NC0004987_Permit Modification_20081021

• Duke DUKE ENERGY CORPORATION
Marshall Steam Station
MWEnergy, 8320 East NC Hwy. 150
October 21, 2008 Terrell, NC 28682
828 478 7700
To: Sergei Chernikov
North Carolina Department of Environment
and Natural Resources _
Division of Water Quality4:
1617 Mail Service Center
Raleigh, North Carolina 27699-1617' E'! OCT 24 2008
�n T_Ft
Subject: Marshall Steam Station °oul,,,
NPDES Permit No. 0004987
NPDES Permit Modification Request
Dear Mr. Chernikov:
Part I. Item 9 of the subject NPDES permit states that after six months of monitoring if a facility
determines that it is consistently meeting the effluent limits then the Permittee may request a
reduction in the monitoring frequency. Marshall Steam Station began to discharge wastewater
from the operation of the Flue Gas Desulfurization (FGD) System in December 2006. At that
time the monitoring frequency for several parameters was increased to weekly at both the final
NPDES outfall 002 (ash basin discharge) and the new internal outfall 004 (FGD wastewater
treatment system discharge). Upon review of the data (summary attached) Marshall Steam
Station requests that the monitoring frequency of the following parameters be reduced as
follows:
NPDES Outfall 002 (Final Outfall)
Reduce to Monthly: Chloride and Selenium
Eliminate Monitoring for: Arsenic, Cadmium, Chromium, Mercury, Nickel, Silver and
Zinc
NPDES Outfall 004 (Internal Outfall)
Reduce to Monthly: Chloride and Selenium
Eliminate Monitoring for: Arsenic, Cadmium, Chromium, Mercury, Nickel, Silver, TSS
and Zinc
Enclosed is a check for $1030.00 to pay for the fee associated with this major permit
modification request. Your efforts to complete this permit modification in a timely manner are
much appreciated. If you have questions or need additional information on this request, please
contact Robert Wylie at [phone].
Sincerely,
Renner, General Manager III
Marshall Steam Station
www. duke -energy. com

L I"
Marshall Steam Station
Parameter Monitoring Request
Summary of Data
NPDES Outfalls 002 and 004
NPDES Outfall 002 (Final Outfall) Average Concentrations
Parameter
Average
Concentration
Proposed
Monitoring
Frequency
Arsenic
4.7 ppb
Eliminate
Cadmium
1.25 ppb *
Eliminate
Chloride
276 ppm
Monthly
Chromium
1.6 ppb * *
Eliminate
Mercury
2.3 ppt
Eliminate
Nickel
14.0 ppb
Eliminate
Selenium
16.5 ppb
Monthly
Silver
1.0 ppb *
Eliminate
Zinc
20.43 ppb
Eliminate
NPDES Outfall 004 (Internal Outfall) Average Concentrations
Parameter
Average
Concentration
Proposed
Monitoring
Frequency
Arsenic
13.8 ppb
Eliminate
Cadmium
2.2 ppb
Eliminate
Chloride
2492.2 ppm
Monthly
Chromium
3.1 ppb * *
Eliminate
Mercury
0.2 ppb *
Eliminate
Nickel
61.4 ppb
Eliminate
Selenium
195.4 ppb
Monthly
Silver
1.8 ppb *
Eliminate
TSS
6.2 ppm
Eliminate
Zinc
20.9 ppb
Eliminate
* Most of the values are less than 1.0 ppb.
** Most of the values are less than 2.0 ppb
• (� ,� Iry � '^,v. `-'",w- . �..
t l OCT 2 1
4 2008
Note: Averaging using the Excel program did not take into account values that are less than
the detection levels so many of the above values are actually lower if the less than values are
also accounted for.

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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secreta
Date: January 12, 2011
To: Coleen Sullins, Director
Division of Water Quality
From: Art Barnhardt, Hearing 0
4
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VIA �
Subject: Duke Energy- Marshall, Riverbend & Allen Steam Stations
NPDES Permits NC0004987, NC0004961, NC0004979
Coal Fired Steam Power Generation Facilities
Catawba River Basin, Gaston & Catawba Counties
C'C(ovG�QVI(.C.
Please find submitted with this transmittal memo, the report for the Public Hearing
associated with the subject 3 NPDES permit renewals. Please advise if any of the
information submitted needs clarification as you consider these permit actions.
Thank you for the opportunity to have served in this role for the State of North
Carolina and the citizens that rely on DWQ to protect the water quality.
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699.1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] l FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748
Internet: www.nc jatergualif .org
An Equal Opportunity 1 Affirmative Action Employer
NorthCaroEna
NRatmully

HEARING OFFICER REPORT
for
Renewal of NPDES Permits and Continuation of 316(a) Temperature
Variances
Duke Energy (Marshall, Riverbend,'and Allen Steam Stations)
This report is presented to the Director of the North Carolina Division of the Water Quality
INTRODUCTION
On September 15, 2010 a notice of Public Hearing was published in the Charlotte Observer and
Hickory Daily Record, requesting public comment on Draft NPDES Permit renewals and proposed
Clean Water Act (CWA) Section 316 (a) temperature variance continuations for three Duke Energy
facilities (i.e., Marshall Steam Station, Riverbend Steam Station, and Allen Steam Station) located in
the Catawba River Basin. The public notice also provided information on a public hearing to be held
to solicit additional comment.
A public hearing was held on October 19, 2010, at the Charles Mack Citizen Center in Mooresville,
NC. Oral and written comments became part of the public record, which was closed at the end of
the hearing. Art Barnhardt with the Division of Water Quality's Fayetteville Regional Office served
as the Hearing Officer.
This Hearing Officer Report summarizes the major issues raised through the public hearing process,
as well as the Hearing Officer recommendations for the NPDES permit renewals and CWA 316(a)
temperature variances. The Director of the Division of Water Quality will take final action on these
recommendations.
1

FACILITY BACKGROUNDS
Duke Energy/Marshall Steam Station (NPDES Permit# NC0004987)
Duke Energy's Marshall Steam Station is a coal .fired steam electric plant in Catawba County. This
facility discharges wastewater to Lake Norman (classified Water Supply) in the Catawba River Basin.
Lake Norman is not listed on the 2010 303(d) list of impaired waters. The facility discharges
wastewater via five permitted outfalls: Outfall 001 (Condenser Cooling Water); Outfall 002 (Ash
basin); Outfalls 002a&b (yard sump overflows); and Internal Outfall 004 (flue gas desulfurization
(FGD) treatment system discharge to ash basin). The facility has an FGD scrubber, dry fly ash
handling system, one active ash pond, one active landfill for FGD waste, and one inactive coal ash
landfill-Th'e facility submitted a Balanced and Indigenous (BIP) report in support of its CWA 316 (a)
temperature variance continuation, and the BIP report was reviewed and approved by the Division's
Environmental Sciences Section (ESS).
Duke Energy/Riverbend Steam Station (NPDES Permit# NC0004961)
Duke Energy's Riverbend Steam Station is a coal fired steam electric plant in Gaston County. The
facility discharges wastewater to Mountain Island Lake (classified Water Supply) in the Catawba
River Basin. Mountain Island Lake is not listed on the 2010 303(d) list of impaired waters. The
facility discharges wastewater via three permitted outfalls: Outfall 001 (Condenser Cooling Water);
Outfall 002 (ash basin); and Outfall 002a (yard sump overflows). Duke Energyplans to close this
peak load facility down by 2015, therefore they have not installed an FGD scrubber system. The
facility currently operates two active ash ponds. The facility submitted a Balanced and Indigenous
(BIP) report in support of its CWA 316 (a) temperature variance continuation, and the BIP report was
reviewed and approved by the Division's Environmental Sciences Section (ESS).
Duke Energy/Allen Steam Station (NPDES Permit# NC0004979)
Duke Energy's Allen Steam Station is a coal fired steam electric plant in Gaston County. The facility
discharges wastewater to the Catawba River and South Fork Catawba River (both classified Water
Supply) in the Catawba River Basin. The Catawba River near the discharge point is listed on the 2010
303(d) list as impaired, while the South Fork Catawba River is not listed as impaired. The facility
discharges wastewater via seven permitted outfalls: Outfall 001 (Condenser Cooling Water); Outfall
002 (ash basin); Outfalls 002a&b (yard sump overflows); Outfalls 003 and 004 (miscellaneous non -
contact cooling water); and Internal Outfall 005 (flue gas desulfurization (FGD) treatment system
discharge to the ash pond). The facility has an FGD scrubber, a dry fly ash handling system, one
active and one inactive ash pond, and oneactive landfill for FGD waste and coal ash. The facility
submitted a Balanced and Indigenous (BIP) report in support of its CWA 316 (a) temperature
variance continuation, and the BIP report was reviewed and approved by the Division's
Environmental Sciences Section (ESS).
P)

PUBLIC RECORD
The Division held a public hearing in Mooresville NC on October 19, 2010. Approximately 74 people
attended the public hearing and about 20 attendees provided oral comments. Attendees and
speakers included representatives from Duke Energy, Mecklenburg County, several environmental
interest groups and concerned citizens. Overall, the Division received 160 written comments.
Each facility discharges heated water via Outfall 001, and ash basin wastewater via Outfall 002.
Primary issues raised through the permit process include potential impacts to aquatic life due to the
heated water discharge, and potential impacts to aquatic life and human health due to the
discharge of ash pond wastewater.
Listed below is a summary of issues raised, and Division staff response to those comments.
1) Effluent Monitoring. There were several requests for more frequent and more expansive
effluent monitoring, particularly for metals from Outfall 002 (ash pond discharge).
Response: Frequency of monitoring and number of parameters that are being monitored
are based on results of the reasonable potential analysis (RPA). If a parameter shows
reasonable potential and requires a limit, monitoring is generally at a monthly or quarterly
frequency. If a parameter does not show reasonable potential, monitoring might drop to
quarterly or not be required. Monthly discharge monitoring reports (DMRs) and priority
pollutant scans (required with each permit renewal) are evaluated for RPA with each
renewal. The proposed monitoring frequencies will provide adequate information to
conduct RPAs for the next permit renewal. The contaminants that have received the most
attention with coal ash discharge include arsenic, mercury, and selenium. These core
parameters are in the Draft permit monitoring requirement for Outfall 002 (with the
exception of mercury at Duke Riverbend), and will be retained regardless of RPA results.
Based on public concern, DWQ staff recommends that quarterly effluent monitoring for
mercury be added to Outfall 002 (ash pond discharge) for the Duke Riverbend Final Permit,
which will result in all three facilities maintaining a core monitoring for arsenic, selenium,
and mercury in their effluent..
2) Effluent Limits. There were several requests for addition of effluent permit limits for all
metals at Outfall 002 (ash pond discharge).
Response: The need for water quality based effluent permit limits is determined according
to a reasonable potential analysis (RPA). The RPA procedure utilized by the Division is in
3

accordance with EPA's regulation at 40 CFR 122.44(d)(1). Permit limits are added only if the
results of the RPA suggest potential for exceeding the water quality standards, and are not
arbitrarily assigned. However, absence of permit limits does not allow the facility to violate
in stream water quality standards.
3) Fish tissue monitoring. There were several requests for the addition of fish tissue
monitoring requirements to the permits, particularly near Outfall 002 (ash pond discharge).
Response: Although the facilities are not currently required to conduct fish tissue
monitoring, Duke Energy has conducted fish tissue monitoring in the past in both Lake
Norman (near Duke Marshall) and Mountain Island Lake (near Duke Riverbend).
Selenium, arsenic, mercury, and zinc concentrations were measured in common carp,
sunfish, and bass collected by electrofishing in July (2004 — 2008) at four locations in
Mountain Island Lake. Trace element concentrations have been measured in Mountain
Island Lake common carp, sunfish, and bass since 1988. Trace element concentrations from
2004 to 2008 remained well below values of regulatory concern, where such values exist.
Limited fish sampling in Lake Norman was also conducted in 2009. Approximately 25 bass
were sampled for selenium and mercury. Concentrations were 0.55 mg/kg and 0.11 mg/kg,
and both were below the recommended NC DHHS criteria of 10 mg/kg (selenium) and 0.4
mg/kg (mercury). Based on public concern, DWQ staff recommends that a fish tissue
monitoring event (once/permit cycle) be added to all three permits. Fish tissue should be
analyzed for arsenic, selenium, and mercury, with details of the monitoring to. be
established by ESS biologists.
4) Instream monitoring. There were several requests to add instream monitoring to the
permits.
Response: Facilities are required to conduct biological studies to support renewal of the
CWA 316(a) temperature variance. These BIP (balanced and indigenous population) studies
include instream monitoring as an integral part of evaluation. Each facility has 6-7
permanent instream monitoring stations, and a few additional temporary stations. DWQ
biologists establish monitoring plans for the biological studies and review the results. Based
on public concern, DWQ staff recommends the addition of semiannual instream monitoring
(upstream and downstream) for arsenic, selenium, mercury, chromium, lead, cadmium,
copper, zinc, and total dissolved solids (TDS). Instream monitoring should be conducted at
the stations that have already been established through the BIP monitoring program.
4

