitoring shall
be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test. The effluent
concentration at which there may be at no time significant acute mortality is 90% (defined as
treatment two in the procedure document). Effluent samples for self - monitoring purposes must be
obtained during representative effluent discharge below all waste treatment. The tests will be
performed during the months of February, May, August and November.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter code
TGE6C. Additionally, DWQ Form AT -2 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699 -1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/ physical measurements
performed in association with the toxicity tests, as well as all dose /response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the
report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to
the Environmental Sciences Section at the address cited above.
Permit NC0001422
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly ,
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a single test is passed. Upon passing,
this monthly test requirement will revert to quarterly in the months specified above.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may
be re- opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow -up testing to be completed no later than the last day of the month following
the month of the initial monitoring.
A. (6) GROUNDWATER MONITORING
The permittee shall, upon written notice from the Director of the Division of Water Quality, conduct
groundwater monitoring as may be required to determine the compliance of this NPDES permitted
facility with the current groundwater Standards.
1. Monitor wells (2C, 413; 5C, 6C, 7C, 8, 9, 10, 11, 12, 17, 18, and 19) shall be sampled every March
for the following parameters: Water Levels, pH, Arsenic, Iron, Total Dissolved Solids, Chlorides and
Selenium.
The measurement of water levels must be made prior to sampling for the remaining parameters. The
depth to water in each well shall be measured from the surveyed point on the top of the casing.
The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the
relative elevation of the measuring point for each monitoring well.
The results of the sampling and analyses shall be sent to NC DENR / DWQ / Groundwater Section,
Permits Group, P.O. Box 29578 Raleigh, N.C. 27626 -0578 on form GW -59 [Compliance Monitoring
Report Form], in sufficient time that the forms will have been received by the last day of April.
2. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
3. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC 2L,
Groundwater Classifications and Standards. The Compliance Boundary for the disposal system
constructed prior to December 31, 1983 is established at either (1) 500 feet from the waste disposal
area, or (2) at the property boundary, whichever is closest to the waste disposal area. An exceedence
of Groundwater Quality Standards at or beyond the Compliance Boundary is subject to immediate
remediation action in addition to the penalty provisions applicable under General Statute 143 -
215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the disposal systems
midway between the Compliance Boundary and the perimeter of the waste disposal area. Any
exceedence of standards at the Review Boundary shall require remediation action on the part of the
permittee.
A. (7) DIKE INTEGRITY
The permittee shall check the dike areas for leaks by a visible inspection and shall report any seepage
detected.
Permit NC0001422
A. (8) BEST MANAGEMENT PRACTICES PLAN
The Permittee shall continue to implement a Best Management Practices (BMP) Plan to control the
discharge of oils and the hazardous and toxic substances listed in 40 CFR, Part 117 and Tables II and
III of Appendix D to 40 CFR, Part 122, and shall maintain the Plan at the plant site and shall be
available for inspection by EPA and DWQ personnel
A. (9) INTAKE SCREEN BACKWASH
Continued intake screen backwash discharge is permitted without limitations or monitoring
requirements-
A. (1 O) NO DISCHARGE OF PCBs
As specified by 40 CFR 423.13 (a), there shall be no discharge of polychlorinated biphenyl compounds
such as those commonly used for transformer fluid.
A. (11) BIOCIDE CONDITION
The permittee shall obtain authorization from the Division of Water Quality prior to utilizing any
biocide in the cooling water. The Permittee shall notify the Director in writing not later than ninety
(90) days prior to instituting use of any additional biocide used in treatment system which may be
toxic to aquatic life other than those previously reported to the Division of Water Quality. Such
notification shall include completion of Biocide Worksheet Form 101 and a map locating the discharge
point and receiving stream. Concentrations of chromium, copper, or zinc added to biocides shall not
exceed applicable water quality standards or action levels in the receiving stream, as determined by
calculations from the Biocide Worksheet Form 101 with Supplemental Metals Analysis worksheet.
