NC0024406_Renewal Application_19930129

Duke Power Company
Generation Services Department
13339 Hagers Perry Road
Huntersville, NC 280 78- 7929
4't�tDUKEPOWER
January 29, 1993
Ms. Coleen Sullins
Permits and Engineering Unit
North Carolina Department of Environment,
Health and Natural Resources
Division of Environmental Management
P.Q. Box 27687
Raleigh; North Carolina 27611-7687
Subject: Belews Creek Steam Station
Renewal of NPDES Permit No. NCO024406
File: BC -704.21
Certified P 623 745 193
Dear Ms. Sullins:
We have reviewed the Belews Creek Steam Station draft NPDES Permit No. NCO024406
and submit for your consideration the attached comments.
We appreciate this opportunity to provide comments If you have questions or need
additional information, please contact me [phone] or John Carter (704)875-
5954.
Sincerely,
Ronald E. Lewis, Scientist
Environmental Protection
Generation Services Department
REL
attachment
xc:, Mr. Randy Kepler, DEM Raleigh
Mr. Ron Linville, DEM Winston-Salem
Mr. Steve Mauney, DEM Winston-Salem
Printed on recycled paper

COMMENTS AND RECOMMENDATIONS FOR DRAFT NPDES PERMIT NO.
NCO024406 FOR BELEWS CREEK STEAM STATION
1. PUBLIC NOTICE PAGE:
In the NPDES No. NC0024406 permit notice for Belews Creek Steam Station in
paragraph number l the domestic wastewater (outfall 002) is included in the
public notice. Because of the recently completed spray irrigation system, this
outfall has been correctly deleted from this draft of the permit, but was
mentioned in the public notice statement. Also, this notice indicates that
outfalls 001, 002, 005, and 006 discharge into Belews Lake. Only outfalls 001
and 005 discharge into Belews Lake. Other Station outfalls include Outfall 006
that is an internal discharge from the metal cleaning wastes basin into the
Station's ash basin that discharges into the Dan River at Outfall 003.
A revised schematic of the water flow diagram and description previously
revised and forwarded to DEM on January 22, 1990, is attached and reflects
outfall and system changes included in the draft NPDES permit for Belews
Creek Steam Station.
2. PERMIT COVER SHEET:
In the statement "and the Dan River (outfalls 003 and 006) in the Roanoke
River Basin" we request the words "and 006" be omitted, as outfall 006 is an
internal outfall where discharges go to the Station's ash basin.
3. SUPPLEMENT TO PERMIT COVER SHEET:
Please omit from paragraph two the reference to outfall 006 as requested in
comment 2.
4. TOPOGRAPHIC MAP WITH OUTFALLS:
Please replace the topographic map with the attached revision that clarifies
oK the location of outfalls and changes of draft permit.
5. PART I.A. OUTFALL 001:
We request removal of the requirement to monitor at two upstream (U) water
temperature monitoring locations. No exceedances of the thermal limits 35°C
(95°F) during the previous permit period were noted at the Southern Railroad
crossing of Belews Creek and East Belews Creek, respectively. If this
requirement is not deleted, then we request that the following statement
"Temperature °C(°F) (April -March)" should be changed to that of the
previous permit, "Temperature 'C ('F) (April -October)". This appears to be
a typographical error.
We request that the downstream temperature limit of 89.1°F be changed to that
of the previous permit, 89.6°F. We believe that this is typographical error,
since the previous permit limit is the State water quality standard limit.