I
5) Total Dissolved Solids (TDS). There were several requests for addition of a 500 mg/L
effluent limit for TDS.
Response: There is a water quality standard for TDS (500 mg/1) for water supply waters,
which includes the subject receiving waterbodies. Duke Energy measured TDS in the ash
ponds for all three powers plants. The results are: Allen — 740 mg/L, Marshall — 730 mg/L,
Riverbend —100 mg/L. Based on the available dilution (instream waste concentrations are
10% at Riverbend, 17% at Marshall, and 20% at Allen), it is unlikely that the instream water
quality standard for TDS would be violated. Actual monitoring in the lakes conducted during
2000 through 2009 indicates that TDS values are well below 100 mg/L. Based on public
concern, DWQ staff recommends the addition of semiannual instream monitoring
(upstream and downstream) for TDS (refer to Response to Comment #4 above).
6) Total Suspended Solids (TSS) and Turbidity. There were several requests for increased
monitoring and/or more stringent permit limits for TSS. - Additionally, the Catawba
Riverkeeper provided a picture of Lake Norman (near Marshall Steam Station) with a darker
color plume apparently emanating from the Outfall 001 cooling water discharge, contending
that this plume is a result of high TSS/turbidity in the discharge.
Response: US EPA sets Effluent Limitations Guidelines for TSS (per 40 CFR 423) for fly
ash/bottom ash; thus these permits incorporate TSS limits at the coal ash pond discharge
(Outfall 002). EPA requirements do not set TSS limitations for once through cooling water
(Outfall 001), and these permits are consistent with that decision. Monthly monitoring for
TSS at the ash pond discharges (Outfall 002) is considered adequate based on the historical
data. Long-term monitoring data indicates very low concentration of TSS in the discharge
from these power plants, usually within 5-10 mg/L.
During summer, Lake Norman is subject to thermal stratification. The Marshall Station
withdraws cooling water from a depth of approximately 60 feet, to ensure compliance with
the temperature limit and for greater power plant efficiency. This deep layer of water
contains reduced forms of iron and manganese, which are formed due to the lack of oxygen.
This phenomenon is similar to formation of dissolved iron and manganese in the
groundwater. When this water from the deep layer of Lake Norman is exposed to the
oxygen on the surface, iron and manganese are oxidized and water becomes discolored.
This plume cannot be attributed to the turbidity of the discharge or TSS concentration. The
maximum concentration of TSS in the cooling water discharge of the Marshall Steam Station
during the previous permit cycle was only 4 mg/L.
5

r
7) Temperature Variance. There were several comments that the existing CWA 316(a)
temperature variances are not protective enough and DWQ should implement daily
maximum temperature limits instead of monthly average limits.
Response: Continuation of the CWA 316(a) temperature variance is predicated on a positive
demonstration of balanced and indigenous macroinvertebrate and fish community in the
receiving waterbodies. The Division's Biological Assessment Unit reviewed the biological
reports and concurred with the BIP conclusions. Therefore, the alternative temperature
limits in the Draft Permit are considered to provide adequate protection for aquatic life.
8) Arsenic exceedences near Riverbend Outfall 002 (ash pond discharge). Both Mecklenburg
County and the Catawba Riverkeeper indicated that some surface water samples collected
near the Riverbend ash pond discharge showed concentrations of arsenic above the water
quality standard of 10 ug/L.
Response: The NC regulations (15A NCAC 213.0206) allow for dilution provided by upstream
flow (either 7Q10, 30Q2, or mean annual flow) when establishing effluent permit
limitations. This approach is consistent with EPA guidance (US EPA 1991, Technical Support
Document for Water Quality -Based Toxics Control). Dilution may not occur instantaneously,
thus there is an implicit mixing zone near the point of discharge where water quality
standards might be exceeded. Surface water sampling indicates that these exceedences are
very infrequent. Surface water samples collected approximately 0.5 miles downstream from
the discharge in the main stem of the Catawba River show 32 out of 39 samples were below
the detection level for arsenic, and the maximum arsenic value was 3.6 ug/L, which is well
below the water quality standard of 10 ug/L. In addition, surface water sampling conducted
at the City of Charlotte's drinking water intake during the same time period showed all
samples (n= 22) below the arsenic detection level.
9) Mixing Zone. There were several comments submitted requesting delineation of mixing
zones in the permits.
Response: As indicated in Response to Comment 8 above, state regulations provide for an
implicit mixing zone based on consideration of upstream dilution, and this was incorporated
into development of metals limits. Evaluation of a mixing zone for temperature is a special
case subject to CWA Section 316(a) requirements. Since all three facilities have a CWA
316(a) temperature variance, they are required to conduct BIP studies. If these biological
studies demonstrate the existence of a positive BIP, then the temperature variance can be
continued and mixing zone delineations are not necessary.
0

10) Coal ash pond closure. - There were several requests for a permit requirement to develop an
Ash Pond Closure Plan, including clean-up, lining, and closure of ash ponds.
Response: EPA is currently developing new regulations for coal ash disposal. Most of the
ash disposal requirements will fall under the purview of the Division of Waste Management,
and it is still uncertain at this time what final regulations will be adopted.
11) Implement proposed water quality standards from Triennial Review. There was one
request for the permits to reflect proposed water quality standard changes from the current
Triennial Review, including copper, zinc, and nickel.
Response: The Triennial Review has not been finalized and approved by the EMC and EPA.
The approval process might cause significant changes in the proposed standards.
Therefore, it is premature for DWQ to implement these standards into permit limits at this
time.
12) Technology/FGD wastewater treatment. There was one request for installation of a zero
discharge Flue Gas Desulfurization (FGD) treatment system for the Marshall Steam Station.
Response: An FGD treatment system is already installed at Duke Marshall, and it would be
extremely expensive to retrofit it with the new technology. It is also difficult to install a zero
discharge system on an existing plant. EPA is currently re-evaluating its Effluent Limitations
Guidelines for the Steam Electric Point Source Category (40 CFR 423), and the Division will
review and incorporate any new federal requirements for FGD discharges once EPA
completes its regulatory process.
13) Technology/Dry cooling system. There was one request for installation of dry cooling
systems to avoid hot temperature discharges.
Response: EPA reviewed dry cooling technologies and concluded that they are very
inefficient and expensive. They require more coal to generate the same amount of energy.
Therefore, they were not recommended for implementation in the 316(b) Phase II rule.
Even the cooling towers, which are less expensive and more efficient than dry cooling
systems, are not currently required by regulation. In addition, BIP studies indicate no
impact on the receiving lakes. Therefore, DWQ does not believe that there is a need for dry
cooling systems.
7

14) Miscellaneous wastes. There was one request for addition of a new permit requirement to
report volumes and types of miscellaneous wastes to be identified and reported by the
permittee.
'Response: Federal and state rules do not contain such a requirement. in addition, the
miscellaneous wastes that are discharged to the ash pond represent an extremely small
percentage of the overall discharge flow. The existing monitoring and reporting
requirements are considered sufficient.
15) Arsenic and mercury in water treatment residuals. There was one comment from the city
of Gastonia expressing concerns about the amount and source of arsenic and mercury found
in their water treatment plant sludge. They requested a scientific evaluation to determine
the source(s) of these elements in the sludge.
Response: Discharges from power plants contribute to the overall mercury and arsenic
loading. Monitoring of the ash pond discharge and surface water indicates that
concentrations of mercury and arsenic in the discharge and the lakes are within a safe
range.
16) Forced Evaporation/Surface Water Loss. There was one request that the permit process
should consider the impact of forced evaporation upon the State water supply.
Response: This request is outside the purview of the NPDES program.
17) Climate change. There was one request that the permits should take climate change into
account.
Response: This request is outside the purview of the NPDES Program.
0

Findings and Observations of the Hearing Officer
After consideration of input from the public, Duke Energy, DWQ staff and results of past
environmental and water quality monitoring data generated it is quite evident that all the
participants in the hearing process have a high level of interest in maintaining the water quality
within this section of the Catawba River Basin. Duke Energy has good historical record of
compliance over the most recent NPDES permit cycle. Utilization of the water resources to help
meet the consumer energy demands, as is done at these three Duke Energy facilities, cannot be
achieved with zero impact. Therefore the permits and temperature variances being considered
through this hearing process are the means to control the impacts to the levels required by State
and Federal regulations. As a result, the public comment process did identify several permit
improvement issues where minor changes will be recommended for incorporation in the permits.
Effluent monitoring, effluent limits (including TDS & TSS):
Some public comment recommended additional effluent monitoring and lower effluent limits. The
inferred reasoning is to protect water quality to a higher standard due to the cumulative impact of
the Duke Energy Facilities along with the many other water quality impacting activities within the
basin. Additionally, one person at the public hearing testified as having some skepticism in allowing
the Duke Facilities to self -monitor effluent and in stream water quality indicators. The Hearing
Officer does not share this skepticism, but is interested in reporting to the Director of DWQ the
perceptions of the public that invested the time and effort to attend the forum.
Since self-monitoring is a standard practice at nearly all NPDES permitted facilities it is important for
all stakeholders to have a high level of confidence in the data being generated. Compliance
monitoring inspections are a part of the DWQ oversight effort and are geared to enhance the quality
control and quality assurance of this important environmental compliance activity. While not
proposing any changes to the draft NPDES permits to address this specific issue, it is a
recommendation to the Director that DWQ staff partner with stakeholders to obtain ideas on
possible ways to structure DWQ compliance sampling inspections that would build confidence in the
self-monitoring data output.
In the opinion of the Hearing Officer, the regulatory NPDES permitting processes by which effluent
monitoring and limits are established have been properly applied by the DWQ permitting staff. It is
also the Hearing Officer's opinion that the monitoring requirements for core parameters (mercury,
arsenic, selenium should be consistent for all 3 permits.
N�

