NC0038377_Permit Renewal and Supporting Documents_20000623

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
BIII Holman, Secretary
Kerr T. Stevens, Director
✓ � �CUt"01`S
June 23, 2000
Mr Roosevelt Childress, Chief
Surface Water Permits Section
Water Management Division
U S Environmental Protection Agency, Region IV
Atlanta Federal Center
100 Alabama Street S W
Atlanta, Georgia 30303-3104
Dear Mr Childress
0� IL
�
NCDENR
Subject NPDES Permit No NCO038377
Carolina Power and Light
Mayo Steam Electric Power Plant
The Division of Water Quality (Division) sent the subject draft permit to public notice on 07/21/97 By
letter dated 09/18/97, EPA Region IV raised several objections which they indicated must be corrected
prior to permit reissuance Since that time, this permit has remained on our backlog The intent of this
letter is to respond to the EPA objections, and ultimately reissue the permit and reduce the backlog
EPA CORE OBJECTION
The CP&L Mayo Steam Electric Power Plant is subject to EPA Steam Electric Effluent Guidelines per 40
CFR 423 The core issue raised by EPA pertains to whether the CP&L Mayo plant should be regulated
by the 1974 Standards of Performance for New Sources (1974 SPNS, now NSPS), or be regulated to
reflect the requirements of the subsequent 1982 regulations EPA contends that since the plant was in
construction prior to the 1982 NSPS (with commercial operation beginning in March 1983), the 1974
SPNS should still apply EPA is therefore objecting to the subject draft permit which is based on the
1982 regulations
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
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ti
Pe=t No. NC0038377
` CP&L- Mayo Steam
Page 2
Response The Division believes that the current draft permit is consistent with applicable regulations for
the following reasons•
• When 40 CFR 423 was promulgated in 1982, the preamble stated that the 1982 regulations contain
both the 1974 and the 1977 limitations that EPA did not change, and the revised limitations that are
the subject of the 1982 regulations [47 FR 52292, 11/19/821 Consequently, the 1982 regulations
reflect a consolidation of both the 1974 and 1982 regulations and any NPDES permits written must
conform to the 1982 promulgated regulations
• 40 CFR 125 3 (c)(1) states that technology-based effluent limitations are not applicable to the extent
that they have been remanded or withdrawn The preamble to the 1982 regulations states that the
1974 SPNS for Bottom Ash transport water and the segregated boiler blowdown source were
withdrawn Consequently, with the promulgation of the 1982 regulations, the 1974 SPNS lost their
legal applicability within the 40 CFR 423 regulations and the NPDES program in general
• Although the EPA has cited several Headquarter's policy memos in support of their position, their
regulatory argument, as required by 40 CFR 123 44, is primarily based on EPA's anti -backsliding
regulations However, anti -backsliding is not relevant to this situation The anti -backsliding
regulations at 40 CFR 12244(l) prohibit (with exceptions) a reissued permit from having effluent
limitations that are less stringent than those in the previous permit However, in this case no
relaxation of the effluent limitations in the previous permit is being proposed. The subject draft
permit contains essentially the same limitations as the previous permit that was effective 02/01/96
The limitations in the previous permit were appropriately based on the 1982 revisions to the Steam
Electric Guidelines Additionally, the two modified versions of the permit (September 1985 and
January 1986) that immediately preceded the 1996 permit were also appropriately based on the 1982
revisions to the Steam Electric Guidelines.

t Permit No NCO038377
CP&L- Mayo Steam
Page 3
EPA SPECIFIC OBJECTIONS
The EPA submitted six specific objections to the draft permit, which are presented below along with the
Division's responses
EPA Comment #1 Mass limitations are required in the permit by the 1974 SPNS We recommend that
flow -weighted concentration limitations consistent with the "Guidance for NPDES Permits Issued to
Steam Electric Power Plants" signed by Ms Rebecca Hammer on 08/22/85 be included in the permit also.
Response As stated previously, it is the Division's belief that the exclusive 1974 SPNS requirements are
no longer the regulations of record as they were superseded by the 1982 regulations The preamble to the
1982 regulations states that the 1982 regulation[s] "allows the permitting authority to establish either
concentration or mass limits for any effluent limitation or standard, based on the concentrations specified
in the regulations " [47 FR 52293] Also, EPA agrees that "the use of mass based limits in all
circumstances is undesirable" [47 FR 52300] Accordingly the Division has exercised their option of
writing the subject draft permit with concentration based limitations because with concentration based
lirrutations the pollutants must be controlled at any discharge flow
Comment #2 Reduction in limitations to include bottom ash recycle under 1974 SPNS (if applicable)
The limitations developed for the bottom ash component of the discharge (OSN 002) should be divided
by a factor of 20
Response The 1974 SPNS are not applicable The 1974 SPNS recycle requirement for 20 cycles of
bottom ash sluice water was specifically withdrawn as stated in the preamble to the 1982 regulations [47
FR 522961 Therefore, according to 40 CFR 125 3 (c)(1) if a technology based lirrutation has been
withdrawn, it is no longer applicable The reasdning provided for the EPA initiated withdrawal was, in
part, that "a recycle system for bottom ash is substantially more expensive than other bottom ash
handling systems" and "the `reasonableness' of [a 20X recycle system] using the cost tests for
conventional pollutants did not pass the BCT test " [45 FR 68328, 68338-9].

Permit No NCO038377
CP&L- Mayo Steam
Page 4
Comment #3 Discharge of pollutants in cooling tower blowdown is limited by both the 1974 SPNS and
1982 BAT standards Accordingly, the discharge of corrosion inhibitors and the 126 priority pollutants
(including chromium, zinc, and phosphorus) in detectable amounts are prohibited
Response. As previously explained, the 1982 regulations reflect a consolidation of both the 1974 and
1982 regulations Therefore the 1982 regulations are the current regulations of use Additionally, the
preamble to the 1982 regulations states that the final BAT and NSPS lirruts for cooling tower blowdown
allow for the discharge of chromium and zinc (based upon concentrations of 0 2 mg/l and 10 mg/1,
respectively), and the limit for phosphorus is deleted [47 FR 52295]
Comment #4 Mass (and concentration) limitations attributable to coal pile runoff and cooling tower
blowdown, and other sources of dilution flow must be incorporated into the ash pond limitations (See
Aug 22, 1985 Hammer Guidance)
Response As indicated in the response to Comment #1, flexibility exists for mass or concentration
limits In regard to other sources of dilution flow, the proposed permit can be reevaluated in this light
Comment #5 'Boiler Blowdown" is a separate category from low volume wastes under 1974 SPNS
Response The 1974 SPNS are not applicable The 1974 SPNS for boiler blowdown were specifically
withdrawn as stated in the preamble to the 1982 regulations [47 FR 522971 According to 40 CFR 125 3
(c)(1) if a technology based limitation has been withdrawn, it is no longer applicable
Comment #6 Both chemical and non -chemical metal cleaning wastes are subject to performance
standards for metal cleaning wastes Although these wastes are not indicated in the application, they are
generally present at steam electric power plants, unless disposed of in an offsite (sic)
Response- Chemical metal cleaning wastes are currently incinerated The Division will reexamine non -
chemical metal cleaning wastes.
OTHER CONSIDERATIONS
Environmental
The viewpoint of James R Patrick Jr, previous Chief, EPA Permits Section, was that "the environmental
benefits of the 1974 NSPS over the 1982 NSPS are minimal" (in letter dated 2/12/92 to James H
Scarbrough, Chief, EPA Water Permits and Enforcement Branch). The Division concurs with this
opinion

Perrrut No NCO038377
CP&L- Mayo Steam
Page 5
Economic
Although the environmental benefits are considered minimal, the cost of compliance with the 1974
regulations for the per►nittee would not be minimal For example, in order to approach compliance with
dust the 1974 bottom ash recycling requirements, the following costs have been estimated
• Capital Material Cost, estimate for installation - $1,353,900
• Capital Installation Cost, estimate including engineering package, labor, ciN it work - $2,100,000
• O&M for the above installation would be $1,950,000 for each five year period
• 3 megawatt loss in generation
These costs do not address the additional potential costs necessary to comply with the other aspects of the
1974 regulations as presented in your letter
In conclusion, the Division is certainly agreeable to reexarrumng the permitting concerns expressed in
comments 4 and 6 After those issues are addressed, the Division believes that the subject draft perrrut
should proceed to reissuance We do not believe that the permitted facility should be subject to
regulations which have been withdrawn for almost 18 years We also believe that there is no backsliding
of effluent limitations between the draft permit and the previous permit We will continue to work with
you to resolve these objections If you require any additional information about this permit, please do not
hesitate to contact me at (919)-733-5083 extension 517, or Tom Belmck at extension 543.
Sincerely,
David A Goodrich
NPDES Unit Supervisor
cc. NPDES Unit, Permit File
Coleen Sullins, DWQ
Bill Reid, DWQ
Doug Mundrick, U S EPA, Water Management Division
Mike McGhee, US EPA
Mick Greeson, CP&L
Fred Holt, CP&L

SEP -22-97 16=30 FROM=G P T S BRANCH I13=404 562 9224 PAGE 1/3
a�%Ito S7ATFs,
UNITED STATES ENVIRONMENTAL PROTEG`"ON AGENCY
Y REGION 4 l
4&1 Awl� ATLANTA FI=DERAL CENTER
100 ALABAMA STREET, S -W.
ATLANTA, GEORGIA $0303-3104
FACSnn7-R TRANSHISSION SHEET
DATE: 22 7 PAGES TRANSMITTM.- -. (including cover)
TO:, ` i ate, PHONE: C_ rl- /'q
' FROM:
c,
Darryl Williams
Environmental Engineer
Permits Section.
Surface Rater Permits and
Facilities Branch
Water Management Division
(404) 5(52-9297
FAX: [phone]
- n
SPECIAL =STRUCTIONS : � � � -_ d� � Sc.t� f�►..Gc
)_
��' � : -` . - ,a• ",��.:.. may:...:
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RecycW/ReeyclaWe-Pdnced with Vegetable OU Based Inks on IDG%Receded Paper (40;6 Postconsumer)

