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NC0038377_Final Permit_20070410
OF WATF'Q \O� o� ©*A co bul r NCDENR > Mr Larry E. Hatcher, Plant Manager Progress Energy Carolinas, Inc Mayo Electric Generating Plant 10660 Boston Road Roxboro, North Carolina 27574 Dear Mr Hatcher Michael F Easley Governor William G Ross, Jr, Secretary North Carolina Department of Environment and Natural Resources April 10, 2007 Alan W Klimek, P E , Director Division of Water Quality Subject Issuance of NPDES Pernut Permit NCO038377 Mayo Electric Generating Plant Person County Division personnel have reviewed and approved your application for renewal of the subject permit Accordingly, we are forwarding the attached NPDES discharge permit This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 1 and the Memorandum of Agreement between North Carolina and the U.S Environmental Protection Agency dated May 9, 1994 (or as subsequently amended) This final permit includes the following major changes from the draft permit sent to you on January 31, 2007: The compliance schedule of 24 months was added for the following parameters Be, Cd, Cr, F, Pb, Mn, Ba, Tl, and V The issue of Chlorides limit will be addressed when Progress Energy submits modeling information that was requested by the Division The Division of Water Quality has reviewed your request to provide an additional 12 months to the mercury limit compliance schedule This request cannot be granted since Mercury is a parameter of concern and the FGD system is expected to contribute a significant amount of Mercury to the effluent The Division has reviewed your request to reduce the monitoring frequency for all parameters for Outfall 002 and Outfall 009 This request cannot be granted The proposed treatment system is innovative and has an extremely hmited record for the proposed use Therefore, weekly monitoring is needed to closely monitor the performance of the system In addition, the new information provided by Progress Energy indicates that there is some uncertainty in the flow volume from the Ash pond, which makes the need for collecting more data even more urgent. You may request reduction after 12 months of monitoring is completed and if the system performs satisfactorily If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings N C Division of Water Quality / NPDES Unit Phone (919) 733-5083 1617 Mail Service Center, Raleigh, NC 27699-1617 fax (919) 733-0719 Internet h2o enr state nc us DENR Customer Service Center 1 800 623-7748 I Letter to Mr Hatcher, page2 (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. Please note that this permit is not transferable except after notice to the Division The Division may require modification or revocation and reissuance of the permit This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be required If you have any questions concerning this permit, please contact Sergei Chernikov at telephone number (919) 733-5083, extension 594. Sincerely, Alan W Klimek, P.E. cc- Central Files (NPDES-Files _ E Raleigh Regional Office / Surface Water Protection Section Aquatic Toxicology Unit Mr Roosevelt Childress, EPA Region IV Environmental Sciences Section, Biological Assessment Unit Shari L Bryant, Piedmont Region Coordinator, North Carolina Wildlife Resources Commission t - Permit No NCO038377 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Carolina Power and Light d/b/a/ Progress Energy Carolinas, Inc. is hereby authorized to discharge wastewater from a facility located at the Mayo Steam Electric Generating Plant off of US Highway 501 northeast of Roxboro Person County 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 I, II, III, and IV hereof. The permit shall become effective May 1, 2007. This permit and the authorization to discharge shall expire at midnight on March 31, 2012 Signed this day April 10, 2007. n /Alan Klimek, P E , Director Division of Water Quality By Authority of the Environmental Management Commission Permit No. NCO038377 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein Carolina Power and Light d/b/a/ Progress Energy Carolinas, Inc. is hereby authorized to: 1. Continue to operate the following systems located at Mayo Steam Electric Generating Plant, off of US Highway 501, northeast of Roxboro, Person County: • Cooling Tower System (Outfall 001). Less than once per year the cooling towers and circulating water system are drained by gravity and discharged directly to Mayo Reservoir. Ash Pond Treatment System (Outfall 002). Outfall 002 discharges directly to Mayo Reservoir. 