Fish Tissue Monitoring and In Stream Water Quality:
Tissue analysis for target indicators is one of many ways to measure overall water quality by
examination of the various fish populations within a water body. Some previous work has been
accomplished by Duke Energy (and others) where the results have Indicated generally acceptable
tissue conditions. While tissue monitoring is not required as part of the ongoing BIP studies, it is
information that can complement the BIP results and produce a more comprehensive view of the
resource status.
The same reasoning applies to in stream water quality monitoring. Conducting water quality
analyses at the BIP station locations for effluent related constituents may not be necessary to
evaluate the indigenous species populations and diversities but it would also be a good complement
to the long term water quality monitoring effort and likewise would provide a better view of the
resource condition. It is the Hearing Officer's opinion that collection of this additional
environmental data would be valuable and easy to accomplish by Duke Energy.
Discharge of Non -Contact Cooling Water
The thermal discharge was a topic discussed with the 2 main concerns; first, the NC Water Quality
Standard—
(15A NCAC 028.0211(3) (i)) should apply without allowing the variance under (15A NCAC
028.0208 (b) m and second, the Impact that warmed water has on forced evaporation rates.
It is the opinion of the Hearing Officer that Duke Energy has made the demonstration through BIP
Studies, results of which have been evaluated by DWQ Biological Assessment Unit, that allow for the
continued CWA 316(a) temperature variance. In relation -to forced evaporation, it is a fact that
there is higher evaporation potential with increased temperature. The scope of the NPDES
Permitting Program does not include regulatory authority to account for loss of water through
forced evaporation. However it is an important Catawba River Basih dynamic that the Hearing
Officer feels the Director or DWQ should be appraised of in order to factor into future resource
management decisions that will arise as our finite water resource use continues to rise.
Arsenic above Water Quality Standard of 10 ug/1 near Riverbend Outfall 002 and Mixing Zones
The zone of water in the area adjacent to an outfall, before effluent has the ability to mix with the
receiving waters, is known as the mixing zone which is defined in ISA NCAC 028.0202 DEFINITIONS
(44). Although none of the mixing zones around any of the Duke Energy outfalls has been officially
delineated, the arsenic sample locations referred to in the Public Hearing were in such close
proximity to the outfall it is with little doubt within this zone. By rule, water quality standards do
not apply within a mixing zone except as defined in 15A NCAC 02B.0204 (b)1-4.Other water quality
data collected from locations (further from the outfall) in the water body such as the BIP Study
sample locations indicate acceptable arsenic concentrations. It is the Hearing Officer's opinion that
10

although.established delineated mixing zones would create a precise boundary in which to measure
in stream water quality compliance, it would not be significantly different than the current
configuration of the BIP monitoring stations or alter the ability of the State to enforce water quality
regulations within the Catawba Basin adjacent to these 3 Duke Energy facilities.
Storage Structure (Dike) Inspections
The draft permits contain the requirement for Duke Energy to inspect the ash pond dikes.
Comments from the hearing indicated the need to specify an inspection schedule -and record
keeping requirement. Many of the DWQ Permits (Non-NPDES) containing storage structures specify.
inspection frequency and record keeping requirements. Similarly, it is the Hearing Officer's opinion
that outlining the inspection frequency and record keeping requirements would be a beneficial
addition to the permit language.
Groundwater Monitoring Comments
The draft permits contains new groundwater monitoring requirements. The comments made during
the open record were in support of the addition of these requirements. It is the Hearing Officer's
opinion that no changes to this proposed portion of the draft permit are in necessary.
Other Water Resource Related Comments
Several comment topics provided during the open record discussed issues of importance related to
protection of the water resource, but are beyond the regulatory oversight of these NPDES Permit
renewals: They consisted of coal ash pond closure, implementing water quality standards from
triennial :review, requiring new technology for FDG wastewater treatment, requiring new cooling
technology, factoring in climate change and developing a drinking water contingency plan in case of
an ash pond failure. It is the Hearing Officer's opinion that these issues are not within the scope of
the NPDES Permitting process and have been given proper consideration.
Hearing Officer Recommendations
Based on review of the public record and written/oral comments received during the public hearing
process, I recommend to the Division Director that the three Duke Energy Draft NPDES Permits
(Duke Energy- Marshall, Riverbend, Allen) be revised and issued with the following minor changes
and continuation of 316(a) Temperature Variances:
11

1- Quarterly effluent monitoring for mercury should be added to Outfall 002 (ash pond
discharge) for the Duke Riverbend Final Permit.
2 -Fish tissue monitoring event (once/permit cycle) be added to all three permits. Fish tissue
should be analyzed for arsenic, selenium, and mercury, with details of the monitoring to be
established by ESS biologists.
3 -Addition of semiannual in stream monitoring (upstream and downstream) for arsenic,
selenium, mercury, chromium, lead, cadmium, copper, zinc, and total dissolved solids (TDS). In
stream monitoring should be conducted at the stations that have already been established
through the BIP monitoring program.
4 -Addition of a specified storage structure (dikes) inspection frequency consisting of weekly and
after any 1 inch or greater rainfall events. A record of the inspection shall also be kept on file
and should consist of date, time and person that conducted the inspection.
12 ,3—,3 k6 Zis Lv it
Steph A. Barnhardt, Hearing Officer Date
12

North Carolina ] ss
Mecklenburg County?
The Charlotte Observer Publishing Co.
Charlotte, NC
Affidavit of Publication
THE CHARLOTTE OBSERVER
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REFERENCE: 30063432
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County of Mecklenburg, and State of North Carolina
and that as such he/she is familiar with the
books, records, files, and business of said
Corporation and by reference to the files of said
publication, the attached advertisement was
inserted. The following is correctly copied from
the books and files of the aforesaid Corporation
and Publication.
i
PUBLISHED ON: 09/17
AD SPACE: 130 LINE
FILED ON: 09/23/10
--- --- - -- - -- -- --------- ---+- - -----------
NAME: TITLE:
DATE: SEP"? 1 201n
In Testimony Whereof I have hereunto set my hand and affixed my seal, the
day and ear aforesaid. o-
Notary': / ly ommmission Expires:
My Commission -Expires Wit 27, 201 `i
K]
C

Hickory Daily Record .
Advertising Affidavit
North Carolina Community Newspapers
PO Box 968
Hickory, NC 28603
NC DENR/DWQ
BUDGET OFFICE
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699
Account Number
3142720
Date
September 15, 2010
Date Category Description Ad Number Ad Size
09/15/2010 Legal Notices PUBLIC NOTICE SUBJECT: The North Carol 0002036277 1 x 78 L
PUBLIC NOTICE
SUBJECT: The North Carolina Environmental Man-
agement Commission proposes to Issue the fol-
lowing NPDES wastewater discharge permits, and
Is Inviting public comment on the draft permits.
Additionally, a public hearing has been scheduled
to provide additional opportunity for comments.
Duke Energy Corp., Riverbend Steam Station
(Gaston County), NPDES Permit #NC0004963
Duke Energy Corp.. Allen Steam Station
(Gaston County), NPOES Permit UNC0004979
Duke Energy Corp., Marshall Steam Station
(Catawba County), NPDES Permit ONC0004987
PURPOSE: On the basis of preliminary staff review
and application of Article 21 of Chapter 143, Gen-
eral Statutes of North Carolina, and other lawful
standards and regulations;. the North Carolina En-
vironmental Management Commission proposes
to reissue NPDES permits for these facilities sub•
sect to specific pollutant limitations and special
conditions and to continue the 316(a) temperature
variances- The Director of the Division of Water
Quality pursuant to NCGS 143-215.1(c)(3) and Reg-
ulation 15 NCAC 2H, Section .0100 has determined
that It Is In the public Interest that a hearing be
held to receive all pertinent public comment on
whether to Issue, modify, or deny the permits.
PROCEDURE: Written comments on the draft per-
mits will be accepted until the date of the Public
Hearing. Any person or organization desiring to
make oral comments should register to do so at
the hearing. The time available for oral comments
may be limited by the Hearing Officer. Oral pre.
' sentations that exceed three minutes should be
accompanied by three written copies. The hearing
record may be closed at the conclusion of the
hearing. ,
WHIN: Tuesday. Oclaber 19. 2010 at 7:00 p.m.
(Registration begins at 6:00 p.m.)
WHERE. Charles Mack Citizen Center
215 North Main Street
Mooresville, North Carolina 28115
INFORMATION: A copy of the draft NPDES
permits can be downloaded from the following
link:
http✓/Portai.ncdenr.org/web/wq/s wp/ps/npdes7'
calendar
The draft permits arealso available by writing or
calling:
Ms. Dina Sprinkle
NC Division of Water Quality/ NPDES Unit
1617 Mail Service Center
- Raleigh, North Carolina 27699-1617
Telephone number- [phone]
The application and other Information are ori file
at the Division of Water Quality, 512 North Salis-
bury Street, Room 925 of the Archdale Building in
Raleigh, North Carolina and at the Division's
Mooresville Regional Office (610'East Center Ave-
nue, Suite 301, Mooresville, NC 28115). They may
be inspected during normal office hours. Copies of
the Information on file are available. Upon request
and payment of the costs of reproduction. All such
comments and requests regarding this matter
should make reference to the permit numbers,
NC0004961. NC0004979, and NC0004987.
Publish: September 15, 2010.
1
THIS IS N
Media General Operations, Inc.
Publisher of
Hickory Daily Record
,Catawba County
Before the undersigned, a Notary Public of Catawba County, North
Carolina, duly commissioned, qualified, and authorized by law to
administer oaths, in said County and State; that he/she is authorized to
make this affidavit and sworn statement; that the notice or other legal
advertisement, a copy of which is attached hereto, was published in the
Hickory Daily Record on the following dates:
09/15/2010
and that the said newspaper in which such notice, or legal advertisement
was published, was a newspaper meeting all the rcquiremcnta and
qualifications of Section 1-597 of the General Statutes of North Carolina.
r, Assist -B00 keeper :_ -
Newspaper reference: 0002036277
S om to and subscribed before me, this day oa--f 2010
Notary Public
�0TAR�
My Commission expires: k 60 o2 O y AO Q L% G V
OTA BILL. PLEASE PAY FROM INVOICE. •THA�1a4ff%f�OITOU'N ;,%%%

Duke Energy
Allen, Marshall, and Riverbend Stations
NPDES Public Hearing
Mooresville, NC
October 19, 2010
Sergei Chemikov., Ph.D.
North Carolina Division of Water Quality,

Steam Electric Plants With Coal Ash Ponds
Progress Energy facilities
Duke Energy facilities
uke .pan,
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Duke Ener2v Stations
Station
FGD'*
Ash
Landfills (only coal ash and
System
Pond
FGD waste)
1) Riverbend
No
2 active
No
Gaston County
,Shut down by 2015
Charlotte drinking
water intake 3.6
miles downstream
2) Marshall
Yes
1 active
1 inactive (coal ash)
Catawba County
F
1 active (FGD waste)
Dry fly ash handling
-
1 proposed double lined with
leak detection (coal ash)
3) Allen
Yes
1 active
1 active double lined with leak
Gaston County
1 retired
detection, on top of retired ash
Dry fly ash handling
I pond
FGD — flue gas desulfurization

Regulatory Framework
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Dam Safety Inspections
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A - I
Fish Tissue Sampling

Permit Limit Development
�c`ility to
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DWQ Regulatory Oversight

