NC0004987_Addendum to Waste Water Permit App_20150520

.. DUKE
ENERGYe
CAROLINAS
May 18, 2015
Mr. Jeffrey Poupart, Section Chief
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RECEIVED/DENRODWR
MAY. 2 0 2 015
Water Quality
Permitting Section
Subject: Addendum to NPDES Waste Water Permit Application Permit
Chemical characterization of water for dewatering of ash basins
Marshall Steam Station
NC0004987
Catawba County
Dear: Mr. Poupart,
Duke Energy
526 South Church Street
Charlotte, NC 28202
Mailing Address:
ECUP / P.O. Box 1006
Charlotte, NC 28201-1006
Duke Energy hereby formally submits the attached characterization of ash basin free water and
ash basin interstitial water for the subject facility. These results were previously submitted to
your staff via email on May 8, 2015.
As discussed in various recent meetings between Duke and DENR staff, while there are no
current plans or commitments to dewater the ash basins at the subject facility, Duke request
that language be included in our re -issued NPDES permit to accommodate that activity if it an
activity the company decides to undertake within the term of the re -issued permit. As discussed
in the meetings, "dewatering" in the NPDES permits refers to the removal of interstitial water
from the ash basin(s).
The attached table provides results of chemical analysis of both ash basin free water and ash
basin interstitial water. The ash basin free water samples were taken at different depths in the
ash basin. The ash basin interstitial water samples results are presented 1.) without additional
treatment and 2.) after additional treatment with three different size filters.
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 routinely discharged from the facility in accordance with the
existing NPDES permit, is largely devoid of Total Suspended Solids and is expected to
meet 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
may require additional treatment before being released to the environment.
If you have any questions regarding this submittal, please contact Mr. Shannon Langley at (919)
546-2439 or [e-mail].
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,
L�
Harry K. Sideris
Senior Vice President
Environmental, Health and Safety
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DUKE
• ENERGY®
May 4, 2015
North Carolina Department of
Environment and Natural Resources
Wastewater Permitting
1617 Mail Service Center
Raleigh, NC 27699-1617
Harry K. Sideris
Senior Vice President
Environmental, Health & Safety
526 South Church Street
Mail Code ECUP
Charlotte, NC 28202
[phone]
RECEIVED/DENR/DWR
Subject: Comments on the draft NPDES Permit for Marshall Steam Station
Permit No.: NC0004987
Attention Wastewater Permitting:
MAY -7 2015
Water Quality
Permittinq Sectior,
The North Carolina Department of Environment and Natural Resources (NCDENR) Division of Water
Resources (the Division) issued a draft National Pollutant Discharge Elimination System (NPDES) Permit
for the Duke Energy Marshall Steam Station on March 6, 2015. Duke Energy Carolinas LLC (Duke Energy)
commends NCDENR for developing the draft permit and recognizing the existing discharges from the
facility's outfalls will not cause contravention of the state water quality standards or EPA criteria. Duke
Energy continues to work as quickly as possible to close the ash basins and finalizing this wastewater
permit is a critical step to advance the ash basin closure process. In order to facilitate the closure
process, Duke Energy needs permit conditions that are reasonable while ensuring the discharges will not
adversely affect water quality. Duke Energy, therefore, respectfully submits the following comments on
the draft permit.
Comments on the Development of the Technolo Ey Based Effluent Limits TBELs
The permit establishes technology based effluent limits (TBELs) for arsenic, selenium and nitrate/nitrite
as N on internal Outfall 004 (FGD wet scrubber wastewater to the ash settling basin), and Outfall 010
(combined seep outfall). The TBELs for arsenic and selenium were based on an evaluation of the effluent
data from the ash basin discharges from Belews Creek, Allen and Marshall Steam Stations. The limits for
nitrate/nitrite as N were based on the proposed EPA Steam Electric Effluent Limitation Guidelines (ELG)
because the Division did not have any long-term nitrate/nitrite data.
The NPDES regulations at 40 CFR §125.3(c)(2) require permit writers developing TBELs to consider the
following:

Page 12
• The appropriate technology for the category class of point sources of which the applicant is a
member, based on all available information.
• Any unique factors relating to the applicant.
The regulations also require that, in setting TBELs, the permit writer consider several specific factors
established in §125.3(d), to select a model treatment technology and derive effluent limitations on the
basis of that treatment technology. That process and the factors considered by the permit writer are the
same factors required to be considered by EPA in developing effluent guidelines. For establishing best
available technology (BAT) requirements for toxic and non -conventional pollutants, the following factors
must be considered:
— The age of equipment and facilities involved,
— Process employed,
— Engineering aspects of the application of various types of control techniques,
— Process changes,
— The cost of achieving such effluent reductions, and
— Non -water quality environmental impacts (including energy requirements).
Based on the information published by the Division, there was no indication that any of these factors
were considered in establishing the TBELs.
Furthermore, the Fact Sheet states "The existing federal regulations require the development of
Technology Based Effluent Limits (TBELs) for the parameters of concern." In Duke Energy' opinion,
however, the permit writer has the discretion to choose whether or not to impose BPJ limits. This
opinion is supported by a recent court ruling in Tennessee. The state court affirmed a 2013 decision of
the Tennessee Board of Water quality, Oil, and Gas (the Board) holding that TVA's Bull Run Fossil Plant is
not required to have "BPJ" permit limits beyond what the 1982 Effluent Limitations Guidelines require.
The Board ruled against claims that more permit limits were required. The Board stated the permit
complies with the 1982 ELG rules, and "[b]ecause the 1982 ELG for power plants governs, a Best
Professional Judgment (BPJ) analysis was not required." The Board further stated, when EPA set the
1982 rules, EPA considered setting numeric limits for metals but decided not to because they were
"present in amounts too small to be effectively reduced" 1.
In addition, it is stated in EPA's NPDES Permitting Manual (September 2010), regarding situations in
which case-by-case TBELs are necessary, "The permit writer should make sure that the pollutant of
concern is not already controlled by the effluent guidelines and was not considered by EPA when the
1 In the Matter of Tennessee Clean Water Network v. Tennessee Dept. of Environment and Conservation, Case No.
WPC10-0116 (Tenn. Dept. of Env. and Conservation Dec. 17, 2013).

Page 13
Agency developed the effluent guidelines."' Since EPA considered setting numeric limits for metals, the
Division is not obligated to establish TBELs for these parameters.
The Division's decision to propose TBELs on FGD wastewater, and seeps appears to be dictated by a
memorandum from James A. Hanlon to EPA Water Division Directors for its Regions: Memorandum,
James A. Hanlon to Water Division Directors, Regions 1-10, "National Pollutant Discharge Elimination
System (NPDES) Permitting of Wastewater Discharges from Flue Gas Desulfurization (FGD) and Coal
Combustion Residuals (CCR) Impoundments at Steam Electric Power Plants" (June 7, 2010). It is
important to note the Hanlon memorandum is guidance and not legally binding, as stated in Section VI
of the memo. Furthermore, the guidance does recommend establishing TBELs for FGD wastewater;
however, the guidance recommends establishing water quality based effluent limits (WQBELs), not
TBELs, for coal combustion leachate (i.e. ash basin seeps)z.
Mercury Limits at Outfall 002 and Outfall 010
The permit imposes TBELs for mercury at the combined Outfall 010 (combined ash basin seeps), and
Outfall 002 (ash basin discharges). These limits are based on the statewide mercury total maximum daily
load (TMDL).
Recommended Chan,oes
1. Duke Energy requests a 5 -year compliance schedule to comply with the mercury limit. With the
limits being newly proposed, a compliance schedule should be included to allow for the design,
evaluation, budget, and construction of a treatment system to meet the limits.
Outfall 004 treated FDG wet scrubber wastewater to ash settling basin
As stated above, the permit establishes TBELs for arsenic, selenium, and nitrate/nitrite as N on the
internal Outfall 004 (treated FDG wet scrubber wastewater to ash settling basin). If the Division has
determined the FGD wastewater treatment systems at Belews Creek and Allen Steam Station represent
BAT for FGD wastewater, the limits should be based on the 95th and 991h percentiles of the effluent data
collected from the internal outfalls at Belews Creek (Outfall 002) and Allen (Outfall 005) Steam Stations.
For example, this analysis would yield the following TBELs for selenium3.
Parameter ,T 95th percentile 99th percentile
Selenium ((µg/L)� 23
_ 99
1 Refer to EPA's NPDES Permit Writers' Manual, September 2010, Section 5.2.3.2 "Identifying the Need for Case -
by -Case TBELs" p. 5-45 — 46.
2 Refer to Attachment B, "Water Quality -Based Effluent Limits Coal Combustion Waste Impoundments", of the
James Hanlon memorandum, June 7, 2010.
3 The 95th and 99th percentiles were calculated from effluent data collected from the internal FGD outfall at Belews
Creek (Outfall 002) and Allen (Outfall 004) from April 2010 to March 2015.

Page 14
If this analysis resulted in a limitation less than 10 gg/L, the ability of the analytical method would need
to be evaluated to determine whether commercial laboratories could consistently detect the parameter
at or below the permit limit.
Due to the lack of long-term data, the Division based the nitrate/nitrite limits on the proposed ELG rule.
It should be noted, however, the nitrate/nitrite limits proposed in the ELG were only based on 10
observations (5 observations from both Belews Creek and Allen Steam Stations)-. These observations
were based on samples collected between June 2010 and January 2011 from the effluent immediately
following the FGD wastewater treatment systems. EPA, therefore, did not even have sufficient long-
term data to develop the limits for nitrate/nitrite in the proposed ELG rule.
In addition, the removal of nitrates/nitrites is only a co -benefit of the removal of selenium in the
anaerobic biological reactor and appears to only have been included in the proposed ELG rule to favor
anaerobic biological treatment over other selenium removal treatment technologies. In fact, EPA did not
derive limits for nitrates/nitrites for the other considered model technologies for the treatment of FGD
wastewater, such as chemical precipitation or vapor -compression evaporation.
These issues were the subject of numerous comments on the nitrate/nitrite limits in the proposed ELG
rule, in addition to the following:
— Analytical detection method: The method detection limit for nitrates/nitrites can be
affected by chlorides in the wastewater. This was not considered in the proposed ELG rule.
— Changes in the ORP can affect the ability of the treatment system to remove nitrate/nitrite.
— The analysis for the ELG rule did not consider removals for stations that have higher
selenium and nitrogen levels than Belews Creek and Allen. The treatment systems at Belews
Creek and Allen target selenium removal but not nitrogen removal, and both plants have
low selenium and nitrate/nitrite levels in their influent compared to the industry.
In addition, the arsenic and selenium limits are listed incorrectly for Outfall 004. Based on the Fact
Sheet, the limits should be listed as:
Monthly Average Daily Maximum
Selenium: 13.6 gg/L 25.5 4g/L
Arsenic: 10.5 gg/L 14.5 gg/L
Recommended Chane. es
2. Duke Energy requests the removal of TBELs from Outfall 004. EPA is under a court -order to
finalize the ELG rule by September 30, 2015. The final ELG rule is expected to impose limits on
- Observations at Allen included the average of four 24-hour composite samples collected from 8/3/10-8/6/10, and
four 24 -hr composite samples collected on 10/5/10, 11/1/10, 12/6/10 and 1/12/11.
Observations at Belews Creek included the average of four 24-hour composite samples collected from 6/8/10 —
6/11/10, and four 24 -hr composite samples collected on 10/6/10, 11/3/10, 12/8/10 and 1/17/11.

Page I5
the internal outfall of the discharge of FGD wastewater; however, EPA proposed three
treatment options for FGD wastewater with each option imposing different limitations. Given
the difficulty, cost and time in developing TBELs on a case-by-case basis in accordance with 40
CFR 125.3(d), it would be reasonable to remove the TBELs and incorporate the limitations and
the implementation schedule established under the final ELG rule. This would avoid any issues
with anti -backsliding and conflicts with North Carolina General Statute § 15013-19.3.
3. If the Division is bound to impose TBELs for this permit issuance, Duke Energy requests the
inclusion of language in the permit allowing the TBELs to be revised, if less stringent limits are
imposed in the final ELG rule. This is especially prudent given the issues associated with the
development of the TBELs noted above (i.e. lack of adherence to 40 CFR 125.3(d)). The receiving
water body, Lake Norman, is in attainment for all parameters limited in the permit and the
reasonable potential analysis (RPA) concluded the discharges will not cause contravention of the
state water quality standards or EPA criteria; therefore, revising these limits to match the final
ELG rule will not impair the water quality or the designated use of the water body. To
accomplish this, Duke Energy recommends making the effective date of the TBELs to coincide
with the effective date of the final ELG rule with compliance required 4.5 years from the
effective date. It is anticipated the ELG rule will be effective in 1" quarter 2016. In addition,
Duke Energy requests an Outfall 004 (post-ELG rule) be created to serve as a "placeholder" to
incorporate the limitations in the final ELG rule into the permit.
4. If the TBELs are applied, Duke Energy requests the specific model technology used to derive the
TBELs that were applied to Outfall 004. In the event the model technology is installed and the
limits imposed are not achieved, Duke Energy would like to have the option of requesting a less
stringent limit as allowed under the Clean Water Act §402(o)2(E). If the Division has determined
the FGD wastewaters treatment systems at Belews Creek and Allen Steam Stations represents
BAT, the limits should be based on the 95th and 99th percentiles of the effluent data from the
internal FGD wastewater outfalls at Allen and Belews Creek Steam Stations. If this analysis
resulted in a limitation less than 10 µg/L, the ability of the analytical method would need to be
evaluated to determine whether commercial laboratories could consistently detect the
parameter at or below the permit limit.
Outfall 010 combined seen
Comments on the 12roposed limits for Arsenic Selenium and Nitrate Z Nitrite as N
Similar to Outfall 004, the permit establishes TBELs for arsenic, selenium, and nitrate/nitrite as N on
Outfall 010 (combined seep outfall). Again, the arsenic and selenium TBELs were based on an evaluation
of the effluent data from the ash basin discharges from Belews Creek, Allen and Marshall Steam Stations
and the limits for nitrate/nitrite as N were based on the proposed ELG rule.

Page 16
The proposed ELG rule classifies seeps from the ash basin as combustion residual leachate, specifically
impoundment leachate'. Under all the preferred options presented in the ELG rule, combustion residual
leachate would only be limited by total suspended solids (TSS) and oil and grease (0&G). In fact, EPA did
not even identify nitrate/nitrite or selenium as pollutants of concern for impoundment leachate in their
analysis for the proposed ELG rule'. Furthermore, the Hanlon memo describes a reasonable potential
approach for establishing limits for seeps based on water quality, not technology.
The nitrate/nitrite limits proposed in the ELG rule were based on data collected immediately following
the FGD wastewater treatment systems at Belews Creek and Allen Steam Stations and were not
associated with the ash basin discharge or ash basin seeps. The FGD treatment systems at Belews Creek
and Allen require denitrification, in order to remove selenium from the FGD wastewater stream. There
are, however, additional sources of nitrate/nitrite into the ash basin and potentially into the seeps that
are unrelated to the FGD wastewater discharge, such as:
— Goose droppings,
— Algae blooms due to nutrient inputs from stormwater runoff, and
— Input of sanitary waste treatment systems to the ash basin.
In addition, the nitrate/nitrite limits established for Outfalls 010 is extremely low and unnecessary. The
EPA 2013 Proposed Reissuance of the NPDES Multi -Sector General Permit for Stormwater Discharges
Associated with Industrial Activity proposed a benchmark for nitrate/nitrate of 0.68 mg/L, which is 5
times the monthly average limit in the draft permit.
Comments on the Implementation
The permit needs to state the methodology to calculate the concentration for the combined seeps to be
reported in the discharge monitoring reports (DMR). A flow -weighted average concentration is the most
appropriate methodology. This methodology is represented by the following formula.
1 Refer to Fed. Reg. / Vol. 78, No. 110 / Friday, June 7, 2013 / p. 34533 §423.11(r) "The term combustion residual
leachate means leachate from landfills or surface impoundments containing residuals from the combustion of
fossil or fossil -derived fuel. Leachate includes liquid, including any suspended or dissolved constituents in the
liquid, that has percolated through or drained from waste or other materials placed in a landfill, or that pass
through the containment structure (e.g., bottom, dikes, berms) of a surface impoundment. Leachate also includes
the terms seepage, leak, and leakage, which are generally used in reference to leachate from an impoundment."
2 Refer to Section 6.7.3 of the Technical Development Document for the Proposed Effluent Limitations Guidelines
and Standards for the Steam Electric Power Generating Point Source Category, April 2013. Nitrites/nitrates as N
were not listed as a pollutant of concern for landfill leachate or impoundment leachate. Selenium was listed as a
pollutant of concern for landfill leachate but not impoundment leachate.

Page 17
Where,
C _ En(Ci X Qi)
Zn Qi
C = Flow -weighted average concentration of combined seeps.
n = Number of seeps sampled.
Ci = Concentration of the parameter for each seep in micrograms per liter.
Qi = Flow of each seep in liters.
Recommended Changes
5. Appendix A of the draft permit proposes that 2 identified seep locations be classified collectively
and permitted as Outfall 010 (combined seep outfall). Duke Energy will be further classifying
seeps into non -engineered seeps at locations where the seepage emerges from natural or
residual material and engineered seeps. Duke Energy requests the seeps listed and updated in
the Discharge Identification Plan (DIP) referenced in Appendix B be used as the official seep
identification with regards to official location and type (non -engineered seeps and engineered
seeps, i.e. toe drains). It would be anticipated that the seepage flows and water quality would
be inherently different at these two types of features. Duke Energy, therefore, believes it is
appropriate that the seeps be grouped into two outfalls: one for engineered seeps and one for
non -engineered seeps. The same permit limits and conditions applied to Outfall 010 should be
applied to engineered seeps.
6. Duke Energy requests the removal of the TBELs from Outfall 010 due to the fact the TBELs were
not developed in accordance with 40 CFR 125.3(d), the proposed ELG rule did not include limits
on arsenic, selenium, or nitrate/nitrate and insufficient data exists to develop TBELs. The data
used to derive the limits were based on other waste streams not specific to ash basin seeps;
therefore, the limits are not technically justified. Furthermore, the RPA was conducted at a flow
rate of 263 times the measured flow rate of the seeps. This added conservatism ensures the ash
basin seeps are not and will not adversely affect water quality. Additionally, the Division
assumed the seeps reach the surface water; however, to be considered a point source
discharge, the Clean Water Act requires a discernible, confined and discrete conveyance, in
which pollutants are discharged to navigable waters. The TBELs, therefore, should be removed
from the permit and doing so will not adversely affect water quality.
7. In lieu of TBELs, Duke Energy requests the Division to adopt a similar process as with new seep
identification to evaluate the constituent concentration and flow. If the concentration of any
parameter exceeds the concentrations in Table 1 of the permit or the total flow of all seeps is
determined to be in excess of 0.5 MGD, the Division should calculate reasonable potential to
determine if water quality based effluent limits (WQBELs) are necessary. If so, a formal
modification of the permit can be conducted to incorporate the WQBELs in the permit. This
approach would be consistent with the Hanlon memo.

