NC0004979_Permit Modification_20010509

Duke
c�
-� I Power.
A Duke Energy Company
May 9, 2001
Mr. David Goodrich
State of North Carolina
1, M AY 1 6 2001 i F
DENR - DATER QUALITY
POINT SOURIE BRANCH
Department of Environment and Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1646
Subject: Duke Power Company — NPDES Permit Modification
Allen Steam Station - # NC0004979
Belews Creek Steam Station - #NC0024406
Buck Steam Station — #NC0004774
Cliffside Steam Station — #NC0005088
Dan River Steam Station - #NC0033468
Marshall Steam Station - #NC0004987
Riverbend Steam Station — #NC0004961
Record.#: DP -005157 .
Certified: 7000 1670 0003 3252 8202
Dear Mr. Goodrich:
Duke Power
Group Environment, Health 6' Safety
MG03A5
13339 Hagers Ferry Road
Huntersville, NC 28078-7929
Asa followup to a telephone conversation between Allen Stowe and Mr. Mike
Templeton of your office on April 27, 2001; Duke Power requests that the
definitions in the Special Conditions of the forenamed permits be revised as boiler
plate language to read as follows:
The term "metal cleaning waste" means any wastewater resulting from
cleaning (with or without chemical cleaning componds) any metal process
equipment including, but not limited to, boiler tube cleaning, boiler fireside
cleaning, and air preheater cleaning.
The term "chemical -metal .cleaning waste" means any wastewater resulting
from the cleaning 'of'any' metal process equipment with chemical
componds, including, but.not limited to, boiler tube cleaning. Chemical
metal cleaning will be conducted according to approved Duke Power
equivalency demonstration.

Duke Power also requests that monitoring for iron and copper only be required
when a chemical metal cleaning is conducted. The Steam Effluent Guidelines in
40 CFR 423.13 (e) list limits for copper and iron concentrations when chemical
metal cleanings are conducted. The compliance history of these facilities is
supportive of this request. Currently, Cliffside Steam Station is the sole facility that
monitors for iron and copper only when chemical metal cleanings are performed.
Several other Duke facilities have submitted this monitoring frequency reduction as
part of their NPDES permit application.
Duke Power also requests that required metal analyses be changed from a "Total
Metal' method to a "Total Recoverable Metal" method to align with the EPA Form,
2C instructions and with 40 CFR 122.45 (c).
Should you have questions regarding this report, please contact Allen Stowe at
[phone].
Sincerely,
Michael Ruhe
Manager, Water Compliance
Group Environment, Health and Safety
jas
xc: Mr. Mike Templeton - NCDENR Division of Water Quality