SEP -22-97 16:30 FROM:G P T S BRANCH ID:404 562 9224 PAGE 2/3
t� UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION
s ATLANTA FEDERAL CENTER
100 ALABAMA STREP, S.W.
Nc t ATLANTA. GEORGIA 30308-2104
SEP 1 8 1997
REF: 4WM-SWPFS
. Steve Tedder, Chief
Water Quality Section
Division of Water Quality
NG Dept. of Environment, Health,
and i4atural kesources
P.O. Sox 29535
Raleigh, North Carolina 27626-0535
RE ArPDPS Overview
ca.ralixa Power & big t; Co.
Mayo H2ectric Generating P3aut
2WDE'S .Permit No. MC0038377
Dear Mr. Tedder:
in accordance with the EPA/DWQ MOA, we have completed our
review of the draft National Pollutant Discharge permit and
supporting materials received on August 5, 1997, for the
referenced facility and our comments are provided below. These
comments were necessary in order to ensure that the permit
complies with the applicable regulations and guidance. Unless
appropriate changes are made, the permit may be subject to an EPA
veto.
Our Comments generally remain the same as those provided to
your office during previous permit reissuances. Reference is
made to our letter dated November 4, 1987 and reiterated in. Mx.
James Elder's memorandum regarding New Source Performance
Standards (attached) . The Standards of Performance for New
Souroes (1974 SP14S) as promulgated on October 8, 1974 (40 CPR
423, 39 FR 36186, particularly § 423.15) remain the applicable
standards for the Mayo plant and not the requirements of the 1982
promulgation (except for more stringent 1982 SAT requirements as
noted below) .
The following must be corrected prior to reissuance:
1. Mass limitations are requxxed in the permit by the 1974
SPNS. We reoolmmend that flow -weighted concentration
limitations consistent with the "Guidance for NPDES
Permits Issued to Steam Electric Power Plants" signed
Flecyclod(AKyclabte .Printed with Vegetable of Basad IN3 on 100%Reg4ed Paper OM PG=Onsume

SEP -22-97 16=30 FROM=G P T S BRANCH ID=404 562 92224 PAGE 3/3
2
. by Ms. Rebecca Harmer on August 22, 1.985 (attached) , be
included in the permit also.
2. Reduction in limitations to include bottom ash recycle
under 1974 SPNS (if applicable), The limitations
developed for the bottom ash component of the discharge
(OSN 002) should be divided by a, factor of 20.
3. Discharge of pollutants in cooling tower blowdown is
limited by both the 1974 SPNS and 19$2 BAT standards.
Accordingly, the discharge of corrosion inhibitors and
the 126 priority pollutants (including chromium, zinc,
and phosphorus) in detectable amounts are prohibited.
4. Mass (and concentration) limitations attributable to
coal pile runoff and cooling tower blowdown, and other
sources of dilution flow mush be incorporated into viae
ash pond limitations. (See Aug 22, 1985 Hammer
Guidance).
5. "Boiler Blowdown" is a separate category from low
volume wastes under 1974 SPNS,
6. Both chemical and non-cheMical metal cleaning wastes
are subject to performance standards for metal cleaning
wastes. Although these wastes are not indicated in the
application, they are generally present at steam
electric power plants, unless disposed of .in an, off-
site.
If you have any cammR„ts or questiozxs, pZea.se contact D 1
Williams of my staff at [phone].
Sincerely,
Douglas 4. Mundrick, P.E., Chief
Surface Nater Permits and
Facilities Branch
Water Management Division-
Enclosures
ivision-
Enclosures

MAR -17-98 10=59 FROM=G P T S BRANCH
ID=404 562 9224 PAGE 1/3
4 rk UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Y REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW
N4 ATLANTA, GEORGIA 30303-89M
FACSIMILE TRANSMISSION SHEET
DATE:- t PAGES T1-2N8MITTED :' (inn-luding cover)
TO.- � � .. PHONE: ` 91 '7 3 3 ,.. ' � 4�3
FAX: (6) 113 --071j
FROM: Dare. Williams,
Environmental Engineer
Permits Section
Surface Water PermiLs and
Facilities Branch
Water Ma.nagement Division
PHONE; [phone] FAX: [phone]
SPECIAL MSTRUCTMONS:
RecycleclAacyc M0 • Ptiftted wt h Vegetable Ott Smo Inks on 100% Recy*d P (40% Pwooci° meo

MAR -17-99 10=59 FROM=G P T S BRAD
ICH ID=404 562 9224 PAGE 2/3
,TUESDAY, OCT013ER S, .1974 ;
WASHINGTON, Dc� _
riFS Og -
.. Volume" 39'19 Number 196
PART !ti �
ENVIRONMENTAL
R T�CTION
AGENCY-
STEAM
ELECTRIC'. PO"WER
GENERATING POINT
SOURCE CATEGORY
Effluent Guidelines crud Standards ----
.r
5
ICH ID=404 562 9224 PAGE 2/3
,TUESDAY, OCT013ER S, .1974 ;
WASHINGTON, Dc� _
riFS Og -
.. Volume" 39'19 Number 196
PART !ti �
ENVIRONMENTAL
R T�CTION
AGENCY-
STEAM
ELECTRIC'. PO"WER
GENERATING POINT
SOURCE CATEGORY
Effluent Guidelines crud Standards ----

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MAR 12-98 10=40 FROM_G P T S BRANCH ID=404 562 5224 PAGE
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
t� REGION 4
4 ATLANTA FEDERAL CENTER
�{r 61 FORSYTH STREr`T. SAI
a<�1' ATLANTA, GEORGIA34303-89051 15 0A 40
CU FG L a
FACSIMILE TRANSMISSION SHEET
IME M1121 WON.
DATi?:� � PAGES TRANSMITTED: �( _ (iricl.ud.ir2g cvvex: )
TO: �_... �-_ PHONE: ( 4 7S a
NC 'DW FAX:r
Ixou; DdX\ yl. Williams
Environmental Engineer
Permits Section
Surface Water Permits and
Facilities Branch
Water Management Division
PHONE: [phone] FAX: [phone]
SPUCTAT XxSTRVCTX0jgS:
ME LVION"''I 1112MEW11). W-10
lip
SAM ME
Raeyc7 KMwydable • PAoW wdh Vegetable Oi18asod Inks Gn 100% R9gaW Paper(40% Posumsumer)
1/11

PART I- WASTEWATER MONITORING, CONTROLS AND LIMITATIONS FOR PERMITTED DISCHARGERS
Page 1 of 6
A.(t ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit Na, MC4038377
During the period beginning on the effective date of the permit and lasting until expirallon, the Permittee is authorized to discharge from outfall serial number
001 (Cooling Tower $lowdown System). Such discharges shall be limited and monitored by the Permittee as specified below:
;PFIUEI�ITx�_ HAftAT
fi t <-
[F Sf <iF xtifbn-x-r'dx�n
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k, 7_}.r^ _P +4+"xn }-� ,:.` {}fi_,•+ {
^I 'ifx mfm;g,r *k'prre ii6nc
Flow
Daily
Pump Logs
E
Free Available Chlorine2
200 pqfl
500 PQA Weok[y
Grab
E
Time of Chlorine AdditionL'
2 hours Weekly
La s
Total ChrorniurrP
0.2 mail
0.2 m fl 21 Month
Grab
E
Total Zln '
1.0 m 1I
1.0 m 1I 21 Month
Grab
E
The 126 Priority Pollutants (40 CFR Part 423, No delectable Amount Annual
Appendix A) Exclusive of Zinc and Chromlum3
Grab
ii E
FIa
Weekl
Grab
IE
' Sample locations: E - Effluent, Samples taken in compliance with the monitoring requirements listed above shall consist of cooling tower blowdown after
mixing with the fly and bottom ash, but prior to discharging into the ash pond.
2 Neither free available chlorine nor total residual chlorine may be discharged from any single generating unit for more than two hours per day, unless the
Permittee dernror)strates io the Division of Water (duality that discharge for more than iwo hours is required for macroinvertebrate control. The 500 ug11
limitation is an instantaneous maximum and is to be measured during the chlorine release pariod, The 200 ggtl limitation Is an average during the chlorine
release period. Simultaneous MUKI-unit chlorination is permitted,
3 These limitations and moniloring requirements apply only it these substances are added by the permittee for cooling tower maintenance. Compliance with
the limitations for the 126 priority pollutants in 40 CFR 423.13 (d)(1) may be determined by engineering catculalions which demonstrate that the regulated
pollutants are not detectable in the final discharge by the analytical methods in 40 GFR Part 136. Ail primary industries are required to submit a priority
pollutant analysis with their application for permit renewal.
4 The pH shall not be less Than 6.0 standard units nor greater than 3.0 standard units.
This permit does not authorize a discharge directly to the Mayo Reservoir except during times in which the cooling tower(s) are drained. The Permittee shall I��
notify the Division of Water Quality, Raleigh Regional 4lfice ([phone]), prior to draining the cooling tower(s), except during non -office hour emergencies ll� ro
when notification muss be made the next working day, The abouo listed limitations for the pollutants shall apply during the draining of the cooling tower(s). 4z -
Sampling shall be conducted during the lime of the evonl at the cooling tower blowdown area. The above listed effluent characteristics and pH shall be ,� M
sampled daily while draining The cooling tower(s).
Special permit conditions applicable to the subject facilly are listed under Part 1, Section 0 of this permit.

PART I: WASTEWATER MONITORING, CONTROLS AND LIMITATIONS FOR PERMITTED DISCHARGERS
A.(2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL.
Page 2 of 6
Permit No. N00038377
During the period beginning on the effective dale of the permil and lasting until expiration, the Permillee Is authorized to discharge from outfall serial number
002 (Ash Pard Treatmant System), Such discharges shall be limited and monitored by the Permittee as specified below_
{ ¢y %�_ ; ,x,rr
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Weekly
Pump Logs or
E
similar readings
Oil and Grease 16.0 M211
20.0 M911 2 f Month
Grab
E
Tota! Suspended Solids 30.4 m 11
100.0 mclil 2 f Month
Grab
E
Tolal Selenium
3.8 lbs/day 21 Month
Grab
a E
Acute Toxicit 2
Quarters
Grab
E
Arserlic3 �'� , .
Quarterly
Grab
E
G4 er3
Grab
E
iron3
Quarlerly
Grab
E
H°
21 Month
Grab
IE
gates: ..
o
' Sample locations; E - Effluent. Samples taken in compliance with the monitoring requirements listed above shall be laken prior to mixing with other waste
streams.
2 Acute Toxicity (Fathead Minnow 24hr) No significant mortality al 90%; February, May, August, and November, See Special Condition 1 under Part I, Section m
C of this permit. to
%%m
3 These metals were monitored during the previous permit period. Allhoegh no level of 'allowable' can currently be established for these metals, continued r ` 10
47�monitoring should be requireddue to thelr presence In the efsluent until an'allowable' level can be determined. i
4 The pH shall not be loss than e.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solidsor viSibfe foam in other than ]race amounis outside an area five(5) meters from the discharge pipe.
No chemical metal cleaning waste may be discharged to tha ash pond. .
ro
b
There shall be no discharge of polychlorinaW blphenyl compounds such as those commonly used for transformer fluid. M
Special permil conditions applicable to The subjeot facility are listed under Part I, Section C of this permit.
w