Page 18
8. If the Division is bound to develop TBELs for seeps, Duke Energy requests a 5 -year compliance
schedule. The permit states the limits can be met by installing a treatment system, re-routing
the discharge to the existing treatment system, or discontinuing the discharge. The Fact Sheet,
however, states it will be time-consuming and ineffective to re-route the seeps back to the ash
basin. Given these conflicting statements, a compliance schedule is necessary to evaluate,
budget, design and construct the treatment system or eliminate the discharge.
9. If the TBELs are imposed, Duke Energy requests the specific model technology used to derive
the TBELs that were applied to Outfall 010 (combined seeps). In the event the model technology
is installed and the limits imposed are not achieved, Duke Energy would like to have the option
of requesting a less stringent limit as allowed under the Clean Water Act §402(o)2(E).
10. Duke Energy requests the inclusion of the methodology for determining the concentration to be
reported in the DMR for Outfall 010. Duke Energy recommends the following approach.
C _ Zn(Ci x Qi)
Dn Qi
Where,
C = Flow -weighted average concentration of combined seeps.
n = Number of seeps sampled.
Ci = Concentration of the parameter for each seep in micrograms per liter.
Qi = Flow of each seep in liters.
Seep Poll utAqAnjhtsh
The permit requires the facility to continue to implement the Plan for Identification of New Discharges
to determine if new seeps have emerged. New seeps identified must have the flow calculated and
sampled for parameters listed in the permit.
Comments on the idents ication of new sees
The permit does not clearly define a seep or how the seep should be identified. It should be recognized
that a wet spot near the ash pond dike is not necessarily a seep from the ash basin and warrant the flow
to be calculated and samples collected. Seeps can emerge due to several factors that are
inconsequential to the ash basin, such as:
— Natural springs,
— Fluctuation in water level of the adjacent water body,
— Naturally formed wetlands,
Intermittent and ephemeral streams, and

Page 19
— Stormwater drainage.
Furthermore, a discernible, confined and discrete conveyance from the seep to waters of the state or
U.S. should be present to classify the seep as a new discharge.
Comments on the Table 1 Parameters
The parameters listed in Table 1 of the permit include the daily maximum concentrations of the TBELs
for arsenic, selenium and nitrate/nitrite as N as opposed to multiplying the highest baseline seep
concentration by 10, as with the other parameters. As stated above, there is no technical justification for
these concentrations to be used as screening values. This is especially true for the nitrate/nitrite
screening value, which was based on the proposed ELG rule specific to FGD wastewater, not ash basin
discharge or discharges from ash basin seeps.
Comments on Notification
The notification requirements for newly identified seeps are not clear in the permit. It is stated in the
permit that newly identified seeps must be reported to the "Division of Water Resources within 5 days
of detection (location only, sampling results shall be submitted within 30 days of sampling) for
administrative inclusion in Appendix A." It is not clear whether the deadlines refer to calendar or
business days. The wording regarding the reporting of the location only and sampling results should
clearly indicate the deadlines. In addition, the permit is unclear on when samples must be collected
from the newly identified seep.
Recommended Chancres
11. Duke Energy requests the inclusion of clarifying language in the permit defining a seep that
warrants further evaluation. Duke Energy requests the following clarifying language be included
in the permit:
"Seepage is considered to be the movement of wastewater from the ash basin
through the ash basin embankment, the embankment foundation, the
embankment abutments, through residual material in areas adjacent to the ash
basin, or through the bottom of the ash basin. Therefore, a seep is defined in
this permit as an expression of seepage at the ground surface above the
ordinary high water mark of any waters of the state. Only seeps that have the
presence of a discernible, confined and discrete conveyance to the surface
water will be considered a new seep warranting further evaluation of flow and
pollutant characterization."
12. Duke Energy requests the screening value of nitrate/nitrite removed from Table 1. There was no
baseline data collected and the screening concentration imposed is based on samples collected
from the discharge of FGD wastewater treatment systems, not ash basin discharge or ash basin

Page 110
seeps. Furthermore, there are natural sources of nitrate/nitrite that are unrelated to the ash
basin. Therefore, there is no technical justification for the inclusion of nitrate/nitrite as N in
Table 1.
13. Duke Energy requests the screening values for arsenic and selenium be revised to be 10 times
the baseline concentration as with the other parameters. Again, the screening values were
based on the TBELs imposed on Outfall 004. These values, however, were not derived in
accordance with 40 CFR 125.3(d) and were not based on data collected from ash basin seeps.
14. Duke Energy requests the inclusion of clarifying language on the notification requirements for
newly identified seeps. The following language is recommended:
"New seeps identified through the seep survey or otherwise discovered or
reported to the permittee shall have their flow calculated, and be sampled for
parameters indicated in Table 1. The location(s) of the seep shall be reported to
Division of Water Resources within 5 business days. Samples of the seep shall be
collected within 10 business days of identification and the sampling results shall
be submitted within 30 days of sampling for administrative inclusion in Appendix
A."
Dewatering,,
15. Duke Energy requests inclusion of clarifying language in the permit authorizing the removal of
free water above the settled ash layer including, but not limited to, decanting, controlled
pumping and/or normal operation. It is Duke Energy's understanding, based on conversations
with Division staff that the permit as drafted allows for the discharge of free water above the
settled ash layer in the ash basin by removal of stop logs, sections of riser and/or controlled
pumping through the permitted outfall flow path. As further discussed with Division staff, Duke
Energy will submit interstitial data to request authorization to conduct interstitial dewatering
activities. Interstitial water should be defined in the permit as entrapped water (i.e., water
occupying the pore space within the ash and below the ash surface). Interstitial wastewater
would be generated through mechanical movement of ash such as through dredging, and
excavating trenches within the ash and discharge would generally occur by controlled pumping.
Nonchemical Metal Cleanin Wastewater
The permit defines chemical metal cleaning wastewater and metal cleaning wastewater, but does not
define nonchemical metal cleaning wastewater. The permit only applies limits for chemical cleaning
wastewater to Outfall 002 (ash basin discharge), but no limits are applied for metal cleaning wastewater
or nonchemical metal cleaning wastewater.
16. Duke Energy requests the inclusion of language defining nonchemical metal cleaning
wastewater as low volume wastewater and only subject to the low volume wastewater limits of

Page Ill
O&G and TSS. In the proposed ELG rule, EPA acknowledged the conflicting guidance given
historically on nonchemical metal cleaning wastewater and proposed to exempt stations from
the proposed revisions to the nonchemical metal cleaning limitation. Given the previous permits
for Marshall only applied limits for chemical metal cleaning, Marshall should qualify for this
exemption.
Duke Energy welcomes any further discussion on our comments or the draft permit. If you have any
questions, please contact Richard Baker at 704 382-7959 or at [e-mail].
Sincerel
r
Harry K. Sideris
Duke Energy
Senior Vice President, Environmental, Health & Safety

Alternate Schedule Request §316(b) of the Clean Water Act
Marshall Steam Station
Final regulations to establish requirements for cooling water intake structures at existing facilities were
published in the Federal Register on August 15, 2014 (i.e. regulations implementing §316(b) of the Clean
Water Act) with an effective date of October 14, 2014. Marshall Steam Station will be subject to the
regulations. The design intake flow of the station is greater than 2 million gallons per day (MGD) and the
historical actual intake flows are greater than 125 MGD; therefore, the following submittals are
expected to be required:
— §122.21(r)(2) Source Water Physical Data
— §122.21(r)(3) Cooling Water Intake Structure Data
— §122.21(r)(4) Source Water Baseline Biological Characterization Data
— §122.21(r)(5) Cooling Water System Data
— §122.21(r)(6) Chosen Method(s) of Compliance with Impingement Mortality Standard
— §122.21(r)(7) Entrainment Performance Studies
— §122.21(r)(8) Operational Status
— §122.21(r)(9) Entrainment Characterization Study
— §122.21(r)(10) Comprehensive Technical Feasibility and Cost Evaluation Study
— §122.21(r)(11) Benefits Valuation Study
— §122.21(r)(12) Non -water Quality and Other Environmental Impacts Study
As allowed under §125.95(a)(2), Duke Energy would like to request an alternate schedule for the
submittals listed above. Information requested in §122.21(r)(2), (3), and (5) were competed under the
remanded rule; however, this information must be updated to reflect current operations and
information requested in §122.21(r)(4) is substantially different from the remanded rule. Information
requested in §122.21(r)(6) – r(12) are new provisions and these submittals must be developed. Duke
Energy will need at least 60 months to prepare the necessary submittals. This timeframe includes
complying with the peer review requirement for submittals §122.21(r)(10), §122.21(r)(11), and
§122.21(r)(12).
The rule requires the necessary submittals to be included with the permit renewal ap ,plication for_
permits with an effective date after July 14, 2018. Duke Energy, therefore, would like to request the
316(b) submittals, with the exception of §122.21(r)(6) Chosen Method(s) of Compliance with
Impingement Mortality Standard, for Marshall Steam Station to be required with the subsequent permit
renewal application due after July 14, 18. Since Marshall Steam Station is subject to the entrainment
best technology available (BTA) determination, a compliance schedule to complete §122.21(rJ(6)
Chosen Methods) of Compliance with Impingement Mortality Standard will be requested to be included
in the permit upon issuance of the entrainment BTA determination.

Fish Tissue Monitoring

Marshall Steam Station
NPDES Permit No. NC0004987
Monitoring of Arsenic, Selenium, and Mercury in Fish Muscle Tissue from Lake
Norman, NC.
Duke Energy
2014

Table of Contents
1.0 Introduction....................................................................................................................... Page 1
2.0 Study Site Description and Sampling Locations............................................................... 1
3.0 Target Species................................................................................................................... 1
4.0 Field Sampling Methods................................................................................................... 1
5.0 Laboratory Processing and Arsenic, Selenium, and Mercury Analysis ............................ 2
6.0 Data Analysis and Reporting............................................................................................ 2
7.0 References......................................................................................................................... 2
List of Tables
Table
Page
1 Arsenic, selenium, and mercury concentrations in axial muscle of fish from Lake
Normanduring April 2014................................................................................................ 3
List of Figures
FigjLre
Page
1 Lake Norman arsenic, selenium and mercury monitoring locations ................................. 4
H

1.0 Introduction
Duke Energy owns and operates the Marshall Steam Station (MSS) located on Lake Norman in
Catawba County, Terrell, NC. The MSS National Pollutant Discharge Elimination System (NPDES)
Permit (No. NC0004987 Section A 25) requires monitoring of trace elements (arsenic, selenium and
mercury) in fish tissues near the discharge once per permit cycle. Fish were collected according to the
submitted study plan (dated December 4, 2013). The resulting data are submitted in this report.
2.0 Study Site Description and Sampling Locations
Fish were collected from three locations on Lake Norman (Figure 1). These locations were
adjacent to the MSS discharge (DD, 6.3 kilometers upstream (UP) and 8.5 kilometers downstream
of the discharge (DN).
3.0 Target Species
The target species of fish were spotted bass and redear sunfish. As recommended by the US
Environmental Protection Agency (EPA), an attempt was made to limit the smallest fish to 75%
of the largest fish total length by species depending on availability (US EPA 2000).
4.0 Field Sampling Methods
Fish were collected using electrofishing according to our Biology Program Procedures Manual
(Procedure NR -00080, Rev. 1), which is approved by the NC Division of Water Resources under
the Company's NC Biological Laboratory Certification (# 006), located at New Hill, NC. Only
live fish that showed little or no signs of deterioration were retained for analysis. Retained fish
were individually tagged (Floy tags), identified to species, measured for total length (mm), weight
(g), placed on ice until frozen and transferred to a freezer within 24 hours of collection.
Water quality data consisting of temperature, pH, dissolved oxygen, specific conductance and
turbidity were recorded daily at the surface at each sampling location. Other noteworthy
environmental conditions including river flow conditions and weather conditions were noted and
are available upon request.
1

5.0 Laboratory Processing and Arsenic, Selenium and Mercury Analysis
All fish samples were processed in the New Hill trace element laboratory according to procedure
NR -00107 (Rev. 4) Trace Element Monitoring Laboratory Procedure. The processed samples
(lyophilized left axial muscle; right muscle occasionally included when needed) were analyzed
for arsenic, selenium and mercury by x-ray spectrophotometry. Quality control was achieved by
analytical standards, replicates and certified reference materials. The remaining fish carcasses
were archived and will be kept for at least two years in the event that re -analysis is needed.
6.0 Data Analysis and Reporting
Arsenic, selenium and mercury concentrations (converted to µg/g fresh weight) in the fish muscle
tissue collected during 2014 are shown in Table 1. In addition to the length and weight of each
fish, the dry -to -fresh weight ratios are presented to convert the arsenic, selenium and mercury
concentrations fresh weight values back to dry weight values as desired. All fish collected during
2014 were below the US EPA Screening Values for Recreational Fishermen of 1.2 gg/g (fresh
weight) for arsenic (US EPA 2000). All fish collected during 2014 were below the NC human
consumption advisory level of 10 µg/g (fresh weight) for selenium. All fish collected during 2014
had mercury concentrations below the NC Health Directors Action Advisory Level of 0.4 µg/g
fresh weight (NCDHHS 2006).
7.0 References
NCDHHS. 2006. Health effects of methylmercury and North Carolina's advice on eating fish.
North Carolina Occupational and Environmental Epidemiology Branch, Raleigh, NC.
US EPA. 2000. Guidance for assessing chemical contaminant data for use in fish advisories. Vol. 1.
Fish sampling and analysis. Third edition. EPA 823-B-00-007. United States Environmental
Protection Agency, Office of Water, Washington, DC.
2

Table 1. Arsenic, selenium and mercury concentrations (fresh weight) in axial muscle of
fish from Lake Norman during April 2014.
* To convert to a dry weight, divide the fresh weight concentrations by the dry -to -fresh weight ratio.
3
Length
Weight
As
Se
Hg
Dry -to -fresh
Fish s ecies
Location
Month
(mm)
(g)
-'U/+')
( /p-)
W -g/¢)
weiUh ratio*
Spotted bass
UP
April
350
564
0.19
0.39
<0.06
0.207
Spotted bass
UP
April
355
522
0.23
0.37
<0.06
0.208
Spotted bass
UP
April
378
590
0.10
0.40
<0.05
0.201
Spotted bass
UP
April
340
512
0.22
0.40
<0.06
0.224
Spotted bass
Up
April
380
611
0.16
0.47
<0.05
0.198
Spotted bass
UP
April
358
523
0.06
0.39
<0.06
0.205
Redear sunfish
UP
April
241
245
0.06
0.56
<0.06
0.208
Redear sunfish
UP
April
258
311
0.08
0.50
<0.05
0.199
Redear sunfish
UP
April
243
276
0.10
0.56
<0.05
0.201
Redear sunfish
UP
April
234
222
0.04
0.58
<0.06
0.208
Redear sunfish
UP
April
220
176
0.08
0.82
<0.06
0.209
Redear sunfish
UP
April
240
254
0.11
0.53
<0.06
0.211
Spotted bass
DI
April
380
668
0.15
0.62
<0.06
0.215
Spotted bass
DI
April
392
692
0.19
0.43
<0.06
0.215
Spotted bass
DI
April
424
972
0.11
0.53
0.09
0.213
Spotted bass
DI
April
338
458
0.13
0.44
<0.06
0.21 I
Spotted bass
DI
April
393
702
0.08
0.44
0.13
0.210
Spotted bass
DI
April
435
1136
0.08
0.74
0.21
0.212
Redear sunfish
DI
April
254
202
0.11
0.78
<0.05
0.181
Redear sunfish
DI
April
271
345
0.10
0.64
<0.06
0.207
Redear sunfish
DI
April
172
82
0.10
0.64
<0.05
0.1.93
Redear sunfish
DI
April
275
380
0.08
0.66
<0.05
0.200
Redear sunfish
DI
April
186
107
0.10
0.58
<0.06
0.208
Redear sunfish
DI
April
185
94
0.10
0.62
<0.06
0.208
Spotted bass
DN
April
429
890
0.08
0.68
<0.05
0.201
Spotted bass
DN
April
404
696
0.08
0.66
<0.05
0.199
Spotted bass
DN
April
367
546
0.08
0.56
<0.06
0.206
Spotted bass
DN
April
416
864
<0.04
0.57
<0.05
0.185
Spotted bass
DN
April
359
602
0.16
0.57
<0.05
0.203
Spotted bass
DN
April
361
562
0.10
0.56
<0.06
0.208
Redear sunfish
DN
April
268
340
0.06
0.77
<0.06
0.209
Redear sunfish
DN
April
261
288
0.10
0.83
<0.05
0.202
Redear sunfish
DN
April
195
109
0.04
0.37
<0.03
0.098
Redear sunfish
DN
April
186
100
0.06
0.82
<0.06
0.206
Redear sunfish
DN
April
177
89
0.04
0.80
<0.06
0.204
Redear sunfish
DN
April
195
118
0.04
0.71
<0.06
0.210
* To convert to a dry weight, divide the fresh weight concentrations by the dry -to -fresh weight ratio.
3

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Metals Sampling in the Vicinity
Of Ash Basins

Marshall Steam Station In -Stream Monitoring Plan
I. Introduction
In -Stream Monitoring Requirement
A requirement to semi-annually sample water quality at locations in Lake Norman upstream and
downstream of the Marshall Steam Station (MSS) ash basin discharge was implemented in 2011
under section Part I # 26 (In -stream Monitoring) of the MSS National Pollutant Discharge
Elimination System permit.
The following discussion describes the specific analyses, methods and analytical results of this
monitoring program for the period 2011 — 2013.
II. Sampling and Methodology
Lake Norman Sampling Locations
The water quality sampling locations associated with this monitoring plan are depicted in Figure
1. The upstream location (15.9) is approximately 2.5 miles upstream of where the MSS ash
basin discharges into the MSS condenser cooling water (CCW) intake cove. The downstream
location (14.0) is approximately 0.5 miles downstream of the MSS CCW discharge into Lake
Norman.
Sampling and Analytical Methods
Grab samples collected from the surface (0.3 m) at both locations in Lake Norman were analyzed
for the following parameters: arsenic (As), cadmium (Cd), chromium (Cr), copper (Cu), mercury
(Hg), lead (Pb), selenium (Se), zinc (Zn), and total dissolved solids (TDS). Storage and
preservation techniques of the samples after collection and prior to analyses were followed
according to Appendix A. Methods of analysis and results for each parameter are presented in
Table 1. Analyses were conducted by Duke Energy's Huntersville analytical laboratory (NC
Wastewater Certification #248).
III. Results & Recommendations
All trace metal results were low, with most values either tabulated as less than the analytical
reporting limit (RL) for the method or close to the RL (Table 1). For example, all samples for
arsenic, cadmium, chromium, mercury, lead and selenium were reported as less than the RL,
whereas only four zinc values were greater than the RL of 1.0 Ng/L. All zinc values were below
the water quality standard (50 Ng/L). Most of the copper values were above the RL, but only
marginally so, and all values were also well below the water quality standard (7.0 pg/L). Total
dissolved solids (TDS) values were low, and reflective of the low ionic strength and
conductivity of waters in Lake Norman and the Catawba River Basin. All values for the nine
water quality parameters monitored were below NC water quality standards. Duke Energy
proposes that the in -stream monitoring frequency be reduced from semi-annually to annually.
1

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Table 1. MSS in -stream monitoring analytical results and methodology. Locations 15.9 and 14.0 represents the upstream and downstream,
respectively, sampling sites.
Method EPA 200.8 EPA 200.8 EPA 200.8 EPA 200.8 EPA 245.1 EPA 200.8 EPA 200.8 EPA 200.8 5M2540C
DepthArsenic
Cadmium
Chromium
Copper
Mercury
Lead
Selenium
Zinc
TDS
4cilit
Date
Location
m
<
. ( L
<
(IIWL)
<
L
< < L)
<
p r�L)
<(PKIL)
<
L)
<
gJL
< ( L
MSS
2/7/2011
15.9
0.3
<
1.00
<
1.00
<
1.00
2.09
<
0.05
<
1.00
<
1.00
<
2.00
50
MSS
2/7/2011
14.0
0.3
<
1.00
<
1.00
<
1.00
3.59
<0.05
<
1.00
<
1.00
<
2.16
55
MSS
8/1/2011
15.9
0.3
<
1.00
<
1.00
<
1.00
1.69
<
0.05
<
1.00
<
1.00
<
2.00
37
MSS
8/1/2011
14.0
0.3
<
1.00
<
1.00
<
1.00
5.31
<
0.05
<
1.00
<
1.00
<
2.00
47
MSS
2/6/2012
15.9
0.3
<
1.00
<
1.00
<
1.00
1.31
<
0.05<
1.00
<
1.00
<
2.00
51
MSS
2/6/2012
14.0
0.3
1 <
1.00
<
1.00
<
1.00
2.31
<
0.05
<
1.00
<
1.00
<
2.00
64
MSS
8/6/2012
15.9
0.3
<
1.00
<
1.00
<
1.00
< 1.00
<
0.05
<
1.00
<
1.00
<
1.00
50
MSS
8/6/2012
14.0
0.3
<
1.00
<
1.00
<
1.00
< 1.00
<
0.05
<
1.00
<
1.00
<
1.00
56
MSS
2/4/2013
15.9
0.3
<
1.00
<
1.00
<
1.00
1.12
<
0.05
<
1.00
<
1.00
2.67
47
MSS
2/4/2013
14.0
0.3
<
1.00
<
1.00
<
1.00
2.46
<
0.05
<
1.00
<
1.00
3.56
47
MSS
8/5/2013
15.9
14.0
0.3
0.3
<
<
1.00
1.00
<
<
1.00
1.00
<
<
1.00
1.00
2.46
5.06
<
<
0.05
0.05
<
<
1.00
1.00
<
<
1.00
1.00
<
1.00
2.23
40
60
MSS 8/5/2013
MSS
8/6/2012
15.9
0.3
<
1.00
<
1.00
<
1.00
< 1.00
<
0.05
<
1.00
<
1,00
<
1.00
50
MSS
8/6/2012
14.0
0.3
<
1.00
<
1.00
<
1.00
< 1.00
<
0.05
<
1.00
<
1.00
<
1.00
56