A. (12) FISH STUDY AND MONITORING
The baseline study for the fish monitoring has been completed and approved (1999). This was
required based on the re- routing of Outfall 004 to the Cape Fear River. Fish tissue analysis will be
performed annually (after Outfall 004 is discharging to the Cape Fear River). Fish tissue monitoring
will only be completed if the ash pond discharges to the river for 120 days in a calendar year. All
contaminant data collected as part of this monitoring requirement will be reported within 4 months
after the calendar year in which the samples are taken. Should fish tissue levels indicate
concentrations of concern, the Division of Water Quality may require additional collection of
environmental data.
This monitoring plan is an enforceable part of the NPDES permit.
Permit NC0001422
NPDES Renewal i
Page 1 ;
r �
� r
4' � Progress Energy
File: Sutton 12520 -B -01
November 9, 2006
Certified Mail # 7005 3110 0001 6185 7544
NCDENR- NPDES Unit
1617 Mail Services Center
Raleigh, NC 27699
NOV 1 4 2006
DENR - WATER QUALI*
POINT SOURCE BRANCH
RE: Sutton Electric Plant
National Pollutant Discharge Elimination System Permit No NCO0O1422
Comments to Draft NPDES Permit
Dear Dr. Sergei Chernikov:
Attached are our comments on the subject draft NPDES permit. We appreciate the opportunity
to comment. If you have any questions concerning this matter, please contact Mr. Steve Cahoon,
Environmental Specialist in our Environmental Services Section, at (919) 546 -7457.
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 I 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.
Progress Energy Carolinas, Inc.
Sutton Steam Plant
801 Sutton Steam Plant Road
Wilmington, NC 28401
Respectfully yours,
Harry Sideris
Manager - Sutton Plant
- Letter to Dr. Sergei Chemikov, Ph.D.
Dated: 11/9/2006, Page 1 of 2
SUTTON ELECTRIC PLANT
DRAFT NPDES PERMIT COMMENTS
Cover Page of Permit
,1 • The Company should be identified as: Carolina Power and Light d/b /a Progress Energy
Carolinas, Inc. instead of Progress Energy Carolinas, Inc.
�,4- • The Plant should be referred to as the L. V. Sutton Electric Plant
Supplement to Permit Cover Sheet
• The Supplement to Permit Cover sheet should read ": Carolina Power and Light d/b /a
Progress Energy Carolinas, Inc." is hereby authorized to:
Section A. Final Limitations and Controls
1. Effluent Limitations and Monitoring Requirements ( Outfall 001)
• The plant requests that the monitoring frequency for Total Arsenic be reduced from the
proposed weekly to 2 /month with a monthly average limit of 50ug/l for a period of 1
year before the limit becomes effective (compliance period). This should allow the
facility to collect enough data to evaluate its compliance options.
• The plant requests that the monitoring frequency for nitrogen and phosphorus be reduced
from monthly to quarterly. In the email from the state the Division expressed EPA's
concern for additional nutrient loading in the river due to the addition of the Rotamix
system. Since the system has been in place we have measured ammonia/nitrogen at the
ash pond discharge. We have 20 data points (see attached table) indicating that 75% of
the samples are less than detect for nitrogen, 20% are 0.1 mg/1, and the other 5% are 0.2
mg/l. In May of 2006, during the operation of the Rotamix system, values for nitrogen
F\ and phosphorus were taken at Outfall 001; the nitrogen result was 1.2 mg/l and the
phosphorus result was 0.04 mg/l, both similar results to our January 2005 sample which
was taken when the Rotamix system had not been installed. Therefore, based on the
ammonia sampling from the ash pond discharge and the annual nitrogen and phosphorus
sampling at Outfall 001,the Sutton plant does not agree with the EPA that the addition of
a Rotamix system causes the need for increased sampling.
• The plant requests that the EPA - recommended monthly dissolved oxygen monitoring not
be added to the final permit. Although a section of the Cape Fear River is included on the
North Carolina 303(d) List —DRAFT 2006 (AU 18 -(71)) based on low dissolved oxygen,
the discharge point for Outfall 001 is upstream of this impaired stretch. Data collected as
part of the Lower Cape Fear River Program at the Cape Fear River water quality
sampling points closest to, above, and below the Sutton Electric Plant outfall (sampling
locations DWQ #B9850100, DWQ# B9910000, and B9921000) indicated dissolved
Letter to Dr. Sergei Chemikov, Ph.D.