6 . PART I.A. OUTFALL 003:
We request that the annual priority pollutant analyses requirement be deleted. `off
Priority pollutant analyses for the last three years have shown no evidence of�Or'`
targeted organic compounds or pesticides are a problem. , Also, the required P
toxicity testing would detect the presence of a priority pollutant, if a problem
occurred. If sampling is required, the inorganic analyses could be
accomplished independently and possibly with a grab sample instead of the
current composite sample.
7. PART I.A. OUTFALL 005:
We request replacing the acute toxicity monitoring requirement for Outfall 005
with the same chronic toxicity monitoring requirement that is required for
OUTFALL 003. The same effluent that would be discharged through OUTFALL
003 would also be discharged through OUTFALL 005. Also, all the chronic
toxicity tests conducted during the previous permit period passed and
support this request. As noted on the page for OUTFALL 005, the discharge
\ " can only be used to augment lake level, and is not to be used when the wet ash
system is put into operation due to a dry ash system upset. During the last
ppermit period Outfall 005 was not used and Duke Power Company does not plan
to discharge through this outfall, except in an emergency situation with lake
4'
levels. The requirement for acute toxicity tests with fathead minnows and
quarterly composite sampling would also require more training, manpower,
and equipment costs.
8. PART I.A. OUTFALL 006:
In the phrase "006(Metal Cleaning Wastes; low-volume waste, coal pile runoff)"
we request that "coal pile runoff" be deleted and the phrase read 11006 (Metal
Cleaning Wastes and low-volume waste)". Coal pile runoff does not enter the
\v, metal cleaning wastes holding basin.
We request that the requirement to monitor for metal cleaning wastes at
OUTFALL 006 be transferred to OUTFALL 003 with the following changes. We
request that when the metal cleaning wastes are discharged through OUTFALL
006 that monitoring for iron be required at OUTFALL 003 and that the
monitoring requirement and associated limit for copper be deleted. We base
this request on the fact that Station piping and equipment consists primarily
of ferrous material with an insignificant amount of copper piping or equipment
present at the Station. No violations of the copper limit have occurred during
previous discharge of metal cleaning wastes.
9. PART II. SECTION B. 12 page 7 of 14:
Request clarification for the word "cause" in the first sentence that reads
A "This permit may be modified, revoked, and reissued, or terminated for
cause.". Request changing this sentence to read "This permit may be
modified, revoked, and reissued, or terminated to comply with any applicable
effluent guideline or water quality standard issued or approved under
Sections 302(b) (2) (c)., and (d), 304(b) (2), and 307(4) (2) of the Clean
Water Act.".
2

10. PART II. SECTION E.6. page 13 of 14 states:
"A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances. "
The requirement of written submission of a report within 5 days of the time the
permittee becomes aware of any non-compliance instead of 15 days, as in the
pervious permit, is a concern. This may not allow enough time for analyses
of additional samples to address this non-compliance to be completed prior to
submittal of the written report. Verbal telephone notifications will have
already been made to the Regional Office. If there were to be a major concern
on their part, we would be working closely with them to remedy the situation.
We request changing the reporting requirement from 5 days to 15 days as
specified in the original permit. However, if the 5 day reporting requirement
should remain, we request that the wording be changed to 115 WORKING days,
excluding holidays and weekends. "
In addition, Section E.6 also states that "Any information shall be provided
orally within 24 hours from, the time the per�.ittee became aware of the
circumstances. " We request that this se'n'tence be amended to state:
" ... orally within 24 hours or the next working day... " .
11. PART II. SECTION E.9. page 14 of 14 states:
"Persons reporting such occurrences by telephone shall also file a written
report in letter form within 5 days following first knowledge of the
occurrence."
This is the same concern as item 10 above. In addition, we would like to
comment that Sections E.6 and E.9 are so interrelated that combining the two
sections would be clearer and. more effective.
� 12. PART III.I.:
We request correction of a typographical error changing "waster" to "waste"
in the fourth line of this paragraph.
PART III.N.:
We request changing from Fathead Minnow (Pimephales promelas) to
Cerodaphnia dubia. Please see comment 7.
We request adding the following sentence to the end of the first paragraph for.
clarification of the first sentence of this paragraph. "The first test will be
performed after thirty days from the effective date of this permit during the
months of February, May, August, and November during which time the
discharge is occurring."
We request that the fourth paragraph have some indication that the discharge
may not be continuous, such as... "Should any single quarterly monitoring
indicate a failure to meet specified limits, then monthly monitoring will begin
immediately until, such time that a single test is passed or the discharge is
3

