NC0038377_Email_20050418

Re Progress Energy permit NCO038377
s
Subject: Re: Progress Energy permit NC0038377
From: Mark McIntire <[e-mail]>
Date: Mon, 18 Apr 2005 11:32:41 -0400
To: Ken Schuster <[e-mail]>
CC: Teresa Rodriguez <[e-mail]>
ken,
i'll ask teresa to look into this and get back to you.
thanks,
mark
Ken Schuster wrote:
Mark,we've recently conducted the site portion of our inspection of the subject Mayo steam
electric generating facility and have a few related questions. The permit limits for Outfall 001
(cooling tower system) include limits for total chromium and total zinc, with a footnote that says the
limitatations and monitoring requirements for the 126 priority pollutants (per 40CFR Part 423,
Appendix A, exclusive of zinc and chromium) apply only if these substances are added by the
permittee for cooiing tower maintenance. The prior Mayo permit did not have the "exclusive of zinc
and chromium" m the permit.
In looking at at Progress Roxboro Steam Electric permit (NC0003425) for Outfall 005 (cooling
tower blowdown to the ash pond), it is worded a little differently. The applicable footnote clearly
states that the limitations apply only for cooling tower maintenance. Further, that there shall be no
detectable amounts of the 126 priority pollutants contained in chemicals added for cooling tower
except for total chromium and total zinc.
It appears that the Roxboro Station permit clearly says they don't have to sample other than when
they are doing cooling tower maintenance. And, if they do sample they are allowed to show
detectable levels of only zinc and chromium. Whereas, they cannot have detects for any of the other
126 priority pollutants. The Mayo permit is worded a little different, but I assume the intent was the
same as the footnote in the Roxboro permit? In the 2006 renewal for NC0038377 would it be worth
ammending the footnote language?
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