MAR -12 -SS 10:42 FROM:G P T 5 BRANCH ID=404 562 9224 PAGE 4/11
SUPPLEMENT TO PERMIT COVER SHEET
Carolina Power & Light Company
is hereby authorized to:
1, Continue to operate the following systems located at Mayo Steam Electric Generating Plant, off
of US Mghway 501, northeast of Poxboro, Verson County (See Dart III of this permit)_
Cooling Tower Slowdown System (outfall 001) This water is usually mixed directly with
the ash sluice water_ Occasionally (once per year maximurn) it is not mixed with bottom
and fly ash and is discharged directly into the ash pond. Heat exchanger water (low
volume waste) is almost continuously discharged through outfall 001. Approximately once
every two years the cooling towers are drained completely for maintenance. This
discharge goes directly into Mayo Reservoir_ Outfall 001 discharges into the ash pond and
is ultimately released into the Mayo Reservoir throygh outfall 002;
Ash Fond Treatment System (Outfall 002) The ash pond receives ash transport water, coal
pile runoff, stormwater runoff, Cooling tower blowdown, and vanous low volume wastes Such
as boiler blowddwn, oily waste treatment, wastes/backwash from the waxer treatment
processes, plant area wash down water, and equipment neat exchanger water. The
domestic waste from the sewage treatment plant also discharges through outfall 002.
• Stormwater Discharge System The facility is permitted to discharge storrmwater through
the following outfaIIs
Outfall 004 - Drainage from the outside storage area.
Outfall 005 - Drainage :From the industrial area and the oil/gas storage
area_
Outfalls 006,006a, 006b, 006c, 0064, 006e - Drainage from the chemical feed
building and the cooling tower area.
2- Discharge from said treatment works at the location specified on the attached rnap into the
Mayo Reservoir which is classified as Class C waters in the Roanoke River Basin.
All discharges shah be in accordance with the attachCd schedules -
past L Wastewater Monitoring, Controls and Limitations for Permitted Discharges
Fart 11; Stormwater Monitoring, Controls and k4mitations for Permitted Discharges
Part M- Standard Conditions for NIFDES Permits
Part IV: Annual Administering and Compliance Monitoring Pee Requirements
Part V: Limitations Reopener
'chis permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state or local law, rule, standard, ordinance, order, judgment or decree.
based effluent limltanonn =W

MAR -12-98 10=42 FROM=G P T S BRANCH ID=404 562 9224 PAGE 5/11
Carolina Power & might Company
Mayo Steam Eleenk Plant
Nadowd Poftutant Mwcge mon System Permit Number NM38377
Water ]clow Rates
dam
1 Dake
2 Cooling Tower (make-up)
3 Raw Watcz T=tl=nt
4 Sewage Treat nem PI= (STP)
5 Backwash
6 Treated Watzr
7 Oily Waste (infrequent)
8 Lown Vol=e Wastes
9 Boiler BIowdown '
10 Cooling Tower Basin Drain
I z Evaporation
12 Ash Transport
13 Intermittent blowdown of circulating
water from heat exchangers
Average Flow
14 MGD
13.7 MGD
0.36 MGD
0.002 MGD (O-01 5 design)
0.00175 MGD
0-36 MGD
Soo GPM (Marc rare)
1.5 MCD
0.05 MOD at startup
2 MG/event, I/yr.
9 MGD
3.9 MOD '
variable, as needed (blowdown)
14 Heat Excdz=ger (primary► route) 8.5 MGD reci=Iatiag flow
15 Coal file Runoff U.0135 MGD a mal daily
average
16 Ash pond 7.3 MGD
NOTES: Flow rates xray notbalance due to mi=llaneous losses and system evapomtion
�tctostzr$ 3
Carolina PdWar A Llont Company
Mayo staam tioutrir. Planx
Person County, N.C.
Sahgmatie of Water Flow
Page 2 of 2 Octobvr 18$6

?vaparaUan �1 Cooling Towers
14
Misr.. Equipment
Heat Exchangers ......_ �.
Ash S€ufoe Water I - . I Conde-
nsera
Maya Reservolr
s Raw Water
Intake SttU re �' atrnent
Fire Protedon Water StarApe
a
Condensate ion F.xoarige
rlt% Boffar &Turbine Istarage
rr �, Ash Pani
-� oma. ��r� C�•��Kr�
Fr dr3'r *s• � c1 4;"414 16
e�sly fI4 ��ia �I %ted
. , r Coai-Pile Runoff
xed ask uy""
0-1
- ° / aye. logo,
�
Potobia &
So nlfary Sysi
S"Sue
Treatment
Ql ly Waste
Treatment
Miso, Low
Volume
E;afQlkna Pa"t & Ught Company
Maya Sleam Eledit Plant
Person Cou*, N. G.
smemoib of Wow HOW
Page 1012 NOvernbet 1996
a
m
Ln
M
N
M
to

MAR -12-96 10=43 FROM=G P T S BRANCH ID=404 562 9224 PAGE 7/11
SEp 1 a 1997
REF: 4WM-SWP1?E
Mr. Steve Tedder, Chief
Water Quality Section
Division of Water Quality
XC Dept. of Environment, Health,
and Natural Resources
P.O. Box 29535
Raleigh, North Carolina 27626-0535
RE : NP,DES overview
rolima Power & zight Co..
MaYV E3eCtr C Generating Plaut
NPDBS Pezvdt NO- MC0038377
Dear Mr, Tedder:
In accordance with the EPA/DwQ LOA, we have completed our
review of the draft National Pollutant Discharge permit and
supporting materials received on August 5, 1997, for the
referenced facility and our comments are provided below. These
comments were necessary in order to ensure that the permit
complies with the applicable regulations and guidance. 'Unless
appropriate changes are made, the permit .may be subject to an EPA
veto.
Our comments generally rema.ira, the same as those provided to
your office during previous permit reissuanc4s. Reference is
made to our letter dated November 4, 1987 and reiterated is Mr -
James Blder's memorandum regarding New Source Performance
Standards (attached), The Standards of Performance for New
Sources (1974 SPNS) as promulgated on October 8, 1974 (40 CFR
423, 39 FR 36186, particularly 5 423.15) remain the applicable
standards for the Mayo plant and not the requirements of the 1982
promulgation (except for more stringent 1982 BAT requirements as
noted below) .
The following must be corrected prior to reissuance:
I. Mass limitations are required in the permit by the 1974
SPNS. we recommend that flow -weighted concentration
limitations consistent with the "Guidance for NPDES
Permits Issued to Steam Electric Power Plants" signed,

MAR -12-96 10=43 FROM=G P T S BRANCH ID=404 562 9224 PAGE
2
by Ms. Rebecca Hanmer on .August 22, 3.985 (attached) , be
included in the permit also.
2. Reduction in limitations to include bottom ash recycle
under 1974 SPNS (if applicable) . The limitations
developed for the bottom ash component of the discharge
(QST' 002) should be divided by a factor of 20.
3. Discharge of pollutants in cooling tower blowdown is
limited by both the 1974 SPNS and 1982 BAT standards.
Accordingly, the discharge of corrosion inhibitors and
the 126 priority pollutants (including chromium, zinc,
and phosphorus) in detectable amounts are prohibited.
4. Mass (and concentration) limitations attributable to
coal pile runoff and cooling tower blowdown, and other
sources of dilution flow must be incorporated into the
ash pond limitations. (See .Aug 22, 3.985 Hanmer
Guidance),
5. "Boiler Blowdown" is a separate category from low
volume wastes under 1974 SPNS.
6. Both chemical and non -chemical metal cleaning wastes
are subject to performance standards for metal cleaning
wastes. Although these wastes are not indicated in the
application, they are generally present at steam
electric power plants, unless disposed of Jza__aa off-
site.
If you have any comments or questions, please contact Darryl
Williams of my staff at [phone].
Enclosures
Please sign. & date:
Proof Williams
Sincerely,
Douglas F. Mundrick, P.E., Chief
Surface Water Perm=its and
Facilities Branch
Water Management Division
Childress
6/11

MAR -12-98 10=47 FROM=G P T 5 BRANCH ID=404 562 9224 PAGE 8/11
2
by Ms. Rebecca Hanmer on August 22, 1985 (attached), be
included in the permit also.
2. Reduction. in limitations to include bottom ash recycle
under 1974 SPNS (if applicable). The limitations
developed for the bottom ash component of the discharge
(OSX 002 ) should be divided by a factor of 20.
3. Discharge of pollutants in cooling tower blowdown is
limited by bath the 1974 SPNS and. 1982 BAT standards.
Accordingly, the discharge of corrosion inhibitors and
the 126 priority pollutants (including chromium, zinc,
and phosphorus) in detectable amounts are prohibited.
4. Mass (and concentration) limitations attributable to
coal pile runoff and cooling tower blowdown, and other
sources of dilution flow must be incorporated into the
ash pond limitations. (See Aug 22, 1985 Hanmer
Guidance).
S. "Boxier Blowdown" is a separate category from low
volume wastes under 1974 SPNS.
6. Both chemical and non --chemical metal Cleaning wastes
ars: subject to performance standards for metal cleaning
wastes. Although these tastes are not indicated in the
application, they are generally present at steam
electric power plants, unless disposed of—Ra off-
site.
If you have any comments or questions, please contact Darryl
Williams of my staff at [phone],
Enolosures
Please sign. & date:
Proof Williams
,J
Sincerely,
Douglas F. Mundrick, P.E., Chief
Surface Water Permits and
Facilities Branch
Water Management Division
Childress