4
'' Draft Permit Summary

DUKE ENERGY CORP PUBLIC HEARING
SIGN IN SHEET — OCTOBER 19, 2010 DUKE ENERGY CORP PUBLIC HEARING
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DUKE ENERGY CORP PUBLIC HEARING
SPEAKER SIGN IN SHEET - OCTOBER 19, 2010 _DUKE- ENERGY CORP PUBLIC HEARING
ALL SPEAKERS MUST BE PRESENT TO SIGN IN
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DUKE MARSHALL STEAM STATION
PERMIT NC0004987
GROUNDWATER MONITORING WELL CONSTRUCTION AND SAMPLING PLAN ;r
1. The permittee shall conduct groundwater monitoring as may be required to determine the
compliance of this NPDES permitted facility with the current groundwater Standards found
under 15A NCAC 2L.0200
2. WELL CONSTRUCTION. Within 120 days of permit issuance, monitoring wells, as
proposed on Attachment 1, shall be installed to monitor groundwater quality.
a. Shallow (S) monitoring wells shall be constructed such that the water level in the
monitoring well is -never above or below the screened (open) portion of the well at
any time during the year. Deep (D) monitoring wells shall have screen(s) at -
designated intervals in the water column below the static shallow groundwater
level. The deep wells should be constructed such that the screened portion is
discrete and situated in the transition zone between competent bedrock and. the
regolith. Monitoring wells shall be constructed in accordance with 15A NCAC 02C
.0108 (Standards of Construction for Wells Other than Water Supply) and any
other jurisdictional laws and regulations pertaining to well construction. The
general locations for all monitoring wells are indicated on Attachment 1.
b. The Mooresville Regional Office, telephone number [phone] shall approve
the location of new monitoring wells prior to installation. The regional office shall
be notified at least 48 hours prior to the construction of any monitoring well and
such notification to the Aquifer Protection Section's regional supervisor shall be
made from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays.
c. Within 60 days of completion of the monitoring wells, the Permittee shall submit.. ,
two original copies of a site map with a scale no greater than 1 -inch equals 500
feet. At a minimum, the map shall include the following information:
i. The location and identity of each monitoring well.
ii. The location of major components of the waste disposal system.
iii. The location of property boundaries within 500 feet of the disposal areas.
iv. The latitude and longitude of the established horizontal control monument.
v. The elevation of the top of the well casing (i.e., measuring point) relative to a
common datum.
vi. The depth of water below the measuring point at the time the measuring
point is established.
vii. The location of compliance and review boundaries.
viii. The date the map is prepared and/or revised.
ix. Topographic contours in no more than ten (10) foot intervals
d. The above information should be overlaid on the most recent aerial photograph
taken of the site. Control monuments shall be installed in such a manner and made
of such materials that the monument will not be destroyed due to activities taking
place on the property. The map and any supporting documentation shall be sent to
the Division of Water Quality, Aquifer Protection Section, 1636 Mail Service
Center, Raleigh, NC 27699-1636.
NPDES Well Construction and Groundwater Monitoring Page 1 of 3 3/15/2010

e.The well(s) must be constructed by a North Carolina Certified Well Contractor, the
property owner, or the property lessee according to General Statutes 87-98.4. If the
construction is not performed by a certified well contractor, the property owner or
lessee, provided they are a natural person, must physically perform the actual well
construction activities.
f.The monitoring wells shall be regularly maintained. Such maintenance shall
include ensuring that the well caps are rust -free and locked at all times, the outer
casing is upright and undamaged, and the well does not serve as a conduit for
contamination.
GROUNDWATER SAMPLING. Monitoring wells shall be sampled after construction and
thereafter at the frequencies and for the parameters as specified in Attachment XX.
Groundwater sampling done by other than monitoring wells shall be monitored at the same
frequency and for the same parameters as required for monitoring wells. The method(s) for
sampling other than by wells shall be at the discretion of the Permittee, but should be
conducted at or as close to the compliance boundary as physically possible. All mapping,
well construction forms, well abandonment forms and monitoring data shall refer to the
permit number and the well nomenclature as provided on Attachment XX.
a. Per 15A NCAC 02H .0800, a Division certified laboratory shall conduct all
laboratory analyses for the required effluent, groundwater or surface water
parameters.
b.The measurement of water levels shall be made prior to purging the wells. The
depth to water in each well shall be measured from the surveyed point on the top of
the casing. The measurement of pH shall be made after purging and prior to
sampling for the remaining parameters.
c. The measuring points (top of well casing) of all monitoring wells shall be surveyed
to provide the relative elevation of the measuring point for each monitoring well.
The measuring points (top of casing) of all monitoring wells shall be surveyed
relative to a common datum.
d.For initial sampling of monitoring wells, the Permittee shall submit a Compliance
Monitoring Form (GW -59) and a Well Construction Record Form (GW -1) listing
this permit number and the appropriate monitoring well identification number.
Initial Compliance Monitoring Forms (GW -59) without copies of the Well
Construction Record Forms (GW -1) are deemed incomplete, and may be returned
to the Permittee without being processed.
NPDES Well Construction and Groundwater Monitoring Page 2 of 3 3/15/2010

e. Two copies of the monitoring well sampling and analysis results shall be submitted
on a Compliance Monitoring Form (GW -59), along with attached copies of
laboratory analyses, on or. before .the last working day of the month following the
sampling month. The Compliance Monitoring Form (GW -59) shall include this
permit number, the appropriate well identification number, and one GW -59a
certification form shall be; submitted with each set of sampling results. All
information shall be submitted to the following address:
Division of Water Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
4. COMPLIANCE BOUNDARY. The compliance boundary for the disposal system shall be
specified in accordance with 15A NCAC 02L .0107(a). This disposal system was
individually permitted prior to December 30, 1983; therefore, the compliance boundary is
established at either 500 feet from the effluent disposal area, or at the property boundary,
whichever is closest to the effluent disposal area. An exceedance of groundwater standards at
or beyond the compliance boundary is subject to remediation action according to 15A NCAC
02L .0106(c) as well as enforcement actions in accordance with North Carolina General
Statute 143-215.6A through 143-215.6C.
ATTACHMENT 1— GROUNDWATER MONITORING PLAN
Permit Number: NC0004987 Version 1.0
WELL
PARAMETER DESCRIPTION
FREQUENCY
NOMENCLATURE
Antimony
Chloride
Manganese
Sulfate
January, May,
Monitoring Wells:
September
Arsenic
Chromium
Mercury
TDS
MW -4, MW -41), MW -
10S, MW- IOD, MW-
Barium
Copper
Nickel
Thallium
115, MW -11D, MW -125,
Water
MW -12D, MW -135,
Boron
Iron
Nitrate
Level
MW -13D, MW -145,
MW -14D
Cadmium
Lead
pH
Zinc
Selenium
Note 1: For locations of monitoring wells, see attached map.
Note 2: Monitoring revisions may be considered, as applicable, if there are no significant detections prior
to permit renewal.
NPDES Well Construction and Groundwater Monitoring Page 3 of 3 3/15/2010

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#� a�M DUKE ENERGY CATAWBA-WATEREE PROJECT
FERC PROJECT NO. 2232Lenen
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Hickory Daily Record
Advertising Affidavit
North Carolina Community Newspapers
PO Box 968
Hickory, NC 28603
NC DENR/DWQ
BUDGET OFFICE
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699
Account Number
3142720
Date
September 15, 2010
Date Category Description Ad Number Ad Size
09/15/2010 Legal Notices
PUBLIC NOTICE
SUB1ECTe The'North Carolina Environmental N131[=
agement commission proposes�to Issue the fol=
lowing NPDES wastewater discharge permits, and
is" inviting public comment on the draft;.permits "�
Additionally, a public hearing'has'been scheduled
to. provide additional. opportunity foccomments.
Duke Energy Corp., Riverbend Steam Station
(Gaston County),.NPDES -.Permit #NC0004961
Duke Energy Corp., Allen. Steam Station
(Gaston County), NPDES Permit #NCOo04979
Duke Energy Corp.. Marshall. Steam Station'
(Catawba County), NPDES 'Permit #NC0004987
era]
NPDES
variances- The .Director of the
Quality pursuant to NCGS 143-2
ulation 15 NCAC 2H, Section .03
that it is in the 'public interest
held to° receive' all. pertinent -p
whether to Issue.'modify,.or dem
PROCEDURE: written comment.
mit. w]II be accepted until the
Hearing. Any. person or organ
make oralcomments should' n
the hearing: The time available
may be limited, by the Hearing
accompanied by three written copies. The hearing
record may be closed at the conclusion of the
hearing.:
WHEN:. Taesday, GC.ober`i9. 2010 at7:00 p m. .
(Registration begins at 6.00 p.m.)
WHERE: Charles Mack Citizen Center+`
215'North Main Street> , -
Mooresville, North Carolina 28115 �,
INFORMATION:' A copy.. of the draft NPDES
permits 'can bedownloaded '-from thefollowing
link:
=//po rtal.ncd en r.o rg/web/wq/swp/ps/n pdes/
calendar
The draft permits are also available by writing.or
calling:,
Ms Dina Sprinkle
NC Division of Water Quality/ NPDES Unit
1617 Mail Service Center -
Raleigh North Carolina276991617
Telephone number:[phone]
The" application and 'other information are on file
at the Division of Water Quality, 512 North Sails-.
NC
comments and requests regarding this matter.
should .make reference to `the permit' numbers,
NC0004961, NC0004979, and NC0004987 '
Publish- September M 2010..''
PUBLIC NOTICE SUBJECT: The North Carol 0002036277 1 x78 L
Media General Operations, Inc.
Publisher of
Hickory Daily Record
Catawba County
Before the undersigned, a Notary Public of Catawba County, North
Carolina, duly commissioned, qualified, and authorized by law to
administer oaths, in said County and State; that he/she is authorized to
make this affidavit and sworn statement; that the notice or other legal
advertisement, a copy of which is attached hereto, was published in the
Hickory Daily Record on the following dates:
09/15/2010
and that the said newspaper in which such notice, or legal advertisement
was published, was a newspaper meeting all the requircment3 and
qualifications of Section 1-597 of the General Statutes of North Carolina.
Assist Boo -per
Newspaper reference: 0002036277
S orn to and subscribed before me,. this day o 2010
IIfitf�rr
Mak/j41
Notary Public � � A,,yj_�.L
My Commission expires: k --POA07 AtJB L \ G V i
THIS IS NOTA BILL. PLEASE PAY FROM INVOICE. THA q4r, 1DIT0U jj%N%%

J��S80 STq�s
A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
<� YW REGION 4
o Q ATLANTA FEDERAL CENTER
61 FORSYTH STREET
+lq< PRO, ATLANTA, GEORGIA 30303-8960
JUL 2 8 2010
Ms. Coleen H. Sullins
Director, Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Draft Permit Review
Duke Energy Corporation — Plant Marshall
NPDES Permit No. NC0004987
Dear Ms. Sullins:
On June 3, 2010, the Environmental Protection Agency (EPA) Region 4 sent a letter to
the North Carolina Department of Environment and Natural Resources (NCDENR) stating we
had an interim objection to the issuance of the National Pollutant Discharge Elimination System
permit for Duke Energy's Marshall Power Plant. The facility's permit application did not
include a Form 2C for outfalls 002A and 002B for yard sump overflows. On July 7, 2010,
NCDENR transmitted the required Form 2C application to Ms. Karrie-Jo Shell of my staff via
email. We have completed our review and have no further comments on the draft permit. EPA
requests that we be afforded an additional review opportunity only if significant changes are
made to the permit prior to issuance, or if significant public comments objecting to the issuance
of this permit are received. Otherwise, please send us one copy of the final permit.
If you have any questions, please call me at [phone] or contact Ms. Shell at
[phone].
Sincerely,
ames D. Giattina
Director
Water Protection Division
cc: Mr. Allen Stowe JUL 3 0 2010
Manager, Duke Power Company--
�recal�_SA8e:5�R C:?%jr^
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

y
'.Chernikov, Sergei
From: Stowe, Allen [AIIen.Stowe@duke=energy.com]
Sent: Friday, July 23, 2010 12:43 PM
To: Chernikov, Sergei; Belnick, Tom; Vinzani, Gil
Subject: RE: request for further info for NPDES review
Sergei,
Here are our comments regarding this certification request by EPA:
At your request, which we understand comes from EPA's inquiry, we have provided estimates of
the composition of sump overflows derived from predictive calculations, using assumptions as
to the degree of dilution afforded by storm flows and constituents from potential sources of
stormwater contamination.
We would like to point out that sump overflows have been very rare, and would be'even more
rare since improvements have been made to the sumps. As the sumps are now configured, an
overflow would occur only as a result of extreme precipitation events during which there was
multiple failures of pumps or motors . Even when sump overflows have occurred in the past,
they have been of very brief duration and a low flow, such that it has not been feasible to
collect a representative sample of_ such overflows, .espec,ially. i2t .,light of the varied -sampling
requirements for the Form 2C parameters.
Because a sump overflow could occur only during a period -of extreme precipitation and the
resulting storm flow, there is no way to project with confidence the concentrations of
constituents in the flow, and, therefore, no way to certify the accuracy of the.projection.
In fact, a sump overflow would be a "bypass" subject to the provisions of 40 CFR 122.44(m).
The outlets provided for sump overflows were installed to prevent severe damage to motors
which power the pumps within the sump. If these outlets were not provided, the motors would
be inundated, requiring replacement or substantial repair, and..thus resulting in potentially
long periods during which the sumps would cease to properly operate. This is no different
than any variety of relief mechanisms for POTWs and other treatment systems which may be used
to avoid comparable damage to treatment or collection systems that would require extended
periods to replace or repair, resulting in environmental damage far more significant than the
bypass would cause. There is no requirement in NC or EPA rules for certification of
predictions of constituent concentrations or loads in hypothetical bypasses. Duke Energy
would, of course, comply with the provisions of 40 CFR 122.41(m) in the event of a sump
overflow.
If you have any comments or concerns, please let me know.
Thanks
Allen Stowe
EHS Water Management
Duke Energy Carolinas
704-382-4309 (Office)
704-516-5548 (Cell)
[e-mail]
-----Original Message -----
From: Chernikov, Sergei[mailto:[e-mail]]
Sent: Friday, July 09, 2010 3:30 PM
To: Stowe, Allen; Belnick, Tom; Vinzani, Gil
1