Appendix A
Sample Preservation and Hold times

Parameter name
Containers
Preservation7-3-
Maximum
holding time4-
Table IS—Inorganic Tests:
1. Acidity
P, FP, G
Cool, 56 °C18
14 days.
2. Alkalinity
P, FP, G
Cool, 56 °CT8
14 days.
4. Ammonia
P, FP, G
Cool, :56 °C78, HISO4 to pH <2
28 days.
9. Biochemical oxygen demand
P, FP, G
Cool, 56 °C18
48 hours.
10. Boron
P, FP, or Quartz
HNO3 to pH <2
6 months.
11. Bromide
P, FP, G
None required
28 days.
14. Biochemical oxygen demand, carbonaceous
P, FP G
Cool, :56 °C78
48 hours.
15. Chemical oxygen demand
P, FP, G
Cool, 56 °C'e, H2SO4 to pH <2
28 days.
16. Chloride
P, FP, G
None required
28 days.
17. Chlorine, total residual
P, G
None required
Analyze within 15
minutes.
21. Color
P, FP, G
Cool, 56 °C18
48 hours.
23-24. Cyanide, total or available (or CRTC) and
P, FP, G
Cool, s6 °G'$, NaOH to pH
14 days.
free
>1058, reducing agent if
oxidizer present
25. Fluoride
P
None required
28 days.
27. Hardness
P, FP, G
HNOs or H2SO4 to pH <2
6 months.
28. Hydrogen ion (pH)
P, FP, G
None required
Analyze within 15
minutes.
31, 43. Kjeldahl and organic N
P, FP, G
Cool, 56 °Cte, H2SO4 to pH <2
28 days.
Table IB -Metals:'
18. Chromium Vt
P, FP, G
Cool, 56 °C18, pH = 9.3.9.720
28 days.
35. Mercury (CVAA)
P, FP, G
HNO3 to pH <2
28 days.
35. Mercury (CVAFS)
FP, G; and FP-
5 mL /L 12N HCI or 5 mUL
90 days."
lined cap"
BrCI47
3, 5-8,12,13,19, 20, 22, 26, 29, 30, 32-34,36, 37,
P, FP, G
HNO3 to pH <2, or at least 24
6 months.
45, 47, 51, 52, 58-60, 62, 63, 70-72, 74, 75. Metals,
hours prior to analysis19
except boron, chromium VI, and mercury
38. Nitrate
P, FP, G
Cool, 56 °CT8
48 hours.
39. Nitrate -nitrite
P. FP, G
Cool, 56 °C18, H2SO4 to pH <2
28 days.
40. Nitrite
P, FP, G
Cool, 56 °C1&
48 hours.
41. Oil and grease
G
Cool to 56 °C18, HCI or H2SO4
28 days.
to pH <2
42. Organic Carbon
P, FP, G
Cool to 56 °C'8, HCI, H2SO4, or
28 days.
HsPO4 to pH <2
44. Orthophosphate
P, FP, G
Cool, to <_6 °C1$24
Filter within 15
minutes; Analyze
within 48 hours.
46. Oxygen, Dissolved Probe
G, Bottle and top
None required
Analyze within 15
minutes.
47. Winkler
G, Bottle and top
Fix on site and store in dark
8 hours.
48. Phenols
G
Cool, 56 °C78, H2SO4 to pH <2
28 days.
49. Phosphorous (elemental)
G
Cool, 56 °C1e
48 hours.
50. Phosphorous, total
P, FP, G
Coot, 56 °C18, H2SO4 to pH <2
28 days.
53. Residue, total
P, FP, G
Cool, 56 °CT8
7 days.
54, Residue, Filterable
P, FP, G
Cool, <_6 °C18
7 days.
55. Residue, Nonfilterable (TSS)
P, FP, G
Cool, 56 0C7B
7 days.
56. Residue, Settleable
P, FP, G
Cool, 56 °C16
48 hours.
57. Residue, Volatile
P, FP, G
Cool, 56 °C18
7 days.
61. Silica
P or Quartz
Cool, 56 °C4B
28 days.
64. Specific conductance
P, FP, G
Cool, :56 °C1e
28 days.
65. Sulfate
P, FP, G
Cool, 56 °C18
28 days.
66. Sulfide
P, FP, G
Cool, 56 °C18, add zinc acetate
7 days.
plus sodium hydroxide to pH >9
67. Sulfite
P, FP, G
None required
Analyze within 15
minutes.
68. Surfactants
P. FP, G
Cool, 56'C"'
48 hours.
69. Temperature
P, FP, G
None required
Analyze.
73. Turbidity
P, FP, G
Cool, 56'C8
48 hours.
'"P" is for polyethylene; "FP" is fluoropolymer (polytetrafluoroethylene (PTFE); Teflon®), or other fluoropolymer, unless stated
otherwise in this Table ll; "G" is glass; "PA" is any plastic that is made of a sterilizable material (polypropylene or other autoclavable
plastic); "LDPE" is low density polyethylene.
2Except where noted in this Table II and the method for the parameter, preserve each grab sample within 15 minutes of
collection. For a composite sample collected with an automated sample (e.g., using a 24-hour composite sample; see 40 CFR
122.21(g)(7)(i) or 40 CFR Part 403, Appendix E), refrigerate the sample at <_6 °C during collection unless specked otherwise in this
Table 11 or in the method(s). For a composite sample to be split into separate aliquots for preservation and/or analysis, maintain the

sample at 56 °C, unless specified otherwise in this Table It or in the method(s), until collection, splitting, and preservation is
completed. Add the preservative to the sample container prior to sample collection when the preservative will not compromise the
integrity of a grab sample, a composite sample, or aliquot split from a composite sample within 15 minutes of collection. If a
composite measurement is required but a composite sample would compromise sample integrity, individual grab samples must be
collected at prescribed time intervals (e.g., 4 samples over the course of a day, at 6 -hour intervals). Grab samples must be analyzed
separately and the concentrations averaged. Alternatively, grab samples may be collected in the field and composited in the
laboratory if the compositing procedure produces results equivalent to results produced by arithmetic averaging of results of analysis
of individual grab samples. For examples of laboratory compositing procedures, see EPA Method 1664 Rev. A (oil and grease) and
the procedures at 40 CFR 141.34(f)(14)(iv) and (v) (volatile organics).
3When any sample is to be shipped by common carrier or sent via the U.S. Postal Service, it must comply with the
Department of Transportation Hazardous Materials Regulations (49 CFR part 172). The person offering such material for
transportation is responsible for ensuring such compliance. For the preservation requirement of Table II, the Office of Hazardous
Materials, Materials Transportation Bureau, Department of Transportation has determined that the Hazardous Materials Regulations
do not apply to the following materials: Hydrochloric acid (HCI) in water solutions at concentrations of 0.04% by weight or less (pH
about 1.96 or greater; Nitric acid (HNO3) in water solutions at concentrations of 0.15% by weight or less (pH about 1.62 or greater);
Sulfuric acid (H2SO4) in water solutions at concentrations of 0.35% by weight or less (pH about 1.15 or greater); and Sodium
hydroxide (NaOH) in water solutions at concentrations of 0.080% by weight or less (pH about 12.30 or less).
`Samples should be analyzed as soon as possible after collection. The times listed are the maximum times that samples may
be held before the start of analysis and still be considered valid. Samples may be held for longer periods only if the permittee or
monitoring laboratory has data on file to show that, for the specific types of samples under study, the analytes are stable for the
longer time, and has received a variance from the Regional Administrator under Sec. 136.3(e). For a grab sample, the holding time
begins at the time of collection. For a composite sample collected with an automated sampler (e.g., using a 24-hour composite
sampler; see 40 CFR 122.21(g)(7)(i) or 40 CFR part 403, Appendix E), the holding time begins at the time of the end of collection of
the composite sample. For a set of grab samples composited in the field or laboratory, the holding time begins at the time of
collection of the last grab sample in the set. Some samples may not be stable for the maximum time period given in the table. A
permittee or monitoring laboratory is obligated to hold the sample for a shorter time if it knows that a shorter time is necessary to
maintain sample stability. See 136.3(e) for details. The date and time of collection of an individual grab sample is the date and time
at which the sample is collected. For a set of grab samples to be composited, and that are all collected on the same calendar date,
the date of collection is the date on which the samples are collected. For a set of grab samples to be composited, and that are
collected across two calendar dates, the date of collection is the dates of the two days; e.g., November 14-15. For a composite
sample collected automatically on a given date, the date of collection is the date on which the sample is collected. For a composite
sample collected automatically, and that is collected across two calendar dates, the date of collection is the dates of the two days;
e.g., November 14-15. For static -renewal toxicity tests, each grab or composite sample may also be used to prepare test solutions
for renewal at 24 h, 48 h, and/or 72 h after first use, if stored at 0-6 °C, with minimum head space.
5ASTM D7365 -09a specifies treatment options for samples containing oxidants (e.g., chlorine). Also, Section 9060A of
Standard Methods for the Examination of Water and Wastewater (20th and 21st editions) addresses dechlorination procedures.
"Sampling, preservation and mitigating interferences in water samples for analysis of cyanide are described in ASTM D7365 -
09a. There may be interferences that are not mitigated by the analytical test methods or D7365 -09a. Any technique for removal or
suppression of interference may be employed, provided the laboratory demonstrates that it more accurately measures cyanide
through quality control measures described in the analytical test method. Any removal or suppression technique not described in
D7365 -09a or the analytical test method must be documented along with supporting data.
7For dissolved metals, filter grab samples within 15 minutes of collection and before adding preservatives. For a composite
sample collected with an automated sampler (e.g., using a 24-hour composite sampler; see 40 CFR 122.21(g)(7)(i) or 40 CFR Part
403, Appendix E), filter the sample within 15 minutes after completion of collection and before adding preservatives. If it is known or
suspected that dissolved sample integrity will be compromised during collection of a composite sample collected automatically over
time (e.g., by interchange of a metal between dissolved and suspended forms), collect and filter grab samples to be composited
(footnote 2) in place of a composite sample collected automatically.
"Guidance applies to samples to be analyzed by GC, LC, or GC/MS for specific compounds.
"if the sample is not adjusted to pH 2, then the sample must be analyzed within seven days of sampling.
90The pH adjustment is not required if acrolein will not be measured. Samples for acrolein receiving no pH adjustment must
be analyzed within 3 days of sampling.
"When the extractable analytes of concern fall within a single chemical category, the specified preservative and maximum
holding times should be observed for optimum safeguard of sample integrity (i.e., use all necessary preservatives and hold for the
shortest time listed). When the analytes of concern fall within two or more chemical categories, the sample may be preserved by
cooling to <-6 °C, reducing residual chlorine with 0.008% sodium thiosulfate, staring in the dark, and adjusting the pH to 6-9; samples
preserved in this manner may be held for seven days before extraction and for forty days after extraction. Exceptions to this optional
preservation and holding time procedure are noted in footnote 5 (regarding the requirement for thiosulfate reduction), and footnotes
12, 13 $regarding the analysis of benzidine).
If 1,2-diphenylhydrazine Is likely to be present, adjust the pH of the sample to 4.0 f0,2 to prevent rearrangement to
benzidine.
„Extracts may be stored up to 30 days at <0 °C.
"For the analysis of dlphenylnitrosamine, add 0.0080% Na2S2O3 and adjust pH to 7.10 with NaOH within 24 hours of
sampling -
"The pH adjustment may be performed upon receipt at the laboratory and may be omitted if the samples are extracted within
72 hours of collection. For the analysts of aldrin, add 0.008% Na2S2O3
15Place sufficient ice with the samples in the shipping container to ensure that ice is still present when the samples arrive at
the laboratory. However, even if ice is present when the samples arrive, immediately measure the temperature of the samples and
confirm that the preservation temperature maximum has not been exceeded. In the isolated cases where it can be documented that
this holding temperature cannot be met. the permittee can be given the option of on-slte testing or can request a variance. The
request for a variance should include supportive data which show that the toxicity of the effluent samples is not reduced because of

the increased holding temperature. Aqueous samples must not be frozen. Hand -delivered samples used on the day of collection
do not need to be cooled to 0 to 6 °C prior to test initiation.
"Samples collected for the determination of trace level mercury (<100 ng/L) using EPA Method 1631 must be collected in
tightly -capped fluoropolymer or glass bottles and preserved with BrCI or HCI solution within 48 hours of sample collection. The
time to preservation may be extended to 28 days if a sample is oxidized in the sample bottle. A sample collected for dissolved
trace level mercury should be filtered in the laboratory within 24 hours of the time of collection. However, if circumstances
preclude overnight shipment, the sample should be filtered in a designated clean area in the field in accordance with procedures
given in Method 1669. If sample integrity will not be maintained by shipment to and filtration in the laboratory, the sample must be
filtered in a designated clean area in the field within the time period necessary to maintain sample integrity. A sample that has
been collected for determination of total or dissolved trace level mercury must be analyzed within 90 days of sample collection.
18Aqueous samples must be preserved at :56 °C, and should not be frozen unless data demonstrating that sample
does not adversely impact sample integrity is maintained on file and accepted as valid by the regulatory authority. Also, for
purposes of NPDES monitoring, the specification of "5°C is used in place of the "4 °C' and "<4 °C" sample temperature
requirements listed in some methods. It is not necessary to measure the sample temperature to three significant figures
(1/100th of 1 degree); rather, three significant figures are specified so that rounding down to 6 °C may not be used to
meet the :56 °C requirement. Them preservation temperature does not apply to samples that are analyzed immediately (less
than 15 minutes).
19An aqueous sample may be collected and shipped without acid preservation. However, acid must be added at least
24 hours before analysis to dissolve any metals that adsorb to the container walls. If the sample must be analyzed within 24
hours of collection, add the acid immediately (see footnote 2). Soil and sediment samples do not need to be preserved with acid.
The allowances in this footnote supersede the preservation and holding time requirements in the approved metals methods.
20To achieve the 28 -day holding time, use the ammonium sulfate buffer solution specified in EPA Method 218.6.
The allowance in this footnote supersedes preservation and holding time requirements in the approved hexavalent chromium
methods, unless this supersession would compromise the measurement, in which case requirements in the method must be
followed.
21Holding time is calculated from time of sample collection to elution for samples shipped to the laboratory in bulk and
calculated from the time of sample filtration to elution for samples filtered in the field.
22 Sample analysis should begin as soon as possible after receipt; sample incubation must be started no later than 8
hours from time of collection.
23 For fecal coliform samples for sewage sludge (biosolids) only, the holding time is extended to 24 hours for the following
sample types using either EPA Method 1680 (LTB -EC) or 1681 (A-1): Class A composted, Class B aerobically digested, and
Class B anaerobically digested.
24The immediate filtration requirement in orthophosphate measurement is to assess the dissolved or bio -available form
of orthophosphorus (i.e., that which passes through a 0.45 -micron filter), hence the requirement to filter the sample immediately
upon collection (i.e., within 15 minutes of collection). [38 FR 28758, Oct. 16, 1973

Ash Basin Capacity Calculations

Duke Energy Company
Marshall Steam Station - Ash Basin Forecasting
2014 Wet Weather Detention Volume Calculation
Determination of Wet Weather Detention Volume: Wet Weather Detention Volume is the sum of the
runoff accumulated in the ash basin which results from a 10 -yr 24 -hr storm (assuming 100% runoff) plus
the maximum 24 -hr dry weather waste stream which discharges to the Ash Basin (refer to NPDES Permit
NC0004961)
I. Estimate Runoff to the Ash Basin from a 10 -yr 24 -hr storm:
1. Natural Drainage Area of Ash Basin = 1180.0 Acres
Station Yard Drainage Area Pumped to Ash Basin = 14.7 Acres
Total = 1194.7 Acres
2. Precipitation from 10 -yr 24 -hr storm 5.0 Inches
3. Total Stormwater Runoff to Ash Basin P97.79 Acre -fee
(Assuming 100% runoff)
Estimated Maximum 24 -hr Dry Weather Waste Stream Discharging to Ash Basin:
1. Maximum recorded Ash Basin Discharge = 11,200,000 Gallons/day
2. Increase maximum daily disharge by 10% for
conservatism and convert units to acre-feet = 7.81 Acre -fee
Wet Weather Detention Volume:
Sum of Parts I. and II. = 35.60 Acre -feed
Estimated Quantity of Solids (Ash) to be discharged to Ash Basin through December 31, 2020.
Note: NPDES Permit expiration date is 4/30/2015.
Time Period
Actual or
% Ash
Estimated
Estimated
Estimated
Estimated
Estimated Coal
Total Ash
Ash Sent to
Ash
Ash
Consumption
Production
Structural
Discharged
Discharged
(1000's tons)
(1000's
Fill or Lined
to Ash basin
to Ash basin
tons)
Land Fills
(1000's
(Acre-feet)
(looms
tons)
tons)
2014 Jun -Dec
2744.79
10.00%
274.48
233.31
41.17
34.37
2015
3642.73
10.000/6
364.27
309.63
_ 54.64
45.61
2016
4106.74
10.000/6
410.67
349.07
61.60
51.42
2017
3495.78
10.001/6
349.58
297.14
52.44
43.77
2018
1 2442.76
10.00%
244.28
207.63
1 36.64 1
30.59
2019
2371.18 1
10.00%
1 237.12
201.55
35.57
29.69
2020
2406.97 1
10.00%
1 240.70
204.59
36.10
1
30.14
Total
21210.94 r
10.00%
1 2121.09
1802.93
318.16
265.60
* Calculation assumes an in-place ash density of 55 lbs. per cubic foot.

V
Duke Energy Company
Marshall Steam Station - Ash Basin Forecasting
2014 Wet Weather Detention Volume Calculation
Estimated Total Storage Volume Required through 2015:
Wet Weather Detention Volume = 535.6 Acre-feet
Estimated Solids to Ash Basin = 265.6 Acre-feet
Required Storage Volume Through 12/31/2020 = 01.2 Acre -feed
VI. Results:
Ash Basin @ Pond Elevation 793'+9" = 849.9 Acre-feet
Total Available Storage = 49.9 Acre -fee
Note: Available Storage based on basin survey dated 8/13/2014
Available Storage> Required Storage
Based on these c3lcula#ions, there Is sufficient capacity in the: ash basin to provide the retention
volume specified in the permit through the year 2020.