-% � Jy - h. +fK - %Rxp
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to
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'10
�
PART I: WASTEWATER MONITORING, CONTROLS AND LIMITATIONS FOR PERMITTED DISCHARGERS
FEaw, MGD
ED
A.(1). EFFLUENT LIMITATIONS AND MOMTORINC RFQUIRAFI VENTS -FINAL
Pump Logs or
Ex�
During theperiod beginning on the effective data of this permit and lasting through expiration, the permittee is authorized to discharge from outfall serial number
001 (Cooling TOWL-rBlowdown System). Such discharges
m
shall be lirnited and monitored by the permittee as specified below:
Free Available Chlor]142 WA
�
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-T�'X- _ %[9i%v.WO]n%-•JC
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FEaw, MGD
Daily
Pump Logs or
Ex�
similar readin s
Free Available Chlor]142 WA
PIA
2o4 wAyi
Soft E9111 weekly
Grab
E
Time of Chlorine Dischar e2 IVA
PIA
NIA
2 hours VVeeklv
Grab
E
Corrosion Inhibiting Cornpounds3 and the 126 No Detectable amount Annually
Grab
E
Priority Pollutants (40 CFR fart 423 Appendix Ar
Hs
1NeelciI
Grab
E
Notes -
'Sample locations: E- Effluent, Samples taken in compiiancewith the monitoring requirements listed above shalt be taken prior to mixing with other waste streams.
Neither free available chlorine nor total residual chlorine maybe dfsoharged from any single generating unit for more than two hours per day, unless the Permittee
demonstrates to the Division of Water Quality that discharge for more than two hours is required for macro inverlebrate control, The 5D0 pgll limitation is an
instantaneous maximum and is to be measured during the chlorine refease period. The 200 Nglf is an average during the chlorine release period. Simultaneous
multi-unitchlorination Is permitted.
s Including but not limited to zinc, chromium, and phosphorus.
4 These limitations and monitoring requirements apply only if chemicals containing these substances are added by the permittee for cooling tower malntenance.
Compliance with thelimitations for corrosion Inhibiting eompounds3 and the 126 priority pollutants in 40 CFR 423.13(d)(1) may be determined by engineering
calculations which demonstrate that the regulated pollutants are not detectable In the final discharge by the analytical methods 140 CFR Part 138. All primary mdustrlas
are required to submit an priority pollutant analyses with their application for permit renewal,
5 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
This permit does not authorize a discharge directly to the Mayo Reservoir except during times in whfch the cooling lower(s) are drained, The permittee shall notify the
Division of Water Quality, Raleigh Office [phone]), prior to draining thecooling tower(s), except during non -office hour emergencies when notification must be T
made lite next working day. Trio above fisted limitations for the pollutants shall apply during the draining of the cooling tower(s). Sampling shall be conducted during the b
time of the event at the cooling lower Blowdown area, The above listed effluent characteristics and pH shall be sampled dally while draining thecooling tower(s), ra
Special permit conditions applicable to the subject facility are fisted under Part I, Sectlon G of this permit,

Page 2 of 6 , s
Permit No. FLD038377
PART h WASTEWATER MONITORING, CONTROLS AND LIMITATIONS FOR PERMITTED DISCHARGERS 03
m
A,(2). EFFLUENT ifMITA TIONS AND MONITORING REQUIREMENTS -FINAL
e
1. During the period beginning on the effective date of this Permit and lasting through expirailon, the perm Ittee is authorized to discharge from outfall serial number m
002 (Ash Pond Treatment System).
a. Such discharges shall be limited and monitored by the permittee asspeoifled below;
nuLay:
' Sample locations, E - Efiluent. Samples taken In compliancewith the monitoring requirements listed above shall betaken prior to mixing with other waste streams.
Z Acute toxioity (Fathead Minnow 2411-11r) No signlllcant mortality at 80%; February, May, August, and November. See Special Condition ? under Part I, Section C of this
permit,
'These metals were monitored during the previous permit period, Although no level of 'allowable' can currently be established for these metals, continued monitoring
should be required due to their presence In the effluent until an'allowable' leve! cen be determined,
'The pH shall not be lass than 6A standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts outside an area five (5) meters from the discharge pipe.
No chemical metal cleaning wastes may be discharged to the ash pond.
There shall be no discharge of polychlorinated biphenyl compounds such as those commonly used for transformer fluid.
SfaWal permit conditions applicable to the subject facility are listed under Part i, Section C of this permit,
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ATTACHMENT A
0P.&LIMayo Steam Electric Plant
Ash Pond OSN 002
AVERAGE
............ _................ ..........__ ..............
.FLOW TSS O&G
....... ....... ........... ..... .............. ........ ,.......
Waste Stream MGD mgli bid mgA Ibld
......................... ............................
CASE f: DRY WEATHER LIMITATIONS
Fly Ash Transport water[1 ]
Bottom Ash Transport wategl,21
Low volume wastes
Oily Wastes Treatment
Boiler Blowdown '
Raw Water Treatment
Sewage Treatment
Condensate Storage[3]
Heat Exchanger Blowdown[31
Ion Exchange[4]
Cooling Tower Blowdown[5]
Ory W eather Lfanitalions [6]
� � N
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MAXIMUM
........................... ......._......_..
FLOW TSS O&G
..... .. ............... ..............
MGD mg1I Ibld mgfl ..._..Ipld.. .
1.300
2.600
30.00`
30.00
325.46
32.65
15.00
162.73
1.300
100.00
1084.85
24.00
216.97
1.500
30.00
375.63
15.00
15.04
16.27
187.76
2.600
1.500
100.00
100.00
108.49
20.00
21.70
0.432
30.00
108.15
15.00
54.08
0.432
100.00
1251.76
360.5
20.00
20,00
260.35
72.1
0.500
0.042
34.00
0.00
125,18
0.40
15.00
62.59
0.600
100.00
417.25
20.00
83.46
4.402
30.00
0.50
0.00
0.00
0.00
0.00
0.042
0.002
0.00
46.00
0.00
0100
0.00
0.75
0.40
0.00
.............. �!�
8.376 867.36 8.fl9 3.42$ 6.376 $--59 3223.52 12.11 6.04.574
11 ] Flows Indicated are assumed for fly and bottom ash, equinient to a total flow for Ash Transport Nater of 3.9 MGD;
[2] Ash Transport component divided by a factor of 20 based on'74 SPNS [Section 423.16(6)]
[3] Not included in calculations since discharge Is infrequent to the ash pond, however, uncontaminated dryweather flow; can give credit based on BPJ and/or available data.
[4] Not included in Oak'ulaticins since discharge Is infrequent to the ash pond; however, guidellIn"mited dry weather flow.
[6] Not included in calculations since cooling tower bfowdown does not occur simultaneously with ash transport water.
[6] Assumes Ash Pond has sufficient capacity; excludes: metal cleaning waste pond effluents, coal pile runoff pond effluent.
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FEB 85 198 88:46AM OPERATIONS & ENVIRONMENT SUPPORT
C P&L
Carolina Power & Light Company
Environmental Services
Harris Energy & Environmental Center
3932 New Hill -Holleman Road
P.O. Box 327
New mill, NC 27562-0327
FAX TO:
FROM:
DATE:
Dave a drich
Fred dolt
362-3558
February 5, 1998
P.1
No. of pages attached: 2
RE: CP&L Mayo Plant NPDES Permit NCO038377
Attached is a "white paper" discussing the issue of anti -backsliding in regard to EPA's
concerns with the Mayo draft permit. We looked at all aspects of the anti -backsliding
issue (legal, technical, policy & common sense) and decided that the best initial approach
to this legal -type issue is a legal -type response. Therefore, this white paper presents a
legal approach to the issue. This approach simply presents the fact that the statute and
reqs. state that anti -backsliding from the previous permit is prohibited. In the case of the
Mayo permit, the proposed draft permit is not less stringent ;from the previous permit so
anti -backsliding isn't applicable.
I would like to meet at your convenience to discuss. Give me a call if there are any
questions.
Thanks,
,A

• FEB 05 '98 08:46AM OPERATIONS & ENVIRONMENT SUPPORT P.2
10
Back rg_ound
NC DENR proposed to reissue a NPDES permit for the CP&L Mayo facility in
July 1997. This proposed draft permit contained essentially the same limitations as the
previous permit that was effective 02/01/96 and expired 04/30/97 (previous permit). The
limitations in the previous permit were based on the 1982 revisions to the Steam Electric
Guidelines (40 C.F.R. Part 423) and not the 1974 NSPS since the 1974 NSPS were
withdrawn by the 1982 revisions. Additionally, the two modified versions of the permit
(September 1985 and January 1986) that immediately preceded the 1996 permit did not
contain 1974 NSPS.
By letter of September 18, 1997, EPA Region IV objected to the reissuance of the
draft permit. Part of the basis for their objection (implied in their objection letter) is that
anti -backsliding prohibits the relaxation of permit limitations that were based on the 1974
NSPS. However, the permit proposed by NCDENR does not contain limitations that are
less stringent than the limitations in the previous permit since the previous permit did not
contain the 1974 NSPS.
Analysis
Anti -backsliding is not relevant to the circumstances associated with the Mayo
NPDES permit. The two sources of authority prohibiting backsliding are
Section 402(o) of the Clean Water Act, and 40 C.F.R. § 122.44(1) (including
§122.62 by reference). Both sources are limited in scope to restricting a
reissued permit from containing effluent limitations that are less stringent than
the comparable limitations in the previous permit. However, the current
permit proceeding for the Mayo Plant does not involve the reissuance of a
permit that contains effluent limitations that are less stringent than the
limitations in the previous permit. Rather, the effluent limitations in the
proposed reissued permit will remain the same as the limitations in the
previous permit. Because no relaxation of the previous permit limitations is

J
FEE BS '98 oe:49AM OPERATIONS & ENVIRONMENT SUPPORT P.3
s
being sought, the backsliding issue is not applicable to the Mayo permit
proceeding.
• Mayo Plant's previous permit does not contain 1974 NSPS-based limitations.
In effiect, EPA is attempting to impose those stricter limitations in the renewed
permit. The Agency lacks the authority to do so. When EPA withdrew the
1974 NSPS in 1982, the 1974 NSPS lost their legal effect within the 40 C.F.R.
Part 423 rules. Even if the 1974 NSPS retained a residual legal effect by
virtue of their having been imposed as a legally binding requirement in an
NPDES permit, any such legal effect dissolved once the 1974 NSPS-based
effluent limitations were removed from the previous permit. EPA now lacks
authority to impose the 1974 NSPS-based limitations in this 1998 proceeding.
Both the 1974 rule on which the 1974 NSPS-based limitations were
predicated, and any previously expired permits containing 1974 NSPS-based
limitations, no longer have any legal sigiuficance. And neither 40 C.F.R.
§ 125.3 nor any other provision authorizes EPA to reinstate the 1974 NSPS in
the renewed Mayo permit.

