NC0004979_Plant Allen SNCR System_20021003

R�: PLANT ALLEN SNCR SYSTEM
Nc000 Y9 29
Subject: Re: PLANT ALLEN SNCR SYSTEM
Date: Thu, 03 Oct 2002 13:36:27 -0400
From: Teresa Rodriguez <teresa.rodriguez @ncmail.net>
Organization: NC DENR DWQ
To: Robert R Wylie <[e-mail]>
Robert,
No further steps are necessary regarding the installation of the SNCR for Plant
Allen. The permit covers the nitrogen monitoring.
Teresa
Robert R Wylie wrote:
> Teresa,
> Per our telephone conversation, please review the following note and let
> me know if any additional steps are needed to ensure NPDES coverage for the
> SNCR project. Plant Allen's NPDES permit was re -issued on May 17, 2002.
> The effective date is July 1, 2002 and the expiration date is May 31, 2005.
> Thanks,
> Robert
> ----- Forwarded by Robert R Wylie/Gen/DukePower on 10103/02 09:43 AM -----
> Robert R Wylie
> To: Na tali e. [e-mail]
> 09/26/02 02:35 cc:
> PM Subject: PLANT ALLEN SNCR SYSTEM
> Natalie,
> As we discussed last week a meeting recently occurred with the
> representatives from the North Carolina Dept. of Environment and Natural
> Resources and Duke Energy to discuss air pollution control projects. One
> NPDES item that came out of that meeting was to ensure that the Plant
> Allen's NPDES permit addressed the upcoming installation of a permanent
> Selective Non -Catalytic Reduction (SNCR) system, since once in operation
> the potential for an increase in levels of ammonia exists. The following
> provides a summary of what has previously been addressed in the NPDES
> process and also more details on the SNCR. It is requested that you
> evaluate the following and advise if an NPDES permit (minor) modification
> request is warranted or if the information provided during the permitting
> process is sufficient for Plant Allen to begin the operation.
> NPDES Permit
> During the Plant Allen NPDES permit renewal process the following paragraph
> was included as a revision to the NPDES permit application in order to
> address the air pollution control projects and the potential for these
> compounds to be discharged into the waste water treatment system:
> "Plant Allen presently has additional air pollution control systems
> installed on two units. Use of these systems entails the use of low
> concentrations of ammonia and sulfur compounds. Additional air
> pollution control systems (i.e. -for S02 and NOx treatment) may be added
> in the future."
1 of 2 10/7/2002 1:53 PM

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Re: PLANT ALLEN SNCR SYSTEM
-' > The results for the NPDES permit application form 2C analysis were 0.12
> mg/1 ammonia (as nitrogen). The final NPDES permit requires that Total
> Nitrogen be monitored and reported.
> SNCR
> Plant Allen (Unit 1) plans to install by March 31, 2003 a permanent SNCR
> system for air pollution treatment (to reduce nitrogen oxide emissions).
> The SNCR system, injects into the boiler, a water mixture containing urea.
> During this operation the potential exists for ammonia to become attached
> to fly ash. The fly ash is collected in the electrostatic precipitators
> (ESP). The fly ash is mechanically shaken off the ESP collection plates
> and collects in the bottom of the ESP. The fly ash is then sluiced to the
> ash basin.
> It is estimated that the concentration of ammonia from the fly ash sluicing
> system will average at a concentration of
> 0.96 mg/1 after it enters the ash basin. The flowrate for the fly ash
> slucing system will not change due to the operation of the SNCR. The
> ammonia is expected to be at a concentration of less than 1.0 mg1l at the
> final discharge (NPDES outfall 002) since the fly ash should absorb some of
> the ammonia and also biological activity should provide for some ammonia
> reduction. I'll be glad to fax to you a process flow diagram that outlines
> the above. Please provide to me your fax number and I'll send it to you.
> Your review of the above is appreciated
> if you have questions.
> Thanks,
> Robert
Please call me at [phone]
2 of 2 10/7/2002 1:53 PM

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70 gpm Urea
Solution
Iniection
Allen Unit 1 Boiler
Electrostatic 15910 NH3 Slip
8 ppm NH3 Slip Preheater Precipitator Ur�9t Stack
= g.0 Ibfhr
slu
— I 1=lyash sluice line
Preheater 7.6 Ib/hr NH3 (Based on 85% NH3 retention on ash)
wash-
approx. 4
timesfyr
0.96 ppm incremental NH3 increase to ash
basin due to Unit I SNCR
MGDMGDAsh Basin)_2?.05 Outfall 002
ALLEN UNIT I $NCR PROCESS FLOW DIAGRAM
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Stacks and NC Clean Air
Leaislation Permits
September 12, 2002

SO2 Downwash
and Stack Extensions
• Background
■ Modeled exceedances of the ambient SO2
NAAQS due to downwash at Riverbend,
Dan River, Buck, Cliffside, Allen and
Marshall.
■ Monitoring program resulted in some
exceedances even though a rare event.
Exception at Marshall with no exceedances
■ Agreement to extend stacks at Riverbend,
Dan River, Buck, Cliffside and Allen.
Riverbend and Dan River Complete.
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SO2 Downwash
and Stack Extensions
• Buck Steam
Station
currently
scheduled to
extend
stack
in
Fall
2003 and
Sprina 2004.
■ Request to extend Buck 5&6 in 2003 and potentially
delay Buck 3&4 extension until Spring 2006.
would continue lower sulfur coal and monitoring.
• Reevaluating value of Buck 3&4 after minimal run time
in 2002.
OPotential repowering opportunities in 2005-06
timeframe
OFirm decision by February 2003
Estimated cost to extend -$2 million for Buck 3&4.

