NC0004979_Fact Sheet_20011017

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FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0004979
erry xoau; tiuntersvtiie,
Prim.SlC Code: 4911
Fork Catawba Rivers
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BACKGROUND
Duke Energy's Allen Steam Station is a coal fired steam electric plant in Gaston County.
The facility has four permitted outfalls in the current NPDES discharge permit, issued in
September 1996. The sources of wastewater for these outfalls include non -contact cooling water,
ash basin discharge, sanitary waste, cleansing and polishing water and stormwater from process
areas. The facility has requested a fifth permitted outfall in the renewal application to cover
weekly cleaning of intake screens, which trap debris and Asiatic clams.
In compliance inspection reports, the Mooresville Regional Office describes the facility
as well maintained with few compliance problems.
In addition to NPDES Permit NC0004979, the facility also holds the; foFlo`_w_ing- pefrriits:
03757 (air permit), NCD043678937 (Hazardous wastes), and WQ0003255 (ash -reuse permit).
r�
Permit Renewal Application:
The permittee submitted the following items for permit renewal: j 0 4'
• EPA Form 1
• EPA Form 2E
• EPA Form 2C (with a priority pollutant analysis). c N
• Site Maps I
Water Flow Diagram L
• Supplemental information a
The following changes were requested:
• Deletion of the oil and grease monitoring requirement at outfalls 602-aAd:00-4_ a ;�
• Deletion of naphthalene, phenol and chromium monitoring at outfall 002
• Reduction of fecal and BOD monitoring from monthly to semi-annually
• Reduction of TSS monitoring from monthly to quarterly
• Make the iron and copper limits applicable only during a chemical metals cleaning
The permittee also requested a continuation of the 316(a) variance for temperature based
on the submitted aquatic life data. The permittee also requested the addition of a fifth outfall
Fact Sheet
NPDES NC0004979Renewal
Page 1

I kw 1 ,

• ' from which intake screen washwater would be discharged once a week with a total flow of about
3000 gpd.
Instream Monitoring and Verification of Existing Conditions and DMR Data Review.
This facility discharges to both the South Fork Catawba River (001) and the Catawba
River (002-004). Both are located within sub -basin 03-08-36 and neither is listed as an impaired
stream [303 (d) -listed as of 2000]. One of the permit requirements is to perform an assessment
of balanced and indigenous populations in downstream Lake Wylie. This requires Plant Allen to
maintain three macroinvertebrate sampling stations in Lake Wylie (2 m. depth) and three fish
monitoring stations (one upstream of the Plant Allen intake). The report was submitted by the
permittee and is attached. The report states that "Macroinvertebrate data show no adverse
impact of the heated discharge; on the macroinvertebrate fauna in Lake Wylie." It also states that
Lake Wylie has a diverse fish community that is not experiencing atypical levels of stress. The
sampling indicates that the fish avoid the Plant Allen discharge in the summer but seem to show
a preference for that location in the spring. Other than the aquatic life data, no other instream
data are collected
Discharge Monitoring Reports (DMRs) for outfalls 001-004 were reviewed from January
1999 -August 2001. Flow and temperature are measured at outfall 001, a discharge consisting of
condenser cooling water; flow during this time averaged 721 MGD. Outfalls 003 discharges
miscellaneous equipment cooling and seal water to the condenser cooling water discharge canal;
average flow at this outfall was 6 MGD. Outfall 004 discharges equipment cooling water and
intake screen backwash. Oil and grease and flow are measured at this outfall. Oil and grease has
not been detected in effluent discharges over the past two years, flow was an average of 8 MGD.
Outfall 002 discharges wastewater from a wide variety of sources including stormwater runoff
from the coal pile area, ash sluice, recirculating !water system, heat exchanger cleaning water,
condensate polishing water, condensate leakage testing water, yard drain sump water, water
treatment system, preheater washes, lab wastes and the powerhouse sumps. The following table
summarizes the effluent data results at outfall 002.
In addition to the aforementioned outfalls, there are two sump overflow outfalls — 002A
and 002B, the coal yard sump overflow and powerhouse sump overflow, respectively. These
discharge to the Catawba River in the event that all pumps in the sump fail. Both were approved
in May 15, 2000. Outfall 002, has only discharged once in the last five years; outfall 002B has
discharged twice in the last five years.
Correspondence.
The Mooresville Regional Office (MRO) conducted six site visits and submitted
corresponding Compliance Evaluation Inspection Reports. The facility typically received
satisfactory ratings on these reports and was described as well maintained with an effluent that
showed no visible adverse impacts to the receiving stream. Two inspections did reveal violations
of the iron daily maximum limit: — one Notice of Violation (NOV) was issued for this exceedence
in October 2000. The facility has also received an NOV for a toxicity test failure (January 1997)
and a Notice of Deficiency (NOD) for unacceptable solids storage (January 1997). Three
compliance biomonitoring inspections were also conducted during the permit period; the facility
passed all three.
The 2001 staff report prepared for this renewal recommends the following:
• Reduce (but not eliminate) oil and grease monitoring at outfalls 002 and 004
• Remove naphthalene, phenol and chromium monitoring at 002.
• Reduce BOD, TSS, and fecal coliform monitoring at 002.
Fact Sheet
NPDES NC0004979Renewal
Page 2
MONITORED PARAMETERS
Flow BOD TSS
(MGD) (mg/L) (mglL)
Fecal
Coliform
#1100 mL)
Oil and Total Total
Grease Nitrogen Phosphorus
(mg/L) ((mg/L mg/L
Average
<5 037 0.07
Maximum
17<0.28
Minimum
8.23
0<
In addition to the aforementioned outfalls, there are two sump overflow outfalls — 002A
and 002B, the coal yard sump overflow and powerhouse sump overflow, respectively. These
discharge to the Catawba River in the event that all pumps in the sump fail. Both were approved
in May 15, 2000. Outfall 002, has only discharged once in the last five years; outfall 002B has
discharged twice in the last five years.
Correspondence.
The Mooresville Regional Office (MRO) conducted six site visits and submitted
corresponding Compliance Evaluation Inspection Reports. The facility typically received
satisfactory ratings on these reports and was described as well maintained with an effluent that
showed no visible adverse impacts to the receiving stream. Two inspections did reveal violations
of the iron daily maximum limit: — one Notice of Violation (NOV) was issued for this exceedence
in October 2000. The facility has also received an NOV for a toxicity test failure (January 1997)
and a Notice of Deficiency (NOD) for unacceptable solids storage (January 1997). Three
compliance biomonitoring inspections were also conducted during the permit period; the facility
passed all three.
The 2001 staff report prepared for this renewal recommends the following:
• Reduce (but not eliminate) oil and grease monitoring at outfalls 002 and 004
• Remove naphthalene, phenol and chromium monitoring at 002.
• Reduce BOD, TSS, and fecal coliform monitoring at 002.
Fact Sheet
NPDES NC0004979Renewal
Page 2

PERMITTING STRATEGY
Waste Load Allocation (WI,A). The Division prepared the last WLA in 1996 for each of the
outfalls. The previous and current effluent limits were based on guidelines and water quality
standards. The Division has judged previous parameters and limits to be appropriate for renewal
with some exceptions (see Reasonable Potential Analysis).
This renewal contains a request to discharge debris and Asiatic clams from the intake
screens back into the Catawba River. I spoke with the Division of Fisheries and the Division of
Wildlife and both agencies saw no problems with this discharge, provided that no additional
detergents or chemicals were added to the effluent. Wayne Jones, a biologist with the Division
of Wildlife stated that since Asiatic clams and natural river debris (twigs, etc) are present in the
river normally, there should be no problem returning these materials to the river. Since there are
no parameters to be monitored for this discharge, it will be treated as a special condition to the
permit which specifies that while the permittee may wash the intake screens and send the debris
and Asiatic clams back to the river, they may not add any detergents or chemicals to the
wastestream without Division ,approval.
Reasonable Potential Analysis (RPA).
The Division conducted EPA -recommended analyses to determine the reasonable
potential for toxicants to be discharged by this facility from outfall 002, based on two and a half
years of DMR data (1999 — August 2001). Calculations included: arsenic (As), chromium (Cr),
lead (Pb), selenium (Se), copper (Cu), iron (Fe) and oil and grease (O & G).
Results suggest no reasonable potential for the facility to discharge As, Cr, Fe and oil
and grease. Reasonable potential was demonstrated for Cu and Se. Guidelines require that the
NPDES permit (see Guidelines section below) limit Fe, Cu and oil and grease.
Arsenic, limited in the current permit, can be monitored monthly now due to no finding
of reasonable potential. Arsenic can be reduced to monthly monitoring. Chromium shall remain
at a quarterly monitoring frequency and oil and -grease can be reduced to a quarterly monitoring
frequency. Phenol and naphthalene, which were not detected during the time period January
1999 -August 2001, shall have their monitoring frequencies reduced to quarterly.
In addition, the primary pollutant analysis was reviewed. 001 discharges non -contact
cooling water and thus no primary pollutant analysis was performed on effluent from this outfall.
The following were detected at outfall 002: aluminum, barium, boron, iron, magnesium,
molybdenum, manganese, titanium, antimony, arsenic, sulfate, copper, nickel, selenium, zinc,
cyanide and cadmium. Several routes were pursued in the determination of monitoring
requirements for these parameters. First, the allowable instream concentrations for all those
parameters with criteria (both NC and EPA recommended criteria) were determined. These
allowable concentrations were compared against the detected concentrations. The only
parameter for which the value of the measured concentration exceeded the allowable
concentrator was selenium. This is anticipated, since this comes from coal, and the parameter is
currently monitored in the NPDES permit. I then called Roy Byrd of the NC Division of Water
Quality Laboratory section in order to determine whether or not the concentrations detected were
comparable to those seen in the environment. Mr. Byrd confirmed that the concentrations
detected for aluminum, magnesium, manganese, titanium, antimony, copper, zinc and cadmium
are either below or in the range of ambient values. Moreover, given the facility's excellent
toxicity record, there is little :reason for concern about the impact of these toxicants on the
receiving stream. With the exception of zinc, these parameters shall not have monitoring
requirements associated with'them beyond what it already present in the NPDES permit.
Copper (already monitored in the NPDES permit) and zinc are now required monitoring
parameters for all major industries (at outfalls with toxicity test requirements) in North
Carolina as per the Division's Action Level policy.
To determine how the remainder of the parameters would be treated, I spoke with Marcus
Zobrist of EPA Central (10/24/01). He confirmed that if water quality standards are not present,
no limits should be included. However, he did recommend (for those parameters with water
Fact Sheet
NPDES NC0004979Renewal
Page 3

quality criteria associated with them) a short term monitoring program. This would apply to
barium, arsenic, sulfate, nickel, cyanide, iron and cadmium. Arsenic and iron are already in the
current NPDES permit, those monitoring requirements and limits will continue to apply.
Quarterly monitoring is recommended for barium, sulfate, nickel, cyanide and cadmium.
If the permittee wishes to submit 10-12 samples for re-evaluation of the monitoring
requirements, this is permitted under Division policy.
A similar procedure was followed for outfall 003. Aluminum, barium, iron, magnesium,
molybdenum, manganese, titanium, sulfate, copper and zinc were detected. Aluminum, iron,
manganese, copper and zinc were all detected at levels below or similar to ambient. Barium was
detected at 0.022 mg/1 with an allowable concentration of 11.2 mg/L, which does not justify a
monitoring requirement. Sulfate and iron will be included as new monitored parameters at
this outfall, with analyses to be performed on a quarterly basis.
For outfall 004, aluminum, barium, iron, magnesium, manganese, titanium, sulfate,
copper and zinc were detected. Aluminum, manganese, copper and zinc were detected at levels
at or below ambient concentrations for those pollutants. Barium was detected at 0.019 mg/l, a
level significantly below the allowable concentration of 8.6 mg/L. Since magnesium and
titanium do not have criteria associated with them, iron and sulfate are the only parameters that
will be monitored at this outfall. Monitoring will be done on quarterly basis.
SUMMARY OF PROPOSED CHANGES
In keeping with Division policies the following will be incorporated into the permit:
• Reduction of phenol, naphthalene, oil and grease monitoring to quarterly at
outfall 002.
• Remove arsenic limit, reduce monitoring frequency to monthly
• Maintain total copper, total iron and total selenium limits. Twice monthly
monitoring for copper and selenium as per Division policy for Class I
facilities. Monthly monitoring for total iron.
• Reduce BOD and fecal coliform monitoring to quarterly. Due to frequency of
detects, maintain TSS monitoring at monthly.
• Reduce oil and grease monitoring at 004 to quarterly due to non -detects.
• Add quarterly zinc monitoring to outfall 002.
• Add quarterly barium, sulfate, nickel, cyanide and cadmium monitoring to
outfall 002.
• Add quarterly sulfate and iron monitoring to 003 and 004. Include note in
cover letter that permittee may wish to test the source water to ensure that it is
not the source of these pollutants
New Weekly Average and Daily Maximum limits are derived from the latest NC/EPA policies
considering V2 FA.Vs and allowable concentrations based on reasonable potential.
ENCLOSURES: Reasonable Potential Analysis for outfall 002, primary pollutant analysis (ppa) for
002-004, aquatic toxicity data, Mooresville Regional Office staff report. Additional compliance data
available upon request.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: November 7, 2001.
Permit Scheduled to Issue: January 7, 2002.
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact
Natalie Sie33-504 ext. 551.
NAME: l DATE:
Fact Sheet
NPDES NC0004979Renewal
Page 4

REGIONAL OFFICE COMMENTS
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NAME: 4 4�1a—1
DATE:
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SUPERVISOR: ��%� DATE:T�
Fact Sheet
NPDES NC0004979Renewal
Page 5

Facility Name =
Qw (MGD) =
WWTP Classification
NPDES # =
Receiving Stream
IWC (%) =
Final Results
16.00
Reasonable Potential Summary
10 20 30 40
—777
Stream Classification
7Q] Os (cfs)= 95
30Q2
av cfs'
Arsenic
I Implementation
1
Max. Pred Cw
168.3 µg/1
lAre all reported values less than?
No Limit?
No
I Monitoring
Allowable Cw
312.5 µg/1IIs
the detection limit acceptable?
Ycs Monitor?
Yes
Frequency
Monthly
Chromium
IImplementation
Max. Pred Cw
2.0 µg/l
Are all reported values less than?
Yes Limit?
No
1 Monitoring
Allowable Cw
312.5 µg/l
IIs the detection limit acceptable? .
Yes x_ 'Monitor?
No
l Frequency
None
I!2 FAU:
S h 1022 ug/# ,
1
I
Copper,
IImplementation
Max. Pred Cw
. 53.2 µg/1.
'Are all reported values less than?
No Limit?
No :'Monitoring
Allowable Cw
43.8 µg/l
!Is the detection limit acceptable?
Yes „Monitor?
Yes
Frequency
Monthly
Ill FAVP1
U2 PAU
5 8g/1
1
Iron
'Implementation
IAre
'
+
Max. Pred Cw
1.5 µg/1
all reported values less than?
No Limit?
No '� Monitoring
Allowable Cw
6.3 µg/1
IIs the detection limit acceptable?
�Yes_ , Monitor?
Yes
I Frequency
Monthly
Lead
I Implementation
I
Max. Pred Cw
5.0 µg/1
IAre all reported values less than?
Yes Limit?
No
I Monitoring
Allowable Cw
156.3 µg/1
IIs the detection limit acceptable?
1, 7 Monitor?
No
1 Frequency
None
$ . b .55 f
. ' a .. _ , "1 11 µgib
1
y
-:3
I
Oil & Grease
IImplementation
I
Max. Pred Cw
2.5 mg/L
Are all reported values less than?
Yes Limit?
No
' Monitoring
Allowable Cw
187.5 mg/L
!Is the detection limit acceptable?
sds =Monitor?
No
!Frequency
None
Selenium
lImplementation
Max. Pred Cw
38.6 µg/1
IAre all reported values less than?
No Limit?
Yes
I Monitoring
Allowable Cw
31.3 µg/1
'Is the detection limit acceptable?
i(es Monitor?
Yes
' Frequency
2/Month

Facility Name =
Duke Power - Allen Steam Station
NPDES # =
NC0004979
Qw (MGD) =
25.7
7Q] Os (cfs)=
95
IWC (%) =
16.00
of data points
FINAL RESULTS
Arsenic
2.01
Max. Pred Cw
168.3405758
Allowable Cw
312.5
Allowable Cw
312.5 µg/1
RESULTS
Arsenic
Std Dev.
26.9466
Mean
43.1
C.V.
0.6255
Number
48.700
of data points
32
Mult Factor =
2.01
Max. Value
83.6 µg/1
Max. Pred Cw
168.3405758 µg/1
Allowable Cw
312.5 µg/1
Date n <
Jan -99 1
Feb -99 2
Mar -99 3
Apr -99 4
May -99 5
Jun -99 6
Jul -99 7
Aug -99 8
Sep -99 9
Oct -99 10
Nov -99 11 <
Dec -99 12
Jan -00 13
Feb -00 14
Mar -00 15
Apr -00 16
May -00 17
Jun -00 18
Jul -00 19
Aug -00 20
Sep -00 21
Oct -00 22
Nov -00 23
Dec -00 24
Jan -01 25
Feb -01 26
Mar -01 27
Apr -01 28
May -01 29
Jun -01 30
Jul -01 31
Aug -01 32
Parameter =
Arsenic
Standard =
50 0
µg/1
Actual Data
BDL=1/2DL
48.7
48.700
24.4
24.400
20.2
20.200
63
63.000
83.6
83.600
56.2
56.200
62.6
62.600
79.8
79.800
55
55.000
39.9
39.900
2
1.000
20.3
20.300
5.3
5.300
15.9
23.1
32.4
20.5
17.1
23
19.1
3.5
5.7
3.4
3.9
13
4.5
4.7
14.4
10.4
13.2
16.6 ..
9.2