LEGEND:
DUKE ENERGY PROPERTY BOUNDARY
ASH BASIN WASTE BOUNDARY
LANDFILL/STRUCTURAL FILL BOUNDARY
ASH BASIN COMPLIANCE BOUNDARY
ASH BASIN COMPLIANCE BOUNDARY COINCIDENT
WITH DUKE PROPERTY BOUNDARY
-- --- -- STREAM
--- --- -- TOPOGRAPHIC CONTOUR (4 -FT INTERVAL)
ASH BASIN COMPLIANCE GROUNDWATER
MONITORING WELL
SEEP SAMPLE LOCATION
AL NPDES OUTFALL LOCATION
NOTES: QUALITY
1. PARCEL DATA FOR THE SITE WAS OBTAINED FROM DUKE ENERGY REI,
2. WASTE BOUNDARY AND ASH STORAGE AREA BOUNDARY ARE APPROI
3. AS -BUILT MONITORING WELL LOCATIONS PROVIDED BY DUKE ENERGY
4. COMPLIANCE SHALLOW MONITORING WELLS (S) ARE SCREENED ACRI
S. COMPLIANCE DEEP MONITORING WELLS (D) ARE SCREENED IN THE ASIN
6. TOPOGRAPHY DATA FOR THE SITE WAS OBTAINED FROM NC DOT 6
7. AERIAL PHOTOGRAPHY WAS OBTAINED FROM WSP DATED APRIL 2014INA
8. THE COMPLIANCE BOUNDARY 15 ESTABLISHED ACCORDING TO THE C
DAA%:
OCTOBER 27, 2014
FI::JRE
1

Ash Basin
..................
. .. . . . . . . . . . .
Marshall
/Steam Station
F
14.0 (Downstream)
15.9 (upstream)
;V_
CD
Cj_
�5yr
t
FAIR 1-7
le
j surface water sampling Locations
Note:
1. Surface water sample locations provided by
Duke Energy Carolinas, LLC.
2. USGS, 1993, Lake Norman 24K Quad.
SCALE (FEET)
Feet
0 1,000 2,000 4,000
DATE
SURFACE WATER QUALITY SAMPLE LOCATION October 1, 2014
MARSHALL STEAM STATION FIGURE
HDR Fgl .. d.g, I— DUKE ENERGY CAROLINAS, LLC
W th. C-11..
CATAWBA COUNTY, NORTH CAROLINA 2
6f0 SWIM -r Chaff .N-2

t DUKE
• ENERGY®
Oct. 9, 2014
Mr. Jeff Poupart
North Carolina Division of Water Resources
NPDES Wastewater Unit
1617 Mail Service Center
Raleigh NC 27699-1617
Subject: Duke Energy Carolinas LLC — NPDES Permit Application
Marshall Steam Station - #NC0004987
Dear: Mr. Poupart:
Marshall Steam Station
8320 Highway 150 E:
Terrell NC 2862
0 828.478.7700
r: 828.478.7679
Duke Energy Carolinas, LLC request the subject permit be renewed and issued. The above
referenced permit expires on April 30, 2015. As mandated by North Carolina Administrative
Code 15A NCAC 2 H.0105 (e), this permit application for renewal is being submitted at least
180 days prior to the expiration of the permit.
Please find enclosed in triplicate, the renewal application, which includes the following items:
EPA Form 1
Outfall Locations Map
EPA Form 2C
Water Flow Diagrams
Supplemental Information
Balanced and Indigenous Population Report (316 a)
Alternative Schedule Request for 316 (b)
Fish Tissue Monitoring
Metals Sampling in the Vicinity of Ash Basins
Ash Basin Capacity Information
Seep Information
Groundwater Information
RECEIVED/DENR/DWR
OCT 15 7.014
Water Uuality
Permitting Section
Duke Energy Carolinas, LLC requests notification that this application is complete.
As required by Part A (15) of the current NPDES permit Duke Energy request that the 316 (a)
thermal variance be continued through to the next permit. The attached Balanced and
Indigenous Population Report (BIP) continues to indicate that Lake Norman supports a
balanced and indigenous population of fish and macro -invertebrates. The BIP also satisfies the
four questions required by the 1988 Kaplan Memo for renewal of the thermal variance.
Therefore, Duke Energy believes the BIP supports the request for renewal of the thermal
variance.
The following monitoring reductions are requested at Outfall 002 and Outfall 004 based on
historical monitoring data.

• Reduce the sampling frequency for Selenium at Outfall 002 from weekly to
monthly
• Reduce the sampling frequency for Selenium at Outfall 004 from weekly to
monthly
S`i/nnccerely�,
Brian Weisker
General Manager III
Regulated Fossil Stations
RECEIVEDIDENR/DWR
OCT 1 5 2014
water Quality
Permitting Section

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gg]]{t•?,s;a.� • �. '� Sleam Station{•� •� _�T ; , ` ` Y, ' .
L7r ~///� i �.r•ti 1: k� ;.�.L Y:T''/fR16•��• •�' L.. ,
}'�•N1'
�
• at tel,', �l�ly:�j}�!•,•.4yi .�:r, y xr'l rrt++ j �r ffl-.kvr"
.74
t,•1t'P/r*iii' -,c1g t sl r. •,.. ,� ,
•tP�t t �tl , f 'i l� 4 " /. l/•' `t�+pp1Y• t °•,/Ter °t/sf ^'i .Kt.�'�Ya,�i•Yr�v�q
�! r*. O t s. '•9. . t� �r ;`i
V.
• ��`3�+`�Fa��J 9 "'�` n (f O% s �. Legend
� _> i� f,: �+ , + ✓;�� w = # NpDF.S OBNaA LacaUon
M S !t' ]k r a +• ,!n �'t gay ia�t,'p ti 4 t + � , J,- ,
is y `„ , i t •� q t "+ ® NPOCS OuifsW Number
Eamgy Wopotty Haundasy
..n� • ty -i' ' �1 .�j / ti +tL �' ;b,►i I � � � _ " ''%'i t t .�
p£FEAFJy10E: L �'
BALKMOIND'FA'rA.USGS7GPOGRAPni000A9, WAS 00TAWCQfMUX WTGECGWj1ICAL Kilometers
WRWhlATION IG@II WEBSNTE THE NM101•ERTYDATA WASOVAR&B FROUTM CATAWBAWiNNY L
NORTH CAMLINA41% VEOMMENT PLEASE NOTE TMS DATA 19FOR W-0A'Aft7KKALP0JPPGSESCKY 0 0.5 1
t4le5
ZXMASIGVRE
IATE' AP SHOWN LOCATION MDUKE ENERGY >
TATE 10-15.2409 Duke MARSHALL STEAM STATION
sRna Nfta RDP NPDE.S # NCO004987
)FDACT Asa: Energya MARSHALL STEAM STATION
1411-06.140 CATAWBACOUNTY, NORTH CAROLINA ,

EPA 4D. NUMBER (rant /ism item I ofFwm I) Form Approved.
Please print or type Inttteunshaded areas only, NC4004987 OMB No. 2040.0086.
ECAPp� expires 3.31-98.
FO(RM� ❑ U.S. ENVIRONMENTAL PROTECTION AGENCY
2C VSLEP "► EXISTING MANUFACTURING, COMMERCIAL, NSNING AND CATION FOR PERMIT TO DISCHARGE WASTEWATER LY CU SILVICULTURE OPERATIONS
NPOES Consokweef A mail Program
I OUTFALL LOCATION
For each oulfal, list the latitude and ION -duds d As Ioeadon to the nearest 13 seconds am the framed the receiving water.
A. OUTFALL NUMBER B. LATITUDE C. LONGITUDE
(r"r) 1 GEC+ 2. WN. 3. S Ee. 1. CEa 2 sgN 9. sEC. D. RECEIVING WATER (name)
001 35 35 42 80 57 49 Lake Norman
002 35 36 22 80 57 40 Lake Norman
002A/002B 35/35 35/35 55/54 80/80 57/57 52/52 Lake Norman (Intermittent)
003 35 35 51 80 57 45 Lake Norman
304 35 36 38 80 58 09 Internal Outfall to 002 to Lake Norman
It, FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECFOJOLOG115
A labeled
a line drawing to the the water now through the fae+lity. Indicate sources d intake water, operations wnftibuting wastewater to the efA ML and treatment ur: s
labeled M eorraspond to the more detailed descriptions In Item B. Construct a water balance on the line drawing by showing average Bows between intakes, operations,
treatment units, and outfalls. ff a water balance cannot be determined (a g., for cetfa)n mining achvrties). provide a pictorial desaip M of the rtalve end amount d any
sources of crater and arty cotiection of treatm m measures.
8 For each outfall, protide a desafptian of (1) A0 operations contributing wastewater to bre effluent, inducing Process wastewater, sanitary wastewater, coding water.
and s�ry water runoff; (2) The average Bow, contributed by each operation; and (3) The treatment received by the wastawrder. Contnue on addi0padnal sheets if
1. OUT. 2.OPERATIORW CONTRIBUTING FLOW 3. TREATMENT
FALL b. AVERAGE FLOW
NO, (list) a OPERATION (rlst) (iadnwk Veils) a, DESCRIPTION b. LIST CODES FROM
ccndevaz cooliag water TABLE 20-1
W1945.9 MCL �: roan dla thargl co aur ate wtic
(OOca through non -contact) -
4A
ARM basin dls:harga wir't santiary 7.7 "W chemical coagularton, ■ecttieg, nrurall:at on..
ZD 2t
system effluent and storm went ion exchange, surface rater diac.'urge
I5r
2.
4A
fber9aney Qverfl0r of yard drain 7nteralttent auctara water discharge
4A
aumP 11 (002A) and auaP e2 (00211)
5aa auoolement.l J.F.—i— I
003
.F. ..i-
003 Induced draft fan eontzol 0.2 MDD surface water discharge
house coaling tures
4A
(ooca through non-eoncacti -
004 Constructed rraataeat mtlanda 0,17 MW sedimentation
:r1iR-crur,,�vrcb)
EPA Form 3510.20 (a .90) PAGE 1 d4 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
C Except far storm runoff, leaks, er spills, are any of the discharges described in Items II -A or B intermittent or seasonal?
® YES (ctvtjdoe tbe,61A_,mg table) ❑ NO (},t) ln,SftWtw 111)
3.FREQUENCY 4 FLOW
a DAYS PER B TOTAL VO ' ME
2.OPERATIONIp WEEK I b MONTHS a. FLOW RATE (Ia.,#:4 (rpwfywi:h�ai
1 OUTFALL CONTRIBUTING FLOW (yrehslt• PER YEAR 1 LONG TERM 2. MAXIMUM 1. LONGTERM 2 MAXIMUM tX1RATe0N
NUMBER (bra) (fill) m+hnor) Gpec+$`nenrgel AVERAGE ONG+r�yl
002A Emergency overflow of yard drain sump See
e1 (see supplmental information} Supple=
mental
Informat-
ion
002B Emergency overflow of yard drain sump See
92 (see supplmental information) Supple.
mental
Informat
ion
III PRODUCTION
A. Does an effluent guideline Wruitatlon promulgated by EPA under Section 304 of the Clean Water Act apply to your taaIW
® YES (camphr,1A..Iff-B) ❑ NO (Lw laSLtrkm 119
B. Aro the limitations in the applicable effluent guideline expressed in terms of production (oradw measure olo0erabbn)7
❑ YES (ros*,L lrrm ll!•C7 ® NO (w, rn.Sreurur 119
C H you answered 'yes' to Item IIk8, list the quantity which represents an actual measurement of your level of production expressed in the terms and units used In the
applicable effluent guideline, and indicate the affected odlals.
L AVERAGE DAILY PRODUCTION
a. QUANTITY PER DAY
LY
AVERAGE
DAILY
(spectd. )
See
NA
See -
IV. IMPROVEMENTS
See
Supple-
by any Federal State er local
Supple-
Supple-
mental
mental
mental
Informat•
Informat-
Informat
ion
ion
=ion
See
Bee
see
Supple-
Supple-
Supple-
mental
mental
mental
Informal-
informat-
Informat
ion
ion
-ion
III PRODUCTION
A. Does an effluent guideline Wruitatlon promulgated by EPA under Section 304 of the Clean Water Act apply to your taaIW
® YES (camphr,1A..Iff-B) ❑ NO (Lw laSLtrkm 119
B. Aro the limitations in the applicable effluent guideline expressed in terms of production (oradw measure olo0erabbn)7
❑ YES (ros*,L lrrm ll!•C7 ® NO (w, rn.Sreurur 119
C H you answered 'yes' to Item IIk8, list the quantity which represents an actual measurement of your level of production expressed in the terms and units used In the
applicable effluent guideline, and indicate the affected odlals.
L AVERAGE DAILY PRODUCTION
a. QUANTITY PER DAY
b. UNITS OF MEASURE
m OPERATION, PRODUCT, MATERIAL, ETC.
(spectd. )
NA
NA
IV. IMPROVEMENTS
A. Are you now required
by any Federal State er local
authorityto mod Implementation
NA
2. AFFECTED OUTFALLS
(lilt ewordf rwvfurs)
tmalment equiprnent or Practices or any other environmental programs Which y ed the discharges
for the corrsbucGam upgradaq or operations Of wastewater
may charges described in this appficat!W Thur includes, but is M limited to,
permit eatditiusus. adrruMislrative or enfoneement orders. enforcement murtprance schedule leCen, stipWtMions, coon aurora, and gram or baro s
❑ YES (caeupfere rhefirlWu-isr mbre) ® NO U. ru Item 1) -B)
1. IDENTIFICATION OF CONDITION, 2. AFFECTED OiTfFALLS 9 BRIEF DESCRIPTION OF PROJECT
AGREEMENT, ETC.
a NO I b SOURCE OF DISCHARGE
B- OPTIONAL You may attach additional sheds describing any additional water pollution ca iugq programs (or Other environmental
drseharges) you now have underway or which your plan. kkicals whether each program is now underway or planned and indicate your
mvatnuction
❑ MARK W IF DESCRIPTIf3N OF AODITIONAl.- CONTROL PROGRAMS IS ATTA :IED
EPA Farm 3910.20 (8.90) PAGE 2 Of 4
4. FINAL COMPUANCE DATE
a REGI FED i b. Fiit1JECTED
s WINCh may 81fect your
or planned scheWas far
CONTINUE ON PAGE 3

- rorm aaIwlvu jc-vu) PAGE 3 d a CGNTWLIE OW REVERSE

CONTINUED FROM THE FRONT
1. BIOLOGICAL TOXICITY TESTING DATA
Do you have any knowledge or reason to Wow that any biological test for acute or chronic taAcIty has been mase on any or your disCharges or on a receiving water §n
relation to your discharge within 0u last 3 years?
® YES (1Awg6• the reiro and ,leserrhe Their perp ues hrl(m) ❑ NO (pp w Secmw 11114
Quarterly analysis of Cericdaphnaa Dubia chrtnic teasing per current permit requarementp on outfall •:. .,.
'All. CONTRACT ANALYSIS INFORMATION
Were any of Lha analyses reported In Rem V pedowned by a contrad tattoratory or oMWAng firm?
® YES (lar rhe name. adJrras mxl fell*. number e f and pallxmau mm)1_cd bj ❑ NO (Rn ro Secthw L1}
rack such Wwrutan• edam belrnr)
A. NAME B ADDRESS C TELEPHONE 0. POLLUTANTS ANALYZED
(ame code ri n e) lost)
Shealy Environmental 1:9 vantage P=int Urlve 101-791-9703 BDD,color,sulfide,sulfite,
Services,Ine. Hest Columbia, SC 29172 fecal eoliform,surfactants,
cyanide,phanol,volati es,
aemi-volatile,acid
eoapoundu,PCB3.pe9tie2des,
mercury
5435 Environmental Services, Inc. 5500 Business Dr. 910-350-1903 Dioxin
Nilmington, HC 28405
OEL Laboratories LLC 2040 Savage Road 043-556-8171 Radiological
Charleston, SC 29417
Duke Energy Analytical 13339 Hagers Perry Road 980-075 5275 Hetals,COD,TIn3r,oil i
Laboratory Hunte=avllle, RC 20079
grease, tOLal
phoaphorous,TSS,'TOC,
bromide,aulfate,fluoride,
nitrate-nitrite
ut CERTIFICATION
) cat* underpenany Oft w 2W this doeunw t and ak aKacrretaattt wee prepared UnderaW din nkm or supervision in aceordance with s system designed to esarar 6WY l7 er and smkrate the htlbrmstiar salupifW D&W on mY fly of ft parson or persons who manage Urs system or those parsons
ens giant eS rg ftfo MMAA", ft bdonnahm s 01*1rdis, to fthest of my knowtadge and Wd, hue, amirats, and aomplefe. ) am aware that chane
kir subrie p take Mlbr—ft 6tdudirtp ft POSs)br7IY &Me And imprfsoruhent Iix knowhV v)datins.
A. NAME 6 OFFICIAL TITLE (Ope nr prinrB PHONE NO (area axle h ria.)
Brian Hefaker, General Manager III., Regulated Fossil Stations [phone]
C S TIJRE 0 DATE SIGNED
EPA Form 3510.2C (9-90) PAGE 4 or 4

PLEASE PRINT OR TYPE IN THE UNSHADED AREAS ONLY. You may report some oral of
tus information on separate sheets (use the same format) instead of completing these pages.
SEE INSTRUCTIONS
EPA I.D. NUMBER (copy from Item 1 of Form 1)
EPA Facility Name:
NCOOD4987 Marshall Steam Station
OUTFALL NO.
, INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 of Form 2-C) 1001
PART A - You must provide the results of at least one anal 's for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.
-
2. EFFLUENT
1 3. UNITS
4. INTAKE (optional)
1, POLLUTANT
a. MAXIMUM DAILY VALUE
b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVG. VALUE
a. LONG TERM AVG. VALUE:
(/ avail"(
llf available)
d. NO. OF
a. Ccrwerr
b. Abss
b. NO. OF
11J
12)Man
(t)CO"nVamn
(2)Mass
(1)cawwwaiaf
(?)Mass
(1)cwcw&atlam
12)Mm
ANALYSES
(ration
ANALYSES
eWdW01l0h0Xyaen
_� 2
< 24417,5
1
AMP
IWDay
2
1
uM (e0u)
cnaal�.lo yoa�
20
244174,7
1
Fro
IF9
'20
1
d ICOR?
_
10 N OTGOAM
2.4
z w1.a
1
mg/l
IwDay
24
1
TOW &.spenow
S
61043.7
1
mgll
IbrDey
a 5-
1
(155)
Aevnaaa(nNJ
- 0.076
9279
1
mo
IWDay
FI"
VALUE
VALUE
VALUE
VALUE
e;a
1411.a
1a{5.0
730
MGD
JWA
ranyeaa.e
VALUE
VALUE
VALUE
VALUE
adder)
_
180
DEGREES CELSIUS
Temp",hre
VALUE
VALUE
VALUE
VALUE
_
04e1
160
DEGREES CELSIUS
pN
MMI(MUM
IMAXIMUM
MINIMUM
IMAXIMUM
-
e
STANDARD UNITS
71
ART B - Mark 'r in column 2a for each poilutant you know or have reason to believe is present. Mark 'X' In column 2b for each pollutant you believe to be absent. If you mark column 2a for any
pollutant which Is limited either directly or indirectly but expressly In an effluent limitations gWdeline, you must provide the results of at least one analysis for that pollutant Forother pollutants
for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each Sultan See the instructions
for additional details and requirements.
1, POLLUTANT
z MARK'X`
1 3. EFFLUENT
4. UNITS
S. INTAKE fopltonal)
AND CAS NO.
swvw
a. MAXIMUM DAILY VALUE
b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVG. VALUE
a. LONG TERM AVG. VALUE
Iffi.pM
n.b.
a avWWkI
IN evaaaarel
Nr aysaaue)
d. NO. OF
a. Conomr
b. Mass
b. NO. OF
(4concawnum
141616a
111eawaft*0
(21 Man
1JCara:an*n
t2)LLtm
1)Cacentmilm
(2)MM
sem
Sera
ANALYSES!
traflon
ANALYSES
eradde
X
�_ 0.10
t 1220.9
1
Wo
busy
Z.J 0.10
1
2kfi7.8)
Caaab.
X
t O OS
_,
a 610.4
1
mge
b9ay
�E' 0.03
.
1
-oW Resld,ar
Coin
X
x. 25.0
WA
WA
WA
1
Std. Urns
WA
25.0
WA
:.Fecal
X
10.0
WA
WA
WA
1
cdonles
WA
"- 9.00
WA
1
=�^
1100 ml
. Flualae
X
s „-- � 0.10
< 12209
1
nVfi
Ib Day
. c- 0.10
1
ms9e�eo-e)
Narate
X
0.32
365fi.0
1MO
",,y
- 0.31
1
ae (n N)
EPA lam 3519-2C (Rev. 245) PAGE V-1 CONTINUE ON PAGE V2

r
PA I.D. NUMBER;oopy from Item 1 of Form 1� OUTFALL NUMBER
W% F brlogm4gaz I gal station
K -x-
OCANO,S
tl
atN OspsNc
I N)
as F). TOW
7723.1441)
ItaJ�erarr
aPw
MR
a, KAAX*AUM DAILYVALUE UE
b.9w-
Sm f+)f4s+recroaaaa (2) mm
b. MAXIMUM 30 DAY ALU C. LON TERM AVG. VALUE
(ifavalwo) (ifar4isNel
, COwroatAn
(2)Man (11r + +lp++
t1)Ma4f
n
0.sz tl209.7
man
INDey
0.54
X
5.W s tl1W3.7
1
m9n
IWDay
x
0.033 402.0
1
t
man
d. NO, OF
ANALYSES
a.Conray.
tration
b Mass
a LONG TERM AVG VALUE
b. NO. OF
ANALYSES
)t)Csnac, W,12)man
WA
man
INDey
0.54
NIA
1
1
m9n
IWDay
5.0U
1
t
man
Ihn]ay
0.032
po
1
X
5.00
NIA
WA
NIA
1
pCN
NIA
5,w
NIA
1
1
eIa!
x
590
NIA
NIA
NIA
1
PCIA
NIA
8.00
NIA
1
141
X
1.00
NIA
NIA
NIA
1
NO
NIA
1.00
NIA
7
Rob-
, TOW
x
1.00
MA
INA
NIA
1
pcin
WA
1.00
NIA
I
AN
as sm)
1490&79.9)
X
4.50
58801.0
1
mo
IOIDay
3.80
1
as Sl
X
100
< 12108.7
1
"ll
May
4.10
1
9426645.3)
x
200
< 24417.5
t
aw
IbQay
zw
1
A
0.05
tl1UA
1
man
0d0ay
0.092
1
«a+
3429,90
n
0.870
1Utl 19
1
mall
INDay
0.890
7
a+a+
7410.99.3)
X
0.018
2109
1'
man
Iwo"
`0.017;
,
1
go
144o -42-a)
X
0,074
117)8.4
1
m911
May
0.050
7
.otl
7"0-46-4)0.001
x
12.2
7
man
"Mosy
O.W1
1
..
143"U)
x
a77s.
05109
1
man
Ih+Oay
M750
,
7431-95.4)
x
1.0
1'd55'LO
1
milli
Ibm w
1.54
1
a43M&TI
12.2
1
ma4
IWO"
0.901
7
oW
143M")1
x
m 0.037'
459.7
mgm
Wft
0.020
1
7440-39.5)
X
3M 0.010
a M.1
1
mom
May
1
0.010
atal
X
0.0X7
129.8
t
f441F1ldi)
man
IOIDay
0.028
1
EPA Fom 351&2C (Ray. 2451
PAGE Y•2
CONTINUE ON PAGE
V-3