SO2 Downwash
and Stack- Extensions
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• Cliffside 14 currently scheduled to extend
stacks Fall 2004.
■ Reevaluating value after minimal run time in
2002 & potentially high stack extension cost.
• Stack extension cost estimated at $5-$10million.
■ Potentially request to either install stack
extensions by Fall 2004 as scheduled or
retire by 2006.
Decision by March 2003

SO2 Downwash
and Stack Extensions
• Allen — Currently scheduled for FGDs with new stacks
between 2009- 2012.
■ Stack extensions scheduled 2006.
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■ FGD Allen 3 F09, Allen 4 S10, Allen 5 F10, Allen1&2 2012
■ Request delay to match FGD installation schedule.
Continue to monitor- until new FGD stacks are installed
• Only 1 exceedance since started monitoring in 2000 and no other close
calls.
— Estimated cost 44million to extend Allen 1-5.
• Marshall — Currently scheduled for FGDs with new stacks
prior to 2009.
■ No commitment to raise stacks & current FGD schedule is
2006-2007.

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SNCR Permits Required
Permits
2002
2003
2004
2005
2006
2007
2008
2009
2010
Air
1
1
4
1
Water
1
1
4
1
Erosion
Control
1
1
4
1
Units
On-line
1_
2
3
7
11

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SNCR - Air Issues
• Prepare modification to existing air permits to
incorporate the new pollution control equipment.
• Requesting response from State within 18 weeks of
submittal to maintain construction schedule.
• Activities include air modeling, ammonia slip
estimation, establishing limits, process descriptions,
etc.

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SNCR - Water Issues
• Prepare modification to existing NPDES permits to
incorporate new waste streams and/or increased
volumes.
• These projects should generate (low volume) waste
streams so we are planning for a minor permit
modification.
• Requesting response from State within 16 weeks of
submittal to maintain construction schedule.

SNCR - Erosion Control Issues
• Prepare erosion control plans for areas that will be
disturbed during construction activities.
• Requesting response from the State within 16 weeks
of submittal to maintain construction schedule.
• Depending on the facility (size, number of units, etc.)
these may or may not be regulatory required.
• Key issues include determining the area that will
disturbed, who will develop and submit the plan to the
State (Duke vs. Contractor), etc.

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FG® Permits Required
Permits
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
Air
1
1
1
1
1
1
Water
1
1
1
1
Erosion
Control
1
1
1
1
Landfill
1
1
1
1
316(b)
Intake
2
1
1
Units
On-line
2
2
2
1
3
2

FGD- Air Issues
• Prepare modification to existing air permits to
incorporate the new pollution control equipment.
• Requesting response from State within 18 weeks of
submittal to maintain construction schedule.
• Activities include air modeling, estimating particulate
and fugitive emission increases, process description,
etc.

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FGD- water Issues
• Prepare modification to existing NPDEs permits to
incorporate new waste streams and/or increased
volumes.
• Schedule allows for a major permit modification (44
weeks after submittal) but potential to demonstrate
these are low Oume waste streams that could be
handled as minor permit modifications.
• Key issues include chloride concentration of
blowdown, potential issues with selenium, nitrogen
and ammonia concentrations, required treatment, etc.
! The schedule reflects the potential for constructing
treatment systems if required (allowing 24 weeks for
construction).

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FGD- Erosion Control Issues
• Prepare erosion control plans for areas that will be
disturbed during construction activities.
• Requesting response from the state within 16 weeks
of submittal to maintain construction schedule.
• Key issues include determining at each facility
whether an erosion control plan is required based on
area disturbed, who will develop and submit the plan
to the State (Duke vs. Contractor), etc.

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FGD- 316(b) Intake Issues
• EPA is expected to issue regulatory guidance in
August of 2003 addressing 316(b).
• Duke will perform 316(b) studies for existing intakes
concurrent with NPDES renewal schedules upon
issuance of regulations.
• Duke would request that required 316(b) studies for
FGD's be addressed with the other studies mentioned
above.
• Evaluate the use of CCW discharge water and other
existing water sources at each facility to eliminate the
need for new intake structures.

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FGD - Gypsum
,Disposal Requirements & Permitting
• Currently planning on producing a wallboard
grade product.
■ If product is used at a wallboard facility no waste
permits required
■ If wallboard facility is not justified current plan is to
use product in a structural fill where space permits
■ Approximately a 6 month lead time to permit and
construct.

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FGD- Gypsum Disposal
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Reguirements & Permitting
• Disposal in Industrial Landfill
■ Evaluating Gypsum characteristics
■ Evaluating potential Landfill sites
■ Should have a good idea of liner or cap requirements by
Spring 2003.
Approximately 2 - 3 year lead time to permit and construct
• Due to the differences in lead times request to apply for
a structural fill permit now to assure we have a place to
dispose of product if structural fill regulations changes.
• EPA proposed not to adopt primary drinking water
standards for sulfates &manganese (June 02).
■ Possibility of removal from 21 groundwater standards?