Facility Name =
NPDES # =
Qw (MGD) =
7QIOs (cfs)=
IWC (%) =
Duke Power - Allen Steam Station
NC0004979
25.7
95
16.00
Max. Pred Cw
53.2
FINAL RESULTS
Copper
Max. Pred Cw
Allowable Cw
53.2
43.8
µg/1
3
Std Dev. 6.4943
Mean 12.2
C.V. 0.5314
of data points 32
tifult Factor =
1.84
Parameter Copper
Standard = w7 0� µg/1
Actual Data BDL=1/2DL
Max. Value
29.0
µg/1
Max. Pred Cw
53.2
µg/l
Allowable Cw
43.8
µg/1
Date
n <
Parameter Copper
Standard = w7 0� µg/1
Actual Data BDL=1/2DL
Jan -99
1
12.50
12.5
Feb -99
2
9.00
9.0
Mar -99
3
7.00
7.0
Apr -99
4
6.00
6.0
May -99
5
9.60
9.6
Jun -99
6
6.00
6.0
Jul -99
7
11.00
11.0
Aug -99
8
5.00
5.0
Sep -99
9
9.00
9.0
Oct -99
10
7.00
7.0
Nov -99
11
7.00
-7.0
Dec -99
12
20.00
20.0
Jan -00
13
25.00
25.0
Feb -00
14
14.00
14.0
Mar -00
15
13.00
13.0
Apr -00
16
7.00
7.0
May -00
17
2.00
2.0
Jun -00
18
5.00
5.0
Jul -00
19
9.00
9.0
Aug -00
20
12.00
12.0
Sep -00
21
29.00
29.0
Oct -00
22
23.00
23.0
Nov -00
23
16.00
16.0
Dec -00
24
21.00
21.0
Jan -01
25
10.00
10.0
Feb -01
26
13.00
13.0
Mar -01
27
22.00
22.0
Apr -01
28
15.00
15.0
May -01
29
17.00
17.0
Jun -01
30
11.00
11.0
Jul -01
31
8.00
8.0
Aug -01
32
10.00
10.0

Facility Name =
NPDES # =
Qw (MGD) =
7QIOs (cfs)=
IWC (%) =
Duke Power - Allen Steam Station
NC0004979
25.7
95
16.00
2
<
FINAL RESULTS
Chromium
Max. Pred Cw
Allowable Cw
2.0
312.5
RESULTS
Std Dev. 0.0000
Mean 2.0
C.V. 0.0000
lof data points 14
Mult Factor = 1,00
Max. Value 2.0 µg/l
Max. Pred Cw 2.0 µg/l
Allowable-Cw 312.5 µg/1
Parameter = IChromium
Standard=
Date n < Actual Data BDL=1/2DL
Feb -99
1
<
4
2.0
May -99
2
<
4
2.0
Aug -99
3
<
4
2.0
Nov -99
4
<
4
2.0
Feb -00
5
<
4
2.0
May -00
6
<
4
2.0
Aug -00
7
<
4
2.0
NOV-00
8
<
4
2.0
Feb -01
11
<
4
2.0
Apr -01
12
<
4
2.0
Jun -01
13
<
4
2.0
Aug -01
14
<
4
2.0

Facility Name =
Duke Power - Allen Steam Station
NPDES # =
NC0004979
Qw (MGD) =
25.7
7Q] Os (cfs)=
95
IWC (%) =
16.00
0.3
FINAL RESULTS
Iron
0.295
Max. Pred Cw
1.5
Allowable Cw
6.3
Std Dev. 0.1501
Mean 0.2
C.V. 0.6153
of data points 32
Mult Factor =
2.01
Max. Value
0.7 µg/I
Max. Pred Cw
1.5 µg/1
Allowable Cw
6.3 µg/1
Date
n
Parameter= Iron
Standard = 10
< Actual Data BDL=1/2DL
Jan -99
1
0.5433
0.5
Feb -99
2
0.265
0.3
Mar -99
3
0.295
0.3
Apr -99
4
0.27
0.3
May -99
5
0.4333
0.4
Jun -99
6
0.2
0.2
Jul -99
7
0.25
0.3
Aug -99
8
0.255
0.3
Sep -99
9
0.275
0.3
Oct -99
10
0.31
0.3
Nov -99
11
0.36
0.4
Dec -99
12
0.255
0.3
Jan -00
13
0.315
0.3
Feb -00
14
0.425
0.4
Mar -00
15
0.7466
0.7
Apr -00
16
0.17
0.2
May -00
17
0.1333
0.1
Jun -00
18
0.105
0.1
Jul -00
19
0.105
0.1
Aug -00
20
0.09
0.1
Sep -00
21
0.1
0.1
Oct -00
22
0.165
0.2
Nov -00
23
0.105
0.1
Dec -00
24
0.155
0.2
Jan -01
.25
0.08
0.1
Feb -01
26
0.15-
0.2
Mar -01
27
0.38
0.4
Apr -01
28
0.35
0.4
May -01
29
0.19
0.2
Jun -01
30
0.1
0.1
Jul -01
31
0.14
0.1
Aug -01
32
0.09
0.1

Facility Name =
Duke Power - Allen Steam Station
NPDES # =
NC0004979
Qw (MGD) =
25.7
7QIOs (cfs)=
95
IWC (%) =
16.00
FINAL RESULTS
Lead
Max. Pred Cw 5.0
Allowable Cw 0.0
RESULTS
n
<
Std Dev.
0.0000
Apr -99
Mean
5.0
10.0
C.V.
0.0000
2
Number
10.0
5.0
of data points
24
<
Mult Factor =
1.00
Jul -99
Max. Value
5.0
µg/I
Max. Pred Cw
5.0
µg/1
Allowable Cw
156.3
µg/l
Parameter = Lead
Standard = 25.0 µg/1
Date
n
<
Actual Data
BDL=1/2DL
Apr -99
1
<
10.0
5.0
May -99
2
<
10.0
5.0
Jun -99
3
<
10.0
5.0
Jul -99
4
<
10.0
5.0
Sep -99
5
<
10.0
5.0
Oct -99
6
<
10.0
5.0
Nov -99
7
<
10.0
5.0
Dec -99
8
<
10.0
5.0
Jan -00
9
<
10.0
5.0
Feb -00
10
<
10.0
5.0
Mar -00
11
<
10.0
5.0
Apr -00
12
<
10.0
5.0
May -00
13
<
10.0
5.0 -
Jun -00
14
<
10.0
5.0
Jul -00
15
<
10.0
5.0
Aug -00
16
<
10.0
5.0
Sep -00
17
<
10.0
5.0
Oct -00
18
<
10.0
5.0
Nov -00
19
<
10.0
5.0
Dec -00
20
<
10.0
5.0
Jan -01
21
<
10.0
5.0
Feb -01
22
<
10.0
5.0
Mar -01
23
<
10.0
5.0
Apr -01
24
<
10.0
5.0

Facility Name = Duke Power - Allen Steam Station
1.59.
NPDES # = NC0004979
24.2 µg/1
Qw (MGD) = 25.7
38.6 µg/1
7QIOs (cfs)= 95
31.3 µg/1
IWC (%) = 16.00
3
FINAL RESULTS
10.3
Selenium
4
Max. Pred Cw 38.6
21.5
Allowable Cw 31.3
5
20.5
RESULTS
Std Dev. 5.2260
Mean 13.2
C.V. 0.3972
of data points 32
Mult Factor =
1.59.
Max. Value
24.2 µg/1
Max. Pred Cw
38.6 µg/1
Allowable Cw
31.3 µg/1
Parameter =I Selenium
Standard
Date n < Actual Data BDL=1/2DL
Jan -99
1
14.3
14.3
Feb -99
2
10.7
10.7
Mar -99
3
10.3
10.3
Apr -99
4
21.5
21.5
May -99
5
20.5
20.5
Jun -99
6
20.4
20.4
Jul -99
7
22.7
22.7
Aug -99
8
24.2
24.2
Sep -99
9
20
20.0
Oct -99
10
11.9
11.9
Nov -99
11 <
2.0000
1.0
Dec -99
12
9
9.0
Jan -00
13
5.7
5.7
Feb -00
14
9.2
9.2
Mar -00
15
11.9
11.9
Apr -00
16
11.3
11.3
May -00
17
12.3
12.3
Jun -00
18
16.9
16.9
Jul -00
19
17.4
17.4
Aug -00
20
16.9
16.9
Sep -00
21
11.4
11.4
Oct -00
22
9.8
9.8
Nov -00
23
9.1
9.1
Dec -00
24
8.6
8.6
Jan -01
25
14.8
14.8
Feb -01
26
9.3
9.3
Mar -01
27
8.4
8.4
Apr -01
28
12
12.0
May -01
29
10
10.0
Jun -01
30
12.2
12.2
Jul -01
31
12.9
12.9
Aug -01
32
14.4
14.4

Primary pollutant analysis results for Duke Energy's Allen Steam Plant
NC0004979
Outfall 002
Parameter of concern
Aluminum Barium Iron Magnesium Manganese Titanium Sulfa#e, Copper Zinc
(ng/L) (m9/1) L..(m9EA) ,°: (mg/L) (mg/L) (mg/L) (rrt9/L)' (ug/L) (mg/L)
Actual concentration 0.4 0.019 01&" , 2 0.056 0.019 18 3 �. 0.009 0.007
Allowable concentration 4.69 8.66 8 6i` not a POC 1.73 not a POC 2 t65, 60.6 0.433
red font indicates that all. Conc. Based upon EPA Rec. Criteria
fields in bold (no highlighting) indicate that concentration detected is around ambient or tap water values (conversation with Roy Byrd, 10/24/01)
fields with highlighting indicate those parameters that will require periodic monitoring to ensure that the discharge has no impact on the water quality of the receiving stream.
Parameter of concern
Parameter of concern
Aluminum >aum Boron IYon
Magnesium
Molybdenum Manganese
Titanium Antimony Arsenrc
Iron Magnesium
(mg/L) CgFI (n►9/L) €....(9f}.,,. .
(m9IL)
(m9/L)
(mg/L)
(mg/L) (ug/L)(�!9/�-).,:'
Actual concentration
0.208 W'468 0.363 125
2.48
0.083
0.11
0.011 7.12 32 4
Allowable concentration
•
4.69 6„��5, x not a POC��3 4 ,,a
not a POC
not a POC
0.677
not a POC not a POC X69 2
Parameter of concern
Sulfate Copper I Nickel Selenium
Zinc
Cyanide
Cadmium
0.04
0.018
(u9/L) ()�g/L) (u91L)...`
(mg/L)
(mg/L)
(ug/L)
Allowable concentration 10.75
14.33;
14 3�� not a POC
not a POC
2.87
not a POC
Actual concentration
49 4 0.029 x 12.8 17
0.024
0.0025
0.52
Allowable concentration
�g
;, •84'6 -„M 23.7 8 4, : 1 9
0.1692
0.0169
6.8
Outfall 003
Parameter of concern
Aluminum Barium Iron Magnesium Manganese Titanium Sulfa#e, Copper Zinc
(ng/L) (m9/1) L..(m9EA) ,°: (mg/L) (mg/L) (mg/L) (rrt9/L)' (ug/L) (mg/L)
Actual concentration 0.4 0.019 01&" , 2 0.056 0.019 18 3 �. 0.009 0.007
Allowable concentration 4.69 8.66 8 6i` not a POC 1.73 not a POC 2 t65, 60.6 0.433
red font indicates that all. Conc. Based upon EPA Rec. Criteria
fields in bold (no highlighting) indicate that concentration detected is around ambient or tap water values (conversation with Roy Byrd, 10/24/01)
fields with highlighting indicate those parameters that will require periodic monitoring to ensure that the discharge has no impact on the water quality of the receiving stream.
Parameter of concern
Aluminum
Barium
Iron Magnesium
Molybdenum
Manganese
Titanium
Sulfate
Copper
Zinc
(ng/L)
(mg/1)
{mgll? (mg/L)
(mg/L)
(mg/L)
(mg/L)
(rig/L)
(ug/L)
(mg/L)
Actual concentration 0.304
0.022
0 537 1.91
0.04
0.018
0.018
14 4
0.014
0.008
Allowable concentration 10.75
14.33;
14 3�� not a POC
not a POC
2.87
not a POC
100.3
0.717
Outfall 004
Parameter of concern
Aluminum Barium Iron Magnesium Manganese Titanium Sulfa#e, Copper Zinc
(ng/L) (m9/1) L..(m9EA) ,°: (mg/L) (mg/L) (mg/L) (rrt9/L)' (ug/L) (mg/L)
Actual concentration 0.4 0.019 01&" , 2 0.056 0.019 18 3 �. 0.009 0.007
Allowable concentration 4.69 8.66 8 6i` not a POC 1.73 not a POC 2 t65, 60.6 0.433
red font indicates that all. Conc. Based upon EPA Rec. Criteria
fields in bold (no highlighting) indicate that concentration detected is around ambient or tap water values (conversation with Roy Byrd, 10/24/01)
fields with highlighting indicate those parameters that will require periodic monitoring to ensure that the discharge has no impact on the water quality of the receiving stream.

y
.' .

Duke Power - Allen Steam Station
NC0004979
DMR data review for outfalls 001-004
by: Natalie Sierra
10/15/01
Outfall 002 -
Date
Flow BOD
TSS
Fecal Coliform Oil and Grease Total N Total P Arsenic Chromium Copper Iron
Selenium Phenols
Napthalene
(MGD) (mg/L)
(mg/L)
(#/100 mL) (mg/L)
(mg/L) (mg/L) (ug/L)
(ug/L)
(mg/L) (mg/L)
(ug/L) (ug/L)
(ug/L)
Jan -99
8.2333
0
25
13
0
48.7
0.0125
0.5433
14.3 <10
<10
Feb -99
8.525
13
7
4
0
0.4 0.28
24.4 <4
0.009
0.265
10.7 <10
<10
Mar -99
20.12
0
8
2
0
20.2
0.007
0.295
10.3 <10
<10
Apr -99
16.475
2
8
2
0
63
0.006
0.27
21.5 <10
<10
May -99
14.02
0
15.7
2
0
83.6 <4
0.0096
0.4333
20.5 <10
<10
Jun -99
18.72
0
8
2
0
56.2
0.006
0.2
20.4 <10
<10
Jul -99
16.725
0
23
4
0
62.6
0.011
0.25
22.7 <10
<10
Aug -99
15.76
0
20
4
0
0.26 0.109
79.8 <4
0.005
0.255
24.2 <10
<10
Sep -99
17.5
0
13
7
0
55
0.009
0.275
20 <10
<10
Oct -99
16.625
0
12
2
0
39.9
0.007
0.31
11.9 <10
<10
Nov -99
21.66
0
26
4
0
0.34 0.069
0 <4
0.007
0.36
0 <10
<10
Dec -99
24.475
4.4
23
0
0
20.3
0.02
0.255
9 <10
<10
Jan -00
22.05
0
4
0
0
5.3 '
0.025
0.315
5.7 <10
<10
Feb -00
21.5
0
27.6
4
0
0.39 0.031
15.9 <4
0.014
0.425
9.2 <10
<10
Mar -00
18.95
7.5
23
2
0
23.1
0.013
0.7466
11.9 <10
<10
Apr -00
21.625
3.7
7
0
0
32.4
0.007
0.17
11.3 <10
<10
May -00
20.88
4.8
10
0
0
20.5 <4
0.002
0.1333
12.3 <10
<10
Jun -00
20.972
0
5
17
0
17.1
0.005
0.105
16.9 <10
<10
Jul -00
18.875
0
7
0
0
23
0.009
0.105
17.4 <10
<10
Aug -00
19.94
26
8
0
0
19.1 <4
0.012
0.09
16.9 <10
<10
Sep -00
20.775
0
5
0
0
3.5
0.029
0.1
11.4 <10
<10
Oct -00
14.5
0
6
0
0
5.7
0.023
0.165
9.8 <10
<10
Nov -00
17.55
0
5
0
0
0.53 0.008
3.4 <4
0.016
0.105
9.1 <10
<10
Dec -00
20.225
2.8
0
0
0
3.9
0.021
0.155
8.6 <10
<10
Jan -01
21.42
2.2
6
0
0
13
0.01
0.08
14.8 <10
<10
Feb -01
20.5
0
10
0
0
0.4 0.011
4.5 <4
0.013
0.15
9.3 <10
<10
Mar -01
23.12
0
7
0
0
4.7
0.022
0.38
8.4 <10
<10
Apr -01
20.4
0
22
4
0
14.4 <4
0.015
0.35
12 <10
<10
May -01
24.62
0
4
2
0
10.4
0.017
0.19
10 <10
<10
Jun -01
22.05
0
7
0
0
13.2 <4
0.011
0.1
12.2 <10
<10
Jul -01
25.02
0
14
2
0
16.6
0.008
0.14
12.9 <10
<10
Aug -01
25.775
0
11
0
0
0.24 0
9.2 <4
0.01
0.09
14.4 <10
<10
Aver�l9?r. ., .... ,
X19 36 2 08 11.79..u..
.,..
, . `,.. 2 41_ _ _ _i ..._,
4 00..�.a;
.0 37 _ .. 0 Q , , 25:3
0 t.... .0.24,a,.�, ..�-13 5 tQ b..;,.k > <10 ..'.
max
25.775
26
27.6
17
0
0.53 0.28
83.6
min 8.2333 0 0 0 0 0.24 0 0
D.L. D.L.
2.0 mg/L 5.0 mg/L

y
�,

NC0004979
DMR data review for outfalls 001-004
by: Natalie Sierra
10/15/01
Outfall 001
Date
Date
Flow
Temperature
Jan -99
(MGD)
(deg .C)
Jan -99
224.8741
52.89
Feb -99
194.0178
May -99
Mar -99
544.8903
6
Apr -99
444.47
Aug -99
May -99
619.2838
6
Jun -99
731.9266
38.9
Jul -99
770.8225
6
Aug -99
774.7612
Feb -00
Sep -99
637.8233
6
Oct -99
500.529
35
Nov -99
491.333
6
Dec -99
505.087
Aug -00
Jan -00
405.1451
56.5
Feb -00
365.2827
Nov -00
Mar -00
382.0903
6
Apr -00
413.55
Feb -01
May -00
577.7612
6
Jun -00
766.07
38.9
Jul -00
764.0741
6
Aug -00
780.9354
Aug -01
Sep -00
698.71
Oct -00
448.9096
35
Nov -00
539.8266
Dec -00
584.7903
Jan -01
530.7838
56.76
Feb -01
382.3392
Mar -01
5533.806
Apr -01
531.333
May -01
663.5677
Jun701
741:3966
38.9
Jul -01
759.3677
Aua-01
777.3419
Outfall 003
Date
Flow
(MGD)
Jan -99
6
Feb -99
6
Mar -99
6
Apr -99
6
May -99
6
Jun -99
6
Jul -99
6
Aug -99
6
Sep -99
6
Oct -99
6
Nov -99
6
Dec -99
6
Jan -00
6
Feb -00
6
Mar -00
6
Apr -00
6
May -00
6
Jun -00
6
Jul -00
6
Aug -00
6
Sep -00
6
Oct -00
6
Nov -00
6
Dec -00
6
Jan -01
6„
Feb -01
6
Mar -01
6
Apr -01
6
May -01
6
Jun -01
6
Jul -01
6
Aug -01
6
AveFage 6
004
(MGD)
Jan -99 8
Feb -99 8
Mar -99 8
Apr -99 8
May -99 8
Jun -99 8
Jul -99 8
Aug -99 8
Sep -99 8
Oct -99 8
Nov -99 8
Dec -99 8
Jan -00 8
Feb -00 8
Mar -00 8
Apr -00 8
May -00 8
Jun -00 8
Jul -00 8
Aug -00 8
Sep -00 8
Oct -00 8
Nov -00 8
Dec -00 8
Jan -01 8
Feb -01 8
Mar -01 8
Apr -01 8
May -01 8
Jun -01 8
Jul -01 8
Aug -01 8
(mg/L)
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5