Dated: 11/9/2006, Page 2 of 2
oxygen concentrations in the "Good" quality status (Mallin, M. A., et al. 2006.,
Environmental Assessment of the Lower Cape Fear River System, 2005. University of
North Carolina Wilmington, CMS Report No. 06 -02. Page 64 and Table 3.4.1).
Furthermore, data sampled by Progress Energy indicate that the dissolved oxygen
concentrations in the cooling pond (which contributes the largest portion of the
discharge) has been consistently greater than the DO from the river water intake
J (Progress Energy Carolinas. Sutton Electric Plant Environmental Monitoring Reports-
2002-2005 data listing attached). In addition, the water released from the discharge point
' is extremely turbulent and collection of a valid DO sample would be impossible based on
Standard Methods procedures.
• The plant requests that the monitoring frequency for toxicity be changed from monthly to
quarterly as stated in the cover letter.
2. Effluent Limitations and Monitoring Requirements ( Outfall 003)
• The plant requests a sentence to be added to the asterisked paragraph below the
monitoring requirements that reads as follows: Following the discharge of metal cleaning
waste from Outfall 003, the requirements of this outfall are re- suspended.
3. Effluent Limitations and Monitoring Requirements ( Outfall 004)
• The plant requests a reduction in the selenium monitoring from monthly to quarterly to be
consistent with the requirements of Outfall 002.
4. Groundwater Monitoring
• Groundwater monitoring wells 17, 18 and 19 should be added to the list of monitoring
u wells to be sampled every March for those parameters listed.
5. Fish Tissue Monitoring
• The plant requests that data be submitted 4 months after the calendar year in which the
samples are taken. Our contract lab runs the analysis in batch mode and generally does
not get enough samples from us to run them when they are received. They preserve the
samples and run them with samples from other facilities. This is causing an issue with
getting reports out to DWQ in a timely manner.
• Also Progress Energy is in receipt of a letter dated June 18, 2004 from the Division
stating that fish tissue monitoring will only be completed if the ash pond discharges to the
river for 120 days in a calendar year. The plant requests some permitting language in
Section A. (12) to reflect this interpretation.
imap:// sergei .chernikov%40dwq.denr.ncmail .net @cxm.ncmail.net:143 /...
Subject: Re: draft permit for Sutton SE
From: Shell.Karrie- Jo @epamail.epa.gov
Date: Mon, 23 Oct 2006 14:10:04 -0400
To: Sergei Chernikov <sergei.chernikov @ ncmail.net>
CC: Hyatt.Marshall @epamail.epa.gov, Childress .Roosevelt @epamail.epa.gov
Yes, what you proposed is fine.
Karrie -Jo Robinson - Shell, P.E.
Sergei Chernikov
<sergei.cherniko
v@ncmail.net> To
Karrie -Jo Shell /R4 /USEPA /US @EPA
10/23/2006 02:07 cc
PM Marshall Hyatt /R4 /USEPA /US @EPA
Subject
Re: draft permit for Sutton SE
Karrie -Jo,
I think that your suggestions are reasonable. We have recently prepared
a new permitting strategy for Cape Fear dischargers for POTWs and other
domestic dischargers. It probably makes sense to apply the same
requirements to Sutton to be consistent. In accordance with this
strategy, TN and TP monthly monitoring is required for permittees with
flow > 1.o MGD. I would also add monthly DO monitoring. Please let me
know if you agree with my suggestion.
Thank you!
Sergei
Shell.Karrie- Jo@epamail.epa.gov wrote:
Sergei,
The Cape Fear River is listed for low D.O., and there are now possibly
two constituents in the plant's effluent that may impact the river's
D.O. levels - temperature and nutrients.
I think the permit should require the plant to monitor for D.O. at the
point of discharge. Also, I think the plant should be required to
monitor for nutrients more frequently (bi- monthly) for at least the
first year in order to quantify the•amount of nitrogen containing
compounds being discharged as a result of the Rotamix Urea injection
system and the ROFA system, which are air pollution control systems.