FPA I,D. NUIIABER(copybam nem 1 of Form td OUTFALL NUMBER
CONTINUED FROM PAGE 3 OF FORM 2•C NCO004987 1 001 Marshall Steam Station
P,q,RT C - If you are a primary industry and This oulfail contains Process wastewater; refer to Table 2c-2 In the instructions to determine which of the GCJMS frachons you must test for, Mark 'X' to
column 2a for at such GC/M5 fractions that apply to your industry and (of ALL toxic metals, cyanides, and total phenols. K you are not required to mark column 2-a (secondary Industries,
nonprocess wastewater outfalls, and nomequked GC/MS fractions), mark W In column 2-b for each pollutant you know or have reason to believe Is present. Me* 'X' in column 2-c for each
pollutant you believe is absent. H you mark column 2a for any potkdanL you must provide the results of at least one analysis for that pollutant. fl you mark column 2b for any pollutant, you
must provide the results of at least one analysis for that pollutant if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater, If you mark column 2b for
acrolein, acrytonitrde, 2, 4 dinitrophenxa, or 2-methy14, 6 dnilrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to
belleve that you discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for witch you mark column 2b, you must either submit at least one analysis or briefly describe the
reasons the pollutant is expected to be discharged. Note that there are 7 pages to this pad; please review each carefully. Complete one table (all 7 pages) for each outfall. See instructions
for additional details and requirements.
1. POLLUTANT
2. MARK W 1 3. EFFLUENT
4, UNITS
5. INTAKE (oplic")
ND CAS NO.
.no-
ewerw Is. MAXIMUM DAILY VALUE
b. MAXIMUM 30 DAY VALUE TERM AVG. VALUE
ay LONG T ERM AVG. VALUE
t(evol")qulr-
b -pa c atr
tLONG
(11 "khA b) M OV011016)
d. NO. OF
a. Careen.
b. Mass
d. NO. OF
ea
sod am .1)Corleal+srauiall (21Mas
(1lCwzWWzeor,1(2)Mm Ill) CWK0ir nal121 Mess
ANALYSES
eatbn
(1)Cmrenauan k2)h ANALYSE
ALS, CYANIDE, AND TOTAL PHENOLS - - - -
1M, Anwno 1r.
X
< 10
< 12.21
1
MA
wfty
< 1.0
1
aW p44t►�a)
+ . 1.0
#no -T"
X
1,0
< 12.21
1
usn
lb0sy
1
744Q•30.2
1.0
X
to
12.21
-
1
u911
lWay
/
; , 1.0
CACINA 1,
x
< 1.0
< 12.21
r
u0n
IWMy
-
1
tltl (744043-9)
4{ 1.0
CraornkoL
X
F< 1,o
< 1221
1
u911
[Way
1
aW (744047-9)
Lm. OePW,TOM
X
0.005
73.25
1
m0A
lbfDsy
0.005
1
'440.5M)
< 1.0
1u, Lead, TOW
X
_= 1
< 12.21
1
UQA
Ib7Day
1
7439.92-1)
Mrnay. TOW
X
0.1)018y ,
0,02
1
U0
Ibovy4.00153
1
1.0
x+, jaw
x
1,0'
< 12.21
1
U0A
IdDay
1
7440-02-0)
1044, 5eIwa^
X
;' 1.0
< 12.21
1
LOA
IKI"
T"M8249-2)
s` 1.0
Ism,Serer,:Tow
X
c_ 1,0
< 12.21
1'
um
IhT"
1
MM4)
12M. Tn iawrm .
X
_ ■ _ 0.001
a 122 -
1
maA
Ib1Day
; 0.001
1
oral sr44a2s�
03AL Zile. TOW
X
0,0049
59.33
i
11194
IWDay
0.0024
1
1444. Cpl�ida.
X
mgA
lw6ey
-+: omo
1
1qy (57.12-s1
I5M. P1WNft;
X
0,0051
82.7
1
m94
lbWay
- 0.02
1
IoW
TOXIN
AJ.BTWS
113ESCMBE RESULTS
'amu&b a PLL
X
�
e 10 1 < 122(>6'7A 1 RBA I Ib1D" 10 1
,w�= (1784018)
VA Fam 3510.20 (mer. 2.651 PAGE V-3 -- CONTINUE ON PAGE V-4

EPA I.D. NUMBER (copy from Ilam 1 of Form OUTFALL NUMBER
rn ITI&I "Cn COMA oer-e v-1 I KIC0604987 1 001 1 Marshall Steam Station
1, POLLUTANT
2 MARKW 3. EFFLUENT 4. UNITS
5. INTAKE optional)
AND CAS NO.
.,s�&W�Awm_
VALUE
b. MAXIMUM 30 DAY VALUE c. LONG TERM AVG. VALUE
a. LONG TERM AVG. VALUE
a antebk►
m+k
=01corwWww"M
(H w4ieb4)d.
NO.OF a. C:otww
b. Mass
j
d, NO.OF
wlan 2)Man (1);212 rcoe 12)Mm
1)Cooeenbetlw� 2 Mna
Man '(1lCwKwc
ANALYSES dalton
ANALYSES
-
CIMS FRACTION
- VOLATILE
COMPOUNDS
1V. Aodit
X
<
(
Up
1
1a7-a2s►
w. AffowM as
X
5 0
01.
9
upA
y
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1
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20
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< 24A2
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2.0
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20
< 24-42-
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up
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- -
-
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24.42
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1
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up
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(74.x7-3)
EPA Form 3510.20 (Res'. 2.55) PA1i(;.'tf4 CONIUM ON PAGE V-5

FPA I.D. t11umBER tcom *cm aem 1 d Form 1 } JOUTrALLNUMBii7
urnnnaanT nn1 Marshall Steam Station
EPA Rain 3510-2C (Rev. 2.95) PAGEV=5 COMMUE ON PAGE V-6
2 MARK W 3. EFFLUENT 4. UNITS 5. INTAKE ioPlfonaq
i. POLLUTANT
AND CAS NO.
5 aveleele)
ur
a
�a
eeFeree a MAXIMUM DAp.Y VALUE
b•P = w
aM sen at)cem.uo. rzl►
b. MAXIMUM 30 DAY VALUE c. LONG TERM AVG. VAWE
ie ••) (e erei4hle)
d. NO. OF z Coral•
ANALYSES tradon
a. LONG TERM AVG. VALUE
n, Mass
11)co�+ 211-
d. NO. OF
ANALYSES
1lca,�w.uon tx)�ns litcd+e.�rrao. I21M+s
=CIMS FRACTION - VOLATILE COMPOUNDS IcOntGwedj
-
z math
�+v�On {T5094)
x
< . 2 0
< 24.42
1
u9n
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i
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< 24.42
$
"n
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(75411.4)
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2
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-
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011Day
T _ 20
i
CJMS FRACTION - ACID COMPOUNDS
SA2i'J�
4x574)
x
t 10
< 122.09
1
uo
IWgay
"* 10
1
w 2 4 ortnoro-
(120432)
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A 4.6-Dw***-
and 1534.52.11
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EPA Rain 3510-2C (Rev. 2.95) PAGEV=5 COMMUE ON PAGE V-6

EPA I.D. NUMBER (copy ham 119M 1 of Form 1) OUTFALL NUMBER
ien ensu nAn-= tl a I Wr.nnnAQAi 1 11111 1 Marshall Steams Station
1. POLLUTANT 12. MARK%(" 3. EFFLUENT 4. UNITS 5,. INTAKE (optbnati
Eng i v n+:S51d71' IWe+,
AND CAS NO. ax
adoved a. MAXIMUM DAILY VALUE b. MAXIMUM 30 DAY VALUE -Tc LONG TERM AVG. VALUE
a. LONG TERM AVG. VALUE
d owslaw) )ear-
b.pe aab. IN avwbe) IN awls@)
d. NO. OF a. Noncan.
b. Mau
d. NO. OF
Sd
ANALY5E5 hagon
tt)Caeeo@nwaen 121 Masa
ANALYZES
sad
Sam (1)C=wW96an (21>aaaa (7)Oarenuaion t2lMaaa It)C [z)S1ass
GC/MS FRACTIO14 - BASE NEUTRAL
COMPOUNDS
,e. AcanaabaEale
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X
I
F-ri 10
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1
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wroay
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9, Acuoph"M
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F
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USA
1 ay
1
7-4") PAGE V-6 CO MUE ON PAGE V-7

EPA Fane 371a4C (flay M) PIWO V•7 CONTINUE ON PAGE V -a
EPA LD. NUMBER (copy bom hm 1 of Fam t)
I
OUTFALL NUMBER
CONTINUED FROM PAGE V -B
NC0004987
001 Marshall Stearn Station
1. POLLUTANT
2. NPM r 3. EFFLUENT 4. UNITS
5. INTAKE (o;p[Abnal)
AND CAS NO.
8.10.
saremd a. MAXIM b. WIMUM 55 UAY v c. LONU I ERM A0. V91uELO
NG TERM AVG-VALUE
eavatlaBle)
pdr.
tfpw G.ab- (ifavaume) 1.%tam t "I, _ _
d. NO. OF a. Canwn-
b. Masa
d. NO. OF
ed
ANALYSES WONT
ANALYSES
awn son (1) atlen (2)M'= (11Concaftoan 1121tdaes (I)Conm*voo+ 1(21 Man
It)Canco+oa+ien 2)Mns
CIMS FRACTION - SASE/NEUTRAL COMPOUNDS (CORUnued)
au 1.44xchia+o- x20 24x42 1 119A IWDay 2.0 t
� (106401 1 F3
- -
%U. 3,3.Oidgam,
x
< 10
< 122.09
1
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4.7)
-
EPA Fane 371a4C (flay M) PIWO V•7 CONTINUE ON PAGE V -a

vn rwm a71va palv..e•wai vAOS V+5
CONTINUE ON FADE V•8
EPA I.D. NUMBER (copy from Ilem 101 Fam 1)
OUTFALL NUM13ER
CONTINUED FROM PAGE V-7_
NCO004987
001
Marshall Steam Station
_ POLLUTANT
2. MARK "X" 3. EFFLUENT
4. UNITS 5. INTAKE (oPMW)
AND CAS NO.
sic -MAXIMUM
DAILY VALUE
b. MAXIMUM 30 DAY VALUE
t. LONGTERM AVG. VALUE
a. LONG TERM AVG. VALUE
BarWe61�)
quir-
6p1s cwr
(iPawrile6le#
I (earai�we► d. NO. OF
a Corceo- b. Matta d- NO. OF
tt)cw=traeon 11'1Mms
ed
sent nea 11)cwcwwatlon (2)um
;1)c"Cowsbw givass ANALYSES
ballon ;1#1 una�waaon I21u1w ANALYSES
"C(MS FRACTION - BASFJMUTRAL COMPOUNDS (Continued)
si' N4ftu-
w+
x
+ ' 10
c 122.08
1
MR
IbSpy
10
Cx•366)
n; Pnpu�ntlwma
X
c. 1f)
< 122.08
1
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10
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56.P"M
x
-c - 10
< 122.02
1
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Way
-<_ 10
t290U4)
e8 1.2,4•Td-
-
.>
X
c 2A
3442
1
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uroay
2.0
1
t21Fa2•q
GCM FRACTION-
PESTICII)ES
op Akim
309092)
304")
91, bOW4W
315857)
P, Downsem
X
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X
-
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-
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IOP. DW"
x
- - -
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-
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x
115.297)
IV, MtCw*uo—
x
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x
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-
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X
-
vn rwm a71va palv..e•wai vAOS V+5
CONTINUE ON FADE V•8

EPA Form 3610•'rC (firs. 2.85) PAGE V-9
EPA I.Q. NUMBER (cwv ham Rein 1 of Farm t)
OUTFALL NUMBER
CONTINUED FROM PAGE V -e
NC0004987
001 _ Marshall Steam Station
1. POLLUTANT 2. MARK W 3. EFFLUENT 4. UNITS 5. INTAKE optlanal
AND CAS NO. a.raeaeevrl a. MAXIMUM DAILY VALUE b. MAXIMUM 30 DAY VALUE Ic. LONG TERM AVG. VALUE a. LONG TERM AVG. VALUE
a ewl") 4uk- o.aro eab• (Aavalahk) (s a al") d. NO.OF a. Concert• b. Mast d. NO, OF
uc--u.6m
w sem wo is>uw ucansamr.lroa a)ruaaa (s>P.oncawasen t2iMala ANALYSES tration tl)Coacamraeon :2)W ANALYSES
CIMS FRACTION -PESTICIDES (contkWW) - -
1rp hwocmw
-
-
-
-
amide
X
ta2a9ra)
uo
leP,waz,s,:
x
rt: am
<
t
57169.21.9) _
_
19P. PCa ,251
X
0.28
<
t
t _ 025
1
no9r•69.1}
ygA
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X
t wx
1
025
1
7L1D1.262}
_
ugn
tP, PCa•tsa2
x
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<
{
illft•16O _
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X
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<
9
* 0.25
1
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X
< _ a28
1
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1
llasuez•s)
U911
'aP.. PC9.1016
X
-41 025
<
1
a:
1
.1267411.2)
_
Tmapana
x
0801-3541
EPA Form 3610•'rC (firs. 2.85) PAGE V-9

VlLtAJt PKIIN I UK I YPE IN THE UNSHADED AREAS ONLY. You may report some or all of
EPA I.D. NUMBER (copy from Item 1 of Form 1)
this information on separate sheets (use the same format) instead of completing these pages.
SEE INSTRUCTIONS
EPA Facility Name:
NC0004987
Marshall Steam Station
V. INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 of Form 2-C)
OUTFALL NO.002
PART A - You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.
2. EFFLUENT
1. POLLUTANT a. MAXIMUM DAILY VALUE b. MAXIMUM 30 DAY VALUE
3. UNITS
Ic. LONG TERM AVG. VALUE
4. INTAKE (optional)
a. LONG TERM AVG. VALUE
(if available)
(if available) d. NO. OF a. Concen- b. Mass
b. NO. OF
(1) Concentration (2)Mass (1) Concentration (2)Mass
a. Biochemical Oxygen < 2
(1) Concentration t Mass ANALYSES tratlon
O
(1) Concentration (2) Mass ANALYSES
< 287.1 0 0.0
"errand
0 0.0 1 mgA Ib/Day
0
(BOD)
b. Chemical Oxygen < 20 < 2870.7 0 O.0
0 0.0 1 mgll IblDay
Demand (COD)
0
Total Organic 1.9 0 272.7 0 0.0
0 0.0 1 mg/I Ib/Day
arbon (TOC)
0
J. Total Suspended 11 0 1578.9 11 0 1578.9
6.1 0 392.0 25 mg/I Ib/Day
Solids (TSS)e.
- 0
Ammonia (as N) 0.28 D 37.2 D 0.0
0 0.0 1 mgll Ib/Day
0
P. Flow VALUE VALUE
VALUE
17'2 17-2
T.7 24 MGD N/A
VALUE
. Temperature VALUE VALUE
VALUE
winter)
VALUE
1 DEGREES CELSIUS
t. Temperature VALUE VALUE
VALUE
summer)
VALUE
DEGREES CELSIUS
pH MINIMUM MAXIMUM MINIMUM MAXIMUM
24 STANDARD UNITS
PART B - Mark "X" in column 2a for each pollutant you know or have reason to believe is Mark "X" in 2b for
present.
column each pollutant you believe to be absent. If you mark column
2a for any
pollutant which is limited either directly or indirectly but expressly in an effluent limitations guideline, you must provide the results of at least one analysis for that pollutant. For
other pollutants
for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions
for additional details and requirements.
1. POLLUTANT
2. MARK
"x"
3. EFFLUENT
4. UNITS
5. INTAKE (optional)
AND CAS NO.
11
Believed
a. MAXIMUM DAILY VALUE
b. MAXIMUM 30
DAY VALUE
c. LONG TERM
AVG. VALUE
a. LONG TERM AVG, VALUE
a.pre-
b.ab-
If available)
(if available)
(if available)
d. NO. OF
a. Concen-
b. Mass
b. NO. OF
'(1) Concentration
(2) Mass
(1) Concentration
(2) Mass
(1) Concentration
(2) Mass
(1) Concentration
(2) Mass
sent
sent
ANALYSES
tration
ANALYSES
a. Bromide
X
3.80
D 545.40
0.0
0 0.0
1
mg/I
Ib/Day
0
24959-67-9)
- -
Chlorine,
X
< 0.05
< 7.2
0 0.0
0 0.0
1
mgllIblDay
0
Total Residual
Color
X
< 25.0
N/A
NIA
NIA
1
Std. Units
N/A
N/A
J. Fecal
X
e 1.00
NIA
NIA
N/A
1
Colonies
NIA
NIA
olifonn
/100 m)
Fluoride
X
0.97
0 139.2
0 0.0
0 0.0
1
mg/I
IblDay
0
1698448-8)
Nitrate-
X
0.60
0 86.7
0 0.00
0.0
1
mgA
Ib/Day
1
0
+iiUite (as N)
EPA Form 3510.2C (Rev. 2-85)
PAGE V-1
CONTINUE ON
PAGE V-2

.,,,, k - ! rr.or= v -c CONTINUE ON PAGE V-3
EPA I.D. NUMBER (copy from
Item 1 of Form 1) OUTFALL NUMBER
ITEM V -B CONTINUED
FROM
FRONT Nrnnn4g87
002
i. POLLUTTP7
2. MARK
W 1
0. IN I AKL
t o -11008.1
AND CAS NO.
Believed
a. MAXIMUM DAILY VALUE b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVG. VALUE
if available)
a,pre-
b.ab- (if available)
(if available) ti. NO. OF
a. Concert-
b. Mass
a. LONG TERM
AVG. VALUE
sent
(1) Concentration 1(2) Mass ANALYSES
tration
b. NO. OF
sent (1) Concentration
(2)Mass
(1) Concentration
1(2) Mass
(1) Concentration
Nitrogen,
(2) Mass
ANALYSES
otal Organic
X
8.60
U 1234.4
8.6
U 1234.4
2.9 0 186.3 25
mg/1
Ib/Day
as N)
. Q1 ano
crease
X
< 5.00
< 717.7
< 5
< 117.7
< 5 < 321.3 8
mg/I
lb/Day
Phosphorous
as P), Total
X
0.800
U 86.1
u.U6
U 8.6
0.03 U 1.9 9
mg11
IbNay
-
-7723.14-0)
-
u
a t 11Y
App a.
1 otal
X
_* ' 5.00
N/A
NIA
NIA 1
pCUI
NIA
NIA
- I eta,
otal
X
5.00
N/A
NIA
NIA 1
pCill
N/A
.�
N/A
I I Radium,
Total
X
""�.. 1.00
NIA
N/A-
NIA 7
pCUI
NIA
a
NIA
arlium
I
Total
X
- ' 058
-
N/A
N/A
N/A 1
PCtll
NIA
_
NIA
N., -,ui ate
----
as SO4)
X
170
U 24400.8
U 0.0
0 0.0 1
mg/I
Ib/Day
0
,14808-79-8)
. au .rue
ass)
X
< 1.110
< 143.5
0 0.0
U 0.0 1
mg/I
Ib/Day
0
.,. ou, Ite
_
as S03)
X
< 2.OU
< 287.1
U U.0
U U.0
1
mg/I
Ib/Day
:l
U
14265-45-3)
ri. Surfactants 8ctants
X
i " 0,050
< 7.2
0 0.0
U 0-0
1
mgfl
lb/Day
0
Aluminum,
otal
X
0.227
U 32.6
0 0.0
0 U.0
1
mg/I
Ib/Day
-
0
7429-90-5)
-an
um,
Total
X
0.076
U 10.8
u U.0
U 0.0
1
mg/I
Ib/Day
0
7440-39-3)
3. Boron,
total
X
7.750
0 1112.4
0 0.0
U 0.0
1
mg/I
Ib/Day
0
.7440-42-8)
_
. Catalt,
_- -
total
X
U.0044
u 0.6
U 0.0
U 0.0
1
mg/I
lb/Day
0
7440.48-4)
-
.Iron, otal
7439-89-6)
X
U 460
U 66.0
0.46
0 66.0
0.41
0 26.3
2
mgll
IblDay
0
t. Magnesium,
-
Iotal
X
67.8
U 9731.6
0 0.0
U 0.0
1
mg/I
Ib/Day
-
0
.7439.95.4)
u. Niolyboenurn.
total
X
- 0.0184
0 2.6
u U.0
U 0.0
1
mg/1
Ib/Day
0
7439-98.7)
r, h,anganese,
otal
X
_: 0.828
U 118.8
U U.0
0 0.0
1
mg/l
lb/Day
u
7439-96-5)
7440-31.5)
X
0.010
< 1.4
U 0.0
0 0.0
1
mgll
lb/Day
u
. itanium,
-
-
otal
0.005
< 0.7
0 0.0
U U.0
1
mgll
lb/Day
0
l44U-3G-8)
.,,,, k - ! rr.or= v -c CONTINUE ON PAGE V-3