Whole Effluent Toxicity Testing Self -Monitoring Summary
FACILITY REQUIREMENT
YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT
September 25, 2001
NOV DEC
Cyprus Foote Mineral CoAOI Perm 24hrp/fac monit: 90%fthd (grab)
1997 —
—
—
—
—
Pass
—
—
—
—
—
—
NC0033570/001 Begin: 1 /1/1999 Frequency: A
NonComp:
1998 —
—
—
—
—
Pass
—
—
—
—
—
—
County: Cleveland Region: MRO Subbasin: BRD05
— NR
1999 --
—
—
—
—
Fail
—
Fail,Pass
Pass
—
—
—
PF: NA Special
2001 Fail
2000 —
Pass
—
—
—
--
—
—
—
—
—
—
7Q10:0.9 IWC(%):17 Order:
Pass
2001 —
—
Pass
—
—
—
—
— Pass
-• --
Pass
--
-- Pass
Dan River Inc. Harris Facility Perm chr tun: 0.75%
County: Gaston Region: MRO Subbasin: CTB34
1997 —
--
>100
—
—
>100
—
—
>100
—
—
Late
NCO083275/001 Begim2/1/1999 Frequency:Q + Mar Jun Sep Dec
+ NonComp:Single
1998 >100
—
>100
—
—
>100
—
—
>100
—
—
>100 '
County: Rutherford Region: ARO Subbasin: BRD02
1999 —
—
Pass
—
—
Pass
—
—
Pass
—
—
Pass
PF: 0.91 Special
1995 —
2000 —
—
Pass
—
—
Pass
—
—
Pass
—
—
Pass
7Q10:186 IWC(%):0.75 Order:
—
2001 —
—
Pass
—
—
Pass
—
— —
Pass —
—
Late
Pass —
Dare County-(RO)/001 Penn 24hr p/fac monit: 90%mysid
7Q10:24.0 IWC(%):33.0 Order:
1997 Poss(s)
—
—
Pass
—
—
Pass
—
—
Feil,Pass
—
—
NC0070157/001 13egin:5/1/1995 Frequency: Q Jan Apr Jul Oct
NonComp:
1998 Pass
—
—
Fail,Pass
—
--
Fail,Pass
—
—
Pass
—
—
County: Dare Region: WARO Subbasin: PAS56
1999 Pass
—
—
Pass
—
--
Pass
—
—
Pass
--
—
PF: NA Special
2000 at
at
—
Pass
—
--
Pass
—
•-
Pass
—
—
7QI0:0 IWC(%)NA Order:
2001 Pass
—
—
Pass
—
—
Pass
Dare County-(RO)/002 Perm 24hr p/fac monit: 90% mysid
1997 Fail(s).Pass
--
—
Pass
—
—
Pass
—
—
Fail,Pass
—
—
NC0070157/002 Begin:5/l/1995 Frequency: Q P/F Jan Apr Jul Oct
NonComp:
1998 Pass
—
—
Pass
—
—
Pass
—
—
Pass
—
—
County: Dare Region: WARO Subbasin: PAS56
1999 Pass
—
—
Pass
—
—
Pass
—
—
Pass
—
—
PF: NA Special
2000 at
—
—
Fail
Fail,Pass
—
Pass
—
—
Fail,Failt
—
—
7QI0:0 IWC(%):100 Order:
2001 Pass
—
—
Pass
—
—
Pass
Delta Mills P2 -perm chr lim: 11%; if exp 1.5MGD chr lim 16%
1997 —
—
16
—
—
16
—
—
Late
31
—
>44
NC0006190/001 Begin:3/1/1998 Frequency: Q Mar Jun Sep Dec
+ NonComp:ChV Avg
1998 —
—
31
—
—
31
—
31
—
—
16
County: Catawba Region: MRO Subbasin: CTB35
1999 —
—
16
—
—
at
—
—
15
—
—
31
PF: 1.0 Special
2000 —
--
4.1
<3
Late
15.6,15.6
—
—
31
—
—
15.6
7QI0: 12 IWC(,/.):Il Order:
2001 —
--
31.1
—
—
15.6
—
Denton WWTP Perm car lim: 90%
1997 Fell
Pass
—
—
Pass
—
—
Fail
Pass
—
Pass
—
NC0026689/001 Begin:4/1/2000 Frequency: Q Feb May Aug Nov
+ NonComp:Single
1998 —
Pass
—
—
Pass
—
—
Pass
—
—
Fail,Pass
—
County: Davidson Region: WSRO Subbasin: YAD08
1899 —
Pass
—
—
>90
—
—
51.9
73.48
>90
>90
--
PF: 0.30 Special
2000 —
21.2
>90
--
36.7
>90
—
Pass
—
—
Pass
—
7Q10:0.0 IWC(%):100 Order:
2001 —
Pass
—
—
Pass
—
—
Dixie Yarns, Inc. Perm chr lim: 90% (Grab)
1997 — —
1997 Pass
—
— Pass
— —
Pass
—
— Pass
— --
NC0083763/001 Begin:5/1/2000 Frequency:Q Jan Apr Jul Oct
+ NonComp:Single
1998 —
Pass
— Pass
— —
Late
Pass
— Pass
— —
County: Stanly Region: MRO Subbasin: YAD12
— Pass —
1999 Pass
—
— NR/Pass
— —
Fall
Pass
— NR
Pass —
PF: 0.072 Special
1997 — —
2000 Fall
Pass
— Pass
— —
Fall
>100
>100 NR
Pass —
7Q10:0 iWC(%):100 Order:
— Pass
2001 Fail
>100
97.5 Lela
H H
H
— Pass
PF: 8.8 Special
2000 — —
Duke Power -Allen 002 Perm chr lim: 16% (Grab)
-- Pass —
1997 Fall
FaiV
Pass Pass
-- —
Pass
—
-- Pass
— —
NC0004979/002 Begin: l0/1/1996 Frequency: Q P/F + Jan Apr Jul Oct
NonComp:Single 6
1998 Pass
—
— Pass
-• --
Pass
--
-- Pass
— —
County: Gaston Region: MRO Subbasin: CTB34
1999 Pass
--
— Pass
-- —
Pass
—
— Pass
— —
PF: 11.6 Special
2000 Pass
—
— Bl
— --
Late
Pass
— Pass
— —
7Q10:95.0 IWC(%):16,� Order:
2001 Pass
—
— Pass
— —
Pass
Duke Power-Belews Creek/003 Perm chr lim: 19% (Grab)
1997 —
Pass
— —
Pass —
--
Pass
— —
Fail,Pass —
NC0024406/003 Begin:2/I/1998 Frequency: Q P/F + Feb May Aug Nov
+ NonComp:Single
1995 —
Pass
— —
Pass —
—
Pass
— —
Pass —
County: Stokes Region: WSRO Subbasin: ROA01
1999 —
Pass
— —
Pass —
—
Pass
— —
Pass —
PF: 7.7 Special
2000 —
Pass
— —
Pass —
—
Late
Pass —
Pass —
7Q10:24.0 IWC(%):33.0 Order:
2001 —
Pass
— —
Pass —
—
Duke Power -Buck Steam Perm chr lim: 0.7% (grab)
1997 — —
>100 —
— >100 —
— >100 —
— >100
NC0004774/002 Begin:2/1/2000 Frequency: Q Mar Jun Sep Dec + NonComp:Single
1998 — —
>100 —
— >100 —
— >100 --
— >100
County: Rowan Region: MRO Subbasim YAD04
1999 — —
>100 —
— >100 —
— >100 —
— >100
PF: NA Special
2000 — —
BI —
— Pass —
— Pass —
— Pass
7QI0: 1030 IWC(%):0.598 Order:
2001 — —
Pass —
— Pass --
Duke Power-CBfisidePearn chr am: 5.6% (Grab)
1997 — —
Pass —
— Pass —
— Pass —
— Pass
NC0005088/002 Begin:3/1/1999 Frequency: Q P/F + Mar Jun Sep Dec + NonComp:Single
1998 — —
Pass —
— Pass —
— Pass —
— Pass
County: Rutherford Region: ARO Subbasin: BRD02
1999 — —
Pass --
— Pass --
— Pass —
— Pass
PF: 8.8 Special
2000 — —
at —
-- Pass —
— Pass --
— Pass
7Q10:287 IWC(%):4.53 Order:
2001 — —
Pass —
— Pass —
LEGEND:
PERM - Permit Requirement LET = Administrative Letter - Target Frequency = Monitoring frequency: Q• Quarterly; M- Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging, D- Discontinued monitoring requirement
Begin= First month required 7Q10 = Receiving stream low flow criterion (cfs) += quarterly monitoring increases to monthly upon failure or NR Months that testing must occur -ex. Jan, Apr, Jul, Oct NonComp = Current Compliance Requirement
PF = Permitted flow (MGD) 1 WC% = ]nstream waste concentration P/F = Pass/Fa0 test AC = Acute CHR = Chronic
Data Notation: f - Fathead Minnow; • - Ceriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reporting Notation: --- = Data not required; NR - Not reported Facility Activity Status: I - Inactive, N - Newly lssued(To construct); H - Active but not discharging; t -More data available for month in question; • = ORC signature needed
16
t'
Z' -

Intake vs 002 Fe
111cr000 q
Subject: Intake vs 002 Fe
Date: Tue, 4 Dec 200109:47:25 -0500
From: "John R Mease" <[e-mail]>
To: [e-mail]
CC: 'Donald L Scruggs" <[e-mail]>
Natalie,
Thanks for "meeting" with us yesterday, you we -re very helpful.
Below is the iron data that we discussed concerning the intake vs ash
basin at Plant Allen. Let me know if you have questions.
Thanks for your help! John
----- Forwarded by John R Mease/Gen/DukePower on 12/04/2001 09:30 AM -----
Donald L
Scruggs To: John R
Mease/Gen/DukePower@DukePower,
Robert R Wylie/Gen/DukePower@DukePower
11/29/2001 cc:
10:31 AM bcc:
Subject: Intake vs 002 Fe
Attached is spreadsheet with 1999-2001 intake Fe concentration vs 002 Fe
concentration.
(See attached file: allenintake.xls)
Name: allenintake.xls
[Mallenintake.xls Type: Microsoft Excel Worksheet (application/vnd.ms-excel)
Encoding: base64
1 of 1 1/7/02 4:55 PM

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Re: Draft Permit -Duke Energy Allen Steam Station-NC0004979
Subject: Re: Draft Permit -Duke Energy Allen Steam Station-NC0004979
Date: Wed, 7 Nov 2001 15:51:42 -0500
From: "Matt Matthews" <[e-mail]>
W.To: "Natalie Sierra" <[e-mail]>
Natalie,
I've pasted the text into this message and also attached the text in a word
document.
Hopefully, you can read one or the other.
Matt
Natalie and Dave,
Thanks for the opportunity to review the subject draft permit. Everything in
the permit looks good from the tox standpoint.
The question I have is concerning the cover letter. The fifth bullet implies
that every facility conducting WET testing should also get copper and zinc
monitoring per the Action Level Policy. This is not my understanding of how
things should work. I thought that Cu and/or Zn monitoring only was required
when there was a reasonable potential to exceed the action level standard
based on analysis of previous data; once the RP was established, the
monitoring requirement was placed in the permit in concert with the WET
test. Based on my understanding, there could be facilities with WET testing
that do not monitor for copper or zinc. Have I misunderstood something?
Let me know what y'all think,
Matt
Matt Matthews
NC DENR/Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
v-[phone]
f-[phone]
MailTo:[e-mail]
----- Original Message -----
From: "Natalie Sierra" <[e-mail]>
To: "Matt Matthews" <[e-mail]>
Sent: Wednesday, November 07, 2001 3:30 PM
Subject: Re: Draft Permit -Duke Energy Allen Steam Station-NC0004979
> Matt-
> For some reason, the letters in your message transmitted in a very
> jumbled fashion - I'm not sure what happened. Can you try to send it
> again?
> Thanks,
> Natalie
> Matt Matthews wrote:
> > Part 1.1 Type: Plain Text (text/plain)
> > Encoding: quoted -printable
1 of 2 inm 4:55 PM

Review of "Assessment of Balanced and Indigenous Populations in Lake Wylie Near Plant Allen
Macroinvertebrate Data
Lake Wylie is an intensively" studied system, with data going back many years to 1972. The 1972
data found'very limited -effects, and there appears to have been very few changes in the benthos
since that time.
Comparison of data from the intake and discharge locations suggests few significant differences,
in spite of the fact that we would expect lower water quality in the South Fork arm of the lake.
The "downlake" location often has higher taxa richness, but this area has more diverse substrate
and (probably) better water quality.
We would like the data examined in greater detail in a few ways, and suggest a small additional
project for Lake Wylie. Deducing the impact of Plant Allen requires that we first understand
other stress factors in Lake Wylie.
-Is there any water quality data that would support greatest problems in the South Fork arm?
Dissolved oxygen, conductivity, etc.?
-We are limited to five years of data for this report, but there is a much longer data set for
these locations. We would like to see Table 3-1 (page 3-9) extended back for the entire data
set, just for taxa richness values. This would allow a better statistical analysis of between -
site differences in water quality. This analysls)is difficult for the small data set presented in
this report, due to high variability at the individual sites. Several years, however, suggest a
depression in taxa richness at the discharge site (1996. 1998).
-Key taxa should be discussed in more detail, especially analysisof fish stomach contents
gives you clues to the more important species. We would like to see better than
"Oligochaeta" as an identification.
*Corbicula is important in many ways, including regulating the flow of energy through the
entire benthic community. Does the power plant still influence the distribution of
Corbicula as described in Lenat and Weiss (1973)? Is Corbicula still of concern in power
plant operation?
*Hexagenia is one of the largest organisms in the Lake Wylie benthic community, and is
likely to be important as fish food.
-The maintenance of rare species should be included in a discussion of "balanced and
indigenous" populations. Quickly scanning these species lists, I can see several taxa of note,
including Microchironomus, Lipiniella, and Zalutschia zalutschicola. The entire data set
should be scanned for this type of species, and we would like to confirm these IDs for our
records.
-Analysis is basically limited to taxa richness. Has anything else been tried? Biotic Indices?
-We would like to see an analysis of midge deformity rates in various portions of the lake.
This would need ponar sampling in deeper water to obtain 20-25 Chironomus larvae per site;
sites should include areas on both branches of the lake (including above and below the
discharge to the South Fork arm), as well as control sites on other arms of the lake.
Fisheries
Tables 3-4 to 3-9 show a seasonal avoidance of the discharge area as reflected in CPUE and
species diversity. The fish avoid the discharge in the summer (how long?) and are attracted to
the warmer water during the spring (and presumably the winter). Thus, -this part of the reservoir
_does.not support a natural fish community.