Allowing the plant to only monitor for Total Nitrogen once per year
does
not provide enough data to determine if the new air pollution control
devices (installed in 2005) are having an impact on the water
discharges.
I of 2 12/12/200611:31 AM
imap:// sergei. chernikov% 4Odwq.denr.ncmail.Det @cms.ncmail ner.143 /...
Karrie -Jo Robinson - Shell, P.E.
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699 -1617
phone: 919- 733 -5083 ext. 594
fax: 919- 733 -0719
2 of Z 12/12/2006 11:31 AM
imap: / /sergei.chernikov%40dwq. derv. ncmad.net@cros.ncmail.net:143 /.-
Subject: Draft Permit Review
From: John Giorgino <john.giorgino@ncmail.net>
Date: Wed, 18 Oct 2006 09:16:04 -0400
To: sergei chemikov <sergei.chemikov@ncmail.net>
Sergei, I have reviewed the following and have no comments:
KC0001422 Sutton Steam Plant
Thanks for forwarding it.
-John
John Giorgino
Environmental Biologist
North Carolina Division of Water Quality
Environmental Sciences Section
Aquatic Toxicology Unit
Mailing Address:
1621 MSC
Raleigh, NC 27699 -1621
Office: 919 733 -2136
Fax: 919 733 -9959
1 of 1 10/18/2006 9:17 AM
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Phone:
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Class:
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Charges:
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Account:
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Start
10/14/2006
List Price:
$ 198.12
Name:
Bryant, Carolyn
Stop
10/14/2006
Pay-
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taken By:
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Columns:
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This is a final proof. If any in ormation is incorrect, please contact your sales representative prior to the deadline of the first In-
;ertion. Otherwise your order Is accepted as having been approved.
To: NPDES Permitting Unit
Surface Water Protection Section
Attention: Sergei Chernikov
Date: 11/06/2006
NPDES STAFF REPORT AND RECOMMEND. 2
County: New Hanover V �n E i
Permit No. NC0001422
f NOV - 8 2006
PART I - GENERAL INFORMATION
i
DEtiR - WATER QUALITY
1. Facility and Address: pIaT
Facility- Progress Energy Carolinas, Inc.
Sutton Steam Plant
801 Sutton Steam Plant Road
Wilmington, NC 28401
Mailing: Mr. Harry Sideris, Plant Manager
Progress Energy Carolinas, Inc.
Sutton Steam Plant
801 Sutton Steam Plant Road
Wilmington, NC 28401
2. Date of Investigation: 04 /26/2006
3. Report Prepared by: Linda Willis
4. Persons Contacted and Telephone Number: Steve Cahoun (Sr. Env. Specialist) 919 -546-
7457, Kent Tyndall (Env. Specialist), Bruce Morefield (ORC), Isaac Alderman (Backup
ORC)
5. Directions to Site: Hwy 421 North to Sutton Steam Plant Road.
6. Discharge Point, List for all discharge points:
Latitude: 340 16'57" Longitude: 77° 59'20"
U.S.G.S. Quad No: S -52 U.S.G.S. Quad Name: Castle Hayne, NC
7. Topography (relationship to flood plain included): This site is approximately 20 feet
AMSL, with little change in elevation over the site.
8. Location of nearest dwelling: Approximately 0.5 mile.
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9. Receiving stream or affected surface waters: Cape Fear River
a. Classification: Class "C Swamp" Waters
b. River Basin and Subbasin No.: CPF 17 (03- 06 -17)
C. Describe receiving stream features and pertinent downstream uses: A tidal tributary to
the Cape Fear River uses secondary recreation includes fishing, boating and crabbing.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
a. Volume of wastewater to be permitted: up to 380 MGD for a duration of 1 -2 days
b. What is the current permitted flow limit? No flow specified.
Actual treatment capacity of the current facility? Not defined.
d. Date(s) and construction activities allowed by previous Authorizations to Construct
issued in the previous two years: None.
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities: Existing facilities consist of. Treatment system is settling,
precipitation, oxidation, neutralization and evaporation via west and south retention
ponds, old and new ash ponds and Sutton Lake (I 110 acre).