Subject: RE: request for further info for NPDES review
Allen,
le
This is a standard cover letter for including a new information with the renewal application
that was submitted previously. I know that Duke submitted such letters in the past.
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex Permitting Unit
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
E-mail correspondence to and from this address may be'subject to the North Carolina Public
Records Law and may be disclosed to third parties.
-----Original Message -----
From: Stowe, Allen [mailto:[e-mail]]
Sent: Friday, July 09, 2010 2:31 PM
To: Chernikov, Sergei; Belnick, Tom; Vinzani, Gil
Subject: RE: request for further info for NPDES review
Sergei,
I'm not trying to be difficult but why should we (Duke Energy) submit a.cover letter asking
to amend the application renewal when in fact EPA requested this additional information, not
us? Why can't EPA's request suffice? We reluctantly provided this information because its
usefulness is highly dubious at best.
Allen Stowe
EHS Water Management
Duke Energy Carolinas
704-382-4309 (Office)
704-516-5548 (Cell)
[e-mail]
-----Original Message -----
From: Chernikov, Sergei [mailto:[e-mail]]
Sent: Friday, July 09, 2010 10:30 AM
To: Belnick, Tom; Stowe, Allen; Vinzani, Gil
Subject: RE: request for further info for NPDES review
Allen,
I think that EPA is just asking for an official cover letter with the request to amend the
renewal application with the attached documents.
Sergei
2

7
'Chernikov, Sergei
From: Ussery, Chris L [[e-mail]]
Sent: Thursday, June 17, 2010 2:39 PM
To: Stowe, Allen; Chernikov, Sergei
Subject: Marshall and Riverbend Water Volumes
Attachments: image001.gif
Hey guys,
I have calculated the water volume that is in the ponds for both Marshall and Riverbend at this time. Marshall is from a
survey that was completed earlier this year and should be fairly accurate, but the Riverbend is based on a survey
completed in 2005 and estimating ash production sent to the ponds after that date. Let me know if you have any
questions or concerns with the numbers below.
Riverbend Water Volume
Primary + Secondary =140 acre -ft or 226,000 cyds
Marshall Water Volume
Primary only = 285 acre -ft or 460,000 cyds (�'�/ �0 �/ p�Z c G
CHRIS USSERY
Engineer I
Byproducts, Fuels & Materials Handling
7047382-7745 Office
704-985-4917 Mobile
526 S.Church Street
Charlotte NC. 28202
[e-mail]
rind Efl=.-I
1

�t4
NCDENR
North Carolina Department of Environment
Division of Water Qualit
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
November 19, 2009
NOV 2 3 2009 Secretary
Allen Stowe DENR - WATER QUALITY
Water Management, Duke Energy
EC13K POINT SOURCE BRANCH
PO Box 1006
Charlotte, NC 28201-1006
Subject: Review of Duke Energy Carolinas, NPDES Permit NC0004987, "Assessment of Balanced and
Indigenous Populations in Lake Norman near Marshall Steam Station", October 2009.
Environmental Sciences Section staff have reviewed the subject document which was received on October 29, 2009. Eric
Fleek and Bryn H. Tracy reviewed the sections on macroinvertebrates and fish, respectively. By agreement with the
Department of Environment and Natural Resources (NCDENR), Duke Energy conducts annual monitoring of Lake
Norman in the vicinit o he Marshall Stea ation ort NPDES Permit NC0004987 Part 1.1. Effluent Limitations
an Monitoring equirements (outfall 001) ("The Regional Administrator has etermined pursuant to Section 316(a) of the
Act that the thermal component of the discharge assures the protection and propagation of a balanced, indigenous
population of shellfish and wildlife in and on the receiving body of water. Water quality temperature standards must be
maintained outside the approved 316 (a) mixing zone.)". The power plant operates under an DWQ- and EPA -approved
Clean Water Act §316(a) thermal variance. The report does fulfill the permit obligations for reporting the results of the
biological monitoring. Based on a review of the data, it is our opinion that the Marshall Steam Station is unlikely in having
an impact to the benthic macroinvertebrate and fish communities in the multi-purpose Lake Norman. We also conclude
that the two aquatic communities currently qualify as balanced, indigenous communities.
We are continuing to review the report. However, at this time we offer the following comment and requests for future
reports beginning with the 2010 report.
Comment
1. Although the fish assemblage in this multi-purpose reservoir is comprised of indigenous and nonindigenous
species (Tables 4-1 and 4-2), the fish community continues to be considered balanced and indigenous. We have
no concerns because the Clean Water Act §316(a) does allow for ".. r. Such a community may include historically
non-native species introduced in connection with a program of wildlife management and species whose presence
or abundance results from substantial, irreversible environmental modification" (40CFR 125.71(c).
Analysis Requests
1. In addition to Tables 3-3 through 3-6, please include a taxonomic table comparing taxa occurrences for the
current sampling year for each station so that a direct side-by-side comparison can be more easily conducted.
Please see Table 1 as an example.
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road; Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: htto:/Ih2o.enr.state.nc.us/esb/
An Equal Opportunity 1 Affirmative Acton Employer
One
NorthCarolina
�aturallry

Table 1.
Waterbody
Licklog Branch
Sugarloaf Creek
Scott Creek
Date
8/9/2007
8/9/2007
8/9/2007
Location
SR 1706
off SR 1708
off SR 1556
County
Jackson
Jackson
Jackson
Taxon
Ephemeroptera
Acentrella spp
R
Plauditus dubius gp.
C
A
Baetis flavistriga
R
Pseudocloeon propinquum
R
Allen Stowe
November 19, 2009
Page 2
2. In addition to Figures 3-1 through 3-6, please include the following graphs for each station and year (in the same
format as currently presented) for the following groups: Non-Chironomid Diptera, Ephemeroptera, Plecoptera,
Trichoptera, Coleoptera, Odonata, Megaloptera, Crustacea, and Mollusca. Again, this will allow for a more direct
side-by-side comparison for each station and each taxonomic group.
3. In addition, EPT taxa richness and EPT density should also be reported for each station going forward. These
metrics can be reported in accordance with current graphical formats.
Upon completion of our detailed review, we will be communicating with you any additional concerns or comments that we
might have. In the mean time, if you have any questions, please do not hesitate to contact me or my staff.
Yours truly,
Jay Sauber
Acting Chief, Environmental Sciences Section
cc: Eric Fleek, Environmental Sciences Section
Rob Krebs, Mooresville Regional Office
Jeff Poupart, Surface Water Protection Section
Sergei Chernikov, Surface Water Protection Section
Bryn H. Tracy, Environmental Sciences Section
Charles Weaver, Surface Water Protection Section

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
June 15, 2009
Mr. David Renner, General Manager III
Duke Energy Carolinas, LLC- Marshall Steam Station
8320 East NC Highway 150.
Terrell, North Carolina 28682
Subject: NPDES major modification
Permit No. NC0004987
Marshall Steam Station
Catawba County
Dear Mr. Renner:
Dee Freeman
Secretary
Division personnel have reviewed and approved your request for major modification.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is modified
pursuant to the requirements of North Carolina General Statute ,143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental Protection
Agency dated October 17, 2007 (or as subsequently amended.)
This permit modification addresses_ the request for a major modification regarding the
elimination or modification of monitoring frequencies for several. constituents discharged from
Outfalls 002 and 004.
The Division has reviewed Duke Energy's comments submitted on April 30, 2009 and has
the following responses.
Regarding the request that the weekly average selenium limit be changed to a monthly
average limit. The Division's established procedure for compliance periods for metals shall be
daily maximum and weekly average limits. North Carolina water quality standards are adopted
based on chronic criteria. Based on the Division's procedure, effluent limitations for selenium
will be added at Outfall 002 and weekly monitoring for selenium will remain at Outfall 004. The
limits will be a weekly average of 29 ug/1 and a daily maximum of 56 ug/1. These limits are
based on the results of a reasonable potential analysis .that indicated the potential to exceed the
North Carolina standard for selenium. Because of the complexity of selenium removal and
reduction, Duke Energy has requested and will be given a three year compliance schedule to
meet this limit. The compliance schedule by Duke Energy is included in Special Condition A. 23
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 A' One�7, 7
Phone: [phone] \ FAX: [phone] \ Customer Service: 1-877-623-6748 1 � Ol thCarolllla.
Internet: www.ncwaterquality.org 0 ;V���N� /
An Equal Opportunity\ Affirmative Action Employer ` `

Letter to Mr. Renner
Page 2 -
with specific dates corresponding to the timetables submitted. Duke Energy must come into
compliance with the selenium limit by July 1, 2012.
Regarding the language in the toxicity condition, staff has confirmed that the forms
(TGP3B and THP3B).listed in paragraph 5 are correct.
. The following modifications included in the March 24th draft remain in the final permit
modification:
• Weekly effluent monitoring for cadmium, chromium, and silver at Outfall 002 and Outfall
004 has been deleted. Data analysis indicated that there was no reasonable potential for
these parameters to exceed water quality standards in the receiving stream. There was
very minimal detection of these three metals in the review of three years of effluent data.
• Weekly effluent monitoring for total suspended solids (TSS) at Outfall 004 has been
deleted. Outfall 004 is an internal outfall discharging into the ash basin (Outfall 002).
Because TSS has an effluent limit and monitoring at Outfall 002, the monitoring
requirement at Outfall 004 can be removed.
The monitoring frequency for total arsenic, chloride, total mercury, and total nickel has
been reduced from weekly to quarterly at Outfall 002 and Outfall 004. Analysis of the
data indicated there was no reasonable potential shown to exceed the state water quality
standards. Because of the effluent concentrations discharged, these constituents are still
considered to be parameters of concern. Quarterly monitoring is the minimum frequency
required in order for the Division to evaluate future effluent data.
The monitoring frequency for total zinc has been reduced from weekly to monthly
monitoring at Outfall 002 and Outfall *004. The reasonable potential analysis indicated
the potential to only exceed the acute allowable concentration for this action level
parameter. Because of a record of consistently passing the toxicity tests and zinc
concentrations not be problematic, it is recommended that the monitoring frequency can
be reduced from weekly to monthly.
• Please note that there have been minor language changes and the addition of a new _
paragraph regarding data submittal in special condition A. 14. Chronic Toxicity Pass/Fail
permit limit. (The new paragraph is located second from the end of the condition).
If any parts, measurement frequencies or sampling requirements contained in this permit
modification are unacceptable to you, you have the right to an adjudicatory hearing upon written
request within thirty (30) days following receipt of this letter. This request must be in the form of a
written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with
the office. of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-
6714. Unless such a demand is made, this permit shall be final and binding.
Please take notice that this permit is not transferable. The Division may require modification
revocation and °reissuance of the permft. , This permit does not affect the legal requirements to
obtain other permits which may be required by the Division of Water Quality or permits required by
the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local
governmental permits may be required.

s, T .
If you have any questions or need additional information, please contact Ms. Jacquelyn
Nowell at telephone number [phone] or email jackie.nowell@ncdenr.,a .
Sincerely,
leen . Sullins
cc: EPA Region IV
Mooresville Regional Office/Surface Water Protection Section
DEH/ Public Water Supply Section/Mooresville Regional Office
Aquatic Toxicology Unit
NPDES File/NC0004987
Central Files
,1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One t
Phone: [phone] \ FAX: [phone] \ Customer Service: 1-877-623-6748 1� C�lT011lla
Internet: www.ncwaterquality.org � T�TIrt11
Oa'����N� //�
An Equal Opportunity\ Affirmative Action Employer ��/ L "