In the spring electrofishing study
discharge? Ten additional sites
below the discharge.
1, why are the 10 "reference" sites all located below the
the discharge) should be added to compare above, at, and
Table 3-13 shows a reservoirwide decline in the forage fish population (primarily threadfin shad,
an exotic species) from 230 million tc 54 million to 14 million between 1995 and 1997, yet no
explanation for the decline is given.
finalized in March 2001.] Is this just
a reliable tool for determining a balanic
adequacy of a forage fish population o
show that the threadfin_shad is found
predators in the reference area. This o
indigenous fish population:
ote: 1999 data were not available when the report was
ampling variability? If so, then this would not seem to be
ed and indigenous fish population and to determine the
the limnetic predators. Tables 3-11 and 3-13 clearly
my in the heated area and is not available to the 4imnetic.:'
es not support one of their contentions for a balanced and

County Gaston
NPDES Permit Number NC0004979, Duke Energy Corporation - Allen Steam Station, 13339 Hagers Ferry Road,
Huntersville, NC 28078 has applied for a permit renewal for a facility located in Gaston County discharging treated
wastewater into Catawba and South Fork Catawba Rivers' in the Catawba River Basin. Currently selenium and iron are
water quality limited. This discharge may affect future allocations in this portion of the receiving stream.
Wednesday, October 31, 2001
1617 Mail Service Center, Raliegh, North Carolina 27699-1617 -Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer - 50% Recycled / 10% post -consumer paper

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Permit NC0003719
Methyl Chlorid
0.345
0.156
Annual
Grab
E
Methylene Chlon a
0.162
0.073
Annual
Grab
E
Naphthalene
0.107
0.040
Annual
Grab
Nitrobenzene
0.124
0.049
Annual
Grab
2-Nitrophenol
0.125
0.075
Annual
Grab
E
4-Nitrophenol
0.225
0.131
Annual
Grab
E
Phenanthrene
0.107
0.040
Annual
Grab
E
Phenol
0.047
0.027
Annual
Gr
E
Pyrene
0.122
0.045
Annual
ab
E
Tetrachloroethylene
102
0.040
Annual
Grab
E
Toluene
0.1 5
0.047
Annual
Grab
E
Total Chromium
5.03
2.017
Quarterly
Grab
E
Total Copper
6.142
1 2.635
Quarte)rf
Grab
E
Total Cyanide
2.181
0.763
Quqjerly
Grab
E
Total Lead
1.254
0.582
arterl
Grab
E
Total Nickel
7.233
3.071
Quarterl
Grab
E
Total Zinc
Qu
Grab
E
1,2,4-Trichlorobenzene
0.254
0.124
Annual
Grab
E
1,1,1 -Trichloroethane
0.098
0.038
Annual
Grab
E
1,1,2 -Trichloroethane
0.098
038
Annual
Grab
E
Trichloroethylene
0.098
0. X8
Annual
Grab
E
Vinvl Chloride 1
0.487
1018
Annual
Grab
E
Total PAHsz 1 6940 0 uarterly I Co osite I E
Hexachlorobenzene 1.73 1 Quarterly I Comp site I E
Notes: N
1. Sample Loca ' n: E - Effluent, I - In uent
2. Total PAHs e comprised of Benzo( )anthracene; Benzo
Benzo(k) oranthene; Chrysene; Di enz(a,h)anthracene
Note: Com osite samples must be refrigerated
3, 4-B enzofluoranthene;
o (1, 2, 3-ed)pyrnene. \

G4vem Z,
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6774
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GKEX88/MPI
10/12/2001
COMPLIANCE EVALUATION ANALYSIS
REPOT
PAGE 1
PERMIT--NC00049'9
PIPE --002
REPORT PERIOD:
9901-9912
FACILITY--DUKE
POWER - ALLEN S.E.
DESIGN FLOW-
10.000SS--1
LOCATION--BELMONT
REGION/COUNTY--03
GASTON
/TOTAL
50050
0031
00530
31616
TGP3B
0400
000600
MONTH
Q/MGD
BOD
RES/TSS
FEC COLI
CERI7DPF
PH
OIL-G
N
LIMIT
NOL
NOL
30.0
NOL
NOL
9.
6.0
F 15.NOL
99/01
8.2333
.00
25.0
13.0
1
7.)--7.1
.000
99/02
8.5250
13.00
7.0
4.0
8.)-7.0
.000
.400
99/03
20.1200
.00
0
2.0
8.
-7.5
.000
99/04
16.4750
2.00
8.0
2.0
1
6.)_
5
.000
99/05
14.0200
.00
15.7
2.0
8.
-8.0
.000
99/06
18.7200
.00
8.0
2.0
9.)-7.4
.000
99/07
16.7250
.00
23.0
.0
8.7-7.4
.000
99/08
15.7600
.00
20.0
4.
9.)-7.5
.000
.260
99/09
17.5000
.00
13.0
7.0
7.3-7.0
.000
99/10
16.6250
.00
12.0
2.0
1
7.3-6.5
.000
99/11
21.6600
.00
26.0
.0
7.3-6.7
.000
.340
99/12
24.4750
4.40
23.0
.0
7.2-G.8
.000
AVERAGE
16.5698
1.61
15.7
3.8
1
.000
.333
MAXIMUM
25.0000
13.00
26.0
13.0
1
.400
MINIMUM
3.7000
LESSTHAN
7.
2'.0
1
6.500
.260
UNIT
MGD
MG/L
MG /L
#/100ML
PASS/FAI
I SU
MG/L
MG/L

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GKEX88/MP
10/12/2001
COMPLIANCE EVALUATON
ANALYSIS REPORT
PAGE 2
PERMIT--NC0004979
PIPE --002
R
PORT
PERIOD:
0001-0012
LOC
---E
FACILITY --DUKE POWER - ALLEN S.E.
DESIGN FLOW-- 10.0000
CLASS, --1
LOCATION--BELMONT
EGION/COUNTY--03
GASTON
00665
01002
01034
0
042
01045
01147
32730
34696
MONTH PHOS
-TOT
ARSENIC
HROMIUM
COPPER
IRON
SELENIUM
PHENOLS
THALE
LIMIT
NOL
NOL
00/01
5.300
.0250
.3150
5.7000
.0000/7
.0000
LIMIT
NOL
NOL
NO,L
NOL
00/02
.0310
15.900
000'
.0140
.4250
9.2000
.0�0
.0000
00/03
23.100
.0130
.7466
11.9000
✓0000
.0000
00/04
32.400
.0070
.1700
11.3000
.0000
.0000
00/05
20.500
.0000
.0020
.1333
12.37
0000
.0000
00/06
17.100
050
.1050
16.9000
.0000
.0000
00/07
23.000
.0
90
.1050
17.4000
.0000
00/08
19.100
.0000
.012
.0900
16.9000
.0000
.0000
00/09
3.500
.0290
.1000
11.4000
.0000
.0000
00/10
5.700
.0230
.1650
9.8000
.0000
.0000
00/11
.0080
3.400
.0000
.0160
.1050
9.1000
.0000
.0000
00/12
3.900
.021/0
1550
8.6000
.0000
.0000
AVERAGE
.0195
14.408
.0000
.'146
179
11.7083
.0000
.0000
MAXIMUM
.0310
32.400
0290
1.2 00
17.4000
MINIUM
.0080UNITM MG/L
.400
�/L
.0050
AMG/L
MGY L
5.7000
UG/L
UG/1,
UGlL

Q
k4bh00o?N
71.4,�-�'��
-,/4
1
06
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GKEX88/MP
10/12/2001
COMPLIANCE EVALUATION ANALYSIS REPORT
PAGE 1
PERMIT --NCO
04979
PIPE --002
REPORT PERIOD:
0103-0112-
LOC ---E
FACILITY --DUKE
PO
R - ALLEN S.E.
DESIGN FLOW-
10.0000
CLASS --1
LOCATION--BELMONT
REGION/COUNTY--03
GASTON
/
50050
310
00530
31616
TGP3B
C0400
00556
001 00
MONTH
Q/MGD
OD
RES/TSS
FEC COLI
CERI7DPF
PH
OIL-GRSE
TO N
LIMIT
NOL
L
F 30.0
NOL
NOL
9./150
O1/01
21.4200
2.2
6.0
.0
1
7.'-:-6.600
LIMIT
NOL
NOL
F 30.0
NOL
NOL
9.0
NOL
01/02
20.5000
.00
10.0
.0
7.",-7.1.400
01/03
23.1200
.00
7.0
.0
7.,-6.600
01/04
20.4000
.00
2 .0
4.0
1
7.
00
01/05
24.6200
.00
4.
2.0
7.
0001/06
22.0500
.00
7.0
.0
7.
..00
01/07
25.0200
.00
14.0
2.0
1
7.3-7.0
.000
01/08
25.7750
.00
11.0
.0
7.
-6.8
.000
.240
AVERAGE
22.8631
.27
10.1
1.
1
1
.000
.320
MAXIMUM
26.5000
2.20
22.0
4.0
1
-.
400
MINIMUM
18.7000
LESSTHAN
4.0
2.0
1
.500
240
UNIT
MGD
MG/L
MG/L
#/100ML
�P SS/FAI
SU
�fUT/L
MG/L
I

=�-s0-_-
I
'�Drlu� NO (aANI
�
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GKEX88/MP
10/12/2001
COMPLIANCE EVALUA
ION ANALYSIS REPORT
PAGE 1
RMIT--NC0004979
PIPE --004
EPORT PERIOD: 0101-0108 LOC ---E
FACILIT DUKE POWER
- ALLEN S.E.
DESIGN FLOW-- 10.0000
CLASS --1
LOCATIONS ELMONT
REGION/COUNTY--03 GASTON
�O10
00556
MONTH Q/MG' OIL-GRSE
;
LIMIT NOL F
5.000
01/01 8.0000
.000
01/02 8.0000
.0
f
01/03 8.0000
.000
/
01/04 8.0000
.000
01/05 8.0000
.000
01/06 8.0000
.000
01/07 8.0000
.000
01/08 8.0000
.000
AVERAGE 8.0000
.000
MAXIMUM 8.0000
MINIMUM 8.0000
UNIT MGD MGjL

V. -OW
� w
Primary pollutant analysis results for Duke Energy's Allen Steam Plt�s
NC0004979 cl
Outfall 002
1
S�
tl �
rU
\Y
Pf
1 IL
q parameter of con n
Parameter of concern
r
Aluminum
Barium
Boron
Iron
Magnesium
MolybdIffurn
Manganese
Titanium
Antimonyr(ug/L)
rsenic
(mg/L)
(ug/L)
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(ug/L)
Actual concentration 0.208
168
0.363
1.29
2.48
0.083
0.11
0.011
7.12
32.4
1
Allowable concentration not a POC
3384.8
not a POC
3.4
not a POC
not a POC
0.677
not a POC
not a POC
169.2
� IkLj
n � �
s21°
DD
N
10
cec
Parameter of concern
Sulfate
Copper
Nick -'
Selenium
Zinc Cyanide
Cadmium
(mg/L)
(ug/L)
(ug/L)
(ug/L)
(mg/L) (mg/L)
(ug/L)
Actual concentration
49.4
0.029
12.8
1
17.4
0.024 0.0025
0.52Feil
b-(0�
Allowable concentration
846.21
2 .7
84.6
16.9
0.1,\692 0.0169
6.8
Outfall 003
Parameter of concern
Aluminum
Barium
Iron
agnesium Molybdenum Manganese
Titanium
Sulfate Copper
Zinc
(mg/L)
(ug/L)
(mg/L)
(mg/L)
(mg/L) (mg/L)
(mg/L)
(mg/L) (ug/L)
(mg/L)
Actual concentration
0.304
0.022
0.537
1.91
0.04 0.018
0.018
14.4 0.014
0.008
Allowable concentration
nota POC
11215.1
11.2
not a POC
not a POC 2243
not a POC
2803.76 5.8
0.067
� IkLj
n � �
s21°
DD
N
10
cec

-1 �, 'k 7 m
r
qowo,6 2? ,
(--'I »—j UCS
yp/t-n
kirr aux
-!P" AL -24-)y --G.md 3�pc S:2-/P/v 3,f
(,TO

REASONAI
American Truetzschler, Inc
NCO085928
Time Period Jan 1998 thru Oct 2000
Ow (MGD) 0.05
70 10S (cfs) 0
30Q2 (cfs) 0
g. Stream Flow, QA (cfs) ;0
Rec'ving Stream UT to Catawba River
STANDARDS & f I REA
PARAMETER TYPE* - CRITERIA PQ CI PO
NCWQS 1/2 FAV RI
.E POTENTIAL ANALYSIS
<< For Instructions, See RED TAB (cell Al).
WWTP Class 2
IWC (%) @ 7Q10S 100.0
@ 30Q2 100.0
QA 100.0
Stream Class WS -1V ,
EiONABLE PRELIMINARY
TENTIAL RESULTS
:SULTS
n= 27 MaxPredCw >> Allowable Cw
1,1-DCE� C 0.057 Max Pred Cw 33.1
f s Allowable Cw (acute) N/A MONITOR?
Allowable Cw (chronic) 0.057 WK. AVG. LIMIT
n — 26 I MaxPredCw << Allowable Cw
1,2 -DCA a C 0.38 99 IMax Pred Cw 0.5
I Allowable Cw (a ute) 99.000 MONITOR?
aAllowable Cw (c roni0 WK. AVG. LIMIT
n = 26 -o MaxPredCw << Allowable Cw
TCE C 3.1 '--- 92 --�T--Max Pred Cw- 0.5
;Allowable Cw (alute) 92 MONITOR?
--- --� k
Allowable Cw (c ironic) 3 MONITOR?
— ... _ ___
n 26
1,1 -DCA C Max Pred Cw 0.5 9#
no criteria Allowable Cw (a ute) N/A MONITOR?
Allowable Cw (cl ironic) 0 I
n=26
1,1,1 -TCA C Max Pred Cw 10.4
! no criteria Allowable Cw (a ute) N/A MONITOR?
t Allowable Cw (cironic) 0
n= 26 P MaxPredCw < Allowable Cw
PCE - C 0.8 5 Max Pred Cw 1.3
Allowable Cw (a ute) N/A MONITOR?
Allowable Cw (c ronic) 1 _ WK. AVG. LIMIT
*Legend. ** Freshwater Discharge
C = Carcinogenic
NC = Non -carcinogenic
A = Aesthetic
NC0085928_RPA, X- MGD
6/12/01

/SIN
� +mowoe
cy
cKsl �'u
e
h(X

The inspection reports describe the facility as well maintained with toxicity problems in
the effluent. The facility has received an NOV following a 2000 inspection, largely for
deficiencies in self-monitoring (viol tion of the daily maximum limit for 1,1-dichloroethene and
six failures of the chronic toxicity t st). In January 1999 and March 2000, the facility received
NOVs and was eventually assessel civil penalties for toxicity violations. Correspondence
between the Aquatic Toxicity Unit (ATU) and the permittee indicates that the source of the
toxicity is in all likelihood, elevated zinc concentrations. ATU suggests that this may come from
piping within the system. The 2001,ATC allowed treatment improvements that were to remove
zinc and reduce toxicity.
Included with the renewal application was an Engineering Alternatives Analysis (EAA)
evaluating discharge alternatives. Given the urban location of the facility, surface water
discharge appears to be the most feasible option at this time.
PERMITTING STRATEGY AND SUMMARY OF PROPOSED CHANGES
No changes are proposed to this permit. The facility will e -advised via cover letter that
should toxicity problems persist, a more comprehensive EAA should be performed to evaluate
non -discharge alternatives.
PROPOSED SCHEDULE FOR PEBMT ISSUANCE
Draft Permit to Public Notice: June 27, 2001
Permit Scheduled to Issue: August 20, 2001
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact
Natalie Sierra at [phone] ext. 551.
NAME: _I_DATE:
REGIONAL OFFICE COMMENTS
NAME:
SUPERVISOR:
DATE:
DATE:
Fact Sheet
NPDES NCO085928 Renewal
Page 2.

It

The inspection reports descr:
the effluent. The facility has recf
deficiencies in self-monitoring (viol;
six failures of the chronic toxicity to
NOVs and was eventually assesse
between the Aquatic Toxicity Unit
toxicity is in all likelihood, elevated
piping within the system. The 2001
zinc and reduce toxicity.
Included with the renewal a]
evaluating discharge alternatives.
discharge appears to be the most fea;
PERMITTING STRATEGY ANI;
No changes are proposed to t
should toxicity problems persist, a rr
non -discharge alternatives.
PROPOSED SCHEDULE FOR
Draft Permit to Public Notice:
Permit Scheduled to Issue:
NPDES DIVISION CONTACT
)e the facility as well maintained with toxicity problems in
ived an NOV following a 2000 inspection, largely for
tion of the daily maximum limit for 1,1-dichloroethene and
;t). In January 19991 and March 2000, the facility received
I civil penalties for toxicity violations. Correspondence
(ATU) and the permittee indicates that the source of the
:inc concentrations. ATU suggests that this may come from
ATC allowed treatment improvements that were to remove
)lication was an Engineering Alternatives Analysis (EAA)
Given the urban location of the facility, surface water
ble option at this time.
)ermit. The facility will e advised via cover letter that
comprehensive EAA should be performed to evaluate
ISSUANCE
June 27, 2001
August 20, 2001
If you have questions regarding any og the above information or on the attached permit, please contact
Natalie Sierra at [phone] ext. 551.
NAME:
REGIONAL OFFICE COMMENTS
NAME:
SUPERVISOR:
DATE:
DATE:
DATE:
Fact Sheet
NPDES NCO085928 Renewal
Page 2

Duke
(Energy®
December 5, 2001
Ms. Natalie Sierra
North Carolina Department of Environment and
Natural Resources
NPDES Unit
1618 Mail Service Center
Raleigh, NC 27699-1618
SUBJECT: Addendum to the NPDES Permit Renewal Supplement
Allen Steam Station NPDES Permit # NC0004979
Record Number: NC -005157
Certified: 7000 1670 0001 5505 9624
Dear Ms. Sierra:
Duke Energy Corporation
EH&S Services
13339 Hagers Ferry Road
Huntersville, NC 28078
The description of the air pollution control systems that Plant Allen uses was
inadvertently left out of the supplemental. Attached is a copy of the updated
supplemental, see the Ash Sluice section on page 4 for the description. Three copies of
the updated supplemental are attached for your files.
If you need further information, please contact John Mease at [phone].
Sincerely,
Michael A. Ruhe, Manager
Water Compliance
cc: Mike Parker — NCDENR, Mooresville Regional Office
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NPDES Supplemental Information
For
Allen Steam Station
NPDES Permit # NC0004979
February 26, 2001