Plant Systems (source water from groundwater wells), fire system (source water from
intake structure) and Units 1 & 2 bearing cooling (source water from fire
system/groundwater wells) discharges via low volume waste sources to either the
concrete south or west retention basins to the Old Ash Pond for discharge via internal
outfall 002 to Sutton Lake for either recirculation to intake structure or discharge from
outfall 001.
Oily waste treatment through an oil water separator to the concrete south retention
basin to the old ash pond discharged through internal outfall 002 to Sutton Lake for
either recirculation to intake structure or discharge from outfall 001.
Yard drain discharge to concrete retention basins (south or west) to the Old Ash Pond
through internal outfall 002 to Sutton Lake for either recirculation to intake structure or
discharge from outfall 001.
Chemical metal cleaning wastewater from internal outfall 003 to the Old Ash Pond for
discharge through internal outfall 002, or the New Ash Pond for discharge through
internal outfall 004 to Sutton Lake for either recirculation to intake structure, or
discharge from outfall 001. Outfall 004 may also discharge directly to Outfall 001.
Units 1, 2 & 3 Ash Sluice (fly ash and bottom ash) discharges (source water from
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intake structure) through either the Old Ash Pond, via internal outfall 002, or the New
Ash Pond, through internal outfall 004 to Sutton Lake. Internal outfall 004 can directly
discharge via outfall 001 without discharging directly to Sutton Lake for either
recirculation to intake structure or discharge from outfall 001.
Units 1, 2 & 3 Condensers (source water from intake structure) and non - contact cooling
water (source water from intake structure) from heat exchangers discharge to Sutton
Lake for either recirculation to intake structure or discharge from outfall 001.
Units 1, 2 & 3 circulating water pumps (source water from intake structure) discharges
to the intake structure (source water from Sutton lake) which provides source water for
screen wash, Units 1, 2, and 3 Ash Sluice, Units 1, 2, & 3 condensers, non contact
cooling water, fire system water and Units 1 & 2 bearing cooling water.
f. Please provide a description of proposed wastewater treatment facilities:
Primarily settling. Chemical metal cleaning waste is not an ongoing process at Sutton
Steam Plant.
g. Possible toxic impacts to surface waters: metals that may be found in ash from coal
burning such as copper, selenium, arsenic, cadmium, lead, mercury, silver, zinc, and
chromium.
h. Pretreatment Program (POTWs only): Not needed.
2. Residuals handling and utilization/disposal scheme: The product separated within the oil
water separator is burned. Fly and bottom ash are permitted for reuse. There is no other
wastewater treatment residual generated for off site disposal.
3. The compliance history for this facility within the past permit cycle is as follows:
Facility has met all permit limitations throughout the entire past permit cycle.
4. Treatment plant classification: Class 2
5. SIC Code(s): 4911
PART III -OTHER PERTINENT INFORMATION
Is this facility being constructed with Construction Grant Funds or are any public monies
(municipals only) involved? N/A
2. Special monitoring or limitations (including toxicity) requests: None
3. Important SOC, JOC or Compliance Schedule dates: N/A
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4. Alternative Analysis Evaluation: Not done.
5. Other Special Items: None
PART IV - EVALUATION AND RECOMMENDATIONS
Evaluation:
Sutton Steam Plant is a steam electric generating facility consisting of 3 coal fired units with
a nominal net capacity of 613 MWe and three internal combustion turbines with a nominal
net capacity of 64 MWe. The plant has an 1110 -acre off stream cooling pond on the east side
of the Cape Fear River approximately 10 river miles upstream of Wilmington. Water is
withdrawn from the Cape Fear River as required to make up evaporative, seepage, and
blowdown losses from the cooling pond.
Chemical constituents contained in their discharge will be comprised of the naturally
occurring chemical quality and quantity of the intake water and will also have chemical
constituents of such quality associated with similar discharges for fossil generating facilities
of this size, type and in this geographical location.