CP&L
Carolina Power & Light Company
Mayo Electric Generating Plant
10660 Boston Road
Roxboro NC 27573
9i A1111ii 19 PH 3: 68
Mr David A. Goodrich, Supervisor
NPDES Permit Group
North Carolina Division of Water Quality
P O Box 29535
Raleigh, North Carolina 27626-0535
Subject. CP&L - Mayo Steam Electric Plant
Person County
NPDES Permit No. 0038377
Comments on Draft NPDES Permit
Dear Mr. Goodrich.
'AUG 1 5 1997
Carolina Power and Light Company (CP&L) has reviewed and prepared comments on the
subject draft National Pollutant Discharge Elimination System (NPDES) permit pursuant
to the North Carolina Division of Water Quality's (NCDWQ) letter dated July 21, 1997
As stipulated, CP&L's comments (Enclosure 1) are being submitted in writing.
CP&L appreciates the continued cooperation demonstrated by the NCDWQ staff in
resolving often complex issues involved in renewal of NPDES permits. If you have
questions regarding the enclosed information please contact Mr. Ricky Miller at
[phone]
Enclosures
Sincerely yours,
Rodney W P efield - Manager
Mayo Electric Generating Plant
10660 Boston Road Tel [phone] Fax [phone]

Na0 6
Enclosure 1
Carolina Power & Light Company
Mayo Electric Generating Plant
Comments on Draft NPDES Permit No. NCO038377
The following comments on Carolina Power & Light (CP&L) Company's Mayo Electric
Generating Plant National Pollutant Discharge Elimination System (NPDES) permit are
submitted pursuant to the North Carolina Division of Water Quality letter dated July
21,1997, from Mr David A Goodrich to Mr Rodney W Patefield The comments
address items in sequence that they appear in the draft NPDES permit and transmittal
letter
Transmittal Letter
• The transmittal letter stated that the Division had not received the 1996 yearly study
on selenium and its effect on the reservoir as required by Part I, Section C of the
current NPDES Permit. This report was submitted to Mr. Preston Howard by letter
dated March 21, 1997. In the future a separate copy will be submitted to the Permits
and Engineering Unit to avoid confusion on this issue.
Permit Cover Sheet
V/ • In the section that begins, "to receiving waters designated as the Mayo Reservoir in
the Roanoke River Basin in accordance with effluent limitations, monitoring
requirements, and other conditions set forth in Parts 1, II, III, and IV hereof', an Y P A
additional Part V needs to be added
Supplement To Permit Cover Sheet
In the first bulleted item under "Cooling Tower Blowdown System (outfall 001)" the
cooling tower is referred to as cooling towers Throughout the permit the cooling tower
is identified as the cooling tower(s) CP&L requests that cooling towers be changed to
cooling tower(s). This change would make the permit more consistent
V/ • Under the third bulleted item "Stormwater Discharge System" Outfall 005, CP&L
requests that the sentence be modified to read as follows
Drainage from the industrial area and the oil /bottled gas storage area
The addition of the word "bottled" clarifies the type of gas
�• Under the third bulleted item "Stormwater Discharge System" Outfalls 006, 006a,
006b, 006c, 006d, 006e, CP&L requests that the sentence be modified to read as
follows
Drainage from the cooling towers) chemical feed building structure and the cooling
towers) area
This would better identify the area covered

Part I , Page 1 of 6 p0 I
1 • Effluent Characteristics, Under Effluent Characteristics pH, is required to be
�n monitored. Since the Cooling Tower(s) normally discharges to the ash pond and the
% ash pond discharge has a pH limit CP&L requests that pH monitoring requirement be
deleted from this outfall and Note 4 be removed from the page It should be noted
that when the cooling tower(s) drain directly to the receiving water, pH is required to
O'k-4„��"� be monitored
&6�
• The free available chlorine limit of 500 pg/l is described as an instantaneous
maximum. The effluent guidelines at 40 CFR 423 13 (d)(1) express the limitation as
({ a "maximum” but does not explicitly state "an instantaneous maximum." The
preamble to these effluent guidelines at FR 47, No 224, November 19, 1982, Page
52295, first column, states that these limits are "daily maximum concentrations".
Consequently, the limitation of 500 pg/1 should be expressed as a daily maximum and
not as an instantaneous maximum.
�/ • The last sentence of Note 3 states that all primary industries are required to submit a
priority pollutant analysis with their application for permit renewal All primary
industries (including steam electric industries) do not have to analyze for all priority
pollutants for their application for permit renewal Consequently, CP&L
recommends that in order to avoid possible misinterpretation of this permit statement
in Note 3, this last sentence be deleted or phrase to read:
All primary industries are required to submit a priority pollutant analysis in
accordance with 40 CFR Part 122 with their application for permit renewal
V/ • In order to clarify the sampling time and the location during the draining of the
cooling tower(s), CP&L requests that the last two sentences that authorize draining of
the cooling tower(s) be changed by dropping the first sentence and changing the
second to read
The above listed effluent characteristics and pHshall be sampled daily, at a
location prior to discharge to Mayo Lake, while draining the cooling tower(s)
Part I, Page 2 of 6 6 4 ,3,)'L -
V/• Effluent Characteristics, The metals arsenic, copper, and iron should be identified
as either "total", "dissolved", or "total recoverable".
2 • Note 3, Since an `allowable' level has not been established for the above mentioned
° metals CP&L requests that the continued monitoring frequency be reduced to annuals J
® sampling Combined with past data, this reduced frequency should continue to
provide a characterization of the effluent Also, a toxicity test is in place to insure the
protection of the receiving stream.
W

Part I, Page 3 of 6
V Analytical Monitoring, CP&L requests that the phrase, "or expansion" be removed
from the first sentence As the sentence is currently written, if CP&L did any
expansion, even a properly permitted expansion, we would not be authorized to
discharge from the stormwater outfalls Under Note 1, the phrase "unless a
significant change in facility operations or configuration" already covers the intent of
the "expansion" restriction
r/• Where, CP&L requests that in 005 the word "bottled" be inserted between oil and
gas to clarify the type of gas and 006 a, b, c, d, e be modified to read:
Drainage from the cooling tower(s) chemical feed building structure and the
cooling towers) area
• CP&L requests that 007 a, b be removed from this page in the permit.
Note 2, Measurement frequency, In order to clarify when the samples should be
taken, CP&L suggests that the words "full year" be inserted between the words "first"
and "and". The sentence would then read "The facility must perform analytical
sampling during the first full year and last year of the permit regardless of cut-off
concentration conditions"
Part I, Page 5 of 6
Section A requires the permit to be reopened if "toxicity testing or other studies"
indicate "detrimental effects." This reopener is unrestricted, and unqualified and
could theoretically require the DWQ to reopen the permit to include limits in the
permit if anyone conducted a study and found "detrimental effects" regardless of who
conducted the study, what type of study was conducted, or the significance of the
"detrimental effects" indicated CP&L believes that the intent of this reopener is to
give DWQ the authority to reopen the permit if legitimate studies conducted by or
under the supervision of DWQ or the permittee indicate that there is a reasonable
potential for the water quality standards for toxicity to be exceeded. Consequently,
CP&L requests that this reopener be replaced with the following language.
This permit may be modified or revoked and reissued to incorporate
alternate monitoring requirements or toxicity limitations in the event that
toxicity testing or other studies conducted on the effluent or receiving
waters by or under the supervision of DWQ or the permittee indicate
decisively that there is a reasonable potential for water quality standards
excursions in the receiving stream

Part I, Page 5 of 6
P"jh,1e�`,�/
yDk1,
• Section B 2. is contradictory to the O&M requirements found at Part III, C 2 Since
Part III, C.2 is the only provision of the two that is based on regulation, CP&L
requests that condition B 2. be deleted or the phrase "at optimum efficiency" be
replaced with "in accordance with Part III C 2 "
PartI' g of Pa e 6 6 i` � ►Jq
ch
• In light of the above comment regarding the permit reopener on page 5 of 6, CP&L ��°�1
requests that the fourth paragraph on this page be deleted
Vj
01)
• Selenium Study, The permit requires that the permittee conduct biological and
© physical /chemical studies by April 1 for the prior calendar year CP&L requests that
the due date be changed to May 1. Most of the CP&L reports are due April 1, so by �(f
allowing the date to be changed, CP&L could utilize it's resources more effectively.
.1 • Crutchfield Branch, The permit as written requires Crutchfield Branch to be ,(
monitored quarterly This discharge has been monitored quarterly since 1985. CP&L AT1
believes that this amount of data should be sufficient to conclude that the ash pond
does not impact Crutchfield Branch CP&L requests that this monitoring be
R e� OVIIJ eliminated or reduced t annually yc—
V)0#��
6 Part III, Page 10 of 21
w• Section B. 3. Civil and Criminal Liability lists "Bypassing" and "Power Failures" as
�1 relief for noncompliance. Since an "Upset" also constitutes an affirmative defense for
noncompliance with technology based effluent limitations, CP&L requests that
"Upsets" also be listed in B.3. as an exception to noncompliance
4

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(Notarial Seal) hr,4,kiPIJBLIC NQTPW�ipto,POST OFFICE PDX,00,16 1�,jALEPt Mir'- %same In,00 I to thi above addressno later thp,9/15197'. AllqqrnmentsrecoIved'pfl0f,16'1haQdaIe will beF—�-ITdetermin�tions',Wre6aiding�, the'proposed pqrmitA public meetingald where the Director of themay be heDIVISIC V,Management finds �a, significantd aft permit sA 'copt, of ther calling the",,of �0 EnvironmentalBox 29535,,olina 27626-0535,Raleig North CanWo appllcatlon',,and otherd at theselocations during normal office hours.Copies of the information on file areavailable upon request and pagentof the costs of reproduction A hdomments or requests regarding aproposed permit should makereference to the NPDES permitnumber listed below.Public notice of intent to issue aState NPDES permitto the following J;NC �7662,jPlant, off US Highway 501, northeastof Roxboro 16 Person -County I TheMGDP1qf4treated,-'domestic and,.industrial w4stewiter from two outfallsw jter�,, body 'in, that, Roanoke River,,,Basi6'.,Fors,soi�'k,pararneters theavailable 16adic4acity of the,ImM6dlate r66eivihg, water will beconsdmed.jhii,ma affect futurewater Ua itwithin this -ad Itl6opi,69, in 014MeVIPTT N1,1377, _erqon,,Oounty, The facility'domestic and"diate receiving�illable loadaled. This may''quality 'based',166 orgirs In q p,Ppj ton Howard Jr.P.5. Director,,VI jRq,%Pnv1
'
ED
BECEIV.
1997" ~
AUG�� �� '
�"v -
'
DVVOBUDbE|n~c`--
F�F