Plant Allen, Gaston County
NPDES Permit # NC0004979
Page 2 of 12
General Information
Plant Allen utilizes waters from the Catawba River for condenser cooling and service
water requirements. A brief discussion of each discharge follows. A schematic flow
diagram of water use, treatment, and discharges indicating typical (average) flow rates
for individual waste streams at Plant Allen is attached. All flows are based on historical
data where possible or pump design capacities and normal run-times.
Outfall 001 - Condenser Cooling Water (CCW)
The CCW system is a once -through, non -contact cooling water system that removes
heat rejected from the condensers and other selected heat exchangers and then
discharges into the South Fork River. Each of the 5 units at Plant Allen has two
condenser cooling pumps. The number of pumps used is dependent on unit load and
intake temperatures with more pumps running with higher loads and intake
temperatures.
Units 1 and 2 share a common cooling water supply tunnel served by a total of 4 CCW
pumps. Units 3 and 4 also share a tunnel and 4 CCW. pumps. Unit 5 has a separate
tunnel and 2 CCW pumps. The common tunnel design enables three pumps to give
Units 1 and 2 or 3 and 4 the equivalent of 1 1/2 pump operation. The 1 1/2 pumps
operation adds an economical range or flexibility when units are on partial load and
when intake water temperatures are minimal.
Unit No.
1 -Pump GPM
1.5 -Pum GPM
2 -Pump GPM
1
55,500
74,800
83,500
2
55,500
74,800
83,500
3
83,000
111,200
126,000
4
83,000
111,200
126,000
5
83,000
126,000
All condenser tubes at Plant Allen are cleaned manually with metal or rubber plugs.
Mechanical cleaning is required once a year for most units.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 3 of 12
Outfall 002 - Ash Basin
Boiler Cleaning
All five boilers at Plant Allen are chemically cleaned with the next cleaning as
needed. The volume of the boilers determines the quantity of chemicals required for
a cleaning. Boilers #1 and #2 each have a waterside volume of 26,700 gallons.
The volume of boilers #3, #4, and #5 is 40,100 gallons each. The volume of dilute
waste chemical discharged from unit #1 or #2 during a cleaning is 294,000 gallons.
The volume of diluted waste chemicals drained from #3, #4 and #5 totals 450,000
gallons each. These wastes are drained through temporary piping to the permanent
ash removal lines, which flow to the ash basin. Immediately prior to the beginning of
a boiler chemical cleaning procedure, additional stop logs are added to the ash
basin discharge structure. This assures longer retention time of the chemical
wastes for proper treatment through dilution, neutralization, precipitation, and ion -
exchange as documented in the Ash Basin Equivalency Demonstration (October
1976).
A list of the chemicals and amounts required to clean the boilers at Plant Allen
follows:
CLEANING CHEMICALS
Sodium bromate
Ammonium carbonate
Ammonium hydroxide*
Hydrochloric acid*
Thiourea*
Citric acid
Sodium Sulfite
Ammonium bifluoride
Detergent (Triton —X)
Antifoam agent
AMOUNT USED PER UNIT
Boiler #1 and #2
550 lbs
1000 lbs
850 gal
3700 gal
1680 lbs
300 lbs
100 lbs
1100 lbs
20 gal
10 gal
Boiler #3, #4 & #5
550 lbs
1000 lbs
950 gal
5500 gal
2010 lbs
400 lbs
100 lbs
1700 lbs
20 gal
10 gal
* During a chemical metals cleaning these chemicals are present in amounts
greater than the reportable quantity as identified under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). If a spill
of any these chemicals were to occur, in most cases, it would be routed to the
ash basin for treatment.
Stormwater run-off #1
The normal rainfall run-off plus ground water seepage from the coal pile area is routed
to the coal yard sump via the coal handling sumps. Perforated pipes beneath the coal

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 4 of 12
pile convey the effluent to the coal handling sumps. The total average flow to the coal
yard sump is calculated to be 0.058 MGD.
Drinking Water
A well supplies the drinking water requirements of Plant Allen. Plant Allen is a non-
transient, non -community drinking water system and it's ID # is 01-36-704 in the state's
drinking water database.
Sanitary Wastes
Sanitary waste at Plant Allen is treated in a septic tank with the effluent from the septic
tank being discharged to the Ash Basin via the Coal Yard sump. Approximately 150
people are responsible for the load on this system. An average flow of 4850 GPD is
treated by the system.
Ash Sluice
Plant Allen utilizes electrostatic precipitators to remove fly ash from its stack gases.
These precipitators require approximately 10.0 MGD for fly ash sluicing to the ash
basin. Bottom ash sluicing to the basin requires approximately 6.0 MGD for a total
average ash removal flow of 16.0 MGD.
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 (ie. for SO2 and NOx treatment)
may be added in the future.
Recirculating Water System
Plant Allen has 2 recirculating water systems (RCW): a chiller system and a pump
cooling water system. Both systems use the biocide H-550 or similar products. In
addition, the corrosion inhibitor CS or similar product is used. Generally, these systems
are closed loop, but may need to be drained occasionally. All such water would enter
the floor drains and then be discharged to the ash basin.
Miscellaneous Waste Streams
Turbine Non-destructive Testing:
Approximately once per year, one turbine is tested for cracks in the generator shaft
using an ultrasonic nondestructive test. During the process a maximum of 400 gal
of demineralized water mixed with 4 gal of corrosion inhibitor is used and discharged
to the ash basin.
Heat Exchanger Cleaning:
From time to time, it may be necessary to clean the small heat exchangers with
polyacrylamide, polyacrylate, sodium laurylsulfate and tri -sodium phosphate. All
wastes would be routed to the ash basin.
Condensate Polishers:
Plant Allen utilizes condensate polishers which divert a portion of the normal
condensate (closed system) flow through one of two cells per unit. The polishers
provide filtration as well as ion exchange functions to remove or substantially reduce

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 5 of 12
dissolved solids and suspended matter present in the condensate stream. The
polishers require precoating with a combination of anion and cation resin. To
facilitate precoating, 125-150 mL of a solution of polyacrylic acid (25%) is added to
the precoat slurry. Upon exhaustion, the precoat is removed from the filters by
water/ air blasting and flushed to the ash basin via sumps.
Condensate water is used to remove the exhausted precoat at the rate of:
Unit 1 & 2 - 1558 gal/precoat
Units 3, 4, & 5 2090 gal/precoat.
A total average waste flow of approximately 980 GPD to the ash basin is realized.
Condenser Leakage Testing:
Fluorescing Dye. Method
Approximately 1 Ib. of a disodium fluorescing dye added to 280,000 gals of
demineralized water is used occasionally to test the condensers for leakage. All
wastes from the testing would be routed to the ash basin.
Sulfur Hexafluoride Method:
Periodically, sulfur hexafluoride is injected into the condenser tubes to locate
condenser tube leaks. Sulfur hexafluoride is a chemically inert, nonflammable,
nontoxic gas with an extremely low water solubility. It is estimated that 150 grams of
sulfur hexafluoride would be used during the leak detection process.
Most of the sulfur hexafluoride would be volatilized during the process.
Ash Basin Treatment
CO2 Injection System:
During warmer periods of the year, algae blooms occur in the ash basin causing pH
levels to rise. A CO2 system is utilized during these events to maintain the pH level
below 9.0 standard units.
Acid Injection System:
An acid injection system utilizing 78-80 % sulfuric acid is maintained as back-up to
the CO2 system for pH adjustment
Sodium Hydroxide System:
A sodium hydroxide injection system utilizing 50% sodium hydroxide is maintained
for low pH treatment.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 6 of 12
Yard Drain Sump
The yard drain sump is a large concrete structure that has three level controlled pumps,
which pump wastewater from Plant Allen to the ash basin. These pumps are operated
on a rotating basis. The combined average flow from all sources tied to the yard drain
sump is approximately 4.0 MGD. Below is a description of wastes going to the yard
drain sump:
Storm Water run-off #2
The ash basin accommodates flows from the yard drain sump, coal yard sump, ash
removal lines and rainfall run-off from the basin watershed area. The average
rainfall run-off flows are based on 47 inches of rain per year with 100% run-off from
pond surfaces and 50% run-off from other areas. The average run-off for the ash
basin watershed area is 0.57 MGD. Average run-off to the yard drain sump is
calculated to be 0.018 MGD.
Oil Storage Run -Off
Plant Allen has an above ground oil storage tank with a capacity of 100,000 gallons,
an above ground 4,500 gallon used oil storage tank and one above ground gas tank
with a 550 gallon capacity. A dike surrounds the 100,000 gallon above ground tank
for the purpose of providing secondary containment. The 4,500 and 550 gallon
tanks have an additional outer tank for secondary containment. Any spills not
contained within dike or outer tank secondary containment will be routed to the ash
basin through the yard sumps. If a spill did occur efforts will be taken to contain and
cleanup the spill.
All storage facilities are presently covered under the Spill Prevention Control and.
Countermeasure Plan.
Floor Drains (Units 1-4)
Wastes, which enter the floor drains, accumulate in the boiler room sumps and
turbine room sumps.
Boiler Room Sumps (Units 1-4)
The water which flows to the boiler room sumps originates from such sources as
floor wash water, boiler blowdown, water treatment waste, condensates, equipment
cooling water, sealing water and miscellaneous leakage (refer to the attached
schematic of water flow for individual flows). The effluent from the units 1 through 4
boiler room sumps is flushed to the yard drain sump. The effluent from the unit 5
boiler room sump is flushed to the power house sump, which is then flushed to the
yard drain sump.
Turbine Room Sumps
The turbine room sumps accommodate flows from floor washing, leakage, and
occasional condenser water box drainage. Effluent from units 1 through 5 turbine
room sumps is flushed to the yard drain sump.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 7 of 12
Water Treatment System
The water treatment wastes consist of sedimentation, filter backwash, reverse
osmosis (RO) concentrate, demineralizer regeneration wastes and boiler blowdown.
The make-up water treatment system is compromised of a clarifier, two pressure
filters, two activated carbon filters, two garnet filters, a reverse osmosis machine and
one set of demineralizers. Make-up water is used in the boilers and closed cooling
systems.
Clarifier:
The clarifier has an average production of 0.252 MGD. Alum and caustic are
used to affect precipitation and thus remove suspended solids from the raw river
water. Desludging of the clarifier takes place approximately 8% of the unit run-
time with an average volume of 2300 GPD going to the ash basin.
Pressure Filters:
There are two pressure filters which follow the clarifier in the water treatment
process. These filters are backwashed once per week with a waste flow of
11,000 gallons per backwash. Each pressure vessel will contain 84 ft3 of
anthracite, 50 ft3 of quartz, 25 ft3 of garnet and 41 ft3 of garnet/quartz support
media. Each vessel will use product water to backwash at a rate of 750 gpm.
On average, both vessels will backwash once per week. The contents of the
pressure filters will be changed out, as internal maintenance requires, and the
used filter medium will be disposed of in the ash basin.
Activated Carbon Filters:
In addition to the pressure filters, there are two activated carbon filters. These
filters are backwashed twice per month. Approximately 30,000 gallons of water
are required to backwash each of these filters. The activated carbon filters are
composed of approximately 250 ft3 of granular activated carbon (coal). The
spent filter medium is changed out yearly and is disposed of in the ash basin.
RO Prefilters:
There are 2 RO prefilter vessels containing garnet, which are used to filter
suspended solids. Both filters are backwashed once per week
with the backwashed material routed to the ash basin. Total waste for both
filters is 4500 gallons per week.
RO Unit:
A RO unit is used to decrease the conductivity in the filtered water, thereby
increasing the efficiency of the demineralizers and reducing the amount of
chemical needed for demineralizer regeneration. During operation, the unit has
a continual blowdown of 60 gal/min, which is discharged, to the ash basin. The
RO unit is cleaned on a quarterly basis with the waste going to the yard drains
and eventually the ash basin. During a cleaning, approximately 30 lbs of the
cleaner OSMO AD -20 (containing sulfamic acid) along with 5 gallons of biocide,
40 lbs of trisodiurn phosphate and 0.5 gallons of sodium lauryl sulfate is used.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 8 of 12
Demineralizer:
The demineralizer consists of two mixed -bed cells. Only one of these cells is
operated at any one time. The cell which is in operation is regenerated
approximately once every 7- 14 days of operation. A regeneration requires 42
gallons of sulfuric acid (78-80%) and 150 gallons of 50% sodium hydroxide. An
average dilute waste chemical and rinse flow of 20,000 gal is realized. The
dilute acid and caustic are discharged to the floor drains simultaneously through
the same header for neutralization purposes. All regeneration wastes are
flushed to the ash basin. The demineralizer resin is changed out approximately
once every 10 years with the spent resin going to the ash basin. Approximately
1 mL of the surfactant Triton CF -54 or similar product is added to the new resin
to improve separation.
Boiler Blowdown:
Each of the five boilers at Plant Allen blowdown at an average rate of
approximately 500 lbs. of steam per hour. The blowdown is allowed to flash in a
blowdown tank. Most of the blowdown is vented to the atmosphere with a
minimal amount of condensate discharged to the boiler room sump. The
average condensate flow to this sump is 0.004 MGD. Hydrazine is maintained at
a concentration of 25 ppb in the condensate system for deoxygenation. A
minute amount of hydrazine (<10 ppb) may be present in the condensate flow to
the boiler room sump.
Preheater Washes
Preheaters are backwashed with raw water approximately 2 times per year to
remove ash and corrosion products. There are 12 preheaters at Allen that would
require approximately 100,000 gallons of backwash water each. The backwash
water is routed to the ash basin through the yard drain sump.
Laboratory Wastes
The chemistry lab on site performs a variety of water analyses and routine sample
collections. Therefore several chemicals are used in the lab in small quantities for
sample preservation, bottle rinsing, equipment calibration, conductivity analyses,
etc. The wastes are flushed down the sink and discharged into the yard drain sump
and then pumped to the ash basin. Some of the laboratory chemicals are as
follows: Ammonia molybdate, Acetic acid, Ferric sulfate, Hydrochloric acid,
Monoethylamine, Nitric acid and Potassium hydroxide.
Power House Sump (Unit 5)
The wastes, which enter the floor drains at Plant Allen, accumulate in the boiler
room sumps and turbine room sumps. The water which flows to the boiler room
sumps originates from such sources as floor wash water, boiler blowdown, water
treatment waste, condensates, equipment cooling water, sealing water and
miscellaneous 'leakage. Effluent from the unit 5 boiler room sump is flushed to the
power house sump, which is then flushed to the yard drain sump. This sump also
collects stormwater from various drains located on the north end of the powerhouse.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 9 of 12
Outfall 002A — Coal Yard Sump Overflow
An overflow pipe that directs flow from the sump to the Catawba River was included in
the construction of the yard sumps. This was done to prevent submergence and
damage of the pump motors within the sumps in the event that all pumps failed or
redundant power supply lines could not be restored in a timely manner. This has
occurred approximately one time in the past 5 years. Observations and monitoring of
effluent during events have indicated no impact to water quality.
Outfall 002B — Power House Sump Overflow
An overflow pipe that directs flow from the sump to the ground was included in the
construction of the yard sumps. This was done to prevent submergence and damage
of the pump motors within the sumps in the event that all pumps failed or redundant
power supply lines could not be restored in a timely manner. If enough water overflows,
the waste could potentially get to the Catawba River. This has occurred approximately
twice in the past 5 years. Observations and monitoring of effluent during events have
indicated no noticeable impact to water quality.
Outfall 003 — Misc Equipment Cooling & Seal Water
Outfall 003 discharges into the CCW discharge canal. The discharge consists of
cooling water from units 4 and 5 boiler feedpump hydraulic coupling coolers and other
miscellaneous equipment cooling. This water is once -through, non -contact cooling
water withdrawn from the service water system.
Outfall 004 Equip. Cooling & Intake Screen Backwash
Equipment Cooling Water
Cooling water for units 1,2 & 3 boiler feed pump hydraulic coupling coolers and other
miscellaneous equipment is discharged through outfall 004. This water is once -
through, non -contact water drawn from the service water system. In addition, water
from a vehicle rinse -down area is directed to this outfall. The rinse water contains no
soaps or other additives.
Intake Screen Backwash
The intake screens at Plant Allen are flushed on an "as needed" basis. Backwash
usually averages 2 hours per shift. The average volume required is 0.053 MGD. The
large debris floating on the river is caught on the parallel bar screens. This trash is
collected and disposed of in a landfill. The silt, twigs, leaves and other light debris
collected on the rotating screens are indigenous to the river and are therefore flushed
back with no harmful environmental consequences.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 10 of 12
Outfall 005 — Asiatic Clam/Debris Filter Backwash
Water for the Unit 5 CCW water is filtered for any twigs, leaves and other light debris
which passed through the intake screens. Asiatic clams, which are common in Lake
Wylie and can clog the condenser tubes, are also captured in this filter. This filter is
backwashed once a week for 15 minutes. A maximum flow of 3000 GPD is realized.
No other additives are in the backwash water. The twigs, leaves, clams and other light.
debris collected in the debris filter are indigenous to the river and are therefore flushed
back with no harmful environmental consequences.
Storm Water General Description
As previously discussed much of the storm water runoff is directed to the ash basin
(outfall 002). There are several other storm water outfalls at Plant Allen. These drains
either discharge into the Catawba River or into the South Fork River via the outfall 001
discharge canal. Plant Allen was included in the storm water group application
submittal (March 1991) to the Environmental Protection Agency for several Duke Power
Company locations.
Plant Allen 316(a) Determination
Duke Power Company's 316(a) demonstration (March 1976) concluded that the "heated
discharge from Plant Allen is such that the protection and propagation of a balanced
indigenous aquatic community in and on Lake Wylie is assured."
Duke's operation experience during the past five years under the thermal limitations
imposed in NPDES Permit No. NC0004979 substantiates the above conclusion and
further supports Duke's belief that the operating characteristics of the station have a
minimal effect of the aquatic environment of Lake Wylie. Surveys of the aquatic
community in Lake Wylie demonstrate that a Balanced Indigenous Population exists in
Lake Wylie. Accordingly, Duke requests a 316(a) variance and further requests that
the thermal limitations imposed in the permit be continued.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 11 of 12
Hazardous and Toxic Substances
Hazardous and Toxic Substances Table 2c- 3
At Plant Allen, the potential for toxic and hazardous substances being discharged is
very low. In reference to Item V -D of Form 2-C, the substances identified under Table
2c-3 that may be in the discharge are as follows: Acetaldehyde, Aniline, Asbestos,
Butyl Acetate, Cresol, Cyclohexane, Formaldehyde, Monoethylamine, Naphthenic Acid,
Propylene Oxide, Pyrethrins, Styrene, Triethanolamine, Vanadium, Vinyl Acetate,
Xylene and Zirconium.
Other - During the course of the year products such as commercial cleaners and
laboratory reagents may be purchased which contain very low levels of a substance
found in Table 2c-3. It is not anticipated that these products will impact the ash basin's
capacity to comply with its toxicity limits, since their concentrations are extremely low.
40 CFR 117 and CERCLA Hazardous Substances
The following table identifies hazardous substances located on-site that may be
released to the ash basin during a spill in quantities equal to or greater than the
reportable quantity (RQ) levels as referenced in 40 CFR 117, 302 and 355. This list is
being provided in order to qualify for the spill reportability exemption provided under 40
CFR 117 and the Comprehensive Environmental Response Compensation and Liability
Act (CERCLA). These values below represent the maximum quantities on-site that
could be released at one time and sent to the ash basin. They do not reflect quantities
that are discharged through typical use.
SUBSTANCE
Ammonia (aqueous)
Benzene
Hydrazine
Sodium Hydroxide
Sodium Nitrite
Sulfuric Acid
QUANTITY (lbs.)
SOURCE
9452
Storage Tank
166
Gas Storage Tank
944
Warehouse/Third
floor of Powerhouse
15,566
Warehouse
2034
Warehouse and/or
Mezzanine Floor
30724
Warehouse