discontinued. Upon passing, this monthly test requirement will revert to
quarterly in the months specified above when discharge is occurring." .
We request amending the last paragraph to read the same as the last sentence
of Part III, Section M.
OTHER COMMENTS
1. IDENTIFICATION OF ADDITIONAL CHEMICALS:
Since submittal of the application for renewal of the NPDES permit for BCSS
on March, 20, 1989, the use of the following additional- chemicals have been
identified in specific Station systems described in the application.
Boiler Condensate Polishing: approximately 200 liters per year of a
poly -electrolyte is used to promote coating of the mixed anion -cation
powdered resin in the filters of this system. Spent resins and
associated wastes are pumped to the ash basin for treatment and
disposal.
Coal Pile Drainage: A surfactant is mixed with water and sprayed in
the coal unloading area periodically for suppression of dust during
unloading of coal from railroad cars. This solution drains to the coal
yard sumps and is pumped to the ash basin.
Intake Screen Backwash: Collected debris from this back wash system
is removed and transported to a permitted landfill for disposal, rather
than the ash basin, as described in the application.
Water Treatment Equipment Waste: As identified in the application, this
system consists of one retention tank, two pressure filters, two
activated carbon filters, and one set of make up demineralizers .
Updated information about this system follows. Approximately 400
cubic feet of carbon is used per year. Approximately 600 lbs of citric
acid is mixed in solution and used per year to clean pressure filters.
A poly -electrolyte solution is also added at rate of 4 ml/min to' this
system to prevent the build up of aluminum on the Station's generator
turbine blades. Wastewater from citric acid treatments (approximately
3200 lbs per year) and brine treatments (approximately 24,000 lbs of
sodium chloride) used to clean the resin filters of the. Boiler Condensate
Polishing System is also handled by this system. Wastes from this
system are pumped to the ash basin for disposal.
2. DESCRIPTION HYPOLIMNETIC AERATION TESTING AND USE:
Duke Power Company (DPC) has experimented with two techniques designed
to provide access to the cooler bottom waters in Belews Lake for improved
power station performance. This undertaking is not new to DPC in that
Marshall Steam Station on Lake Norman and Oconee Nuclear Station on Lake
Keowee, South Carolina, utilize cool bottom waters to increase the efficiency
of these power stations.
4

Two years were spent on Belews Lake experimenting with a plastic curtain
that was placed across the intake cove of BCSS to block withdrawal of surface
water and promote, the intake of bottom waters by the Station. That technique
was marginally successful and was replaced with an aeration system that
forces air from a compressor into the bottom water in front of the intake. As
air bubbles rise cool bottom water and warmer surface water is mixed and
drawn .into the Station intake. During operation this system effectively
lowers the intake temperature by about 4°F, as well as the discharge
temperature. Additionally, the system lowers the depth of the thermocline in
the lake from about 10 m to 17 m below the "surface of Belews Lake. On-going
biological monitoring studies indicate that no adverse effect on biota of Belews
Lake from utilization of this cool water.
3. RECOVERY OF BELEWS LAKE FISHERY:
On-going environmental monitoring programs being conducted by Duke Power
Company indicate that the warmwater fishery of Belews Lake is recovering
following rerouting of the ash basin discharge to the Dan River in 1985.
Monitoring studies conducted in the 1970's indicated that selenium and other
trace elements in fly ash sluiced from the Station to Belews Lake contributed
to the deterioration of the Belews Lake fishery. On-going studies continue
to indicate recovery of the fishery of Belews Lake and no adverse impact of
the Station's ash basin discharge to the biota of Dan River.

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PLANT: BELM, (:GEEK
COUNTY: GTOK Is'. ;
STATE: NORTH CAPRI I PIA
JANUARY 1993

0
LEGEND
Plant Belews Creek Schematic
Flow Stream
1. Ash Basin Rainfall Runoff
2. Coal Yard Rainfall Runoff
3. Yard Drainage to Intake Canal
.4. Yard Drainage to Discharge. Canal
Avg. Daily Flow. MGD*
A. Intake Water
B. RCW Cooling Water
C. Condenser Cooling Water
D. High and Low Pressure Service -Water
E. Intake Screen Backwash
F. Miscellaneous Plant uses including Washdown
and Fire Protection
G. Water Treatment System
H'. Coal Handling System
I. Service Water Discharge to Ash Removal
J. -Water Treatment System to Miscellaneous
Equipment and Seals.
K. I.D. Cooling Water
L.. Hydrogen and oil coolers
M. Plant air conditioning
N. Water Treatment System Wastes
0. Condensate.Feedwater System Effluent
P. Continuous - Ash hopper Seals and Cooling
Q. Sanitary System influent
R. Condensate Feedwater System
S. Power House Sumps Effluent
T. Evaporative Losses,, Soot Blowing
U. Boiler Cleaning -Wastes
V. Fly and Bottom Ash Sluicing
W. Yard Holding Sump Effluent
X. Turbine and Boiler Room Drains
001 Condenser and Miscellaneous Equipment
Noncontact Cooling Yater
003 Ash Basin.Discharge
0.47
0.08
0.03
0.05
1088.5
50.20
1023.847
14.403
0.02
1.073
0.38
0.45
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1.30
0.087
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0.003
0.10
3.85
0.10
0.003
2.75
3.35
1.163
1079.677
7:6.
*Flows are extrapolated. beyond the scope of significant figures in
this table and throughout this narrative to account for variations
in flow capacities.

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