Loading...
HomeMy WebLinkAboutNC0001422_Issuance of Permit_20061214OF W ArF9 U� OG ,QUA r NCDENR —I 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 •10'I1 -O6 10:20am From -STAR NEWS 9103432229 T -682 P 01/01 F -839 otiu -New L. i.e• _ _ 1V Y,,l 1(!v, 1.INK.I nAI ..b NI( 1003 J:)JLM 37U1 SLracL . P.O. BOA 040 - VVlln.-M9QLu,1. NC 26102- nF3/10 Cl.ytolflc�l Pflury : 91() -3113 -2323 Cla:sr11tt0 r6x. 910 -3113 -2207 Order -._._ W0021602(19 Py(a __ 1,15 Rate: L9 Phone: (919)733 -5 )83 Class: 0001 Charges: $ 0 -00 Account: N7335083 Start 10/14/2006 List Price: $ 198.12 Name: Bryant, Carolyn Stop 10/14/2006 Pay- $ 0.00 Caller: Carolyn /fax!kjy Inser- 2 Balance: $ 198.12 taken By: 43 Columns: 1 Lines: 127 Schedule. 10/14 Ix, 10/14 lx, , , Sysi.m (NPOES) wowswaler Taken On: 10/11/2006 PUIIL.IL NUI ILk b.f NL.00014111 d.acbwp,ng to STATE OF NORTH CAROLINA the C.P. Few R.•er .n (no ENVIRONMENTAL MANAGE Copo Fear R,.w Basin C,4- VENT COMMISSIONNPOES rams, arsenic and solom,um ate UNIT wale( Quamv lim,ted This dli. 1617 MAIL SERVICE CENTER cherde may affect fuwrs 111110ce RALEIGH. NC 27090.1617 I,OnI In Intl 00rudn of the Cope NOTIFICATION OF INTENT TO Fear 111 901 n SSUE A NrOES WASTEWw TEII PERMIT On mo oJoi 01 Inorough sloli re, ,ow and oppucab0n of NC Don0r01 GIOIuto 1021 P„Ofo Iaw v2 -$00 7n0 Dthw fao,%t slondards an0 regulations. Irw Nbnh CarallnA knv ronmorltel Managomeni Comm,sston Qro. 01 to is310 a Nat venal Pal. r2 l, omcnerge Lhmnslron Sysi.m (NPOES) wowswaler dteche1 a permit to Ine Do(- ;lI d Oslo« anecll.e e5 00x1 from n16 Pubksn data of Ilya n011ce WnO.n comments reowdlno the peopolMl permit +nil be aU CeOted unla 30 days &flat Ina publtsn dole of INe notice NI comments re00wed prior to that date Ora cOn slowed In %h0 IIn(N dalerrnrnat,ons r jaramp tn0 propofod pf InhI Tno O,focfOf Oi 1110 Nl D,vIS10n Of Wator CVII may Ooclds 10 (1010 a 0uolic hearing for Ins propoaoo Parma 4"wo the D,vls,on r0. cm.e a /,Qn,oconl doproo of 0�bllc n10(0161 Copme of rbe waft p.fmll ena other support-no mfOrl..1,on on rile wed to 0elwmwel C&,Adl- 1-016 present 'n Ins OW Parma "to e.bilaole ,Pon (eQuaal ens Payment of the costs of repro. dVcly) Mail comments snolor reowlls rot ,nformol:On 10 Ins NC Division of Vva19( Ouslny of Via 000.0 90(9066 or Call Ms Cwolyn tlryun 19!4) 733 - '30x3 olsansion 3W or Ms Francoo CarWelmw (916) 733600], a.• tene,ofl 620 at the Point source 6renc.h PWese ,nowde the NPOES Parma n..mbsir (al- taCned) In env commun,cahon g Infoated potions met also ytsd fns 0 ,,dian of Weter 0.01 rtr al .112 N Seltsbury slfa&t_ Rola10h. NC 27604 -11x6 be- la0on Ina news of moo am and 600 pp n m revrsw Infof• m.hOn on Lk. Progross Enorgy . x01 button Gloom Plan, Hood. Waminglon. NC 20401 Now Honolor Co'nty ho■ appue0 (w renewal of rte NPOES drachwoe permit for Sutton E,eciric Plant ^M. Attention: OA�112_ � Li-i nJ Fax: Go �tA 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. 1 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 K 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 3 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 4 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. 5 y t 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