Catawba 550 .0
River/—MGD
Plant Allen Water Schematic
Condenser
Cooling Outfall 001
520.0 MGD
Water
Sanitary
Waste
Coal Handling Coal Yard
Sumps Sump
Ash Sluice
Water
Treatment
Boiler Rm
Sumps
Intake screen
Backwash%.°
Atm
Boiler
Powerhouse Sump
Turbine Rm
Sumps
Misc Equip
Cooling & Seals
Plant Allen, Gaston County
NPDES Permit # NC0004979
Page 12 of 12
South Fork
10 River
Outfall 002A --------- ------- 0. Catawba
River
Stormwater #1
Ash Basin Outfall 002 Catawba
20.05 MGD* River
Yard Drainage Stormwater #2
Sump
Outfall 003
4.5 MGD south Fork
River
..-._._.... Outfall 002B ----•--•----------•- Catawba
'-'-'♦ River
Outfall 004 Catawba
6.5 MGD River
Outfall 005
Catawba
0.003 MGD
River

To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
SOC PRIORITY PROJECT: No
Date: May 10, 2001
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Gaston
NP_ DES Permit No.: NC0004979
MRO No.: 01-49
PART I - GENERAL INFORMATION
1. Facility and address: Allen Steam Station
c/o Duke Power Company
13339 Hagers Ferry Road
Huntersville, N.C. 28078
2. Date of investigation: May 2, 2001
LI M Ay 1 5 2001
1 Report prepared by: Michael L. Parker, Environmental Engineer II
4. Person contacted and telephone number: John Mease, Tel#[phone]
5. Directions to site: From the jct. of Hwy. 7 and SR 2525 (South Point Rd.) in the Town of
Belmont, travel south on SR 2525 = 2.5 miles. The entrance to the Allen Steam Plant is
on the left (east) side of SR 2525.
6. Discharge point(s), List for all discharge points: -
outfall 001 outfall 002 outfall 002A outfall 002B
Latitude: 350 11' 23" 350 10' 30" 350 11'17" 350 11' 15"
Longitude: 81 ° 00' 45" 810 00' 23" 81' 00' 46" 81' 00' 22"
outfall 003 outfall 004 outfall 005
Latitude: 350 11' 24" 350 11'15" 350 11' 24"
Longitude: 81 ° 00' 46" 81 ° 00' 22" 81 ° 00' 45"
Attach a US GS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: G 14 NE
7. Site size and expansion area consistent with application:
Yes. There is additional area available for expansion, if necessary..

Page Two
8. Topography (relationship to flood plain included): The site was graded considerably when
built, which removed existing contours. The steam plant is constructed above the high water
elevation of Lake Wylie (the receiving stream). The surrounding area has gently rolling
topography (slopes <10%).
9. Location of nearest dwelling: Approx. 1000+ feet from the steam plant site.
10. Receiving stream or affected surface waters: Catawba River (Lake Wylie) -outfalls 002,
002A, 002B, 004 & 005. South Fork Catawba River (Lake Wylie) -outfalls 001 & 003.
a. Classification: Catawba River, WS -IV & B; South Fork Catawba River, WS -V.
b. River Basin and Subbasin No.: Catawba 030834
C. Describe receiving stream features and pertinent downstream uses: Outfalls 002,
002A, 002B, 004 & 005 enter the main segment of the Catawba River (Lake Wylie),
which is used for primary and secondary recreation and as a receiving stream for
point source (NPDES) discharges both upstream and downstream of the steam plant.
There are no known municipal water intakes located above or below these outfalls.
Outfalls 001 & 003 enter a manmade discharge canal located west of the steam plant.
This canal travels for a distance of z 1.2 miles where it enters the South Fork
Catawba River (an arm of Lake Wylie). This -area is also used for primary and
secondary recreation and there are no known water intakes from the point of
discharge to the mouth of the South Fork of the Catawba River.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
Outfall
001 002 002A 002B 003 004 005
a. Volume of wastewater (MGD): 784.8 11.6 N/A N/A 6.3 8.0 0.003
b. What is the current permitted capacity: No flow limit for any outfall in Permit.
C. Actual treatment capacity of current facility (current design capacity): N/A
d. Date(s) and construction activities allowed by previous ATCs issued in the previous
two years: N/A
Description of existing or substantially, constructed WWT facilities:
outfall 001- no existing WWT facilities. Waste stream consists of Condenser
Cooling Water (CCW). Duke Power has submitted a request to perform a pilot study
at this outfall using portable cooling towers. In full operation, the towers will
remove = 15% of the CCW water from the discharge pipe. The cooled water will
then be returned to the discharge canal. This Office has reviewed Duke's request to
conduct this pilot study and has no objections pending a final review by the NPDES
Unit.

Page Three
outfall 002 - Ash Basin. The only existing treatment facility discharging into the Ash
Basin is a septic tank that receives all the plant's domestic wastewater. This
domestic wastewater enters the existing ash basin where additional treatment occurs.
pH adjustment (carbon dioxide, sulfuric acid, and sodium hydroxide) is available at
the effluent, if needed. Other wastewater sources entering the ash basin and
discharge at outfall 002 include: stormwater runoff from the coal pile area, ash
sluice, recirculating water system, turbine non-destructive testing, heat exchanger
cleaning, condensate polishers, condensate leakage testing, yard drain sump, water
treatment system, preheater washes, laboratory wastes, and the power house sump
(unit 5),
outfall 002A - Coal yard sump overflow. No existing WWT facilities. An overflow
pipe directs flow directly to the Catawba River in the event that all pumps in the coal
yard sump failed or redundant power supply could not be restored in a timely
manner. This overflow pipe was approved by the Division in a letter dated May 15,
2000. Only one discharge has occurred from this outfall in the past five years.
outfall 002B - Power House Sump Overflow. No existing WWT facilities. An
overflow pipe directs flow directly to the Catawba River in the event that all pumps
in the yard sump failed or redundant power supply could not be restored in a timely
manner. This overflow pipe was approved by the Division in a letter dated May 15,
2000. Only two (2) discharges have occurred from this outfall in the past five years.
outfall 003 - Miscellaneous Equipment Cooling and Seal Water. No existing WWT
facilities. Discharge is to the CCW discharge canal.
outfall 004 - Equipment Cooling and Intake Screen Backwash. No existing WWT
facilities.
outfall 005 - Asiatic Clam/Debris Filter Backwash. No existing WWT facilities.
f. Description of proposed WWT facilities: There are no proposed WWT facilities.
g. Possible toxic impacts to surface waters: This facility has consistently passed toxicity
tests required at outfall 002. Various chemicals are used during the cleaning and
maintenance of equipment (see list provided with the application package).
h.. Pretreatment Program (POTWs only): Not Needed.
2. Residual handling and utilization/disposal scheme: Septage generated in the septic tank is
removed as needed by Cline Septic Tank Services (permit# 00136). With the exception of
fly ash, no other residuals generation is expected. Duke Power Company has obtained a
non -discharge Permit (WQ0003255) for the disposal of fly ash.

PDuke
Power.
A Luke EuV Compa17
May 9, 2001
Mr. David Goodrich
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
NPDES Unit
1617.Mail Service Center
Raleigh, North Carolina 27699-1646
Subject: Duke Power Company — NPDES Permit Modification
Allen Steam Station - # NC0004979
Belews Creek Steam Station - #NC0024406
Buck Steam Station — #NC0004774
Cliffside Steam Station — #NC0005088
Dan River Steam Station - #NC0033468
Marshall Steam Station - #NCb004b87
Riverbend Steam Station — #NC0004961
Record #: DP -005157
Certified: 7000 1670 0003 3252 8202
Dear Mr. Goodrich:
Duke Power
Group Environment, Health 6- Safety
MG03A5
13339 Ha ers_Ferry-Road
As a followup .to a telephone conversation between Allen Stowe and Mr. Mike
Templeton of your office on April 27, 2001; Duke Power requests that the
definitions in the Special Conditions of the forenamed permits be revised as boiler
plate language to read as follows:
The term "metal cleaning waste" means any wastewater resulting from
cleaning (with or without chem icaLcleaning componds) any metal process
equipment including, but not limited to, boiler tube cleaning,, boiler. fireside
cleaning; and air preheater cleaning.
The term "chemical metal cleaning waste" means any wastewater resulting
from'the cleaning of any meta( process equipment with chemical
componds, including, but riot limited. to, boiler tube cleaning. Chemical
metal cleaning will be conducted according to approved Duke Power
equivalency demonstration.
a
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4
As a followup .to a telephone conversation between Allen Stowe and Mr. Mike
Templeton of your office on April 27, 2001; Duke Power requests that the
definitions in the Special Conditions of the forenamed permits be revised as boiler
plate language to read as follows:
The term "metal cleaning waste" means any wastewater resulting from
cleaning (with or without chem icaLcleaning componds) any metal process
equipment including, but not limited to, boiler tube cleaning,, boiler. fireside
cleaning; and air preheater cleaning.
The term "chemical metal cleaning waste" means any wastewater resulting
from'the cleaning of any meta( process equipment with chemical
componds, including, but riot limited. to, boiler tube cleaning. Chemical
metal cleaning will be conducted according to approved Duke Power
equivalency demonstration.

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

Duke
Power.
A Duke Energy Company
February 26, 2001
Mr. Charles H. Weaver, Jr.
NC DENR/Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: NPDES Permit Renewal, NC0004961
Allen Steam Station, Gaston County
File: AS -006121
Certified: 7099 3400 0015 4643 8357
Dear Mr. Weaver:
Duke Power
Group Environment, Health 6- Safety
MG03A5
13339 Hagers Ferry Road
Huntersville, NC 28078-7929
® EC EOWE
WI-1 M01
DENR-WATER QUALITY
POINT SOURCE BRANCH
Duke Power requests the subject permit be renewed and reissued. The above referenced permit
expires August 31, 2001. As required by North Carolina Administrative Code (15A NCAC
2H.0105(e)), this permit application for renewal is being submitted at least 180 days prior to
expiration of the current permit.
Please find enclosed in triplicate, the application for renewal, which includes the following items:
• EPA Form 1
• EPA Form 2C - Including Priority Pollutant Analysis
• EPA Form 2E
• Site maps
• Water flow diagram and supplemental information.
Duke Power requests notification that the application is complete.
The following monitoring reductions at outfall #002 are requested based on historical monitoring
data, see attached. The frequencies were determined using the EPA guidelines for
"Performance -Base Reduction of Monitoring Frequencies".
• Deletion of monitoring for oil & grease at outfall #002 and #004. Analytical results for the
last two years have all been below detection.
• Deletion of monitoring for naphthalene, phenol and chromium at outfall #002. Analytical
results for the last two years have all been below detection.
• Reduction of fecal & BOD monitoring from monthly to once/six months.
• Reduction of TSS monitoring from monthly to quarterly.
The Steam Electric Effluent Guidelines (40 CFR 423) restricts iron and copper, during a chemical
metals cleaning, to 1.0 mg/I above background levels. It is requested that the iron and copper
limitation for outfall #002 only apply during a chemical metals cleaning.

- � u' � �. r' �P � � f
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Plant Allen requests a continuation of the 316(a) variance. The on-going studies show the
balanced indigenous aquatic community in the Catawba River is being maintained under the
current limits.
Thank you for your assistance with this permitting request. Should you have questions or need
additional information, please contact Susan Robinson at [phone].
Sincerely,
Michael A Ruhe
Manager, Water Compliance
Attachments
cc w/Attachments: Mr. Rex Gleason, NCDENR, Mooresville, N.C.

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Jan -00
Feb -00
Mar -00
Apr -00
May -00
Jun -00
Jul -00
Aug -00
Sep -00
Oct -00
Nov -00
<1.0
4.0
<10.0
<10.0
<2.0
<2.0
<1.0
36.0
<10.0
<10.0
<0.04
4.0
<2.0
23.0
24.0
<1.0
23.0
<10.0
<10.0
2.0
7.5
<1.0
7.0
<10.0
<10.0
<2.0
3.7
<1.0
10.0
<10.0
<10.0
<0.04
<2.0
4.8
<1.0
5.0
<10.0
<10.0
17.0
<2.0
<1.0
7.0
<10.0
<10.0
<2.0
<2.0
<1.0
8.0
<10.0
<10.0
<0.04
<2.0
26.0
<1.0
<1.0
5.0
<10.0
<10.0
<2.0
<2.3
<1.0
6.0
<10.0
<10.0
<2.0
<2.2
<1.0
5.0
<10.0
<10.0
<0.04
<2.0
<6.7
O&G TSS Phenol Napthtalen Chromium Fecal BOD
Average 0.0 14.1 0.0 0.0 0.0 3.2 2.6

Allen Parameter History December 1998 - November 2000 (Outfall 002)
bate O&G TSS Phenol Napthtalen Chromium Fecal BOD
Dec -98
Jan -99
Feb -99
Mar -99
Apr -99
May -99
Jun -99
Jul -99
Aug -99
Sep -99
Oct -99
Nov -99
Dec -99
<1.0
10.0
<10.0
<10.0
8.0
<2.0
<1.0
25.0
<10.0
<10.0
13.0
<2.0
<1.0
7.0
<10.0
<10.0
<0.04
4.0
13.0
<1.0
8.0
<10.0
<10.0
2.0
<2.0
<1.0
8.0
<10.0
<10.0
2.0
2.0
<1.0
20.0
<10.0
<10.0
<0.04
2.0
<2.0
12.0
20.0
11.0
<1.0
8.0
<10.0
<10.0
2.0
<2.0
<1.0
23.0
<10.0
<10.0
4.0
<2.0
<1.0
20.0
<10.0
<10.0
<0.04
4.0
<2.0
<1.0
13.0
<10.0
<10.0
7.0
<2.0
<1.0
12.0
<10.0
<10.0
2.0
-<2.0
<1.0
26.0
<10.0
<10.0
<0.04
4.0
<2.0
<1.0
23.0
<10.0
<10.0
<2.0
4.4

NPDES Supplemental Information
For
Allen Steam Station
NPDES Permit # NC0004979
February 26, 2001

L E G E N D
0 o a v o PLANT DRAINAGE
DISCHARGE PDIWS
c:\dan\ai-nodes.dan Feb. 08. 2001 10:36:15
aKE
0 20
SCALE 1" = 20'

Plant Allen, Gaston County
NPDES Permit # NC0004979
Page 2 of 12
,General Information
Plant Allen utilizes waters from the Catawba River for condenser cooling and service
water requirements. A brief discussion of each discharge follows. A schematic flow
diagram of water use, treatment, and discharges indicating typical (average) flow rates
for individual waste streams at Plant Allen is attached. All flows are based on historical
data where possible or pump design capacities and normal run-times.
Outfall 001 - Condenser Cooling Water (CCWJ
The CCW system is a once -through, non -contact cooling water system that removes
heat rejected from the condensers and other selected heat, exchangers and then
discharges into the South Fork River. Each of the 5 units at Plant Allen has two
condenser cooling pumps. The number of pumps used is dependent on unit load and
intake temperatures with more pumps running with higher loads and intake
temperatures.
Units 1 and 2 share a common cooling water supply tunnel served by a total of 4 CCW
pumps. Units 3 and 4 also share a tunnel and 4 CCW pumps. Unit 5 has a separate
tunnel and 2 CCW pumps. The common tunnel design enables three pumps to give
Units 1 and 2 or 3 and 4 the equivalent of 1 '/ pump operation. The 1 '/ pumps
operation adds an economical range or flexibility when units are on partial load and
when intake water temperatures are minimal.
Unit No.
1 -Pump GPM
1.5 -Pump GPM
2 -Pump GPM
1
55,500
74,800
83,500
2
55,500
74,800
83,500
3
83,000
111,200
126,000
4
83,000
111,200
126,000
5
83,000
126,000
All condenser tubes at Plant Allen are cleaned manually with metal or rubber plugs.
Mechanical cleaning is required once a year for most units.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 3 of 12
Outfall 002 - Ash Basin
Boiler Cleaning
All five boilers at Plant Allen are chemically cleaned with the next cleaning as
needed. The volume of the boilers determines the quantity of chemicals required for
a cleaning. Boilers #1 and #2 each have a waterside volume of 26,700 gallons.
The volume of boilers #3, #4, and #5 is 40,100 gallons each. The volume of dilute
waste chemical discharged from unit #1 or #2 during a cleaning is 294,000 gallons.
The volume of diluted waste chemicals drained from #3, #4 and #5 totals 450,000
gallons each. These wastes are drained through temporary piping to the permanent
ash removal lines, which flow to the ash basin. Immediately prior to the beginning of
a boiler chemical cleaning procedure, additional stop -logs are added to the ash
basin discharge structure. This assures longer retention time of the chemical
wastes for proper treatment through dilution, neutralization, precipitation, and ion-.
exchange as documented in the Ash Basin Equivalency Demonstration (October
1976).
A list of the chemicals and amounts required to clean the boilers at Plant Allen
follows:
CLEANING CHEMICALS
Sodium bromate
Ammonium carbonate
Ammonium hydroxide*
Hydrochloric acid*
Thiourea*
Citric acid
Sodium Sulfite
Ammonium bifluoride
Detergent (Triton —X)
Antifoam agent
AMOUNT USED PER UNIT
Boiler #1 and #2
550 lbs
1000 lbs
850 gal
3700 gal
1680 lbs
300 lbs
100 lbs
1100 lbs
20 gal
10 gal
Boiler #3, #4 & #5
550 lbs
1000 lbs
950 gal
5500 gal
2010 lbs
400 lbs
100 lbs
1700 lbs
20 gal
10 gal
* During a chemical metals cleaning these chemicals are present in amounts
greater than the reportable quantity as identified under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). If a spill
of any these chemicals were to occur, in most cases, it would be routed to the
ash basin for treatment.
Stormwater run-off #1
The normal rainfall run-off plus ground water seepage from the coal pile area is routed
to the coal yard sump via the coal handling sumps. Perforated pipes beneath the coal

