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HomeMy WebLinkAboutNC0003417_Update to Pending Renewal App 2015_20150316 4as DUKE H.F.Lee Energy Complex ENERGY® Duke Energy Progress PROGRESS 1199 Black Jack Church Road Goldsboro,NC 27530 March 11,2015 Mr. Jeff Poupart North Carolina Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Duke Energy Progress, Inc. RECEIVEDIDENR/DWR H.F. Lee Energy Complex Update to pending NPDES renewal application and MAR 16 2015 Submittal of chemical characterization of water for dewatering ash basin and EPA Form 2C data NC0003417 Water Quality Permitting Section Wayne County Dear Mr. Poupart: In response to the request from the North Carolina Division of Water Resources,please find attached a chemical characterization of the ash basin free water, ash basin interstitial water and water from the sites small chemical metal cleaning basin located adjacent to the ash basin is provided. The analysis conducted and reported herein is consistent with the information requested by NC DENR for other Duke Energy sites. This is submitted in support of potential upcoming dewatering activities that would be directed to outfall 001. The results of analysis on the chemical characterization of the ash basin free water, ash basin interstitial water and small triangular basin water are presented: 1.)without additional treatment beyond the treatment in the basin and 2.)after additional treatment using three different filter sizes. Because of the low water levels in these basins,Duke foresees dewatering activities involving the use of pumps and/or removal of sections of risers or stop logs to facilitate potential dewatering activities. Specific dewatering work plans will be developed to assure the work will be done safely and in compliance with all applicable requirements. These plans can be made available to you for review upon request. The following definitions may be useful as you consider these activities. Ash basin free water: Water in an ash basin located above the settled layer of ash. Ash basin free water has undergone treatment in the ash basin,has the same general characteristics as water discharged when the facility was active sluicing ash to the ash basin, is largely devoid of Total Suspended Solids and meets all applicable NPDES permit limits. Ash basin interstitial water: Water in an ash basin that is located within the pore space of accumulated wastewater sludge or slurry. Ash basin interstitial water must be removed from an ash basin by some means such as trenching,well points, etc. and would likely require additional treatment before being released to the environment. Mr. Jeff Poupart Update to HF Lee NPDES application March 11, 2015 Page 2 of 3 RECEIVED/DENRIDWR MAR 1 6 2015 Water Quality The process we envision for dewatering the ash basins is as follows: Permitting Section Ash basin free water will be removed from the primary basin via the use of pumps. Additional treatment of ash basin free water may be completed via chemical and/or physical processes prior to discharge through the secondary basin to Outfall 001. This treatment system may require the addition of a coagulant and/or flocculent to enhance solids removal. Interstitial water removal will be accomplished through rim ditching,trenching, and pumping. Additional treatment of ash basin interstitial water may be completed via chemical and/or physical processes prior to discharge through the secondary basin to Outfall 001. This treatment system may require the addition of a coagulant and/or flocculent to enhance solids removal. Compliance monitoring required by the NPDES Permit as well as robust process control monitoring will be performed. Process control monitoring and additional safeguards and controls to be employed include: All pumps will be controlled to stop at a user-defined level set point which is set manually every 7 days. The maximum free water drawdown rate will be one foot over seven days. Following free water removal, accumulated storm-water will be removed at a maximum rate of 2 feet over 1 day. Additionally, dewatering discharge rates will not exceed historical discharge rates of 2.01 MGD as reported in the NPDES renewal request submitted in November of 2012 . The ash basin pumps will be controlled with a real-time process control total suspended solids (TSS)meter. A real-time process control pH meter will control a carbon dioxide injection system to maintain pH between 6.0 and 9.0 standard units(SU). In addition to the real-time monitoring,handheld TSS and pH meters will be used daily for additional process control field measurements of samples. The handheld TSS meter will undergo laboratory validation and site-specific field verification. Daily pH monitoring will be conducted with a portable pH meter. Discharge flow rates will be monitored daily using an inline flow meter, a handheld flow meter, or a v-notch discharge weir. Normal monitoring required by the NPDES permit will continue uninterrupted during the dewatering process. As the dewatering process transitions from the removal of ash basin free water to the removal of ash basin interstitial water phase it is anticipated that a filtration system may be used to maintain compliance with permit limits. Please include a provision in the modified permit to allow the use of a coagulant or flocculent from the state's approved list to facilitate the filtration process if needed. Mr. Jeff Poupart Update to HF Lee NPDES application March 11, 2015 Page 3 of 3 If you have any questions,please contact Mr. Shannon Langley at(919)546-2439. 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, td utt Rick Grant-Plant Manager H.F. Lee Energy Complex Enclosures RG/esl cc: Ricky Miller w/enclosure Shannon Langley w/enclosure-NCRH14