EPA I.D. NUMBER (copy from Item 1 of Form 1) OUTFALL NUMBER
CONTINUED FROM PAGE 3 OF FORM 2-CNC0004987 002
Marshall
Steam Station
PART C - If you are a primary industry and this outfall contains process wastewater, refer to Table 2c-2 in the instructions to determine which of the GC/MS fractions must test for. Mark "X"
you in
column 2-a for all such GC/MS fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2-a (secondary industries,
nonprocess wastewater outfalls, and nonrequired GC/MS fractions), mark "X" in column 2-b for each pollutant you know or have reason to believe is present. Mark "X" in column 2-c for
each
pollutant you believe is absent. If you mark column 2a for any pollutant, you must provide the results of at least one analysis for that pollutant. If mark column 2b for
you any pollutant, you
must provide the results of at least one analysis for that pollutant if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for
acrolein, acrylonitrile, 2, 4 dinitrophenol, or 2 -methyl -4, 6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to
believe that you discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for which you mark column 2b, you must either submit at least one analysis or briefly describe the
reasons the pollutant is expected to be discharged. Note that there are 7 pages to this part; please review each carefully. Complete one table (all 7 pages) for each outfall. See instructions
for additional details and requirements.
1. POLLUTANT 2. MARK "X" 3. EFFLUENT 4. UNITS 5. INTAKE (optional)
AND CAS NO. a.re Believed a. MAXIMUM DAILY VALUE b. MAXIMUM 30 DAY VALUE TERM AVG. VALUE a. LONG TERM
AVG. VALUE
if available) qulr- b.pre- c.ab- ('rf available) available)d. NO. OF a. Conced.
j;c.LONG
�tratlon
NO. OF
ed sent sent (1)Concentration (2)Mass (1) Concentration (2)Mass centration (2)Mass ANALYSES (1)Concentration
METALS, CYANIDE, AND TOTAL PHENOLS
(2)Mass 'ANALYSE
1M. Antimony, X < 1.0 < 0.14 0 0.00 0 0.00 1 ug/I Ib/Day
D.00
btal(7440.36-0) - -
',M. Arsenic, Total X 14.7 0 2.11 14.7 0 2.11 7.89 0 0.51 10 ugll Ib/Day
0.00
7440.38-2)
3M. Beryllium, X < 1.0 < 0.14 0 0.00 0 0.00 1 ug/I lb/Day
I'
0.00
otal (7440-41-7)
W. Cadmium, X { 1.0 < 0.14 0 0.00 0 0.00 1 ug/1 Ib/Day
0.00
Total (7440-43-9) --'
5M. Chromium, X ; 1.0 < 0.14 0 0.00 0 0.00 1 ugll Ib/Day
0.00
rotal(7440-47-3)
L.M. Copper, Total X < 0.005 < 0.72 < 0.005 < 0.72 < 0.005 <0.32 3 mgll IblDay
0.00
7440-50.8) '
IM. Lead, Total X f < 1 < 0.14 0 0.00 0 0.00 1 ugll Ib/Day 1
0.00
7439-92-1) '
IM, Mercury, Total X 1.28 0 0.18 1.28 0 0.18 0.73 0 0.05 10 rtg/l Ib/Day
0.00
17439.97-6)
W. Nickel, Total X 10.6 0 1.55 10.8 0 1.55 7.4 0 0.48 10 ug/I lb/Day t0.00
7440.02-0) -
1UM. Selenium, X 6.04 U 0.87 5.7 0 0.82 3.19 0 0.20 103 ug/l Ib/Day
0.00
I otal (7782.49.2) _
11 M. Silver, Total X < 1.0 < 0.14 0 0.00 0 0.00 1 ug/1 Ib/Day
0.00
-7440-22-4)
12M. Thallium, X 0.001 < 0.1 0 0.0 0 0.0 1 mg/1 lb/Day
0.00
Total (7440.26-0)
13M. Zinc, Total X 17.300 0 2483.14 17.3 0 2483.14 1 7.687 0 493.94 26 ug/I IblDay
0.00
7440-66-6)
14M. Cyanide, X 0,010 < 1.44 0 0.00 0 0.00 1 mg/1 lb/Day
0.00
Iotal(57.12-5)
15M. Phenols, X 0,0054 0 0.8 0 0.0 0 0.0 1 mg/I Ib/Day =1
0,00
Total
DIOXIN
,3,7,8 Tetra DESCRIBE RESULTS
Worodibenzo P X < 9.95 < 1428.2 0 0.0 0 0.0 1 -
P9/l IblDay
ioxin (1764-01-6)
EPA Form 3510.2C (Rev. 2-85) PAGE V-3
CONTINUE ON PAGE V-4

EPA I.D. NUMBER (copy from Item 1 of Form 1) OUTFALL NUMBER
CONTINUED FROM
PAGE
V-3
NCOOO4987
002
Marshall
Steam Station
1. POLLUTANT
2. MARK
"X"
3. EFFLUENT
AND CAS NO.
a. re-
Believed
a. MAXIMUM DAILY VRLUE
b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVG. VALUE
4. UNITS
5. INTAKE
(optional)
if available)
quir-
b.pre- c.ab-
(if available)
a. LONG TERM
AVG. VALUE
(-d available)
d. NO. OF
a. Conan-
b. Mass
d. NO. OF
GC/MS FRACTION
ed
- VOLATILE
sent .sent
COMPOUNDS
(1)Concenuation (2)Mass
(1) Concentration (2)Mass
h) concentration 1(2) Mass
ANALYSES
tration
(1) Co
'(L)Rgass ANALYSES
1 V. Acroleln
X
{ - 5.0 1 < 0.72
0 0.00
0 0.00
1
ugll
IblDay
107-02-8)
0.00
V. Acrylonitrile
X
< : 5.0 < 0.72
0 0.00
0 0.00
1
ugh
Ib/Day -
.107-13.1)
0.00
W. Benzene
X
s 2.0 < 0.29
0 0.00
0 D.pO
1
ug/l
IblDay
71.43-2)
0.00
!V. Bis (Chloro-
i�,,elhyl) Ether
X
0
0
0
542-88-1)
D
5V. Bromoform
X
t 2.0 < 0.29
0 0.00
0 0.00
1
ugll
IblDay
75.25.2)
0.00
� V. Carbon
etrachloride
X
c 2.0 < 0.29
0 0.00
0 0.00
1
ug/I
IblDay
56.23-5)
0.00
W. Chlorobenzene
X
2.0 < 0.29
0 0.00
0 0.00
1
ug/l
IblDay -
108-90.7)
0.00
r: -V. Chlorodi-
�romomethane
X
c _ 20 < 0.29
0 0.00
0 0.00
1
ugll
Ib/Day -
124-48-1)
0.00
W. Chloroethane
X
{ 2.0 < 0.29
0 0.00
0 0.00
1
ug/l
----Tb-/Day
75-00-3)
_
-
0.00
1 OV. 2 -Chloro-
-
thylvinyl Ether
X
5.0 < 0.72
0 0.00
0 0.00
1
ug/I
Ib/Day
0,00
110-75-8)
-
11V. Chloroform
X
£ _: 2.0 < 0.29
0 0.00
0 0.00
1
u9/1
lb/Day
0.00
67.66-3)
12V. Dichloro-
romomethane
X
+; 2.0 < 0.29
0 0.00
0 0.00
1
ugh
Ib/Day !7
0.00
7627-4)
13V. Dichloro-
ifluoromethane
X
K ; 2.0 < 0.29
0 0.00
0 0.00
1
ug/I
Ib/Day 71
0.00
75.71-8)
14V.1,1-Dichloro-
X
rt 2.0 < 0.29
0 0.00
0 0.00
1
ug/1
lb/Day
0.00
thane (75-34-3)
_--
15v. 1,2-131chlao-
X
2.0 < 0.29
0 0.00
0 0.00
1
ug/l
Ib/Day - -
0.00
thane (107-06-2)
16V.1,1-Dichloro-
X
.4 2.0 < 0.29
0 0.00
0 0.00
1
ugll
Ib/Day
0.00
thylene (75-354)
17V.1,2-Dichloro-
X
c 2,0 < 0.29
0 0.00
0 0.00
1
ug/I
Ib/Day
0.00
ropane (78-87-5)
18V.1,3-Dichloro-
X
e 2.0 < 0.29
0 0.00
0 0.00
1
ugll
lb/Day
0.00
ropylene (542-75-6)
19V. Ethylbenzene
X
2.0 < 0.29
0 0.00
0 0.00
1
ugh
Ib/Day
0.00
1(H1-41-4)
OV. MethylX
2.0 < 0.29
0 0.00
0 0.00
1
ugh
Ib/Day
0.00
romide (74-83-9)
_
"M Methyl
X
< 2.0 < 0.29
0 0.00
0 0.00
1
ug/l
IblDay
p.pp
-hlodde (74-87-3)
EPA Form 3510-2C (Rev. 2-85) PAGE V-4 CONTINUE ON PAGE V-5

EPA 1. D. NUMBER (copy from Item 1 of Form 1) OUTFALL NUMBER
CONTINUED FROM
1. POLLUTANT
AND CAS NO.
available)
GC/MS FRACTION
PAGE V-4
2, MARK "X"
a.re Believed
quir- b.pre- c.ab-
ed sent sent
- VOLATILE COMPOUNDS
a. MAXIMUM DAILY VALUE
NC0004987
3. EFFLUENT
b. MAXIMUM 30 DAY VALUE
(if available)
002
c. LONG TERM AVG. VALUE
(Ifavailable)
d. NO. OF
4. UNITS
a. Concert-
b. Mass
Marshall Steam Station
5. INTAKE (optional)
a. LONG TERM A�VAWEif
(1) Concentration
(continued)
(2) Mass
0) Concentration
(2) Mass
(1) Concentration
(2centration(L
996-57-8)57-8)
42V. Methylene
:hloride (75-09-2)
X
2.0
< 0.29
0 0.00
-(T- 0.00
1
ugfl
Ib/Day
0.00
!3V. 1,1,2,2 -Tetra-
�A. 2,4-Dichloro-
X
< 1.44
0 0.00
0 0.00
_
ugA
Ib/Day
:hloroethene
79-34-5)
X
< 0.29
0 0.00
0 0.00
1
ug/I
Ib/Day
0.00
2
K 2.0
14V. 7etrachloro-
"ene(127-18-4)
X_
2.0
< 0.29
$A. 2,4 -Dimethyl-
-0---
0.00
0 0.00
1
ug/I
Ib/Day
10
< 1.44
0.00
0 0.00
'5V. Toluene
108.88-3)
X
- 2 0
< 0.29
lb/Day
0 0.00
0.00
0 0.00
1
ugA
Ib/Day
1'
r (5344.552-1)1)
0.00
''6V. 1,2-Trans-
. 2,4-Dinitro-
X-.,
)ichloroethylene
156-60.5)
X
< 0.29
0 0.00
0 0.00
1
ug/1
IblDay
0.00
2.0
7V. 1,1,1-Tri-
hloroethane
71.55-6)
X
# 2.0
< 0.29
0 0.00
< 1.44
0 0.00
1
ugA
IblDay
-
-..
0.00
Ib/Day
8V. 1,1,2-Tri-
60
88-75-5)
Woroethane
79.00-5)
X
< 0.29
0 0.00
IA. 4-Nitropnena
0 0.00
1
ugfl
Ib/Day
-1
0.00
0.00
771 2.0
9V. Trichloro-
thylene (79-01-6)
X
- 2.0
< 0.29
0 0.00
0 0.00
1
ug/I
lb/Day
-
0.00
OV. Trichloro-
'
+A. P -Chloro -M-
X
< 10
ucromethane
r5-69-4)
X
< 0.29
0 0.00
2
0 0.00
1
ugfl
Ib/Day
-
0.00
S 2.0
W. Vinyl
hionde (75.01-4)
X
5.0
< 0.72
0 0.00
0 0.00
7
ug/l
Ib/Day
0.00
9A. Pentachloro-
3C/MS FRACTION
- ACID COMPOUNDS
< 10
< 1.44
0 0.00
0 0.00
2
ug/I
Ib/Day
0.00
1A, Chlorophenol
X
10
< 1.44
0 0.00
0 0.00
2
ughIb/Day
0.00
996-57-8)57-8)
10
�A. 2,4-Dichloro-
X
< 1.44
0 0.00
0 0.00
2
ugA
Ib/Day
0.00
rhenol(120-83-2)
s - 10
< 1.440
0.00
0 0.00
2
ug/I
Ib/Day
0.00
$A. 2,4 -Dimethyl-
X
henol (105-67-9}
10
< 1.44
0 0.00
0 0.00
2
ug/l
lb/Day
0.00
4,6 -Di -
'rasa
X
r (5344.552-1)1)
50
. 2,4-Dinitro-
X-.,
< 7.18
0 0.00
0 0.00
2
ughIblDay
0.00
henol(51-28.5)
k.2-Nitrophenol
X 1
e 10
< 1.44
0 0,00
0 0.00
2
ugA
Ib/Day
60
88-75-5)
IA. 4-Nitropnena
X
< 10
< 1.440
0.00
0 0.00
2
ug/l
Ib/Day
0.00
100-02-7)
'
+A. P -Chloro -M-
X
< 10
< 1.44
0 0.00
0 0.00
2
ug/l
I lb/Day
0.00
..resol(59-50-7)
_
9A. Pentachloro-
X
< 10
< 1.44
0 0.00
0 0.00
2
ug/I
Ib/Day
0.00
phenol(87-86.5)
10A. Phenol
X
< 10
< 1.44
0 0.00
0 0.00
2
ug/l
Ib/Day
0.00
108-95-2)
-
11A. 2,4,6-Tri-
'hlorophenol
X
< 1.44
0 0.00
0 0.00
2
u9A
Ib/Day
0.00
10
88.06-'2)
rH,.t V -o CONTINUE ON PAGE V-8
D

EPA Form 3510-2C (Rev. 2-85) PAGE V-6 CONTINUE ON PAGE V-7
EPA I.D. NUMBER (copy from Item 1 of Form 1)
I
OUTFALL NUMBER
,
CONTINUED FROM PAGE V-5
NC0004987
002 _
Marshall Steam Station
1. POLLUTANT
2. MARK "X" 3. EFFLUENT
4. UNITS 5. INTAKE (optional)
AND CAS NO.
a.re-
Believed a. MAXIMUM DAILY VALUE
b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVG. VALUE
a. LONG TERM AVG. VALUE
if available)
quir-
b.pre- c.ab-
(if available)
(if available)
d. NO. OF
a. COncerl-
b. Mass
d. NO. OF
(1) Concentration (2)Mass _
(1j Concentration (2)Mass
ed
sent sent (1) Concentration (2j Mass
ANALYSES
tration
(1) Concentration 1(2) Mass
ANALYSES
GC/MS FRACTION
- BASE
NEUTRAL COMPOUNDS
< 10 < 1.44 0 0.00
1 B. Acenaphthene
X
0 0.00
1
ug/I
Ib/Day
0.00
83.32-9)
- < 10 < 1.44 0 0.00
'B. Acenaphtylene
X
0 0.00
1
ug/l
Ib/Day
0.00
208-96.8)
10 < 1.44 0 0.00
36. Anthracene
X
0 0.00
1
ug/I
Ib/Day
0.00
.120-12.7)
< 100 < 14.35 0 0.00
.IB. Benzidine
X
0 0.00
1
ug/I 1
Ib/Day
-
0.00
92-87.6)
5B. Benzo (a)
.nthracene
X
< 10
< 1.44
0 0.00
0 0.00
1
ug/I
Ib/Day
0.00
56.55.3)
-B. Benzo (a)
X
< 10
< 1.44
0 0.00
0 0.00
1
ug/I
Ib/Day
0.00
Pyrene (50-32-8)
'B. 3,4-Benzo-
iuoranthene
X
< 10
< 1.44
0 0.00
0 0.00
1
ug/I
Ib/Day
0.00
205-99-2)
B. Benzo(ghi)
X
< 10
< 1.44
0 0.00
0 0.00
1
ugll
Ib/Day
_
0.00
Perylene (191.24-'L)
.+8. Benzo (k)
Fluoranthene
X
< 10
< 1.44
0 o.00
0 0.00
1
ugh
Ib/Day
0.00
.207.08.9)
10B. Bis (2-Chloro-
ethoxyl) Methane
X
< 10
< 1.44
0 0.00
0 0.00
1
ug/I
Ib/Day
0.00
111-91-1)
118, Bis (2-Chlaro-
lhyl) Ether
X
< 10
< 1.44
0 0.00
0 0.00
1
ug/I
INDay
0.00
111.44-4)
12B.Bis (2-Chloroiso-
ropyl) Ether
X
K 10
< 1.44
0 0.00
0 0.00
1
ugh
Ib1Day
0.00
108-60-1)
13B. Bis (2-Ethyl-
,exyl) Phthalate
X
t 10
< 1.44
0 0.00
0 0.00
1
ug/I
Ib/Day
0.00
117-81.7)
14B. 4-Bromo-
henyl Phenyl
X
< 10
< 1.44
0 0100
0 0.00
1
ugll
Ib/Day
_�
0.00
ther(101-553)
15B. Butyl Benzyl
X
10
< 1.44
0 0.00
0 0.00
1
ugll
Ib/Day
0.00
Phthalate (85-66-7)
166. 2-Chloro-
aphthalene
X
< 10
< 1.44
0 0.00
0 0.00
1
ug/1
Ib/Day
_
0.00
91-58-7)
17B. 4-Chloro-
phenyl Phenyl
X
-e 10
< 1.44
0 0.00
0 0.00
1
ug/I
Ib/Day
_
0.00
Ether (7005-72-3)
1813.Chrysene
X
< 10
< 1.44
0 0.00
0 0.00
1
ugh
Ib/Day
_
0.00
218-01-9)
_
19B. Dibenzo(a,h)
Anthracene
X
< 10
< 1.44
0 0.00
0 0.00
1
ug/I
Ib/Day
0.00
53.70-3)
'OB. 1,2-Dichloro-
X
e -- 2.0
< 0.29
0 0.00
0 0.00
1
ug/I
Ib/Day
0.00
enzene(95-50-1)
'1B. 1,3-Dichloro-
X
_ 1- 2.0
< 0.29
0 0.00
0 0.00
1
ug/I
Ib/Day
_ %
0.00
nzene(541-73.1)
_j
EPA Form 3510-2C (Rev. 2-85) PAGE V-6 CONTINUE ON PAGE V-7