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 4 of 12
pile convey the effluent to the coal handling sumps. The total average flow to the coal
yard sump is calculated to be 0.058 MGD.
Drinking Water
A well supplies the drinking water requirements of Plant Allen. Plant Allen is a non-
transient, non -community drinking water system and it's ID # is 01-36-704 in the state's
drinking water database.
Sanitary Wastes
Sanitary waste at Plant Allen is treated in a septic tank with the effluent from the septic
tank being discharged to the Ash Basin via the Coal Yard sump. Approximately 150
people are responsible for the load on this system. An average flow of 4850 GPD is
treated by the system.
Ash Sluice
Plant Allen utilizes electrostatic precipitators to remove fly ash from its stack gases.
These precipitators require approximately 10.0 MGD for fly ash sluicing to the ash
basin. Bottom ash sluicing to the basin requires approximately 6.0 MGD for a total
average ash removal flow of 16.0 MGD.
Recirculating Water System
Plant Allen has 2 recirculating water systems (RCW): a chiller system and a pump
cooling water system. Both systems use the biocide H-550 or similar products. In
addition, the corrosion inhibitor CS or similar product is used. Generally, these systems
are closed loop, but may need to be drained occasionally. All such water would enter
the floor drains and then be discharged to the ash basin.
Miscellaneous Waste Streams
Turbine Non-destructive Testing:
Approximately once per year, one turbine is tested for cracks in the generator shaft
using an ultrasonic nondestructive test. During the process a maximum of 400 gal
of demineralized water mixed with 4 gal of corrosion inhibitor is used and discharged
to the ash basin.
Heat Exchanger Cleaning:
From time to time, it may be necessary to clean the small heat exchangers with
polyacrylamide, polyacrylate, sodium laurylsulfate and tri -sodium phosphate. All
wastes would be routed to the ash basin.
Condensate Polishers:
Plant Allen utilizes condensate polishers which divert a portion of the normal
condensate (closed system) flow through one of two cells per unit. The polishers
provide filtration as well as ion exchange functions to remove or substantially reduce
dissolved solids and suspended matter present in the condensate stream. The
polishers require precoating with a combination of anion and cation resin. To

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 5 of 12
facilitate precoating, 125-150 mL of a solution of polyacrylic acid (25%) is added to
the precoat slurry. Upon exhaustion, the precoat is removed from the filters by
water / air blasting and flushed to the ash basin via sumps.
'Condensate water is used to remove the exhausted precoat at the rate of:
Unit 1 & 2 - 1558 gal/precoat
Units 3, 4, & 5 - 2090 gal/precoat.
A total average waste flow of approximately 980 GPD to the ash basin is realized.
Condenser Leakage Testing:
Fluorescing Dye Method.
Approximately 1 Ib. of a disodium fluorescing dye added to 280,000 gals of
demineralized water is used occasionally to test the condensers for leakage. All
wastes from the testing would be routed to the ash basin.
Sulfur Hexafluoride Method:
Periodically, sulfur hexafluoride is injected into the condenser tubes to locate
condenser tube leaks. Sulfur hexafluoride is a chemically inert, nonflammable,
nontoxic gas with an extremely low water solubility. It is estimated that 150 grams of
sulfur hexafluoride would be used during the leak detection process.
Most of the sulfur hexafluoride would be volatilized during the process.
Ash Basin Treatment
CO2 Injection System: `
During warmer periods of the year, algae .blooms occur in the ash basin causing --pH
levels -to rise. A CO2 system is utilized during these events to maintain the pH level
below 9.0 standard units.
Acid Injection System:
An acid injection system utilizing 78-80 % sulfuric acid is maintained as back-up to
the CO2 system for pH adjustment
Sodium Hydroxide System:
A sodium hydroxide injection system utilizing 50% sodium hydroxide is maintained
for low pH treatment.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 6 of 12
Yard Drain Sump
The yard drain sump is a large concrete structure that has three level controlled pumps,
which pump wastewater from Plant Allen to the ash basin. These pumps are operated
on a rotating basis. The combined average flow from all sources tied to the yard drain
sump is approximately 4.0 MGD. Below is a description of wastes going to the yard
drain sump:
Storm Water run-off #2
The ash basin accommodates flows from the yard drain sump, coal yard sump, ash
removal lines and rainfall run-off from the basin watershed area. The average
rainfall run-off flows are based on 47 inches of rain per year with 100% run-off from
pond surfaces and 50% run-off from other areas. The average run-off for the ash
basin watershed area is 0.57 MGD. Average run-off to the yard drain sump is,
calculated to be 0.018 MGD.
Oil Storage Run -Off
Plant Allen has an above ground oil storage tank with a capacity of 100,000 gallons,
an above ground 4,500 gallon used oil storage tank and one above ground gas tank
with a 550 gallon capacity. A dike surrounds the 100,000 gallon above ground tank
for the purpose of providing secondary containment. The 4,500 and 550 gallon
tanks have an additional outer tank for secondary containment. Any spills not
contained within dike or outer tank secondary containment will be routed to the ash
basin through the yard sumps. If a spill did occur efforts will be taken to contain and
cleanup the spill.
All storage facilities are presently covered under the Spill Prevention Control and
Countermeasure Plan.
Floor Drains (Units 1-4)
Wastes, which enter the floor drains, accumulate in the boiler room sumps and
turbine room sumps.
Boiler Room Sumps (Units 1-4)
The water which flows to the boiler room sumps originates from such sources as
floor wash water, boiler blowdown, water treatment waste, condensates, equipment
cooling water, sealing water and miscellaneous leakage (refer to the attached
schematic of water flow for individual flows). The effluent from the units 1 through 4
boiler room sumps is flushed to the yard drain sump. The effluent from the unit 5
boiler room sump is flushed to the power house sump, which is then flushed to the
yard drain sump.
Turbine Room Sumps
The turbine room sumps accommodate flows from floor washing, leakage, and
occasional condenser water box drainage. Effluent from units 1 through 5 turbine
room sumps is flushed to the yard drain sump.

Plant Allen, Gaston County
NPDES Permit No.'NC0004979
Page 7 of 12
Water Treatment System
The water treatment wastes consist of sedimentation, filter backwash, reverse
osmosis (RO) concentrate, demineralizer regeneration wastes and boiler blowdown.
The make-up water treatment system is compromised of a clarifier, two pressure
filters, two activated carbon filters, two garnet filters, a reverse osmosis machine and
one set of demineralizers. Make-up water is used in the boilers and closed cooling
systems.
Clarifier:
The clarifier has an average production of 0.252 MGD. Alum and caustic are
used to affect precipitation and thus remove suspended solids from the raw river
water. Desludging of the clarifier takes place approximately 8% of the unit run-
time with an average volume of 2300 GPD going to the ash basin.
Pressure Filters: F,
There are two pressure filters which follow the clarifier in the water treatment
process. These filters are backwashed once per week with a waste flow of
11,000 gallons per backwash. Each pressure vessel will contain 84 ft3, of
anthracite, 50 ft3 of quartz, 25 ft3 of garnet and 41 ft3 of garnet/quartz support
media. Each vessel will use product water to backwash at a rate of 750 gpm.
On average, both vessels will backwash once per week. The contents,ofthe
pressure filters will be changed out, as internal maintenance requires,, and the
used filter medium will be disposed of in the ash basin.
Activated Carbon Filters:
In addition to the pressure filters, there are two activated carbon filters. These
filters are backwashed twice per month. Approximately 30,000 gallons of water
are required to backwash each of these filters. The activated carbon filters are
composed of approximately 250 ft3 of granular activated carbon (coal). The
spent filter medium is changed out yearly and is disposed of in the ash basin.
RO Prefilters:
There are 2 RO prefilter vessels containing garnet, which are used to filter
suspended solids. Both filters are backwashed once per week
with the backwashed material routed to the ash basin. Total waste for both
filters is 4500 gallons per week.
RO Unit:
A RO unit is used to decrease the conductivity in the filtered water, thereby
increasing the efficiency of the demineralizers and reducing the amount of
chemical needed for demineralizer regeneration. During operation, the unit has
a continual blowdown of 60 gal/min, which is discharged, to the ash basin. The
RO unit is cleaned on a quarterly basis with the waste going to the yard drains
and eventually the ash basin. During a cleaning, approximately 30 lbs of the
cleaner OSMO AD -20 (containing sulfamic acid) along with 5 gallons of biocide,
40 lbs of trisodium phosphate and 0.5 gallons of sodium lauryl sulfate is used.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 8 of 12
Demineralizer:
The demineralizer consists of two mixed -bed cells. Only one of these cells is
operated at any one time. The cell which is in operation is regenerated
approximately once every 7- 14 days of operation. A regeneration requires 42
gallons of sulfuric acid (78-80%) and 150 gallons of 50% sodium hydroxide. An
average dilute waste chemical and rinse flow of 20,000 gal is realized. The
dilute acid and caustic are discharged to the floor drains simultaneously through
the same header for neutralization purposes. All regeneration wastes are
flushed to the ash basin. The demineralizer resin is changed out approximately
once every 10 years with the spent resin going to the ash basin. Approximately
1 mL of the surfactant Triton CF -54 or similar product is added to the new resin
to improve separation.
Boiler Blowdown:
Each of the five boilers at Plant Allen blowdown at an average rate of
approximately 500 lbs. of steam per hour. The blowdown is allowed to flash in a
blowdown tank. Most of the blowdown is vented to the atmosphere with a
minimal amount of condensate discharged to the boiler room sump. The
average condensate flow to this sump is 0.004 MGD. Hydrazine is maintained at
a concentration of 25 ppb in the condensate system for deoxygenation. A
minute amount of hydrazine (<10 ppb) may be present in the condensate flow to
the boiler room sump.
Preheater Washes
Preheaters are backwashed with raw water approximately 2 times per year to
remove ash and corrosion products. There are 12 preheaters at Allen that would
require approximately 100,000 gallons of backwash water each.. The backwash
water is routed to the ash basin through the yard drain sump.
Laboratory Wastes
The chemistry lab on site performs a variety of water analyses and routine sample
collections. Therefore several chemicals are used in the lab in small quantities for
sample preservation, bottle rinsing, equipment calibration, conductivity analyses,
etc. The wastes are flushed down the sink and discharged into the yard drain sump
and then pumped to the ash basin. Some of the laboratory chemicals are as
follows: Ammonia molybdate, Acetic acid, Ferric sulfate, Hydrochloric acid,
Monoethylamine, Nitric acid and Potassium hydroxide.
Power House Sump (Unit 5) ,
The wastes, which enter the floor drains at Plant Allen, accumulate in the boiler
room sumps and turbine room sumps. The water which flows to the boiler room
sumps originates from such sources as floor wash water, boiler blowdown, water
treatment waste, condensates, equipment cooling water, sealing water and
miscellaneous leakage. Effluent from the unit 5 boiler room sump is flushed to the
power house sump, which is then flushed to the yard drain sump. This sump also
collects stormwater from various drains located on the north end of the powerhouse.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 9 of 12
Outfall 002A — Coal Yard Sump Overflow
An overflow pipe that directs flow from the sump to the Catawba River was included in
the construction of the yard sumps. This was done to prevent submergence and
damage of the pump motors within the sumps in the event that all pumps failed or
redundant power supply lines could not be restored in a timely manner. This has
occurred approximately one time in the past 5 years. Observations and monitoring of
effluent during events have indicated no impact to water quality.
Outfall 002B — Power House Sump Overflow
An overflow pipe that directs flow from the sump to the ground was included in the
construction of the yard sumps. This was done to prevent submergence and damage
of the pump motors within the sumps in the event that all pumps failed or redundant
power supply lines could not be restored in a timely manner. If enough water overflows,
the waste could potentially get to the Catawba River. This has occurred approximately
twice in the past 5 years. Observations and monitoring of effluent during events have
indicated no noticeable impact to water quality.
Outfall 003 — Misc Equipment Cooling & Seal Water
Outfall 003 discharges into the CCW discharge canal. The discharge consists of
cooling water from units 4 and 5 boiler feedpump hydraulic coupling coolers and other
miscellaneous equipment cooling. This water is once -through, non -contact cooling
water withdrawn from the service water system.
Outfall 004 Equip. Cooling & Intake Screen Backwash
Equipment Cooling Water
Cooling water for units 1,2 & 3 boiler feed pump hydraulic coupling coolers and other
miscellaneous equipment is discharged through outfall 004. This water is once -
through, non -contact water drawn from the service water system. In addition, water
from a vehicle rinse -down area is directed to this outfall. The rinse water contains no
soaps or other additives.
Intake Screen Backwash
The intake screens at Plant Allen are flushed on an "as needed" basis. Backwash
usually averages 2 hours per shift. The average volume required is 0.053 MGD. The
large debris floating on the river is caught on the parallel bar screens. This trash is
collected and disposed of in a landfill. The silt, twigs, leaves and other light debris
collected on the rotating screens are indigenous to the river and are therefore flushed
back with no harmful environmental consequences.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 10 of 12
Outfall 005 — Asiatic Clam/Debris Filter Backwash
Water for the Unit 5 CCW water is filtered for any twigs, leaves and other light debris
which passed through the intake screens. Asiatic clams, which are common in Lake
Wylie and can clog the condenser tubes, are also captured in this filter. This filter is
backwashed once a week for 15 minutes. A maximum flow of 3000 GPD is realized.
No other additives are in the backwash water. The twigs, leaves, clams and other light
debris collected in the debris filter are indigenous to the river and are therefore flushed
back with no harmful environmental consequences.
Storm Water General Description
As previously discussed much of the storm water runoff is directed to the ash basin
(outfall 002). There are several other storm water outfalls at Plant Allen. These drains
either discharge into the Catawba River or into the South Fork River via the outfall 001
discharge canal. Plant Allen was included in the storm water group application
submittal (March 1991) to the Environmental Protection Agency for several Duke Power
Company locations.
Plant Allen 316(a) Determination
Duke Power Company's 316(a) demonstration (March 1976) concluded that the "heated
discharge from Plant Allen is such that the protection and propagation of a balanced
indigenous aquatic community in and on Lake Wylie is assured."
Duke's operation experience during the past five years under the thermal limitations
imposed in NPDES Permit No. NC0004979 substantiates the above conclusion and
further supports Duke's belief that the operating characteristics of the station have a
minimal effect of the aquatic environment of Lake Wylie. Surveys of the aquatic
community in Lake Wylie demonstrate that a Balanced Indigenous Population exists in
Lake Wylie. Accordingly, Duke requests a 316(a) variance and further requests that
the thermal limitations imposed in the permit be continued.