There are a total of 4 outfalls identified (001 through 004). Each source of wastewater is
fully described in Section H. e. A review of discharge monitoring reports for the previous
permit cycle indicate that discharge occurs to maintain appropriate levels in Sutton Lake and
to some extent control the pollutant concentrations in the settling basins. A review of the
discharge flow from 2002 to 2006 indicates monthly flow averages that range from zero to
215 MGD. Some years indicated Sutton Steam Plant had as few as 4 out of 12 months of
discharges from outfall 001 to all 12 months indicating flow discharges (2004 and 2005). A
review of the compliance history for the facility shows no violations from the permit cycle
2002 through present time. From 2003 to the present, thirty-nine 24 hr. static acute toxicity
tests using Fathead Minnow have been conducted on the Outfall 001 wastewater discharge.
All 39 tests resulted in an average survival rate of greater than 99 %.
125.94(a)(1)(i) of the Phase H 316(b) regulation allows a determination of best technology
available for minimizing adverse impact for a facility that demonstrates they have reduced
their flow commensurate with a closed -cycle recirculating system. The facility demonstrated
a realized reduction in flow of 92% comparing actual withdrawals to potential withdrawals
for cooling water. The facility claims they are deemed compliant with 316(b) of the Clean
Water Act.
No calculations were included in the permit application to show the amount of storage
capacity within the Old and New Ash ponds.
Recommendations:
PEC requested reduction of weekly TRC monitoring to monthly at Outfall 001. WiRO is not
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in favor of reducing the monitoring since a mixture of chlorine and bromine are fed into the
intake structure approximately one hour once or twice per week. Although the residual
oxidant concentration is maintained at or below 0.2 ppm in Outfall 001, failure of the
delivery system to control concentrations could occur and monthly monitoring would be too
infrequent to catch the problem to prevent environmental impact.
PEC request: Reduction of monitoring frequency for copper from monthly to quarterly at
Outfall 001. WiRO recommends maintaining monitoring frequency. The action level for
copper in class C waters is 7 µg/L. According to PEC, Outfall 001 copper levels have
averaged 6.9 µg/L.
PEC request: Reduction of monitoring frequency for selenium from weekly to monthly at
Outfall 001. Metals analysis provided with the permit application indicated a selenium
concentration of 32 pg/L. Permit limitation for outfall 001 is 56 gg/L. PEC's application
indicates 82 samples were analyzed for selenium and the average concentration was 11.9
µg/L. The results of the tests were not provided with the permit application nor were the
frequency of sampling. WiRO recommends no reduction in frequency.
PEC request: Reduction of arsenic from monthly to quarterly at Outfall 001. PEC states the
average arsenic discharge concentration at the outfall 001 is 11.8 pg/L over 27 sampling
events. Although there were no limits in the previous permit and frequency for arsenic
sampling was monthly, stream standards for arsenic for class C waters is 50 gg/L. PEC's
permit application indicated an arsenic concentration of 41 µg/L. WiRO supports the central
office's decision to include an arsenic limit for outfall 001 and impose a weekly monitoring
frequency.
PEC request: Reduce monitoring frequency for toxicity from monthly to quarterly at outfall
001. Should the permitting unit not reduce any monitoring frequencies for any metals and
include the arsenic limit/monitoring frequency in outfall 001, WiRO supports a reduction in
toxicity testing from monthly to quarterly. However should one quarterly test fail, the facility
should resume monthly toxicity monitoring.
PEC request: Reduce monitoring frequency for total suspended solids and oil and grease at
outfall 002 and outfall 004. PEC claims monthly monitoring should be sufficient to
demonstrate compliance with effluent limitations. WiRO has no objections to this request
considering the data provided by PEC indicating average TS S concentration of the discharge
for internal outfall 002 was 2.8 mg/L and 4.3 mg/L for internal outfall 004 from February
2003 to December 2005. Also oil and grease at the respective outfalls for the same time
period were 2.3 mg/L and 2.2 mg/L.
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y
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WiRO recommends reissuance of NPDES Permit NC0001422 in accordance with the Cape
Fear River Basinwide Permitting Strategy provided no significant adverse public comments
are received.
i ature o Report Preparer Date /
al 710
Water Quality Regional Supervisor Date
cc: WiRO NPDES Permit File Folder (RED) New Hanover Cnty NC0001422
Central Files
Linda Willis, WiRO
C