EPA I.D. NUMBER
(copy from Item 1 of For 1)
OUTFALL NUMBER
CONTINUED FROM PAGE V-6
N00004987
002
Marshall Steam Station
1. POLLUTANT
2. MARK "X"
3. EFFLUENT
AND CAS NO.
ax Behaved
a. MAXIM M DAILY VALUE
30
DAY VALUE c. LONG TERM
AVG. VALUE
4. UNITS
5. INTAKE (optional)
-.VALUE
if available)
quit- b.pre- c.ab-
Fb.MAXIMUM
vailable)
(if available)
d. NO. OF
a. Conten-
b. Mas.d.
a. LONG TERM Wit
ed sent sent
(1)Concentrabon
(2)Mass
entration
(2)Mass (1) Concentration
1(2) Mass
ANALYSES'ration
140 OF
GC/MS FRACTION - BASE/NEUTRAL COMPOUNDS (continued)
(1)Concentra8on (2)Mass ANALYSES
26.1,4-Dichloro-
X
< 2.0
<
0.29
0
0.00
0
0.00
1
ug/I
Ib/Day
enzene(106-46.7)
0.00
236. 3,3.Dichloro-
renzldine
X
10
<
1.44
0
0.00
0
0.00
1
ug/I
IblDay
91-94-1)
0.00
'4B. Dlethyl
hthalate
X
s 10
<
1.44
0
0.00
0
0.00
1
ug11
Ib/Day
84-66.2}
0.00
`5B. Dimethyl
Phthalate
X
F:V, 10
<
1.44
0
0.00
0
0.00
1
ugA
IblDay
131-11.3)
0.00
68. Di -N -Butyl
Phthalate
X
< 10
<
1.44
0
0.00
0
0.00
9
ug/1
Ib/Day
0.00
84-74-2)
7B. 2,4-Dinitro-
X
< 10
<
1.44
0
0.00
0
0.00
1
ug/I
IblDay
oluene (121-14-2)
0.00
`8B.2,6-Dinitro-
X
10
<
1.440
0.00
0
0.00
1
ugll
lb/Day
oluene(606-20-2)
0,00
' 9B. 01-N-Octyl
-
-
hthalate
X
< 10
<
1.44
0
0.00
0
0.00
1
ug/I
Ib/Day
? 0.00
117-84-0)
OB. 1,2-Diphenyl-
ydrazlne (as Azo-
X
< 10
<
1.44
0
0.00
0
0.00
1
ugA
lb/Day
0.00
3enzane)(122-66-7)
_I
31B. Fluoranthene
X
< 10
<
1.44
0
0.00
0
0.00
1
ugll
IblDay
0.00
206.44-0)
'12B. Fluorene
X
10
<
1.44
0
0.00
0
0.00
1
ugll
lb/Day
0.00
86.73.7)
_. .
33B. Hexachloro-
X
I 10
<
1.44
0
0.00
0
0.00
1
ugA
lb/Day
0.00
enzene (118-74.1)
34B. Hexa-
hlorobutadiene
X
10
<
1.44
0
0.00
0
0.00
1
ug/I
Ib/Day
0.00
i,tl7.68.3)
15B. Hexachloro-
-
yctopentadiene
X
10
<
1.44
0
0.00
0
0.00
1
ug/I
Ib/Day
0.00
77-47-4)
-- -
e. Hexachloro-
X
10
<
1.44
D
0.00
0
0.00
1
ug/l
Ib/Day
0.00
thane (67-72-1)
- -
7B. Indeno
1,2,3 -cd) Pyrene
X
e 10
<
1.44
0
0.00
0
0.00
1
ug/I
lb/Day
0,00
.193-39-5)
38B.Isophorone
X
e 10
<
1.44
0
0.00
0
0.00
1
ugll
lb/Day
0.00
78-.59-1)
I-- -
39B. Naphthalene
X
10
<
1.44
0
0.00
0
0.00
1
ug/I
lb/Day
0,00
.91-20-3)
-
108.Nitrobenzene
X
10
<
1.44
0
0.00
0
0.00
1
ug/I
IblDay
0.00
98-95-3)
41B. N-Nitro-
wdimethylamine
X
'- <'' 10
<
1.44
0
0.00
0
0.00
1
ug/l
IblDay
j 0.00
:62-75-9)
- _
2B. N-Nitrosodl-
-Propylamine
X
e 10
<
1.44
0
0.00 10
0.00
1
ug/I
Ib/Day
=] 0.00
s21 -s4-7)
EPA Form 3510-2C (Rev. 2-85)
PAGE V-7
CONTINUE ON PAGE V-8

EPA I.D. NUMBER (copy from it 1 of Farm 1) OUTFALL NUMBER
CONTINUED FROM PAGE V-7
N00004987
002
Marshall Steam Station
1. POLLUTANT 2. MARK "X"
3. EFFLUENT
AND CAS NO. a.re- Believed
a. MAXIMUM DAILY VALUE
b- MAXIMUM 30 DAY VALUE c. LONG TERM AVG. VALUE
4. UNITS
5. INTAKE (optional)
ifavailable)
a. LONG TERM AVG. VALUE
quit- b.pre• c,ab-
(if available) (if available)
d. NO. OF
a. Concen-
b. Mass
d. NO. OF
ed sent sent
(1)Concentra0on (2)Mass
{1)Concenvation (2)Mass (1)Concenbation
(2)Mass
ANALYSES tration
(1) Concentration(2)Mass ANALYSES
GC/MS FRACTION - BASE/NEUTRAL COMPOUNDS (continued)
-
13B. N -Nitro
-
,odiphenylamine X
< 10 < 1.44
0 0.00
0
0.00
1
ug/I
lb/Day
86-30-8)
0.00
14B. Phenanthrene X
ti - 10 < 1.44
0 0.00
0
0.00
1
ug/I
Ib/Day
85-01-8)
0.00
5B. Pyrene X
10 < 1.44
0 0.00 1
0
0.00
1
ug/l
I Ib/Day
0.00
129-00-0)
:68. 1,2,4 -Tri-
-
-hlorobenzene X
: 2.0 < 0.29
0 0.00
0
0.00
1
ug/I
IblDay
0.00
120.82-1)
GC/MS FRACTION - PESTICIDES
1P. Aldrin X
0
309-00-2)
P. alpha -BHC X
0
319-84-6)
3P. beta -BHC X
0
31&8:,7)
tP. gamma -BHC X
0
-
58-89-9)
P. delta -BHC X
0
-
319.86-8)
••P. Chlordane X
0
57-74.9)
'P. 4,4' -DDT X
0
50-29-3)
'P. 4,4' -DDE
X
0
-
72-55.9)
'"P. 4,4'
X
0
72-54-8)
1 OP. Dieldrin
X
0
60-57.1)
11 P.slphs-Endosulfan
X
0
115-29-7)
12P. beta-Endosulfan
X
0
115.29.7)
13P. Endosulfan
su8ate
X
0
1031.07-8)
14P. Endrin
X
0
72-20.8)
15P. Endrin
-
de
X
0
95.4)
L174
X
0
8)
EPA Form 3510-2C (Rev. 2-85)
PAGE V-8
CONTINUE ON PAGE V-9

EPA I.D. NUMBER (copy from Item 1 of Form 1) OUTFALL NUMBER
CONTINUED FROM PAGE V-8 NCOOO4987 002 Marwhall Steam Cta+inn
1. POLLUTANT
2. MARK "X"
3. EFFLUENT 4. UNITS
5. INTAKE (optional)
AND CAS NO.
a.re-
Believed
a. MAXIMUM DAILY VALUE b. MAXIMUM 30 DAY VALUE
C. LONG TERM AVG. VALUE
a. LONG TERM AVG. VALUE
'if available)
quir-
b.pre-
c.ab-
(8 available)
(if available)
d. NO. OF a. Conten-
b. Mass
d. NO. OF
(1) Concentration (2)Mass 0) Concentration (2)Mass
(1)Concentration (2)Mass
ed
sent
,sent
(1) Concentration (2)Mass
ANALYSES tration
ANALYSES
GC/MS FRACTION - PESTICIDES (continued)
17P. Heptachlor
-
Epoxide
X
0
1024-57-3)
1
ug/1
18P. PCB -1242
X
-,1 0.30
<
53469-21-9)
ug/I
19P. PCB -1254
X
.j 0.30
<
1
11097.69-1)
Ug/1
'OP. PCB -1221
X
0.30
<
1
11104.28-2)
ug/I
'1P. PCB -1232
X
< 0.30
<
1
11141-16-5)
ugfl
2P. PCB -1248
X
0.30
I <
1
12672-2940)
ug/1
3P. PCB -1260
X
- 0.30
<
1
.11096-82-5)
ug/I
'4P. PCB -1016
X
< 0.30
<
1
12674-11-2)
'15P. Toxaphene
X
0
8001-35.2)
EPA Farm 3510-2C (Rev. 2-85) PAGE V-9

Marshall Steam Station Water Schematic
Unit 4 ID Fan Control
NPDES Permit #NC0004987 House Cooling Water Catawba County
Outfall 003
0.2 MGD
Intake Screen Backwash
Condenser Coaling Outfall 001 Lake
Water 1093 MGD Norman
Ash Sluice
3.21 MGD --
Lake
Norman
4� Evap. 1.7 MGD
Flue Gas
FGD Wetland Wastewater
Desulfurization Treatment System NPDES Internal 1.2 MGD
(FGD) Blowdown Outfall 004 1
Drinking Water
(groundwater) Sanitary Storm Water
1.45 MGD
Misc. Equipment 0.4MGIDCoding0.01 MGD Seeps
Water TreatmentBoiler and Turbine mps Ash Basin Outfall 002Lake
Room Sumps 1.9 MG` 2.43 MG 8.3 MGD Norman
Outfalls 002a and 002b
Emergency overflow onl Lake
(no flow expected) Norman

1.0 General Information
Marshall Steam Station (MSS) is located on NC Highway 150, six miles west of 1-77 in Catawba
County on Lake Norman near Terrell, North Carolina. MSS consists of four coal-fired steam electric
generating units. Units 1 and 2 can generate 380,000 kilowatts (net) of electricity each and units 3
and 4 have the capacity to generate 660,000 kilowatts (net) of electricity each.
A brief discussion of the individual waste streams follows.
2.0 Outfall Information
2.1 Outfall 001 - Condenser Cooling Water (CCW) Units 1-4
The CCW system is a once through non -contact cooling water system, which condenses
steam from the condensers and other selected heat exchangers. When MSS is operating at
full power, it has a design capacity to pump 1463 MGD (1,016,000 GPM) of cooling water
through a network of tubes that runs through the condenser and selected heat exchangers.
The raw cooling water is returned to the lake. No biocides or other chemicals are used in the
condenser cooling water.
Units 1 and 2 have two CCW pumps per unit and Units 3 and 4 have three CCW pumps per
unit with the following maximum flow capacities:
Unit No.
1 -Pump
2 -Pump
3 -Pump
GPM
GPM
GPM
1
126,000
190,000
-
2
126,000
190,000
-
3
150,000
253,000
318,000
4
150,000
253,000
318,000
The operational schedule for these pumps is dependent on the intake water temperature and
on the unit loads. Depending on the electrical demand, pumps are operated to maximize MSS
efficiency and to assure balanced and indigenous populations are maintained in Lake Norman.
Each unit is on an independent system to avoid a system trip that would suddenly reduce the
discharge flow at outfall 001. This practice leads to a higher reliability factor for the units and
protection of aquatic life taking refuge in the discharge canal during cold weather. Flow
recorded on the monthly Discharge Monitoring Reports is based on CCW pump run times.
The condensers are mechanically cleaned. Normally, amertap balls are cleaning the tubes on
a continuous basis while the plant is operating. Periodically, after the condenser is drained,
metal scrapers, plastic scrapers or rubber plugs are forced through the tubes to rid them of
scale or other deposits. The condenser tubes may also be tested for leaks, as needed. A leak
test can be conducted in approximately two to three hours per unit with usually no more than
six injections of tracer gas (i.e., sulfur hexaflouride, helium, etc) each within approximately a 30
second period and/or checked with fluorescent dye. The dye is added to the condensate water
and put on the outside of the condenser tubes. During the test, if fluorescent water does leak
into the tubes, this discharge indicates a leak does exist in the condenser tubing. The levels of
gas or dye that might be discharged would be well below any levels of aquatic biological
toxicity concerns. If leaks are detected, then one method used to temporarily stop small leaks
is to add sawdust to the CCW system, as previously approved by NCDENR. The sawdust is

• added at amounts that will plug the leaks and not result in an environmental impact. This is a
temporary measure until the unit can come off-line so the leaks can be permanently repaired.
2.1.1 Intake Screen Washing Manually by Removing Screens
The intake screens (32 total) are washed on an as needed basis. Normally, the screens
require washing once a month for a period of approximately 5 minutes per screen. The
screens (10 ft x 20 ft) are stationary type and are removed for cleaning. A low-pressure
pump supplies the raw water required for washing with a design capacity of 300 gpm.
Therefore, the average flow of water used to backwash the screens is 0.002 MGD.
Should it become necessary to backwash the screens on a continuous basis the
maximum flow would be 0.43 MGD per screen. The debris collected on the screens
consists of twigs, leaves, and other material indigenous to Lake Norman and is removed
and properly disposed. The intake screen backwash water drains back to the station
intake cove without any adverse environmental impact.
2.2 Outfall 002 - Ash Basin
The ash basin at MSS accommodates flows from two yard -drain sumps, an ash removal
system, low volume wastes and non -point source storm water. Low volume waste sources
include, but are not limited to: wastewater from wet scrubber air pollution control systems, ion
exchange water treatment system, water treatment evaporator blowdown, laboratory and
sampling streams, boiler blowdown, floor drains, and recirculating house service water
systems. Total average influent from these sources combined is approximately 8.3 MGD. At
times, due to unit loads, rainfall, evaporation and seepage of ash basin ponds, the amount of
effluent may be different than influent volumes.
2.2.1 Yard -Drain Sumps
The yard -drain sumps are concrete structures having four level controlled pumps each
that direct wastewater from the powerhouse area to the ash basin. These pumps are
operated on a rotating basis. Usually two pumps are set so that one pump is primary
and the other is backup. After a selected period the controls are changed so that
different pumps are utilized.
The yard -drain sumps collect wastewater from many sources, such as, the filtered water
system, turbine and boiler room sumps, miscellaneous equipment cooling water,
foundation drainage, low volume wastes, and tunnel unwatering. The yard -drain sumps
also collect some storm water runoff from the coal pile, rail access, and powerhouse
roofs and pavement. Ground water from a foundation drainage system under the track
hopper is also intermittently discharged to the yard -drain sumps. The combined
average flow from all sources tied to the yard -drain sumps is approximately 2.43 MGD,
which is pumped to the ash basin for physical and biological treatment.
2.2.2 Turbine Room Sumps
The turbine room sumps collect approximately 0.35 MGD of wastewater. This
wastewater comes from non -contact cooling water (from Units 1 & 2 boiler feedpump
turbine lube oil coolers) and floor drains. Floor drains contain boiler blowdown, leakage
from seals, equipment cooling water, condensate from the feedwater system, low
volume wastewater, boiler room sump overflow, emergency fire fighting water, general
mechanical maintenance activities, miscellaneous plant wastes and area washdown
water.

2.2.3 Boiler Room Sumps
The average flow pumped from the boiler room sumps directly to the ash basin is
approximately 1.55 MGD. The sources of input to the boiler room sumps include the
following:
2.2.3.1 Water Treatment System
The MSS make-up water treatment system is comprised of a clarifier, three
gravity filters, two sets of activated carbon filters, a reverse osmosis system and
two sets of demineralizers. The water treatment wastes consist of floc and
sedimentation, filter backwash, reverse osmosis concentrate reject and cleaning
wastes, and demineralizer regeneration wastes. Water processed through this
system is supplied to the boilers to generate steam to turn the turbines. On
occasion a vendor may be used with a mobile water treatment unit to augment
the facility water treatment capacity. Any vendor will use traditional water
treatment methods, chemicals, and disposal methods generally described below.
This wastewater is drained to the boiler room sump, which ultimately discharges
to the ash basin.
Clarifier.
The clarifier utilizes typical water treatment chemicals such as, Ferric sulfate (),
sodium hydroxide, and calcium hypochlorite for the primary treatment of raw
water. The sedimentation wastes collected in the clarifier consists of solids that
were suspended in the service water plus Ferric precipitate formed as a result of
adding Ferric sulfate () and sodium hydroxide. The quantity of Ferric Sulfate
used per year is approximately 14,000 gallons. The total amount of caustic is
roughly one quarter the amount of Ferric Sulfate The average volume of water
required for desludging the clarifier is approximately 0.008 MGD. These
sedimentation wastes along with dilute water treatment chemicals and by-
products are piped to a floor drain which flows to the boiler room sumps where
they are pumped to the ash basin via the yard -drain sump.
Gravity Filters:
There are three gravity filters composed of anthracite (coal) which follow the
clarifier in the water treatment process. They are used for removal of colloidal
material and are backwashed as necessary, dependent upon the level of solids
in the water. Normally, one of these filters is backwashed each day.
Approximately 0.007 MGD of backwash water is required for each filter. This
flow is discharged to the floor drains to the boiler room sump, which pumps to the
yard -drain sump. The gravity filter medium is changed out on an as -needed
basis with the spent filter media being landfilled.
Activated Carbon Filters:
Two activated carbon filters remove organics and the chlorine that is injected into
the clarifier. These filters are typically backwashed approximately once a week.
The flow of water required to backwash one of these filters is 20,000 gallons per
day. The wash water flows to the boiler room sump and is pumped to the yard -
drain sump. Activated carbon is replaced on an as needed basis with the spent
carbon sluiced to the ash basin.

Reverse Osmosis System
There is a two stage Reverse Osmosis (RO) system which processes
approximately 535 gallons per minute of filtered water. Approximately 400 gpm
of permeate water is produced and flows to the permeate water storage tank.
Approximately 135 gpm of concentrate water is produced which flows to the
boiler room sump and ultimately the ash basin via the yard drain sump. Water
from the permeate tank is pumped to the demineralizers as supply water.
The RO system is cleaned approximately twice per year using a dilute low pH
cleaner (sulfonic acid/citric acid), biocide (Trisep Tristat 110), and a high pH
cleaner (sodium hydroxide/sodium lauryl sulfate).
Demineralizers:
Demineralizers at MSS consist of two sets of mixed -bed cells which supply
make-up water to the boilers and other closed systems. Normal plant operation
requires that only one cell of each demineralizer set operate at any one time.
Each cell has a capacity of 225 gpm.
Each cell is regenerated approximately every four weeks. Each year MSS will
use an estimated 8,000 gallons of 50% caustic and 2,500 gallons 93% sulfuric
acid for demineralizer regenerations. The dilute acid and caustic are discharged
from the cell simultaneously through the same header for neutralization
purposes. The regeneration wastes flow to the boiler room sumps where it is
pumped to the ash basin via the yard -drain sump. The useful life of the resin
varies and when replaced spent resin is sluiced to the ash basin.
2.2.3.2 Miscellaneous Waste Streams
• Closed system drainage, cleanings, testing containing corrosion inhibitors
(Calgon CS), biocides (Calgon H-550 and H 7330), cleanings) (small heat
exchangers), dispersant (polyacrylamide), wetting agent (sodium lauryl
sulfate), detergent (tri -sodium phosphate), and leak testing (disodium
fluorescing dye).
• Turbine room sump overflow
• Boiler seal water (trace oil and grease)
• Miscellaneous system leakages (small leaks from pump packings and seals,
valve seals, pipe connections)
• Moisture separators on air compressor precipitators
• Floor wash water
• Emergency fire fighting water
• Pyrite (ash) removal system overflow
• Low Volume Wastewater.
2.2.3.3 Chemical makeup tanks and drums rinsate
Intermittent rinse water containing small amounts of Ferric sulfate, sodium
hydroxide, hydrazine, ammonium hydroxide.
2.2.3.4 Boiler blowdown
1 To date small closed system cleanings (e.g. heat exchangers) have not used these chemicals, reserved for
future use.