PERSON COUNTY v vy PRINTER'S AFFIDAVIT
=------------ S��"------- ------ ------------- --
----------- being duly sworn, deposes and says:
That he is-----------_f_'_1:� --- ------------------------ of The Courier -Times, with its principle place of business
located in the City of Roxboro, County of Person, State of North Carolina; that the foregoing or attached
newspaper notice was published in The Cour'er-Times, once a week for -------- k ---- _--- successive weeks, be-
ginning y _-_ _ ----------, 19 9�., ands ending with its issue of____ �-___-_
innin wit its issue of __ __�_____da of _ _ _ __
day of _ __ _ __ _______________________ 19_?7__; that The Courier-Times,giepowner and publisher of
said ne paper, The Courier -Times. - -- -----------------------.___(Affiant)
Sworn to and subscribed before me,
th' the5 ------ day of -- -------------------r 193-7
4d)--- = - ---------- ------------- Notary P lic _ __-CjQ
My commission expires the-��_day of__ _ _ _----__---_--------------------- 19_! U _. ,
- (Publication Fee $ 8 7 L L )
(Notarial Seal) t` is y, `PUBLIC NTiCE'°`'� 7
i
STATE OF, NORTWCAR&1114 ``
ENVIRONMENTALI,';!,< ,:;;1
�IANAGEMENT,COMMISSION s;
POST OFFICE.BOX 29535. t<'
RALEIGH, NORTH CAROLINA'f
1":'27626-0535
NOTIFICATION OF INTENTYTO,.; r$
I ISSUE A STATE NPES PERMIT. ` ', EIV ED
' On the tiasis�"o};ihoidughylstaff`�� '
review and application of Aiticlei21 df
Chapter, 143,' GenfiraI',Statutes'i of; n
North Carolina„ Public; L'aw? 92-5b0 h AUG
0197
and other, lawfur, tand, i -i and -�
• regulafin a,!tHa North' C5t51in4A'
Envir0nmen4al!'?� Maria bment 1
Commission pproposes' to; s§ue',a;, DWQ BUDGET OFFICE
permit to discti5rge"to this' 'e'rsBriS';
listed below effe6tive'9/1%97,and
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I Pr ared B Q--- Date
Ap roved By Date -
Rf: e(ved By Date
Da a Entered By
Ve dor ID#- D / 2Z Group#
Co trol# Date: Company
Amour ACCOUnt Cent .r
Tha You For Your Business'
EI =j
AUG 0 4 1997
DWQ GUOGEt OFFICE
e xa St w e t ,'Mc'AM U
� * !�A YOUR NE s .,, n gr a r
� i k rpt=SzaBALAf�GE'(S # i iv 300It15 OD Y
'3
`]Me Courier-T3=e
PUBLISHED WEDNESDAYS AND SATURDAYS
• 109 Clayton Ave - P 0 Box 311
STATEMENT
ROXBORO, NORTH CAROLINA 27573
ACCOUNTw,IDATEQ—
PHONE [phone]NUMBE�I
.0 onv YR
stabl�shed FAX [phone]
b101750
08!01197
1881
TERMS. Net due first of month following service
MS. FRANCES COTTEN
charge 1'/2% per month on past due
NCDEHNR DIV. OF ENVIRONMENTAL
accounts - $1 00 minimum
P.O. BOX 29535
RALEIGH, NC 276264125
$ 9 9.
INDICATE AMOUNT
PAID
RETAIN THIS PORTION
ACCOUNT STATEMENT DATE CHECK
NO
PREVIOUS
BALANCE
.00
b101750 NUMBER 08/01/97 DATE PAID
17/12/97 b5 s'520
NPSES No. NC0038377 Carolina
10.75 L
gal Notices
8.15 87.61
f
'
I Pr ared B Q--- Date
Ap roved By Date -
Rf: e(ved By Date
Da a Entered By
Ve dor ID#- D / 2Z Group#
Co trol# Date: Company
Amour ACCOUnt Cent .r
Tha You For Your Business'
EI =j
AUG 0 4 1997
DWQ GUOGEt OFFICE
e xa St w e t ,'Mc'AM U
� * !�A YOUR NE s .,, n gr a r
� i k rpt=SzaBALAf�GE'(S # i iv 300It15 OD Y

Of
DEHNR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No NC0038377
Wasteload Allocation Summary
1982 looks as it plant had not yet been completed I-acllrty chd receive permit for
doinestic waste tre lted to Secondaly levels
1987 WLA perfoimed with limits foi vartou� pipe
1991 notes indicate that EPA objected to ptevunn D1aft perntt .ind the hsue5 had
not been settled, therefore facility had been operating without a permit since 1987,
(EPA's reasons for objecting not outlined) WLA was tot combination of pipe
003 (domestic) to the ash pond, (pipe 002) Recommendations included BOD,
TRC, and fecal coliform limits These were dropped after consideration of
dilution involved in this effluent
Metals
Even with a conservative estimate of' 1 2 dilution, mon1to11ng was recommended
Crutchfield Branch
This tributary used to have its head at the location of the Ash Basin Because of
this, it was suspected that the clay berm which creates the dam for this ash basin
may be leaking into this waterbody Therefore, a requirement to do quarterly
Facitity Information
A phcant/Facility Name:
CP&L / Mayo Steam Electric Generating Plant
Applicant Address
10660 Boston Road, Roxboro, NC 27573
Facility Address
US HW 501, Northeast of Roxboro
Permitted Flow
Not Limited
Type of Waste
Industrutl - 99 8%
Domestic 0 2°c
Facility/Permit Status
Existing/Renewal
County
Person
Stream Characteristics
Receiving Stream
Mayo Resei volr
Stream Classification
C
Subbasin
03 02-05
Drainage Area (m12)
Lake
Summer 7Q10 (cfs)
Lake
Winter 7Q10 (cfs)
Lake
Average Flow (cfs)
Lake
IWC (%).
Lake
Miscellaneous
Regional Office
Raleigh
USGS Topo Quad
I A23SW
Wasteload Allocation Summary
1982 looks as it plant had not yet been completed I-acllrty chd receive permit for
doinestic waste tre lted to Secondaly levels
1987 WLA perfoimed with limits foi vartou� pipe
1991 notes indicate that EPA objected to ptevunn D1aft perntt .ind the hsue5 had
not been settled, therefore facility had been operating without a permit since 1987,
(EPA's reasons for objecting not outlined) WLA was tot combination of pipe
003 (domestic) to the ash pond, (pipe 002) Recommendations included BOD,
TRC, and fecal coliform limits These were dropped after consideration of
dilution involved in this effluent
Metals
Even with a conservative estimate of' 1 2 dilution, mon1to11ng was recommended
Crutchfield Branch
This tributary used to have its head at the location of the Ash Basin Because of
this, it was suspected that the clay berm which creates the dam for this ash basin
may be leaking into this waterbody Therefore, a requirement to do quarterly

CP&L Mayo Steam Electric Generating Plant
NCO038377
Page 2 of 2
monitoring of this waterbody was required in the permit, (Part I, Section C)
Below is the data from the beginning of 1995 to the present.
Total Total Total
Date Copper Arsenic Selenium Comments
June 3, 1996 < 1 1 < 5
March 4, 1996 < 1 < 1 < 1 arsenic
December 6, 1995 99 26 < 1
July 10, 1995 < 20 < 1 < 1
April 27, 1995 < 20 < 1 < 1
January 12, 1995 < 20 < 1 < 1
Proposed Schedule for Permit Issuance
previously
given in mg/l,
now µg/1
Iron 3,400
µg/l - facility
believes this
to be an
anomaly,
probably lab
error as they
were
switching
labs at that
time.
Iron 2,000
µg/l
Iron 2,500
µ/I
Iron 3,600
µg/1
Draft Permit to Public Notice: July 16, 1997
Permit Scheduled to Issue: September 1, 1997
State Contact
If you have any questions on any of the above information or on the attached
permit, please contact Jeff Myhra at [phone] ext 597

Facility Notes for CP& -L Mayo (NC0038377)
May 1, 1997
MEMORANDUM
TO: File
FROM: Jeff Myhra
DATE: May 1, 1997
SUBJECT: Permit file review for CP&L Mayo (NC0038377)
Facility Information:
Qw = Flow Not Limited
Mayo Reservoir
03-02-05
Stream Class:
Mayo Reservoir
C
9-1-57
22-58-15
There are currently two permitted discharge points at the facility (outfall 001 and outfall 002) In
addition, four outfalls (outfalls 004, 005, 006a, b, c, d, e, and 007a, b) were established to
monitor facility stormwater flow. The following is a description of each outfall at the CP&L Mayo
facility (see attached map for outfall locations):
Outfall 001: Cooling tower blowdown. This water is usually directly
mixed with the ash sluice water. Occasionally (once per year maximum (if ever))
it is not mixed with bottom and fly ash and is discharged directly into the ash
pond. Heat exchanger water (low volume waste) is almost continuously
discharged through outfall 001. Approximately once every two years the cooling
towers are drained completely for maintenance. This discharge goes directly to
the Mayo Reservoir. The established permit limits still have to be met with this
discharge (see attached flow chart for further clarification).
• Outfall 002: The ash pond receives ash transport water, coal pile runoff,
stormwater runoff, cooling tower blowdown, and various low-volume wastes
such as boiler blowdown, oily waste treatment, wastes/backwash from the water
treatment processes, plant area wash down water, and equipment heat exchanger
water. The sewage treatment plant effluent is also routed to the ash pond.
• Outfall 003: Domestic sewage use to discharge here. It now discharges
into the ash pond.
• Outfall 004: Drainage from the outside storage area.
• Outfall 005: Drainage from the industrial area and the oil/gas storage area.
• Outfall 006a,b,e.d,e: Drainage from the chemical feed building and the
cooling tower area. l� Ac4e.,, IWd/ �c
✓ 'b-" el l
• Outfall 007a,b: Drainage from the railroad area. �`� � .7 -`o -r ���

Facility Notes for CP<&L Mayo
May 1, 1997
Page 2 of 3
The facility currently has a daily maximum limit of 3 8 lbs/day for selenium Apparently during
the last renewal, CP&L questioned Se as a daily maximum limit The old model run for Se in
Mayo used the 5 µg/1 cntena under design conditions Therefore, the daily maximum limit is
appropriate. This information is dust a FYI I think CP&L will closely scrutinize the Se limit
during this renewal
Special condition 4 under Part I, Section C was included to ensure proper maintenance and
operation of the domestic plant to secondary standards.
Staff report was prepared on March 3, 1997 by Steve Mitchell
• Staff report identified the following constituents as having a possible toxic effect on the
receiving stream Selenium, Arsenic, Cadmium, and Chlorine
• Region recommend reissuance of permit The facility has a history of compliance with
the permit limitations and monitoring requirements
WLA was prepared by Ferrell Keough on 4-6-97 See attached summary sheets (40 CFR
requirements) prepared for modeler review
• Special Condition 3 requires an ongoing study of Crutchfield Branch. The ash pond
was built such that the headwaters of Crutchfield Branch might be affected by the
leaching of metals or other toxicants through the berm into the receiving stream
Samples taken in December 1995 indicated very elevated levels of copper, arsenic, and
selenium.
Arsenic, Copper, and Iron monitoring was added to outfall 002 The following conclusions were drawn
by performing a reasonable potential analysis:
Parameter
Maximum Predicted
Concentration
Gtg/O
Allowable
Concentration
Arsenic
46 8 g/1
26 0 µg/l
Copper
8.5 0 µg/1
50 0 µg/l
Iron
1 2 mg/1
0 6 m g/1
The monitoring requirements for the parameters listed above were included in the draft due to the
fact that the maximum predicted concentration for each parameter, determined by performing a
reasonable potential analysis, is greater than the allowable concentration as stated above

Facility Notes for CP&L Mayo
May 1, 1997
Page 3 of 3
Upon review of the available DMR data, it was noticed that data was missing for the following two
months : 5-96 and 6-96. I contacted Ricky Miller on 1-14-97 to discuss this issue. Evidently they
were in a maintenance outage during these two months.
The existing permit listed specific stormwater definitions under the Part III "Other requirements;
Special Condition G." These definitions were removed from the special conditions section since
they are covered in the boilerplate language under Part III, Section A of the draft permit.
pH monitoring was added to outfall 001 and outfall 002. Monitoring for pH is required as per 40
CFR 423.12 (b)(1) BPT.