PERMIT NO: NC0004987
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control
Act, as amended,
Duke Energy Carolinas, LLC
is hereby authorized to discharge wastewater from a facility located at
Marshall Steam Station
At the intersection of NC Highway. 150 and NCSR 1841
Terrell
Catawba County
to receiving waters designated as the Catawba River (Lake Norman) in the Catawba
River Basin in accordance with effluent limitations, monitoring requirements, and
other conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective July 1, 2009.
This permit and authorization to discharge shall expire at midnight on April 30, 2010.
Signed this day June 15, 2009.
'C?Authority
een H. Sullins, Director
/ ision of Water Quality
of the Environmental Management Commission
Page 1 of 13

a
PERMIT NO. NC0004987 .
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are
hereby revoked, and as of this issuance, any previously issued permit bearing this number is
no longer effective. Therefore, the exclusive authority to operate and discharge from this facility
arises under the permit conditions, requirements, terms, and provisions included herein.
Duke Energy Carolinas, LLC
is hereby authorized to:
1. Continue to discharge once -through cooling water and intake screen backwash
through outfall 001; treated wastewater (consisting of metal cleaning wastes,
coal pile runoff, ash transport water, domestic wastewater, low volume wastes,
and flue gas desulfurization (FGD) wet scrubber wastewater) from the ash
settling basin through outfall 002; treated FGD wet scrubber wastewater
through internal outfall 004 (upstream of the ash settling basin); yard sump
overflows through outfalls 002A and 00213; and non -contact cooling water from
the induced draft fan control house through outfall 003. All discharges result
from activities at Duke Energy's Marshall Steam Station at the intersection of
NC Highway .150 and NCSR 1841 in Terrell, Catawba County;
2. Continue to operate a 'FGD wet scrubber wastewater treatment system
discharging to the ash settling basin through internal outfall 004; and
3. Discharge from said treatment works at the locations specified on the attached
map into the Catawba River (Lake Norman) which is classified WS -1V and B CA
waters in the Catawba River Basin.
Page 2 of 13

Lake Norman North QuadSo-
1 000
03-08-32
.:( y �, I •�r1'...I. ``-4_'('jT. Si:y'ty`iT'k(5:ri �.i .^ '','n
.� .JI. Internal
Outfall 0(
002A and 002B
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i J 1
i
r y.
Facility
�,,'LfF?rR^`b �G.,: y �3,ys `' `"b'w1• ,fi4t .
Outfall #: 002
Location�MaY�
Receivinq Stream-
Catawba River
Receivinq Stream:
e.r
/� /O I�
Duke Power Corporation
NC0004987
Marshall Steam Station
Outfall #: 002
Outfall #: 003
Receivinq Stream-
Catawba River
Receivinq Stream:
Catawba River
/� /O I�
Latitude:
35036'22"
Latitude:
35°35'51"
\SII
Longitude:
80057'40"
Longitude:
80057'45"
Ir LI
Duke Power Corporation
NC0004987
Marshall Steam Station

-PART I
SECTION A. FINAL LINETATIONS AND CONTROLS
1. Effluent Limitations and Monitoring Requirements (Outfall 001)
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from Outfall 001 (once -through cooling water). Such
discharges shall be limited and monitored by the Permittee as. specified below:
EFFLUENT
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Monthly
T
Daily
Measurement
Sample
Sample
CHARACTERISTICS
Average
Maximum
Frequency
Type
Location
Pump logs or
Flow (MGD)
Monitor & Report
Daily
similar
Effluent
readings
Temperature
(November 1 - June 30
33.3 oC
Daily
Grab
Effluent
Temperature
ul 1 - October 31
34.4 oC
Daily
.Grab
Effluent
Free Available Chlorine'
0.2 mg/L
0.5 mg/L
Daily
Grab
Effluent
NOTES:
1 Once -through cooling water shall not be chlorinated. Should the facility wish to chlorinate once -
through cooling water, a permit modification must be issued prior to commencement of chlorination.
The monitoring requirement and effluent limitations only apply if chlorination is commenced.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The Regional Administrator has determined pursuant to Section 316(a) of the Act that the thermal
component of the discharge assures the protection and propagation of a balanced, indigenous population
of shellfish and wildlife in and on the receiving body of water. Water quality temperature standards must
be maintained outside the approved 316(a) mixing zone.
Page 4 of 13

PART 1
2. Effluent Limitations and Monitoring Requirements (Outfall 002)
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from Outfall 002 (ash settling basin discharge). Such
discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING
REQUIREMENTS
Monthly
Average
11 Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Locationl
Flow (MGD)
Monitor & Report
Monthly
Pump logs or
similar readings
Effluent
Oil and Grease
9.0 mg/L
12.0 mg/L
Quarterly
Grab
Effluent
Total Suspended Solids2
20.0 mg/L
65.0 mg/L
Monthly
Grab
Effluent
Total Arsenic
Monitor & Report
Quarterly
Grab
Effluent
Chloride
Monitor & Report
Quarterly
Grab
Effluent
Total Copper
1.0 mg/L
1.0 mg/L
See note 3
Grab
Effluent
Total Iron
1.0 mg/L
1.0 mg/L
See note 3
Grab
Effluent
Total Mercury
Monitor & Report
Quarterly
Grab
Effluent
Total Nickel
Monitor & Report
Quarterly
Grab
Effluent
Total Selenium
Monitor & Report
Weekly
Grab
Effluent
Total Selenium4
11
29 ug/111
56 ug/l
Weekly
Grab
Effluent
Total Zinc
Monitor & Report
Monthly
Grab
Effluent
Total Nitrogen
02+N 03+TKN
Monitor & Report
Monthly
Grab
Effluent
Total Phosphorus
Monitor & Report
Quarterly
Grab
Effluent
Chronic Toxicity
See Part I, Section A, #14
Quarterly
Grab
Effluent
PH
Between 6.0 and 9.0 Standard Units
Monthly
Grab
Effluent
Pollutant Analysis
See Part I, Section A, #20
Grab
Effluent
NOTES:
1 Effluent sampling shall be conducted at the discharge from the ash settling basin prior to mixing with
any other waste stream(s).
2 A total suspended solids monthly average of 40 mg/L is permitted provided the Permittee can
demonstrate that the difference between the monthly average of 20 mg/L and 40 mg/L is the result of
the concentration of total suspended solids in the intake water.
3 Monitoring shall be per occurrence of chemical metal cleaning and samples shall be from a
representative discharge.
4 There will be a three year compliance schedule for the weekly average limit of 29 ug/l and the daily
maximum limit of 56 ug/l for selenium. The limits shall become effective on July 1, 2012. See Part I
Section A.23 for Selenium Compliance Schedule
There shall be no discharge of floating solids or visible -foam in other than trace amounts.
Page 5 of 13

PART I
3. Effluent Limitations and Monitoring Requirements (Outfall 002A)
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from Outfall 002A (yard sump #1 overflows). Such
discharges shall be limited and monitored by.the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample Sample
Frequency Type Location'
Flow (MGD)
Episodic Estimate Effluent
pH
Episodic Grab Effluent
Total Suspended Solids
Episodic Grab Effluent
Total Iron
See note 2 Grab Effluent
NOTES:
1 Effluent samples shall be collected at a point upstream of the discharge to the Catawba River.
2 Sampling for iron is required when TSS is reported as greater than 100 mg/L.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
All flows shall be reported on monthly DMRs. Should no flow occur during a given month, the words "No
Flow" shall be clearly written on the front of the DMR. Episodic sampling is required per sump overflow
occurrence lasting longer than one hour. All samples shall be of a representative discharge.
Page 6 of 13

PART I
4. Effluent Limitations and Monitoring Requirements (Outfall 002B)
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee -is authorized to discharge from Outfall 002B (yard sump #2 overflows)_ . Such
discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT.
CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample Sample
Fre uency Type Location
Flow (MGD)
Episodic Estimate Effluent
pH
Episodic Grab Effluent
Total Suspended,Solids
Episodic Grab Effluent
Total Iron
See note 2 Grab Effluent
NOTES:
1 Effluent samples shall be collected at a point upstream of the discharge to the Catawba River.
2 Sampling for iron is required when TSS is reported as greater. than 100 mg/L.
There shall be no discharge of floating solids or visible foam. in other than trace amounts.
All flows shall be reported on monthly DMRs. Should no flow occur during a given month, the words "No
Flow" shall be clearly written on the front of the DMR. Episodic sampling is required per sump overflow
occurrence lasting longer than one hour. All samples shall be of a representative discharge:
.. .. Page 7 of 13 . , .

' . • PART I
5. Effluent Limitations and Monitoring Requirements (Outfall 003)
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from Outfall 003 (non -contact cooling water from the
induced draft fan control house). Such discharges shall be limited and -monitored by the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample
Fre uency Type
Sample
Location
Flow (MGD)
Temperature'
Total Residual Chlorinez
Free Available Chlorine2
0.2 mg/L
0.5 mg/L
p H
Between 6.0 and 9.0 Standard
Units
NOTES:
1 The temperature of'the effluent shall be such as not to cause an:increase in the temperature of the
receiving stream of more than 2.8oC and in no case cause the ambient water temperature to exceed
29oC.
2 Monitoring requirements apply only if chlorine is added to the cooling water. Neither free available
chlorine nor total residual chlorine may be discharged from any unit for more than two hours in any
one day and not more than one unit in any plant may discharge free available chlorine or total
residual chlorine at any one time.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Limitations shall be met at the discharge effluent. Monitoring frequencies are not specified as the
discharge is to the intake canal for outfall 001.
Page 8 of 13

PART I
6. Effluent Limitations and Monitoring Requirements (Outfall 004)
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from Internal Outfall 004 (treated FGD wet scrubber
wastewater to ash settling basin). Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Monthly
____Average
Daily
Maximum
Measurement
___Frequency
Sample
Type
Sample
Location'
Flow (MGD)
Monitor & Report
Monthly
Pump logs or
similar
readings
E
Total Arsenic
Monitor & Report
Quarterly
Grab
E
Chloride
Monitor & Report
Quarterly
Grab
E
Total Mercury
Monitor & Report
Quarterly
Grab
E
Total Nickel
Monitor & Report
Quarterly
Grab
E
Total Selenium
Monitor & Report
Weekly
Grab
E
Total Zinc
Monitor & Report
Monthly
Grab
E
NOTES:
1 Sample Location: E - Effluent from the constructed wetland prior to discharge'to the ash settling
basin.
All flows shall be reported on monthly DMRs. Should no flow occur during a given month, the words "No
Flow" shall be clearly written on the front of the DMR. All samples shall be of a representative discharge.
Page 9 of 13

PART I
7. DEFINITIONS
The term "low volume waste sources" means, taken collectively as if from one source, wastewater from all
sources except those for which specific limitations are otherwise established in this part. Low volume
wastes 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. Sanitary
and air conditioning wastes are not considered low volume wastes.
The term "metal cleaning waste" means any wastewater resulting from cleaning (with or without chemical
cleaning compounds) 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 compounds, including, but not limited to, boiler tube cleaning.
Chemical metal cleaning will be conducted according to approved Duke Power equivalency
demonstration.
The term "FGD wet scrubber wastewater" means wastewater resulting from the use of the flue -gas
desulfurization wet scrubber.
8. TOXICITY RE -OPENER CONDITION
This permit shall be modified, or revoked and reissued to incorporate toxicity limitations and monitoring
requirements in the event toxicity testing or other studies conducted on the effluent or receiving stream
indicate that detrimental effects may be expected in the receiving stream as a result of this discharge.
9. MONITORING FREQUENCIES
If the Permittee, after monitoring for at least six months, determines that effluent limits contained herein
are consistently being met, it may be requested of the Director that the monitoring requirements be
reduced to a lesser frequency.
10. POLYCHLORINATED BIPHENYL COMPOUNDS
There shall be no discharge of polychlorinated biphenyl compounds such as those commonly used for
transformer fluid.
11. BIOCIDE CONDITION
The permittee shall not use any biocides except those approved in conjunction with the permit
application. The permittee shall notify the Director in writing not later than ninety (90) days prior to
instituting use of any additional biocide used in cooling systems which may be toxic to aquatic life other
than those previously reported to the Division of Water Quality. Such notification shall include
completion of Biocide Worksheet Form 101 and a map locating the discharge point and receiving stream.
Completion of Biocide Worksheet Form 101 is not necessary for those outfalls containing toxicity testing.
Division approval is not necessary for the introduction of new biocides into outfalls currently tested for
whole effluent toxicity.
12. INTAKE SCREEN BACKWASH
Continued intake screen backwash discharge and overflow from the settling basin are permitted without
limitations or monitoring requirements.
13. BEST MANAGEMENT PRACTICES
It has been determined from information submitted that the plans and procedures in place at Marshall
Steam Station are equivalent to that of a Best Management Practice (BMP).
Page 10 of •13