Primarily when units 1 & 2 startup and until water chemistry stabilizes the
blowdown from these boilers is allowed to flash in a blowdown tank. During
startup a significant portion of this blowdown steam is vented to the atmosphere.
After water chemistry has stabilized, blowdown venting is minimal and
condensate flow is small. Trace amounts of hydrazine, ammonia, and silica
oxide may be present in the condensate. The combined condensate flow from
blowdown amounts to an average of approximately 0.002 MGD. This flow is
routed to the boiler room sump and then to the ash basin.
2.2.3.5 Boiler Cleaning
Boilers #1, #2, #3 and #4 at MSS are chemically cleaned on an as needed basis.
Tube inspections are performed during outages, which indicate when cleaning
needs scheduling. Boilers #1 and #2 are controlled circulation boilers and boilers
#3 and #4 are supercritical boilers. The wastes produced from a boiler chemical
cleaning are pumped to the ash basin.
Boilers #1 and #2 each have a water -side volume of 51,600 gallons. The volume
of #3 and #4 boilers is 35,300 gallons each. The total volume of dilute waste
chemicals, including rinses, discharged from #1 or #2 boilers during a chemical
cleaning is 580,000 gallons. The total volume of dilute waste chemicals drained
from #3 or #4 amounts to 320,000 gallons. This dilute wastewater is drained
through temporary piping to permanent ash removal piping where flow goes to
the ash basin. The chemicals and approximate amounts for each cleaning are
listed below.
CLEANING CHEMICALS AMOUNT USED PER UNIT
Alkaline Boilouts — (only after major boiler tube work)
Soda Ash
Trisodium Phosphate
Triton X-100* Detergent (0.05%)
Antifoam Agent (0.025%)
* or equivalent detergent
EDTA Boiler Chemical Cleaning
Tetra -ammonium EDTA (38%)
Antifoam Agent
Ammonium Hydroxide (260Be')
Di -ammonium EDTA (44.5%)
Rodine 2002 (corrosion inhibitor)
Boiler #1 or #2
4400 Ib
NA
25 gal
13 gal
Boiler #1 or #2
11000 gal
15 gal
NA
NA
300 gal
Boiler #3 or #4
NA
3000 Ib
18 gal
9 gal
Boiler #3 or #4
NA
10 gal
1,400 gal
6,000 gal
240 gal
Regardless of the method used for cleaning, no waste water will be discharged to
the ash basin, rather all cleaning waste waters will either be evaporated in the
boiler or collected and transported off-site for proper treatment and disposal.

2.2.4 Stormwater Runoff
The ash basin collects/receives flows from the yard drainage basins, ash removal lines
and rainfall run-off from the basin watershed area. Some of the flows pumped into the
ash basin from the yard drains include roof runoff, stormwater discharge from
transformer containments, stormwater discharge four fuel oil containments, stormwater
from the FGD facility, rail lines, coal handling facilities, chemical storage and
miscellaneous plant equipment. Details of storm water the runoff that flows into the ash
basin via gravity are described in section 2.2.15.
2.2.5 Induced Draft Fan Motor Bearing Cooling Water
Once through non -contact cooling water is supplied to eight induced draft (ID) fan motor
bearings to remove excess heat. No chemicals are added to the once through raw lake
water. The rate of flow through the ID fan heat exchangers that discharges to the yard -
drain sumps is approximately 0.08 MGD, which is pumped to the ash basin.
2.2.6 Track Hopper Sump
The track hopper sump collects ground water from a foundation drain system
underneath the track hopper. The flow is usually intermittent; however, the pump
capacity is 100 gpm. On a daily basis it is estimated that the run time is only 50% which
would correspond to a flow of 0.07 MGD to the yard -drain sumps, which is pumped to
the ash basin.
2.2.7 CCW Tunnel-Unwatering Sump
In the event that maintenance activities are needed in the intake or discharge tunnels an
unwatering sump is provided to remove water from the tunnels. Raw water in the
tunnels can be pumped to the yard -drain sumps that ultimately discharge to the ash
basin.
2.2.8 Turbine Non -Destructive Testing
Bore sonic testing of turbine rotors is infrequent, once every 5 years. Demineralized
water is mixed with a corrosion inhibitor, e.g. Immunol 1228, at a ratio of 100 parts
water to 1 part inhibitor. The mixture is applied to the turbine rotors. The excess is
drained and mixed with low volume wastewater and discharged to the ash basin via the
yard -drain sumps.
2.2.9 Ash Sluice
MSS utilizes electrostatic precipitators as its air pollution control devices. Under normal
plant operations, the dry fly ash captured in these precipitators is collected in temporary
storage silos for subsequent disposal in a permitted on-site structural fill or for recycling
in off-site ash utilization projects. If the system that collects the dry fly ash is not
operating, the fly ash can be sluiced to the ash basin. Bottom ash from the boilers is
usually sluiced with water to a holding cell for recycling activities. Pyrites from the mills
are sluiced with water to an ash basin settling -cell. Approximately 3.21 MGD of
fly/bottom ash and pyrite sluice is pumped through large steel pipes (ash lines) directly
to the ash basin settling -cell. Once through non -contact cooling water from the coal
pulverizing mill is discharged to the bottom ash hopper and pumped to the ash basin.
Electrostatic precipitators at MSS are normally cleaned by mechanically vibrating the
wires and rapping the plates inside the precipitator. Before major precipitator work is
performed they are cleaned by a wash down. The wash water is pumped to the ash
basin from the yard -drain sump.

2.2.10 Sanitary Waste
A sanitary waste treatment system is operational and consists of an aerated basin that
provides treatment with a 30 -day retention time and has a total volume of 587,000
gallons. Effluent from the aerated basin is polished further through additional residence
time in the ash basin. The system is designed for 6100 gpd (normal) and 13,500 gpd
(outage).
The powerhouse lift station was installed as a central collection point to receive all the
sanitary waste from MSS and pump it to the aerated basin.
The sanitary system accommodates wastewater flow from the following sources:
• General plant sanitary wastewater
• Vendor facilities sanitary wastewater
• Laboratory drains (Small amounts of laboratory chemicals used to test
wastewater effluents and high purity boiler water, see the following table for
non -hazardous substance).
Substance
Quantity
Location
2 -Propanol
4 qal.
Lab/Warehouse
Glycerin
4 gal.
LabNVarehouse
Indigo carmine
0.3 Ib
Lab
Dimethylaminobenzaldehyde
0.22 lbs
Lab
Table values represents typical quantities on-site at any given time and do not
necessarily reflect quantities discharged.
2.2.11 Ash Silo Storm Water Sump
A ash silo system has been constructed for dry handling of the ash. This system
includes a sump for collection of rainfall runoff and washdown of the silo area, which is
pumped to the ash basin. This sump's drainage area is approximately 1 acre. Overall,
this will be a minimal input to the ash basin.
2.2.12 Wastewater from Plant Additions
2.2.12.1 Selective Non -Catalytic Reduction (SNCR)
As part of the compliance with the North Carolina Clean Air Initiative (NCCAIR),
Marshall installed urea based "trim" Selective Non -Catalytic Reduction (SNCR)
systems on units 1, 2, and 4. The trim SNCR systems are expected to reduce
NOx emissions by approximately 20%. SNCR systems operate by injecting urea
liquor into the upper section of the boiler where a chemical reaction occurs to
reduce the NOx to water and nitrogen. Some residual ammonia will be collected
in the fly ash from the electrostatic precipitators. The majority of this ammonia will
stay with the ash as it is handled dry but a small amount may be carried to the
ash basin. However, the operation of the SNCR system is not expected to
require additional treatment capabilities to ensure compliance with NPDES
permit limits. Marshall units 1, 2, and 4 currently are using this technology to
reduce NOx whereas unit 3 operates a Selective Catalytic Reduction (SCR)
system.

2.2.12.2 Selective Catalytic Reduction (SCR)
As part of the compliance with the North Carolina Clean Air Initiative (NCCAIR),
Marshall has replaced unit 3's SNCR with a more efficient Selective Catalytic
Reduction (SCR) system, capable of reducing NOx by approximately 90%. This
SCR utilizes a urea to ammonia (U2A) which converts the urea liquor into an
ammonia gas, external to the boiler in a hydrolyzer. The hydrolyzer contains
approximately 1000 gallons of urea while in operation and periodic blowdowns
occur to flush out sediment in the bottom of each hydrolzer. Small quantities of
urea will be discharged into the ash basin from the blowdown process. Roughly,
10 gallons a week is discarded during the blowdown process and is collected in
the ash basin. Similar to the SNCR, the SCR will also result in small traces of
ammonia in the fly ash that is collected from the electrostatic precipitators. The
majority of this ammonia will remain with the ash as it is handled dry but a small
amount may be carried to the ash basin. However, the operation of the SCR
system is not expected to require additional treatment capabilities to ensure
compliance with NPDES permit limits.
2.2.12.3 Flue Gas Desulfurization (FGD)
The installation of a Wet Flue Gas Desulfurization (FGD) system was completed
in 2006 at Marshall for Unit 4. The remaining units FGD systems were
completed in 2007. The FGD is an air pollution control system that removes SO2
from the flue gas system. In a Wet Scrubber system the SO2 component of the
flue gas produced from the coal combustion process is removed by reaction with
limestone -water slurry. The particular system used at Marshall will collect the
flue gas after it passes through the electrostatic precipitator and route the gas
into the lower end of a vertical tank. As the gas rises through the tank to the
outlet at the top, the gas passes through a spray header. An atomized slurry of
water and limestone droplets is continually sprayed through this header into the
stream of flue gas. The SO2 in the flue gas reacts with the calcium in the
limestone and produces SO3. The SO3 slurry falls to the bottom of the tank
where a stream of air is injected to oxidize the slurry to form gypsum
(CaSO4-H2O). The gypsum slurry is drawn off the tank to a hydrocyclone and
subsequently routed to a vacuum belt filter. The liquid waste from this process
will be treated as wastewater in the constructed treatment wetlands. The effluent
from the CTW discharges to the ash basin (via NPDES Internal Outfall 004).
The FGD system requires a material handling system that supplies limestone to
the scrubber and a gypsum storage area for the gypsum removed from the
process. The limestone comes into the site by rail and is stored in an area near
the coal pile. It is then transferred to the FGD site via a covered conveyor.
Runoff from the storage area is routed to the ash basin. The gypsum is routed
from the FGD tank via a covered conveyor belt that carries it to a storage pile.
The runoff from this area is also routed to the ash basin.
The FGD system also requires a gypsum landfill. The FGD landfill is located
west of the Marshall Ash Basin. The runoff and leachate from this landfill is
routed to the ash basin. FGD residue material that is not suitable for beneficial
use as wallboard will be placed in the landfill. In addition to this material, material
is periodically removed from the clarifier stage of the wastewater treatment

system and placed in the landfill. The landfill footprint contains approximately
20.64 acres. The landfill is permitted to receive asbestos from Duke Genergy
Carolinas, facilities, generated gypsum from the Allen, Marshall and Cliffside
Stations, generated clarifier sludge from the Allen, Marshall and Cliffside Sations
as well as the following wastes generated soly from the Marshall Station: fly and
bottom ash, C&D debris, pyrites, waste limestone material, land clearing and
inert debris, boiler slag, mill regects, sand blast material and coal waste.
The FGD residue is conveyed to the landfill site by truck, where the material is
spread and compacted. The landfill began receiving FGD residue in the fall of
2006. The volumetric capacity of the landfill is 2.19 million yd3, Duke Energy is
exploring other beneficial uses for the FGD residue (gypsum). If these options
are determined to be viable, the FGD residue meeting the material requirements
for the beneficial uses will not be disposed in the landfill.
2.2.13 Seepage
MSS has identified two seeps in the vicinity of the of the ash basin dam. These
seeps contribute a small amount of water to Lake Norman.
2.2.14 Industrial Waste landfill Leachate
Construction of an industrial waste landfill is scheduled to begin in early 2010.
Landfill operation is slated for late 2010. Fly ash, FGD gypsum and clarifier
sludge will be disposed in this landfill. Landfill runoff and leachate will be routed
to the ash basin for treatment.
2.2.15 Stormwater Gravity Drains to the Ash Basin
Marshall Steam Station has several non-stormwater discharge drainage areas
that drain via gravity flow into the ash settling basin, or discharge into station
sumps that subsequently pump to the ash settling basin. These aere addressed
were addressed in Section 2.2.4. All of the areas north of the primary coal
delivery rail lines gravity drain to the ash settling basin. The following is a
summary of the stormwater that gavity drains to the ash basin:
2.2.15.1 FGD Gypsum Radial Stacker
This drainage area includes the FGD gypsum radial stacker operation and
portions of an adjacent soil borrow area. Stormwater runoff from this area
enters a detention basin before discharging into a tributary of the ash
settling basin to the north.
2.2.15.2 Soil Borrow Area
This drainage area includes the remaining portions of the soil borrow area.
Stormwater runoff from this area enters a detention basin on the west side
of the drainage area before discharging into a small creek that flows to the
ash settling basin.
2.2.15.3 Drainage Area 15 — FGD Landfill
This drainage area includes the FGD residue landfill. Stormwater runoff
from this area enters a detention basin at the southeastern edge of the
landfill and is subsequently piped via gravity flow to the ash settling basin.

This landfill also includes FGD wastewater treatment sludge, asbestos,
flyash, bottom ash, mill rejects, and construction and demolition debris.
2.2.15.4 Coal Pile
This drainage area is comprised entirely of the station coal storage pile.
Stormwater runoff from this area enters perimeter ditches that discharge
into the ash basin.
2.2.15.5 Sanitary Wastewater Lagoon
This drainage area is comprised of the sanitary wastewater treatment
lagoon and surrounding area. Stormwater runoff discharges into the ash
basin to the north.
2.2.15.6 FGD Constructed Wetland Treatment System
This drainage area is comprised of the constructed wetland treatment
system (CWTS) designed to treat wastewater from the FGD solid removal
wastewater treatment system. Stormwater runoff from the CWTS area
flows into the adjacent ash settling basin.
2.2.15.7 Bottom Ash Operation and Pyrite Operation
This drainage area includes the bottom ash operation and recovery of coal
from pyrites. All stormwater runoff from this area is routed via ditches into
the ash settling basin.
2.2.15.8 Closed Ash Landfill
This drainage area includes the closed and capped ash landfill. All
stormwater runoff from this area is routed via ditches into the ash settling
basin.
2.2.15.9 Beneficial Structural Fill
This drainage area includes the active beneficial ash structural fill. All
stormwater runoff from this area is routed via ditches into the ash settling
basin.
2.3 Outfalls 002A and 002B - Yard -Drain Sump Emergency Overflow
An overflow pipe that could direct flow from the sump to Lake Norman was included in the
construction of the two yard sumps. This modification was performed to prevent submergence
and damage of the pump motors within the sumps in the event that all pumps failed or
redundant power supply lines could not be restored in a timely manner. Outfall 002A has
overflowed five times between April 2007 and March 2009. Outfall 002B has overflowed two
times between April 2007 and March 2009. Observations and monitoring of effluent during
these events have indicated no noticeable impact to water quality. No sanitary waste is routed
through the yard -drain sumps.
2.4 Outfall 003 - Unit 4 ID Fan Control House Cooling Water
Once through non -contact cooling water is supplied to the Unit 4 induced draft (ID) fan motor
control -house equipment to remove excess heat. No chemicals are added to the once through
raw lake water. The flow rate through the control equipment that discharges to Lake Norman
is approximately 0.2 MGD.

2.5 Internal Outfall 004 — Treated FGD Wet Scrubber Wastewater
The wastewater from the FGD system is conveyed to the wastewater solids removal system,
which discharges into the mixed equalization tank. The wastewater contained in the
equalization tank is conveyed to the flocculating clarifier which is utilized as the liquid/solids
separation device. Polymer may be injected to aid in the settling process. Clarified effluent is
conveyed to the Constructed Treatment Wetlands (CTW) supply tank.
Settled solids are removed from the clarifier by the operating sludge transfer pump and
conveyed to the mixed sludge holding tank and dewatered by the filter presses. Dewatered
cake from the filter presses is ultimately landfilled. Filtrate from the dewatering process is
conveyed to the equalization tank for reprocessing.
The CTW system receives wastewater from the clarifier unit where it enters two equalization
basins, each with a 24-hour hydraulic retention time (HRT) for cooling, mixing, concentration
equalization, and settling of solids. Water from the equalization basins is normally split into 6
flows then to three equal flows, each entering a treatment train consisting of two 1.28 acre
wetland cells (36 hour HRT), a 0.24 acre rock filter and a 1.67 acre final wetland cell (64 hour
HRT). Total area of treatment is approximately 15 acres with a normal HRT of 8 days based
on average projected flows. The CTW system will treat an average flow of 1.2 and a peak flow
of 1.4 MGD.
3.0 Additional Information
FUEL AND OIL STORAGE TANKS
The following above ground fuel and oil storage tanks are located at MSS:
• two 500 gallon,
• three 1,000 gallon,
• 2,000 gallon,
• 5,000 gallon
• two 500,000 gallon fuel -oil tanks;
• 1000 gallon gasoline tank;
• four 750 gallon lubricating -oil tanks;
• 500 gallon hydraulic -oil tank;
• 900 gallon used -oil tank;
• 8000 gallon used -oil tank (inside the powerhouse).
At the time of this application, only one of the 500,000 gallon fuel -oil tanks is in service. All above
ground tanks at MSS have secondary containment provided that is capable of containing the entire
contents of the tank.
All oil storage facilities and oil filled equipment are presently covered under Spill Prevention Control
and Countermeasure Plans (SPCC)2.
5.0 Hazardous and Toxic Substances
5.1 Hazardous and Toxic Substances Table 2c-3
2 SPCC Plan required by 40 CFR 112.

At IVISS, the potential for toxic and hazardous substances being discharged is very low. In reference
.to item V -D of Form 2-C, the substances identified under Table 2c-3 that may be in the discharge are
as follows:
Marshall Steam Station Hazardous and Toxic Substances
Table 5.1
Acetaldehyde
Dodecylbenzenes ulfonic
Acid
Nitric Acid
Sodium Hydroxide
Acetic Acid
Ethylbenzene
Phenol
Sodium Hypochlorite
Adipic Acid
Ferrous Sulfate
Phosphoric Acid
Sodium Phosphate
Diabasic
Aluminum sulfate
Formaldehyde
Phosphorus
Sodium Phosphate
Tribasic
Ammonia
Hydrochloric Acid
Potassium Bichromate
Styrene
Ammonium
Chloride
Hydrofluoric Acid
Potassium Hydroxide
Sulfuric acid
Ammonium
Hydroxide
Hydrogen Sulfide
Potassium Permanganate
Toluene
Antimony Trioxide
Maleic Acid
Propionic Acid
Vanadium Pentoxide
Asbestos
Mercuric Nitrate
Pyrethrins
Vinyl Acetate
Benzene
Monoethylamine
Sodium
Dodec lbenzenesulfonate
Xylene (Mixed Isomers)
Chlorine
Naphthenic Acidalene
Sodium Fluoride
Zinc Chloride
Cupric Nitrate
Cyclohexane
Nickel Hydroxide
During the course of the year products such as commercial cleaners and laboratory reagents may be
purchased that can contain very low levels of a substance found in Table 2C-3. It is not anticipated
that these products will impact the ash basin's capacity to comply with its toxicity limits, since their
concentrations are extremely low.
5.2 40 CFR 117 and CERCLA Hazardous Substances
The table below identifies hazardous substances located on-site that may be released to the ash
basin during a spill. Substances listed are present in quantities equal to or greater than the
reportable quantity (RQ) levels as referenced in 40 CFR 117, 302 and 355. This list is being provided
in order to qualify for the spill reportability exemption provided in 40 CFR 117 and the Comprehensive
Environmental Response Compensation and Liability Act (CERCLA).
Marshall Steam Station Hazardous Substances in Excess of RQ
Table 5.2
SUBSTANCE
QUANTITY
SOURCE
Aluminum sulfate
40,987 lbs
Powerhouse/Water Treatment
Ammonium hydroxide
3,317 lbs
Powerhouse
Benzene
167 lbs
Gasoline Tank
-Hydrazine*
2,1451bs
Powerhouse/Warehouse
Methyl Tert-But I Ether
1,334 lbs
Gasoline Tank
Naphthalene
41,700 lbs
Fuel Oil Tanks

Sodium hydroxide
50,040 lbs
Powerhouse
Sulfuric acid
6,738 lbs
Powerhouse
Xylene Mixed Isomers)
42,992 lbs
Fuel Oil Tanks
Ferric Sulfate
116,620 lbs
Water Treatment
Values in Table 5.2 represent maximum quantities usually on-site at any given time and do not necessarily reflect
quantities discharged. Various amounts of these substances may go to the ash basin for treatment due to use in site
laboratories, small leaks, spills, or drainage from closed loop systems. Treatment of these substances and their by-
products is achieved by physical and biological activity in the ash basin.
"Listed in 40 CFR 302.4 - Table 302.4 List of Hazardous Substances and Reportable Quantities.
6.0 Marshall Steam Station 316 Determination
6.1 316(a) Determination
During the term of this permit Duke Energy has continued to monitor the receiving waters
of Lake Norman in an attempt to determine if the Lake still supports a balanced and
indigenous population. The attached Balanced and Indigenous Population Report (BIP)
continues to indicate that Lake Norman continues to support a balanced and indigenous
population of fish and macro -invertebrates. Therefore, Duke energy request that the
thermal variance for the Marshall Steam Station be continued for the next permit cycle.
6.2 Marshall Steam Station 316(b) Determination
Please see the attached alternate schedule request.

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