'_ _ _ --t �iLt_e � %`�''S C9'%��,� � �L2�� E� -•vn11%62 Ce_Utclti��Fle�, �elaNCl-I
'� -L- 3j(G

FOR APPROPRIATE DISCHARGES, LIST COMPLETE GUIDELINE LIMITATIONS BELOW
Effluent haractg�ri
outrall 060t
Monthly
.A.ver4ge
Daily Maximum
-
Comments
H
Shall be in the ran e of 6.0 to 9.0.
40 CFR 423.12 (b)(1) BPT
TS S2
30.0 m
100 0 m
40 CFR 423 12 (b)(3) BPT
Oil, and Grease
15.0 m
20.0 m
40 CFR 423.12 (b)(3) BPT
Free Available Chlorine
0.20 m
0.50 m
40 CFR 423 13 (d)(1.) BAT
126 Priority Pollutants
No Detectabae Amount
40 CFR, 423.13 (d)(1) BAT
Chromium, Total
0.20 mgil
0.20 m
40 CFR 423.13 (d) (1) BAT
Zinc, Total
10 m
10 m
40 CFR 423 13 (d)(1) BAT
40 CFR 423 13 (d)(2) BAT
40 CFR 423.13 (d)(3) BAT
Cooling tower blowdown. This water is usually directly mixed with the ash sluice water. Occasionally (once per year maximum
(if ever)) it is not'mixed with bottom and fly ash and is discharged directly into the ash pond. Heat exchanger water, (low volume
waste) is almost continuously discharged out 001 Approximately once every two years the cooking towers are drained
completely for maintenance. This discharge goes directly to the Mayo Reservoir. The established permit limits still have to be met
with this discharge, (see attached flow chart for further, clanfication).
2, This provision applies to outfall 001 since low volume wastewater is discharged through this outfall. I believe these limits were
not applied to this outfall in the last renewal because these parameters are monitored at outfall 002 Outfall 001 discharges into
the ash pond and the ash pond then discharges into the Mayo Reservoir through outfall 002 The limits are being met at outfall
002 so it would not make sense to monitor there parameters at outfall 001. See attached flow diagram for clarification
Type of PriiAiict Produced
Mwe P66dikid
Effluent Gu,idelines ReNrence
Electricity (the facility is an electric
745
40 CFR Part 423 - Steam Electric Power
generating plant using coal-fired boilers to
Generating Point Source Category
produce steam for turbine generators with a
combined net capacity of 745 MWe.

FOR APPROPRIATE DISCHARGES, LIST COMPLETE GUIDELINE LIMITATIONS BELOW
u[en haracteristi,cs
0!! aall 'P ]G
Monthly
Av rag -7...
Daily Maximum
comments
H
TSS
Shall be in the range,
of 6.0 to 9 0.
-11
40 CFR 423 12 (b)(1) BPT
Oil & Grease
30.0 m
15.0
10 0. 0 T mg
40 CFR 423 2 (b)(3) BPT
Free Available Chlonne2
m
0 20 m
20.0 mo
0 5'0 m
40 CFR 423 12 (b)(3) BPT
40 CFR 423.13 (d)(1) BAT
126 Priority, Pollutants
' No Detectable Amount
40 CFR 423.13 (d)(1) BAT
Chromium, Tota12
0 20 m
0.20 m
40 CFR 423.13 (d) (1) BAT
Zinc, Totah o �„
1.0 m
'10 m
40 CFR 423.13 (d) (1) BAT
40 CFR 423.13 (d)(2) BAT
40 CFR 423 3 (d)(3 BAT
The ash pond receives ash transport water coal pile runoff, stormwater runoff, cooling tower blowdown, and vanou low
volume wastes such as boiler blowdown, oily waste treatment, wastes/backwash from the water treatmen processes plant area
wash down water, and equipment heat exchanger water. The sewage treatment plant effluent is also routed to the ash pond
These parameters are monitored at outfall 001. Outfall 001 discharges into the ash pond. The ash ,pond discharges into the Mayo
Reservoir through outfall 002. See attached flow diagram for clarification.
Ty -0e of Piodu_cT7Fr_Mu&da
ro uce
dent Guid0ifies Raki6ce
Electricity (the facility is an electric
generating plant using coal-fired boilers to
produce steam for turbine generators with a
combined net capacity of 745 MWe
745
40 CFR Part 423 Steam Electric Power
Generating point Source Categoy

MEMORANDUM
SUBJECT:
Facility Review Questions for CPc&L, Mayo
May 2, 1997
Dave GoodripJi
Jeff Myhra
May 2, 199
Review Questions for CP&L Mayo (NC0038377)
The following is a list of questions I came up with as I put the draft permit together.
• In reference to stormwater monitoring: The facility acknowledged the fact that they
have not completed EPA form 2F to date. Evidently the facility has been unable to
sample representative stormwater discharges at the outfalls because of abnormal
meteorological conditions. The facility will submit form 2F once th are able to col�ect
a
the proper samples. Is this a major problem?? V G�(41a4l #V- 17-1
• Special Condition 2 requires the subject facility to perform a selenium study. The
results of this study are required to be submitted each year by April 1 for the prior ��, ��O'fp4'
calendar year. To date, this report has not been received Farrell made a call to the ' 1'
facility and it is expected that a copy of the report will be submitted in the near future v
Would this holdup reissuance of the permit??,� l7 �, F P'� � (.-,���t��8�0s1 «,
• I assumed that the stormwater monitoring requirements as stated in previous permit
would remain unchanged in the renewal (Page A.(3)) It would probably be a good
idea for us to sit down and discuss this. I really do not know that much about the
stormwater program. D(,
• The following questions pertain to the "new" boilerplate language for CP&L facilities
(the format that you e-mailed to me):
• Under Part II ... I assume that the facility has already prepared ae r,,
Stormwater Pollution Prevention Plan since this language was included,'' L� J
in the last permit cycle. I did not see record of this in the permit file.
Should this language be included again? I kept this language in the draft
permit.
• On the Supplement to Permit Cover Sheet .... Part V " Limitations
Reopener" language was not included in last permit cycle. I included it .
as part of the draft permit since it is part of the new boilerplate language
you sent to me.
• On the Supplement to Permit Cover Sheet The second to last
paragraph " Any other wastewater. " was included to the draft since it
was included in the last permit cycle This language was not part of the /
new boilerplate you sent to me Should it be included as part of the
draft?
• On the Supplement to Permit Cover Sheet . I mcltided Part II
"Stormwater Monitoring, Controls and Limitations for Permitted

Facility Review
May 2, 1997
Page 2 of 2
Questions for CP&L Mayo
Discharges." I assume this is how we should reference these
conditions. All the language in the existing permit is covered under the {/
new boilerplate just in a different order.
• On the Supplement to Permit Cover Sheet .... I deleted Part III "Other
Requirements" on existing permit. I revised this to match the boilerplate
you sent to me. Special conditions are now covered under Part I,
/ Section C.
v Under Part II ... The language in the new boilerplate, under Minimum
Monitoring and Reporting Requirements, you sent to me is somewhat as
different than what was listed in the last permit cycle. Paragraphs a, b,
c, d, e, and f are all new This text was not included in last permit
cycle. Should I keep it in the draft permit?
Under Part III, Section A . The definition for Representative Storm��
• Event (Number 16) was somewhat different in the last permit cycle. Ir
included the definition as stated in the existing permit not what was
listed in the boilerplate language you sent to me.
• Should the 126 Priority Pollutant analysis be applied to outfall 001 or outfall 002?
Does it make sense to perform this monitoring at outfall 001 since 001 is an internal `U
outfall (see outfall descriptions under facility notes)? The existing permit has the 126 I,t
priority pollutant analysis (performed monthly by grab sample) at outfall 001 and the
priority pollutant analysis (performed annually by grab sample) at outfall 002. Maybe
the monitoring at 001 was the old APAM monitoring and we should actually apply the
priority pollutant analysis at 002. The WLA only indicated priority pollutant analysis at
001. What do you think?
• In Susan's notes from the last renewal, she stated that the facility requested a reduction CG�!
in monitoring from 2 / month to monthly. Evidently this was not possible in 1995, but (%
she stated that it may be possible at time of renewal. Let's sit down and discuss the
monitoring frequencies here.

F
1,
To: Permits and gi erin nit
Water Qu ity Section
Attent ' n: ,Lef f Myrha^
Date c
NPDES STAFF REPORT AND RECOMMENDATION
County--P-ex-s-on
Permit No. NC0038377
PART
I - GENERAL INFORMATION
1.
Facility and Address:CP & L Mayo
2.
Date of Investigation:March 3, 1997
3.
Report Prepared by: S. Mitchell
4.
Persons Contacted and Telephone Number:Ricky Miller
362-3566F
�6Z-3Zb
��
5.
Directions to Site:501 n to Bethel Hill. Right
CD
to
plant.
6.
Discharge Point(s), List for all discharge points:
Latitude: 36"31'15" 001 Longitude: 78952'56
Latitude: 36"3203_ 002 Longitude: 78953'27
Attach a USGS map extract and indicate treatment
facility site and discharge point on map.
U. S. G. S. Quad No. --A2.3_S-W—U . S. G. S. Quad Name C1ust-e-r-
B-ps in gs-_
7. Site size and expansion area consistent with
application ? Yes
Yes No If No, explain:
8. Topography (relationship to flood plain included):
rolling hills
9. Location of nearest dwelling:1/2 mile
10. Receiving stream or affected surface waters:
MAYO LAKE
a. Classification:C
b. River Basin and Subbasin No.:Roanoke 030205
C. Describe receiving stream features and
pertinent downstream uses:Mayo Reservoir

PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: 0-012.5
MGD(Ultimate Design Capacity)
b. What is the current permitted capacity of the Waste
Water Treatment facility?0.0125 MGD
C. Actual treatment capacity of the current facility
(current design capacity)?0.0125 MGD
d. Date(s) and construction activities allowed by previous
Authorization to Construct issued in the previous two years:
e. Please provide a description of existing or
substantially constructed wastewater treatment facilities:
001 discharge from Cooling Towers
002 discharge from Low Volume Wastes (coal pile, package
plant),
f. Please provide a description of proposed wastewater
treatment facilities:
g. Possible toxic impacts to surface waters:Se, As, Cd, C1
h. Pretreatment Program (POTWs only):
in development approved
should be required not needed
2. Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please specify DEM
permit no.
Residual Contractor
Telephone No.
b. Residuals stabilization: PSRP
PFRP Other
c. Landfill:
d. Other disposal/utilization scheme (Specify):On site in
ash pond
3. Treatment plant classification (attach completed rating
sheet):
4. SIC Code(s):4911
Wastewater Code(s) of actual wastewater, not particular
facilities i.e.., non -contact cooling water discharge from a
metal plating company would be 14, not 56.
Primary 14 secondary 16-, 12, 60,x$, 70, 73,
Main Treatment Unit Code: D3-%5= 0 — 2

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:None
3. Important SOC, JOC or Compliance Schedule dates: (Please
indicate)
Date
Submission of Plans and Specifications
Begin Construction
Complete Construction
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non -discharge options available. Please provide
regional perspective for each option evaluated.
Spray Irrigation:NA
Connection to Regional Sewer System:NA
SubsurfaceNA
Other disposal options:
5. Other Special Items:
PART IV - EVALUATION AND RECOMMENDATIONS
This facility has a history of compliance with the permit
limitations and monitoring requirements of the NPDES Permit and
the Raleigh Regional Office recommends the renewal of the
discharge permit for a period of time consistent with the river
basin policy.
Signature of report p:Ceparer
�p Water Qua ity Regional Supervisor
Date

cP&L
Carolina Power & Light Company
Mayo Electric Generating Plant
10660 Boston Road
Roxboro NC 27573
Mr. A. Preston Howard, Jr. Director
North Carolina Division of Water Quality
512 N. Salisbury Street
P O. Box 29535
Raleigh, North Carolina 27626-05354
Subject: Carolina Power and Light Company
Mayo Steam Electric Power Plant
National Pollutant Discharge Elimination System (NPDES)
Permit No. NCO038377
Dear Mr. Howard-
On October 28, 1996, Carolina Power & Light Company (CP&L) requested that the NPDES permit for the
Mayo Steam Electric Plant be renewed. At the time the renewal request was made abnormal meteorological
conditions prevented representative stormwater samples, associated with industrial activity, from being
obtained from the applicable outfalls.
Since then CP&L has been able to obtain representative samples from all outfalls except outfall 007. CP&L
has still not been able to collect a sample from discharge point 007, which is drainage form the railroad area.
As a result of conversations and meetings with Bradley Bennett, the Stormwater Supervisor, and with Steve
Mitchell, Raleigh Regional Office, it is believed that this discharge point should be deleted in the new permit
because of the small amount of drainage area and the sufficient buffer area between the discharge points
(A&B) and the lake. This action is further supported because there has not been an opportunity to sample
this discharge location because of the retention time that this drainage area has. CP&L requests that this be
considered when the new permit is issued Enclosed are the 2-F forms required to be submitted.
CP&L appreciates the continued cooperation demonstrated by the NCDWQ staff. If there are any questions
regarding the information provided, please contact Mr. Ricky Miller at [phone].
Sincerely,
Rodney W. Patefield
Mayo E. G. Plant - Manager
DFP/dfp
Enclosures
c: Mr. Dave Goodrich, Permits Supervisor
10660 Boston Road Tel [phone] Fax [phone]
JUL 1 0 1997 —'
C—
On October 28, 1996, Carolina Power & Light Company (CP&L) requested that the NPDES permit for the
Mayo Steam Electric Plant be renewed. At the time the renewal request was made abnormal meteorological
conditions prevented representative stormwater samples, associated with industrial activity, from being
obtained from the applicable outfalls.
Since then CP&L has been able to obtain representative samples from all outfalls except outfall 007. CP&L
has still not been able to collect a sample from discharge point 007, which is drainage form the railroad area.
As a result of conversations and meetings with Bradley Bennett, the Stormwater Supervisor, and with Steve
Mitchell, Raleigh Regional Office, it is believed that this discharge point should be deleted in the new permit
because of the small amount of drainage area and the sufficient buffer area between the discharge points
(A&B) and the lake. This action is further supported because there has not been an opportunity to sample
this discharge location because of the retention time that this drainage area has. CP&L requests that this be
considered when the new permit is issued Enclosed are the 2-F forms required to be submitted.
CP&L appreciates the continued cooperation demonstrated by the NCDWQ staff. If there are any questions
regarding the information provided, please contact Mr. Ricky Miller at [phone].
Sincerely,
Rodney W. Patefield
Mayo E. G. Plant - Manager
DFP/dfp
Enclosures
c: Mr. Dave Goodrich, Permits Supervisor
10660 Boston Road Tel [phone] Fax [phone]

OUTFALLS
Narrative Description
Outfall 004 - Drainage From Outside Storage
This outfall is located on the west side of the plant site and drains to the reservoir, using
catch basins and storm sewer. The industrial activity drained to this outfall is primarily
the facility's outside storage area including a loading dock. Materials that are not weather
sensitive are stored in this area. These include empty lubricant drums, structural steel,
pipes, and some large equipment parts Virtually the entire area is loose gravel, except
for the unloading dock which is concrete. There is a small storage shed in the back of the
outside storage area. This shed contains any chemicals or oils that would be stored in this
area.
Outfall 005 - Drainage From Industrial Area
The outfall is located on the west side of the facility and is the end point of the plant's
primary storm sewer system that drains the "power block" of the plant, including the area
around the boilers and turbine buildings (both are open, no roof or walls), precipitators,
and the roofs of the machine shops, administrative buildings, warehouse, parking lot, and
miscellaneous support facilities, such as the water supply treatment, ash storage silo, and
transformers. Also draining to this outfall through sewers is the grassed area intended for
Unit 2 at some time in the future. The potential pollutants that could be in this discharge
include coal, coal ash, sediment, and the chemical make-up of the rain water.
Outfall 006a b.,c,d,e - Cooling Tower Area
Outfall 006 is located at the eastern end of the site and drains the area around the cooling
towers, including the roof of the chemical feed building and associated roads and parking.
There are five separate outfalls in the cooling tower area. All these outfalls involve catch
basins ans storm sewers that drain to swales and then to the reservoir. The cooling tower
itself has a basin for recirculating cooling water and therefore, does not directly contribute
to storm water runoff. The potential pollutants that could be in this discharge could
include sediment and the chemical make-up of the rain water.
Outfall 007a,b - Drainage From Railroad Area
Outfall 007 drains the terminal end of the railroad spur used to temporarily store coal
cars. This outfall discharges to a swale that leads to the reservoir. The distance along this
swale to the reservoir is approximately 300 yards through natural vegetation and a pine
tree stand. Based on the area and discharge make-up, no potential pollutants would be
expected.
DISC\OUTFALLS EH\KJ

Carolina Power & Light Company
Mayo Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NCO038377
2 F Form
ATTACHMENT 3
IV C
Narrative Description
Taken from the Mayo Steam Electric Plant's
Storm Water Pollution Prevention Plan

MATERIAL HANDLING
Four areas of coal handling were evaluated for their potential to create dust or particles. Also the
methods of controlling the dust were evaluated to ensure they were satisfactory in maintaining
dust control. The areas evaluated were the coal car dumper, transfer boom, conveyor belt system
and coal pile.
The primary method of coal car unloading at the Mayo Plant is the coal car dumper. The coal car
dumper is equipped with a dust suppression system that is used to minimize the generation of
dust clearing coal car unloading. Water spray nozzles are positioned such that as the coal car is
dumped into the transfer pit, the spray suppresses any dust that could be created due to the
unloading activity. Different conditions such as wind, rain and coal condition dictate the need
for the dust suppression system. Whenever the operators feel the system is needed, it will be
used to prevent the creation of a dust that could enter the storm water system.
Another operation where there is the potential to create dust is the transfer of coal from the
conveyor belts to the coal pile. Dust is controlled by the raising or lowering of the boom tower,
as needed, to minimize dust.
The conveyor belt system was evaluated for its potential to create dust. The possibility of the
conveyor belt system to create dust or come in contact with storm water has been reduced
because the system is covered. Efforts are made to ensure the conveyor belts stay covered.
The coal pile is known as a "live pile". This is because of the way coal is fed into the unit. Coal
is pulled from the bottom of the pile, therefore reducing the possibility of dust. Storm water that
comes in contact with the coal pile is routed to an NPDES discharge point 002.
EH kI/DISC/MATLHDLG

Carolina Power & Light Company
Mayo Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NCO038377
2 F Form
ATTACHMENT 4
V1
Significant Leaks or Spills
Taken from the Mayo Steam Electric Plant's
Storm Water Pollution Prevention Plan

F -Z
40 1 - s'
Completed by: E1 i 7ah th Hutchins
LIST OF SIGNIFICANT SPILLS AND LEAKS
Title: rn�neexing Techrni ri an
Date: March 1996
Directions- Record below all significant spills and significant leaks of toxic or hazardous pollutants that have occurred at the
facility in the three years prior to the effective date of the permit
Definitions Significant spills include, but are not limited to, release of oil or hazardous substances in excess of reportable
quantities
1st Year Prior
Description
Response Procedure
Date
Location
Preventive
Material No
(month/day/year)
Spill Leak (as indicated
Type of
Am
Amount of
Longer Exposed
1\1easures
on site map)
Material Quantity Source, if Known
Reason
Material
to Storm Water
Taken
Recovered
(Trac/False)
X Fuel Oil
Fuel Oil 250 Fuel oil
Pipe
250 gals
True
Pipe
Storage
gals relief valve
failurE
repaired
2nd Year Prior
Description
Response Procedure
Date
Location
Preventive
nlatcri.rl No
(month/day/year)
Spill
Leak
(as indicated
Type of
Amount of
Longer Exposed
pleasures
Oil site map)
Material
Quantity
Source, if Kuown
Reason
Alaterial
to Storm Water
Taken
Recovered
(Ti uc/False)
3rd Year Prior
Description
Response Pr ocedure
Date
Location
Preventive
Material No
(monlli/day/yeas)
Spill
Leak
(as ►ndicated
Type of
Amount of
Longer Exposed
Measures
on site map)
)\'falci ial
Quantity
Source, if Known
Reason
I17aterial
to Storni Water
Taken
Recovered
(True/False)
X
I
ILake Intake
Oil
1 cit.Make—up
Pump
Over—
1 quar
True
Booms
Motor
filled
kept on
tianil