Plant Allen, Gaston County
NPDES Permit No. NC0004979
Page 11 of 12
Hazardous and Toxic Substances
Hazardous and Toxic Substances Table 2c- 3
At Plant Allen, the potential for toxic and hazardous substances being discharged is
very low. In reference to Item V -D of Form 2-C, the substances identified under Table
2c-3 that may be in the discharge are as follows: Acetaldehyde, Aniline, Asbestos,
Butyl Acetate, Cresol, Cyclohexane, Formaldehyde, Monoethylamine, Naphthenic Acid,
Propylene Oxide, Pyrethrins, Styrene, Triethanolamine, Vanadium, Vinyl Acetate,
Xylene and Zirconium.
Other - During the course of the year products such as commercial cleaners and
laboratory reagents may be purchased which contain very low levels of a substance
found in Table 2c-3. It is not anticipated that these products will impact the ash basin's
capacity to comply with its toxicity limits, since their concentrations are extremely low.
40 CFR 117 and CERCLA Hazardous Substances
The following table identifies hazardous substances located on-site that may be
released to the ash basin during a spill in quantities equal to or greater than the
reportable quantity (RQ) levels as referenced in 40 CFR 117, 302 and 355. This list is
being provided in order to qualify for the spill reportability exemption provided under 40
CFR 117 and the Comprehensive Environmental Response Compensation and Liability
Act (CERCLA). These values below represent the maximum quantities on-site that
could be released at one time and sent to the ash basin. They do not reflect quantities
that are discharged through typical use.
SUBSTANCE
Ammonia (aqueous)
Benzene
Hydrazine
Sodium Hydroxide
Sodium Nitrite
Sulfuric Acid
QUANTITY (Ibs.)
SOURCE
9452
Storage Tank
166
Gas Storage Tank
944
Warehouse/Third
floor of Powerhouse
15,566
Warehouse
2034
Warehouse and/or
Mezzanine Floor
30724
Warehouse

Catawba 550 .0
River/—MGD
Plant Allen Water Schematic
Ash Sluice
Atm
I IF
Water Boiler Turbine Rm
Treatment k---O.F
Sumps
Boiler Rm
Sumps
Intake screen
Backwash
AsiaticClam/ Debris
Filter
Backwash
Powerhouse Sump
Misc Equip
Cooling & Seals
Plant Allen, Gaston County
NPDES Permit # NCO004979
Page 12 of 12
South Fork
10 River
r---------------- Outfall 002A -------------- loo- Catawba
i River
i
Coal Yard ��Sto�rmwater�#1
Sump
Ash Basin- Outfall 002 Catawba
20.05 MGD* River

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
May 15, 2000
Ms. Angela M. Grooms, Manager
Water Protection
Duke Power
Group Environment, Health & Safety
13339 Hagers Ferry Road
Huntersville, North Carolina 28078-7929
• �
A4
&v=1k ���
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Modification
Dan River — Permit No. NC0003468
Allen — Permit No.;NC0004979 �,
Marshall — Permit No. NC0004987
Riverbend — Permit No. NC0004961
Dear Nis. Grooms:
The Division issued NPDES permit numbers NC0003468. NC0004979, NC0004987, and
NC0004961 on April 25, 1997. September 4, 1996, August 31. 1995, and July 29, 1996 respectively. The
Division has reviewed your request for permit modification at the subject facilities. Specifically, you requested
that all sump overflows as outlined in your December 1, 1999 correspondence be permitted as individual
outfalls. In accordance with your permit modification request the Division is forwarding herewith
modifications to the subject permits. These permit modifications incorporate effluent sampling requirements
for sump overflows in accordance with the permitting strategy developed for Buck Steam Station.
Enclosed please find the modified NPDES permit pages. These pages should be inserted into the
respective permits and the old ones discarded. These permit modifications are issued pursuant to the
requirements of North Carolina General Statute 145-215.1 and the Memorandum of Agreement between
North Carolina and the U. S. Environmental Protection Agency dated December 6. 1983.
Please take notice that these permits are not transferable. Part 11, E.4. addresses the requirements
to be followed in case of change in ownership or control of this discharge. These permits do not affect the
legal requirement 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
government permit that may be required.
1617 MAIL SERVICE CENTER. RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - $O% RECYCLED/ 10% POST -CONSUMER PAPER

If you have any questions concerning these modifications, please contact Mr. Mark McIntire at
telephone number [phone], extension 555.
Sincerely
7d'
/l err T. Stevens
Enclosures: modified permit pages
Cc: Central Files (correspondence, letter, modified permit pages)
NPDES Permit File<y(correspondence, letter, modified permit pages)
Mooresville Regional Office (letter, modified permit pages)
Winston-Salem Regional Office (letter, modified permit pages)
Point Source Compliance/Enforcement Unit (letter)

m

A. NCDENR/DIVISION OF WATER QUALITY
Water Quality Section/NPDES Unit
October 9, 1998
MEMORANDUM
To: Dave Goodrich
From: Mark McIntire
Subject: Sump Overflows
Duke Power Fossil Plants
I have been in discussions for quite some time with John Mease and Angela Grooms of Duke Power Company regarding
sump overflow issues_ NPDES permits for Allen, Buck, Dan River, Marshall, and Riverbend steam stations do not
currently accommodate these overflows. Our discussions have been aimed at finding a practical, protective way of
handling these situations.
Earlier in the year. I instructed Duke Power to grab a series of eight samples from the sump at Buck Steam Station
over a two week period (these sumps are those that deliver wastewater to the ash basins). Duke collected the samples
and subsequently forwarded the results, attached, to our office on March 27, 1998. The data is indicative of an ash
basin discharge with the exception of relatively high solids and iron. Incidents of high iron and TSS were likely due to
heavy rains agitating sediment prior to raw water intake.
These sump overflows occur in small volumes and on rare occasions. In light of the very high stream flows associated
with the streams into which Duke discharges, the impact from these sump overflows is very likely minimal to zero. As
such, I recommend permitting these sump overflows as a serial numbered outfall with appropriate monitoring installed
typical of that required at ash basin discharges. Furthermore, as these sump overflows are relatively consistent from
facility to facility, I do not think it's necessary to require characterization of the other four facilities_ Attached is a
letter to Duke Power to that affect. As this proposition would involve the permitting of -an additional outfall, we would
likely need to proceed with the major modification route_ In addition to monitoring for these overflows, I propose that
we require Duke Power to make every reasonable attempt to minimize the occurrence of these overflows. We should
also require Duke to make every reasonable attempt to redirect these overflows to the respective ash basins.

ff

Re: Duke Power Sump,Overflow...
U
Subject: Re: Duke Power Sump Overflow...
Date: Mon, 01 May 2000 13:46:41 -0400
From: Larry Coble <[e-mail]>
Organization: NC DENR Water Quality
To: Mark McIntire <[e-mail]>
This sounds fine to the WSRO.
Mark Mcintire wrote:
Gentlemen,
You may remember corresponding with me about sump overflows at Duke
Power fossil plants. Working with Duke Power at Buck Steam Station, we
developed a strategy for permitting the yard sump overflows they were
experiencing. These overflows occur very rarely (perhaps once per year)
and typically involve de minimus flows. However, given the current
legal and third part climate, Duke would like to have these overflows
permitted at Allen, Dan River, Riverbend, and Marshall as well.
As a refresher, we required episodic sampling for pH, TSS, fecal
coliform, and iron. Episodic being defined as any overflow lasting
longer than 1 hour. All overflows will be reported to regional office
staff within the required timeframe. Iron will be analyzed if the TSS
sample is reported as greater than or equal to 100 mg/L. Fecal coliform
will only be required for those yard sumps receiving sanitary
wastewater.
The ultimate goal is to eliminate all overflows completely. Until that
time, permitting these as outfalls with analytical requirements provides
Duke with a level of comfort in the context of third party litigation
and the Division's new overflow policy.
Let me know if you have concerns regarding this matter. My plan is to
handle these as minor modifications to the fossil plant permits
referenced above.
Thanks for your assistance.
Mark
Mark D. McIntire
Environmental Engineer
NPDES Unit - Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
[phone], extension 553
mailto:[e-mail]
wd-
t �f '7 nsrnQi*?nnn In -;n e n

Duke
Power,
A Duke En gy Company
December 1, 1999
Mr. David A. Goodrich
NCDENR/NPDES Unit
Water Quality Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Permitting Sump Overflow Pipes
Plant Allen Permit No. NC0004979
Dan River Steam Station Permit No. NC0003468
Marshall Steam Station Permit No. NCO004987
Riverbend Steam Station Permit No. NC0004961
Record #: NC -005157
Certified: Z 335 554 746
Dear Mr. Goodrich:
Duke Power
Group Environment, Health 6 Safety
13339 Hagers Ferry Road
Huntersville, NC 28078-7929
Duke Power requests that the overflow pipes for the yard sumps listed below be
permitted in the same manner as detailed in the draft NPDES permit (NC0004774) for
Buck Steam Station Outfall #002A. That outfall page is attached. Plant Allen's coal yard
sump and Riverbend Steam Station's yard sump are the only sumps containing sanitary
waste. Duke Power requests that only these two sumps be required to monitor for fecal.
Station
Sump
New Outfall Number
Allen
Coal yard
#002A
Power House
#0028
Dan River
Yard
#002A
Marshall
Sump 1
#002A
Sump 2
#0026
Riverbend
Yard
#002A
See the attached site maps for location of the sump overflow discharges. Should you
have questions or need additional information, please contact John Mease at (704) 875-
5347.
Sincerely,
i
Angela M. Grooms
Manager, Water Protection
j rm
cc: Mr. Rex Gleason, NCDENR, Mooresville, N.C.
Mr. Larry Coble, NCDENR, Winston-Salem, N.C. 00,) a

w

SUPPLEMENT TO PERMIT COVER SHEET
Duke Power Company
is hereby authorized to:
Permit No. NC0004979
Continue to discharge once -through, non -contact cooling water (outfall 001),
operate a septic tank/sand filter and ash pond with pH adjustment (outfall 002),
discharge coal yard sump overflows (outfall 002A), discharge power house sump
overflows (outfall 002B), discharge miscellaneous non -contact cooling waters
(outfall 003) and discharge miscellaneous non -contact cooling water, vehicle
washwater, intake screen and filter backwash (outfall 004) from a facility located
at Plant Allen, NCSR 2525, South of Belmont in Gaston County (See Part III of
this Permit), and
2. After receiving an Authorization to Construct from the Division of Water Quality,
construct and operate a groundwater remediation system discharging into the ash
pond (outfall 002), and
3. Discharge from said treatment works at the location specified on the attached map
into the Catawba River (outfalls 002, 002A, 002B, and 004) and the South Fork
Catawba River (outfalls 001 and 003) which are classified Class WS -IV & B CA
and WS -V waters, respectively, in the Catawba River Basin.

A (3). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL Permit No. NC0004979
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 002A
— Coal Yard Sump Overflows. Such discharges shall be limited and monitored by the Permittee as specified below: -
EFF°L' UENT .CHARACTERISTICS
;`' e aIS:CHARGE L=IMITATIONS '°;'
MO:NITQRING :RE.QUIRENIENTS
IVlontltl'y. Average, ,. "Dally: aximum
Me,asu.rement Sample
Frequency' : Sample Type Location s
Flow (MGD)
Episodic Estimate E
pH
Episodic Grab E
Total Suspended Solids
Episodic Grab E
Fecal Coliform
Episodic Grab E
Iron
See Footnote 2 Grab E
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
ALL FLOWS WILL BE REPORTED ON MONTHLY DMRS. SHOULD NO FLOW OCCUR DURING A GIVEN MONTH-, THE WORDS "NO FLOW" SHOULD BE CLEARLY WRITTEN ON THE FRONT OF THE DMR:
EPISODIC SAMPLING 15 REQUIRED PER OCCURRENCE WHEN SUMP OVERFLOWS OCCUR FOR LONGER THAN ONE HOUR. ALL SAMPLES SHALL BE OF A REPRESENTATIVE -DISCHARGE.
NOTES:
I Sample Locations: E — Effluent; Effluent sampling shall be conducted at a point upstream of discharge to the receiving stream.
2 Sampling for iron is required when TSS is reported as greater than 100 mg/L.

A (4). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL Permit No. NC0004979 -
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfalls) serial number 002A
— Power House Sump Overflows. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT, CHARACTERISTICS.
_.
DISCHARGE LIIVIITATI;ONS,
1VMONITORING REQUIREMENTS
1Vlorithly-Average Datly,Maximum.
Meastirernent Sample
:. ,°Fre,Quency Sanlgle Type Locationl
Flow (MGD)
Episodic Estimate E
pH
Episodic Grab E
Total Suspended Solids
Episodic Grab E
Fecal Coliform
Episodic Grab E
Iron
See Footnote 2 Grab E
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
ALL FLOWS WILL BE REPORTED ON MONTHLY DMRS. SHOULD NO FLOW OCCUR DURING A GIVEN MONTH, THE WORDS "NO FLOW" SHOULD BE CLEARLY WRITTEN ON THE FRONT OF THE MIR.
EPISODIC SAMPLING IS REQUIRED PER OCCURRENCE WHEN SUMP OVERFLOWS OCCUR FOR LONGER THAN ONE HOUR. ALL SAMPLES SHALL BE OF A REPRESENTATIVE DISCHARGE.
NOTES:
I Sample Locations; E — Effluent; Effluent sampling shall be conducted at a point upstream of discharge to the receiving stream.
2 Sampling for iron is required when TSS is reported as greater than 100 mg/L.

A. (5). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Permit No. NC0004979
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge
from outfall(s) serial number 003. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Lbs/day Units (specify) Measurement Sample Samplel
Mon. Avg. Daily Max. Mon. Ave. Daily Max. Frequency Tvpe Location
Flow Weekly Estimate E
Notes:
I Sample Locations: E - Effluent
Chlorination of the once through cooling water, discharged through outfall 003, is not allowed under this permit. Should Duke Power wish to
chlorinate its once through cooling water, a permit modification must be requested and received prior to commencing chlorination.

A. (6). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Permit No. NC0004979
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge
from outfall(s) serial number 004. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Lbs/day Units (specify) Measurement Sample Samplel
Mon. Ave. Daily Max. Mon. Avg. Daily Max. Frequency Type Location
Flow Weekly Estimate E
Oil and Grease 15.0 m /l 20.0 m /l 2/Month Grab E
Notes:
1 Sample Locations: E - Effluent
Chlorination of the once through cooling water, discharged through outfall 004, is not allowed under this permit. Should Duke Power wish to
chlorinate its once through cooling water, a permit modification must be requested and received prior to commencing chlorination.

ow...
Subject: Re: Duke Power Sump Overflow...
Date: Mon, 01 May 2000 13:46:41 -0400
lk From: Larry Coble <[e-mail]>
anization: NC DENR Water Quality
To: Mark Mcintire <[e-mail]>
This sounds fine to the WSRO.
Mark Mcintire wrote:
Gentlemen,
You may remember corresponding with me about sump overflows at Duke
Power fossil plants. Working with Duke Power at Buck Steam Station, we
developed a strategy for permitting the yard sump overflows they were
experiencing. These overflows occur very rarely (perhaps once per year)
and typically involve de minimus flows. However, given the current
legal and third part climate, Duke would like to have these overflows
permitted at Allen, Dan River, Riverbend, and Marshall as well.
As a refresher, we required episodic sampling for pH, TSS, fecal
coliform, and iron. Episodic being defined as any overflow lasting
longer than 1 hour. All overflows will be reported to regional office
staff within the required timeframe. Iron will be analyzed if the TSS
sample is reported as greater than or equal to 100 mg/L. Fecal coliform
will only be required for those yard sumps receiving sanitary
wastewater.
The ultimate goal is to eliminate all overflows completely. Until that
time, permitting these as outfalls with analytical requirements provides
Duke with a level of comfort in the context of third party litigation
and the Division's new overflow policy.
Let me know if you have concerns regarding this matter. My plan is to
handle these as minor modifications to the fossil plant permits
,referenced above.
Thanks for your assistance. A4 f GtJa j ltoL
Mark �lNo 1, C.a�_ ► tA
l
Mark D. McIntire
Environmental Engineer
NPDES Unit - Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
[phone], extension 553
maiIto:[e-mail]

NCDENR/DIVISION OF WATER QUALITY
Water Quality Section/NPDES Unit
e Goodrich
k McIntire
Subiect: Sump 'Overflows
Duke Power Fossil Plants
October 9, 1998
I have been in discussions for quite some time with John Mease and Angela Grooms of Duke Power Company regarding
sump overflow issues. NPDES permits for Allen, Buck, Dan River, Marshall, and Riverbend steam stations do not
currently accommodate these overflows. Our discussions have been aimed at finding a practical, protective way of
handling these situations.
Earlier in the year. I instructed Duke Power to grab a series of eight samples from the sump at Buck Steam Station
over a two week period (these sumps are those that deliver wastewater to the ash basins). Duke collected the samples
and subsequently forwarded the results, attached, to our office on March 27, 1998. The data is indicative of an ash
basin discharge with the exception of relatively high solids and iron. Incidents of high iron and TSS were likely due to
heavy rains agitating sediment prior to raw water intake_
These sump overflows occur in small volumes and on rare occasions. In light of the very high stream flows associated
with the streams into which Duke discharges, the impact from these sump overflows is very likely minimal to zero. As
such, I recommend permitting these sump overflows as a serial nuinhered outfall with appropriate monitoring installed
typical of that required at ash basin discharges. Furthermore, as these sump overflows are relatively consistent from
facility to facility, I do not think it's necessary to require characterization of the other four facilities. Attached is a
letter to Duke Power to that affect. As this proposition would involve ,the permitting of -an additional outfall, we would
likely need to proceed with the major modification route_ In addition to monitoring for these overflows, I propose that
we require Duke Power to make every reasonable attempt to minimize the occurrence of these. overflows. We should
also require Duke to make every reasonable attempt to redirect these overflows to the respective ash basins_
Iv V
In
\IV

Page Four
3. Treatment plant classification: Class I for outfall 002. Outfalls 001, 003 and 004 do not
meet the minimum criteria for a class I rating.
4. SIC Code(s): 4911 Wastewater Code(s): 68,66 MTU Code(s): 50002
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? No
2. Special monitoring or limitations (including toxicity) requests:
a. Permittee has requested that monitoring for oil and grease (O/G) be deleted at
outfalls 002 & 004. Rationale: analytical results for the past two (2) years have all
been below detection. MRO staff can support a reduction in the monitoring
frequency, however, the potential exists for O/G to enter this waste stream, therefore,
complete removal of this parameter is not recommended. Defer to the NPDES Unit
for review and comment.
b. Permittee has requested the deletion of monitoring for naphthalene, phenol, and
chromium at outfall 002. Rationale: analytical results for the past two (2) years have
all been below detection. Upon review of the analytical testing for these parameters,
MRO staff can support the removal of all three (3) parameters, pending concurrence
by the NPDES Unit.
C. Permittee requests the reduction of fecal coliform & BODS monitoring from monthly
to semi-annually, and TSS monitoring from monthly to quarterly. Rational: none
given. Concurrence with the reduction in monitoring for fecal coliform and BODS is
recommended based on a review of available analytical data. A reduction in the
monitoring frequency for TSS is not recommended at this time.
d. Permittee requests that the iron and copper limitation in the permit be restricted to
periods only when chemical metal cleaning is occurring. Rationale: 40 CFR 423
(Steam Electric Guidelines) restricts iron and copper during a chemical metals
cleaning to 1.0 mg/1 above background levels. Defer to the NPDES Unit for review
and comment.
3. Important SOC/JOC or Compliance Schedule dates: N/A
4. Alternative Analysis Evaluation: There are no practicable alternatives for the elimination of
any of the existing waste streams.

Page Five
PART IV - EVALUATION AND RECOMMENDATIONS
The permittee is requesting renewal of the subject permit. There have been no changes to
the facility and/or the permit since the last renewal. Changes requested by Duke for this renewal are
discussed in Part III, No. 2 above.
Pending review and approval of the WLA and review and approval by P & E, it is
recommended that the Permit be renewed as requested.
Signature of Report Preparer Date
,U, � -/ el-%�--� S'/0/0 /
Water Quality Re nal Supervisor Date
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