PART I
14. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)- OUTFALL 002
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 12%.
The permit holder shall perform at a minimum, auarteriu monitoring using test procedures outlined in the
"Nortli Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of
February, May, August, and November. Effluent sampling for this testing shall be performed at the
NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two
following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the months in which tests were performed. If reporting pass/fail
results using the parameter code TGP3B, DWQ Form AT -1 (original) is sent to the below address. If
reporting Chronic Value results using the parameter code THP3B, DWQ Form AT -3 (original) is to be sent
to the following address:
Attention: Environmental Sciences Section
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response, data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine • of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow' in the comment area of the form. The report shall be submitted to the
Environmental Sciences Section at the address cited above.
Should• the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the results of such
monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT
Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later than
the last day of the month following the month of the initial monitoring.
Page 1 I of 13 , .

PART I
15. ASH SETTLING BASIN
Beginning on the effective date of this permit and lasting until expiration, there shall be no discharge of
plant wastes to the ash pond unless the permittee provides and maintains at all times a minimum free
water volume equivalent to the sum of the maximum 24-hour plant discharges plus all direct rainfall and
all runoff flows to the pond resulting from'a 10 -year, 24-hour rainfall event, when using a runoff
coefficient of 1.0.
During the term of the permit, the permittee shall remove settled material from the ponds or otherwise
enlarge the available storage capacities in order to maintain the required minimum volumes at all times.
Annually the permittee shall determine and report to the permit issuing authority: (1) the actual free
water volume of the ash pond, (2) physical measurements of the dimensions of the free water volume in
sufficient detail to allow validation of the calculated volume, and (3) a certification that the required
volume is available with adequate safety factor to include all solids expected to be deposited in the ponds
for the following year. Any changes to plant operations affecting such certification shall be reported to the
Director within five days.
NOTE: In the event that adequate volume has been certified to exist for the term of the permit, periodic
certification is not needed.
16. CHEMICAL METAL CLEANING WASTES
It has been demonstrated that under certain conditions it is possible to reduce the concentration of
metals in boiler cleaning wastes in the range of 92 to 99+ percent by treatment in ash ponds. Because of
dilution problems, and the existence of boundary interface layers at the extremities of the plume, it is
difficult to prove beyond doubt that the quantity of iron and copper discharged will always be less than
one milligram per liter times the flow of metal cleaning when treated in this manner.
The application of physical/chemical methods of treating wastes has also been demonstrated to be
effective in the treatment of metal cleaning wastes. - However, the effectiveness of ash pond treatment
should be considered in relation to the small differences in effluent quality realized between the two
methods.
It has been demonstrated that the presence of ions of copper, iron, nickel, and zinc in the ash pond
waters was not measurably increased during the ash pond equivalency demonstration at the Duke Power
Company's Riverbend Steam Station. Therefore, when the following conditions are implemented during
metal cleaning procedures, effective treatment for metals can be obtained at this facility:
(1) Large ash basin providing potential reaction volumes.
(2) Well-defined shallow ash delta near the ash basin influent.
(3) Ash pond pH of no less than 6.5 prior to.metal cleaning waste addition.
(4) Four days retention time in ash pond with effluent virtually stopped.
(5) Boiler volume less than 86,000 gallons.
(6) Chemicals for cleaning to include only one or more of the following:
(a) Copper removal step- sodium bromate, NaBr03; ammonium carbonate, (NH4)2CO3; and
ammonium hydroxide, NH40H.
(b) Iron removal step -hydrochloric acid, HCl; and ammonium bifluoride, (NH4)BF2 and proprietary
inhibitors.
(7) Maximum dilution of wastes before entering ash pond 6 to 1.
(8) After treatment of metal cleaning wastes, if monitoring of basin effluents as required by the permit
reveals discharges outside the limits of the permit, the permittee will re -close the basin discharge,
conduct such in -basin sampling as necessary to determine the cause of nonconformance, will take
appropriate corrective actions, and will file a report with EPA including all pertinent data.
17. FLOATING MATERIALS ,
The Permittee shall report all visible discharges of floating materials, such as an oil sheen, to the Director
when submitting DMRs.
18. DIKE INSPECTIONS
The permittee shall check the diked areas for leaks by a visible inspection and shall report any leakage
detected.
Page 12 of 13

PART I
19. .CHEMICAL DISCHARGES
Discharge of any product registered under the Federal Insecticide, Fungicide, and Rodenticide Act to any
waste stream which may ultimately be released to lakes, rivers, streams or other waters of the United
States is prohibited unless specifically authorized elsewhere in this permit. Discharge of chlorine from
the use of chlorine gas, sodium hypochlorite, or other similar chlorination compounds for disinfection in
plant potable and service water systems and in sewage treatment is authorized. Use of restricted use
pesticides for lake management purposes by applicators licensed by the N.C. Pesticide Board is allowed.
20. PRIORITY POLLUTANT ANALYSIS
The Permittee shall conduct a priority pollutant analysis (in accordance with 40 CFR Part 136) once per
permit cycle at outfall 002 and submit the results with the application for permit renewal.
21. WAIVERS
Nothing contained in this permit shall be construed as a waiver by permittee or any right to a hearing it
may have pursuant to State or Federal laws or regulations.
22. SECTION 316 (B) OF CWA
The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95.
23. COMPLIANCE SCHEDULE FOR SELENIUM LIMITATION
The permittee shall have a three year schedule of compliance for the effluent limitation for total selenium.
The following are interim milestones for the installation of the proposed treatment system. The date for
compliance with the selenium limit shall be July 1, 2012
• Technology selection, treatment system design and obtaining an authorization to construct
permit for the wastewater treatment system by August 31, 2010
• Construction of wastewater treatment system and commissioning by June 30, 2012
• Compliance with selenium limit - July 1, 2012
Page 13 of 13

DENR/DWQ
FACT SKEET FOR NPDES PERAUT DEVELOPMENT
O R� 16111111g'%37
Facility Information
Applicant/Facility Name:
Duke Energy Carolinas, LLC — Marshall Steam Station
Applicant Address:
526 S. Church St. Charlotte NC 28202
Facility Address:
8320 E. NC Highway 150, Terrell, NC 28682
Permitted Flow
Not Limited
Type of Waste:
100% Industrial
Facility/Permit Status:
Existing/Modification
Court :
Catawba
BACKGROUND
Duke Energy Carolinas LLC has requested a permit modification seeking a reduction in frequency or the
elimination of monitoring for effluent parameters from outfall 002 (ash basin discharge) and internal outfall
004 (Flue Gas Desulfurization treatment system discharge.). The request was as follows:
Outfall 002
Reduce from weekly monitoring to monthly monitoring: Chloride and Selenium
Elimination of weekly monitoring: Arsenic, Cadmium, Chromium, Mercury, Nickel, Silver and Zinc.
Outfall 004
Reduce from weekly monitoring to monthly monitoring: Chloride and Selenium
Elimination of weekly monitoring: Arsenic, Cadmium, Chromium, Mercury, Nickel, Silver, TSS and
Zinc.
SUMMARY OF FACILITY AND WASTELOAD ALLOCATION.
Duke Energy operates Marshall Steam Station in Catawba County. The Station operates five outfalls. These
outfalls are 001, 002, 002A, 002B, and 003. The permitted outfalls are summarized below:
• 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 turbines and other selected heat exchangers. When the station is operating at frill power, it has a
design capacity to pump 1463 MGD (1.016 MGPM) of cooling water through the 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 operate two CCW pumps each while units 3 and 4 operate three pumps. 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 station 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
Marshall Steam Station Fact Sheet
NPDES Modification
Page 1
A iscellaneous
Receiving Stream:
Lake Norman
Regional Office: Mooresville
Stream Classification:
WS -IV & B CA
USGS To o Quad:
303(d) Listed?:
No
Permit Writer: Jacquelyn M. Nowell
Subbasin:
03-08-32
Date: March 6,2009
Drainage Area (mi2) :
NA
t
Summer 7Q 10 (cfs) Release (60 cfs)
Winter 7Q10 (cfs): NAS
Average Flow (cfs): NA
IWC f%1: I See Below
BACKGROUND
Duke Energy Carolinas LLC has requested a permit modification seeking a reduction in frequency or the
elimination of monitoring for effluent parameters from outfall 002 (ash basin discharge) and internal outfall
004 (Flue Gas Desulfurization treatment system discharge.). The request was as follows:
Outfall 002
Reduce from weekly monitoring to monthly monitoring: Chloride and Selenium
Elimination of weekly monitoring: Arsenic, Cadmium, Chromium, Mercury, Nickel, Silver and Zinc.
Outfall 004
Reduce from weekly monitoring to monthly monitoring: Chloride and Selenium
Elimination of weekly monitoring: Arsenic, Cadmium, Chromium, Mercury, Nickel, Silver, TSS and
Zinc.
SUMMARY OF FACILITY AND WASTELOAD ALLOCATION.
Duke Energy operates Marshall Steam Station in Catawba County. The Station operates five outfalls. These
outfalls are 001, 002, 002A, 002B, and 003. The permitted outfalls are summarized below:
• 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 turbines and other selected heat exchangers. When the station is operating at frill power, it has a
design capacity to pump 1463 MGD (1.016 MGPM) of cooling water through the 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 operate two CCW pumps each while units 3 and 4 operate three pumps. 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 station 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
Marshall Steam Station Fact Sheet
NPDES Modification
Page 1

canal during cold weather. Flow recorded on the monthly Discharge Monitoring Reports is based on
CCW pump run times.
• Outfall 002 — Ash Basin:
The station ash basin accommodates flows from two yard -drain sumps, an ash removal system, low
volume wastes and non -point source stormwater. 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 7.9 MGD. At times, due to unit loads, rainfall, evaporation, and seepage of ash basin
ponds, the effluent flow may vary from the influent flow.
• Outfall 004 (internal outfall) — FGD system discharge into Ash Basin:
In association with Clean Smokestacks legislation, Duke Energy has installed a flue -gas desulfurization
(FGD) wet scrubber. This scrubber generates a wastewater needing treatment prior to discharge. An
internal outfall (004) has been established for the effluent from the FGD treatment system. Weekly
effluent monitoring has been established at outfall 004 for flow, arsenic, cadmium, chromium, chloride,
mercury, nickel, selenium, silver, suspended solids, and zinc.
Internal outfall 004 discharges to the ash settling basin which is currently permitted as outfall 002.
Duke Energy has been working with faculty from Clemson University to identify FGD wastewater treatment
options. Pilot scale constructed wetlands have provided positive results. Construction of a clarifier,
equalization basin, and constructed wetland to treat the FGD wastewater was completed in October 2006.
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 dewatering. The yard -drain sumps also collect some
stormwater runoff from the coal pile (coal pile runoff), rail access, and powerhouse roofs and pavement.
Groundwater 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 2.3 MGD, which is pumped to the ash basin for physical and biological treatment.
The turbine room sumps collect approximately 0.25 MGD of wastewater. This wastewater comes from non -
contact cooling water (from Units 1 & 2 boiler feed -pump turbine lube oil coolers) and floor drains. Floor
drains contain boiler blowdown, leakage from seals, equipment cooling water, condensate from the feed -
water system, low volume wastewater, boiler room sump overflow, emergency fire fighting water, general
mechanical maintenance activities, miscellaneous plant wastes and area wash -down water.
The average flow pumped from the boiler room sumps directly to the ash basin is approximately 1.3 MGD.
The sources of input to the boiler room sumps includes the following:
Water Treatment System — the station make-up water treatment system consists of a clarifier,
three gravity filters, two sets of activated carbon filters, and two sets of demineralizers. The
water treatment wastes consist of floc and sedimentation, filter backwash, and demineralizer
regeneration wastes. Make-up water 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.
• Miscellaneous Waste Streams:
Marshall Steam Station Fact Sheet
NPDES Modification
Page 2

• Closed system drainage, cleanings, testing containing corrosion inhibitors, biocides,
cleanings (small heat exchangers), dispersant (polycrylamide), 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.
• Chemical makeup tanks and drum rinsate - intermittent rinse water containing small amounts of
aluminum sulfate, sodium hydroxide, hydrazine, and ammonium hydroxide.
Boiler blowdown — Primarily when units 1 & 2 startup and until water chemistry stabilizers 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.
Boiler cleaning — Boilers #1, #2, #3, and #4 at the station 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 cleaning are pumped to the yard
sumps and then to the ash basin.
The ash basin collects stormwater flows from the yard drainage basin, ash removal lines and rainfallrunoff
from the basin watershed area. A total of 18.0 acres drain to the yard sumps with an'average daily runoff
estimated at 0.03 MGD. The average daily runoff is calculated based on an annual rainfall of 49 inches with
1.0 and 0.5 runoff coefficients applied appropriately. Trace amounts of oil and grease may be present in the
first flush of stormwater.
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.
The track hopper sump collects groundwater 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; then to
the ash basin.
In the event that maintenance activities are needed in the intake or discharge tunnels, a dewatering 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.
Bore sonic testing of turbine rotors is infrequent, occurring approximately 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.
Marshall Steam Station Fact Sheet
NPDES Modification
Page 3

The station utilizes electrostatic precipitators as its air pollution control devices. Under normal plant
operations, the dry 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 3.0 MGD of 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.
The electrostatic precipitators 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.
A sanitary waste treatment system was installed during the term of any earlier NPDES permit, thus
eliminating the package plant near the intake structure of the plant. An aerated basin 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 10 year old system is designed for
6100 gpd (normal) and 13500 gpd (outage).
The powerhouse lift station was installed as a central collection point to receive all the sanitary waste from
the station and pump it to the aerated basin. The present lift station serving the vendor facilities and Units 3
and 4 were upgraded.
The sanitary system accommodates wastewater flow from the following courses:
• General Plant sanitary wastewater;
• Vendor facilities sanitary wastewater; and
• Laboratory drains (small amounts of laboratory chemicals used to test wastewater effluents and
high purity boiler water).
Non -point sources of stormwater to the ash basin includes coal pile runoff, a pond area of 82.3 acres and an
up -gradient watershed area of 1097.7 acres. The estimate for stormwater runoff is based on forty-nine inches
of rain per year with a 1.0 and 0.5 runoff coefficient for the pond area and up -gradient watershed,
respectively. The average non -point source stormwater input for the ash basin is estimated at 2.6 MGD.
The coal pile covers an area of approximately 33 acres with an estimated stormwater runoff to the ash basin
of 0.06 MGD.
• Outfall 002A — Sump #1 Overflow:
This outfall discharges very infrequent overflows of yard sump number 1. The overflow generally
consists of the same wastewaters discharged by the ash basin (excluding sanitary wastewaters).
• Outfall 002B — Sump #2 Overflow:
This outfall discharges very infrequent overflows of yard sump number 2. The overflow generally
consists of the same wastewaters discharged by the ash basin (excluding sanitary wastewaters).
• 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.
One of the previous permit requirements was to perform an assessment of balanced and indigenous
populations in Lake Norman. The report stated that "the thermal regimes resulting from the operation of
the MSS (Marshall Steam Station have supported the protection and propagation of a balanced and
indigenous fish community in Lake Norman".
Marshall Steam Station Fact Sheet
NPDES Modification
Page 4

BASIS FOR EFFLUENT LIiIIITS
• Outfall 001 — Condenser Cooling Water (CCW) Units 1— 4:
Currently, only temperature is limited in this outfall. Summer and winter thermal limits have been
established in support of the 316(a) temperature variance issued by EPA in May of 1975. The
determination noted that the "thermal component of the discharge assures the protection and
propagation of shellfish, fish, and wildlife in and on the receiving body of water." Continued
implementation of the aforementioned thermal variance is supported by the "Assessment of Balanced
and Indigenous Populations in Lake Norman near Marshall Steam Station." Furthermore, an evaluation
of the downstream temperature of Lake Norman suggests that Marshall Steam Station is not appreciably
elevating instream temperature.
A free available chlorine limit is currently part of the effluent limitations for this outfall. 40 CFR 423.12 (b)
(6) establishes maximum free available chlorine concentrations for discharges of once -through cooling water.
These maximum values are 0.5 mg/L and 0.2 mg/L daily maximum and monthly average respectively.
Inclusion of these limits is merely a matter of record keeping as the permit does not authorize chlorination of
the once -through cooling water. These limits will be footnoted such that monitoring is only required if the
facility proposes to implement chlorination of its once -through cooling water.
• Outfall 002 — Ash Basin:
The existing permit limits oil & grease, TSS, pH, total copper, and total iron at this outfall. Limits for Cu
and Fe are consistent with federal guidelines and monitoring is per occurrence of chemical metals
cleaning. Effluent monitoring has been established for flow, total arsenic, total cadmium, total
chromium, chloride, total mercury, total nickel, total selenium, total silver, nitrogen, phosphorus, chronic
toxicity and total zinc.
• Outfalls 002A and 002B — Yard -Sump Overflows:
On occasion, the yard -sumps at the station experience overflows. These overflows occur rarely, typically
once per year, and can range in time from less than one hour to several hours. Late in 1998, the Division
developed a permitting strategy for these overflows. Analytical monitoring is required for flow, pH, and
TSS for all overflows lasting longer than an hour. When TSS is reported as greater than 100 mg/L,
monitoring for iron is required. All overflows, regardless of time length, are reported to the DWQ
regional office.
• Outfalls 003 — Non -Contact Cooling Water:
Limitations for this outfall are consistent with non -contact cooling water requirements defined in the
federal guidelines.
TOXICITY TESTING:
Current Requirement: Outfall 002 — Chronic P/F @ 12% using Ceriodaphnia
Recommended Requirement: Outfall 002 — Chronic P/F @ 12% using Ceriodaphnia
No changes in the toxicity testing requirements are recommended at this time. This facility has passed all
toxicity tests during this permit cycle (4/2005 through 12/2008).
COMPLIANCE SUMMARY:
A review of this facility's effluent data indicates an excellent compliance history with few permit limit
violations during the review period (4/2005 — 12/2008). There was one pH exceedance in March 2008.
INSTREAM MONITORING:
None Required
REASONABLE POTENTIAL ANALYSIS (RPA)
For the major modification request, the Division conducted EPA -recommended analyses to determine the
reasonable potential for toxicants to be discharged by this facility from outfall 002. The average flow from
Marshall Steam Station Fact Sheet
NPDES Modification
Page 5

outfall 002 for the past three years has been 7.99 MGD and this flow will be used in the reasonable potential
analysis.
A RPA was conducted for the following: Arsenic, cadmium, chromium, chloride, iron, mercury, nickel,
selenium, silver and zinc based on sampled data in discharge monitoring reports (DMRs) from January 2006
through December 2008. The RPA analysis is attached. (Note: Data for copper and iron were reviewed,
however since these limitations are required by federal guidelines, no changes were made.)
• Cadmium, Chromium and Silver — The maximum predicted values demonstrated no reasonable
potential to exceed state water quality standards or acute criteria. Nearly all data were reported
below detection levels. Weekly monitoring will be deleted from the permit. No effluent monitoring
will be recommended in the permit since these do not appear to be parameters of concern.
• Arsenic, Mercury, Nickel and Chloride — The maximum predicted values demonstrated no
reasonable potential to exceed state water quality standards or acute criteria. Nearly all data were
reported above detection levels. Weekly monitoring will be deleted from the permit however
quarterly monitoring is recommended for these parameters because of the presence in the effluent.
• Selenium — the maximum predicted value indicated a reasonable potential to exceed both the chronic
and acute allowable concentrations. Based on this result, it is recommended that a weekly average
Emit of 29 ug/l and a daily maximum limit of 56 ug/l be added to the permit. Duke Energy has
requested a three year compliance schedule in order to meet the proposed limit for selenium. This
will be granted with milestones to be met during the term of the compliance schedule.
• Zinc — The maximum predicted value demonstrated a reasonable potential to exceed only the acute
allowable concentration. This is an N.C. Action Level standard and should be reviewed in
conjunction with toxicity testing. Duke Energy has passed all chronic toxicity tests for the past three
years. It is recommended that weekly monitoring can be reduced to monthly monitoring.
PROPOSED CHANGES:
Outfall 002
• Elimination of monitoring for: total cadmium, total chromium, total silver
• Monitoring reduced from Weekly to Quarterly for: total arsenic, chloride, mercury, total nickel
• Monitoring reduced from Weekly to monthly for: zinc
• Addition of limit of 29 ug/l (weekly average) and 56 ug/l (daily maximum) for selenium
Outfall 004
• Elimination of monitoring for: total cadmium, total chromium, total silver, and total suspended
solids
• Monitoring reduced from Weekly to Quarterly for: total arsenic, chloride, mercury, total nickel
• Monitoring reduced from Weekly to monthly for: zinc
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please contact
Jacquelyn M. Nowell at 919-807-6386 or [e-mail].
NAME: DA
Marshall Steam Station Fact Sheet
NPDES Modification
Page 6

1Duke
nergy®
April 27, 2009
DUKE ENERGY CORPORATION
Marshall Steam Station
8320 East NC Hwy. 150
Terrell, NC 28682
828 478 7700
To: Ms. Jacquelyn M. Nowell R16=
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Marshall Steam Station
Draft NPDES Permit No. NC0004987
Dear Ms. Nowell,
APR 3 0 2009
DENR - WATER QUALITY
POINT SOURCE BRANCH
Duke Energy Carolinas, LLC representatives have reviewed the subject permit and offer
the following comments:
Outfall 002
a. Selenium is listed with weekly average and daily maximum limits. The
monitoring frequency is weekly. Since typically only one sample will be
collected each week this weekly average limit equates to a daily maximum limit.
40 CFR 122.45(d) indicates that limits are to be expressed in the form of a
maximum daily and/or a monthly average for all dischargers other than publicly
owned treatment works. Section 5.2.3 of the Environmental Protection
Agency's Technical Support Document for Water Quality Based Toxic Control
also supports limiting the expression of permit limits to monthly average and daily
maximum limits.
Therefore, it is requested that the weekly average limit be changed to a monthly
average limit.
b. To meet the proposed selenium limits a three year schedule of compliance is
needed in order to allow for technology selection, design, permitting and
construction. The following provides an approximate timeframe to achieve
installation of the treatment system:
1. Two months for technology selection.
2. Six months for design of treatment system.
3. Six months for obtaining a permit to construct the wastewater treatment
system.
4. Twenty two months for construction and commissioning.
www. duke -energy. com

Permit Page 11 of 13
a. Please confirm the mentioned parameter code of THP313 for DWQ Form AT -
3.
Thank you for the opportunity to review this draft permit. If you have any questions or
need additional information please contact Robert Wylie at 704 3 82-4669.
Sincerely,
D d Renner, General Manager III
Marshall Steam Station
cc: Donna Burrell — Marshall Steam Station