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, equipment heat exchanger water, and treated domestic wastewater Internal Outfall 008. Cooling tower blowdown is directly discharged to the ash pond. Cooling tower blowdown is usually mixed with ash sluice water prior to discharge to the ash pond. Cooling tower blowdown is indirectly discharged to Mayo Reservoir via the ash pond treatment system (Outfall 002). • Internal Outfall 009. Discharge from the FGD blowdown treatment system. • Stormwater Discharge System The facility is permitted to discharge stormwater to Mayo Reservoir through the following outfalls - Outfall 004 - Drainage from the outside storage area. Outfall 005 - Drainage from the industrial area and the oil/bottled gas storage area. Outfalls 006a, 006b, 006c, 006d, 006e - Drainage from the cooling tower(s) chemical feed building structure and the cooling tower area 2. Discharge from said treatment works and/or outfalls at the locations specified on the attached maps into Mayo Reservoir, which is classified as WS -V waters in the Roanoke River Basin. Permit NCO038377 A. (1 ) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [001] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 001 (Cooling Tower System) Monitoring is required only during discharge events to the Mayo reservoir Such discharges shall be limited and monitored by the Permittee as specified below PARAMETER LIMITS MONITORING REQUIREMENTS Monthly Daily Average Maximum Measurement Sample Type Sample Frequency Locationl Flow Daily Pump Logs or similar readings Effluent Free Available Chlonne2 200 pg/L 500 Ng/L Weekly Grab Effluent Time of Chlorine Addition2 2 hours Weekly Logs Total Chromium3 0 2 mg/L 0 2 mg/L 2 / Month Grab Effluent Total Zinc3 10 mg/L 10 mg/L 2 / Month Grab Effluent Priority Pollutants 3 No Detectable Amount Annual Grab Effluent H > 6 0 and < 9 0 standard units Weekly Grab Effluent Notes: 1 Samples taken in compliance with the monitoring requirements listed above shall consist of cooling tower effluent prior to its discharge to Mayo Reservoir 2 Monitoring is required only if chlorine -based compounds is added to the system 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 demonstrates to the Division of Water Quality that discharge for more than two hours is required for macroinvertebrate control The 500 pg/l limitation is an instantaneous maximum and is to be measured during the chlorine release period The 200 pg/1 limitation is an average during the chlorine release period Simultaneous multi -unit chlorination is permitted 3 Limitations and monitoring requirements for the 126 Priority Pollutants (per 40 CFR Part 423, Appendix A, exclusive of zinc and chromium) apply only if 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 calculations which demonstrate that the regulated pollutants are not detectable in the final discharge by the analytical methods in 40 CFR Part 136 All primary industries are required to submit a priority pollutant analysis in accordance with 40 CFR Part 122 with their application for permit renewal The above listed effluent limitations shall be sampled prior to draining the cooling tower(s), at a location prior to discharge to Mayo Reservoir There shall be no discharge of polychlorinated biphenyl compounds such as those commonly used for transformer fluid Permit NCO038377 A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [008] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 008 (internal outfall, Cooling Tower System) Such discharges shall be limited and monitored by the Permittee as specified below PARAMETER LIMITS MONITORING REQUIREMENTS Monthly Daily Average Maximum Measurement Frequency Sample Sample Type Locationl Flow Daily Pump Logs or Effluent similar readings Free Available Chlonne2 200 Ng/L 500 Ng/L Weekly Grab Effluent Time of Chlorine Addition2 2 hours Weekly Logs Total Chromium3 0 2 mg/L 0 2 mg/L 2 / Month Grab Effluent Total Zinc3 1 0 mg/L 1 0 mg/L 2 / Month Grab Effluent Priority Pollutants 3 No Detectable Amount Annual Grab Effluent H > 6 0 and < 9 0 standard units Weekly Grab Effluent Notes - 1 . 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 Monitoring is required only if chlorine -based compound is added to the system 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 demonstrates to the Division of Water Quality that discharge for more than two hours is required for macroinvertebrate control The 500 pg/l limitation is an instantaneous maximum and is to be measured during the chlorine release period The 200 µg/l limitation is an average during the chlorine release period Simultaneous multi -unit chlorination is permitted 3 Limitations and monitoring requirements for the 126 Priority Pollutants (per 40 CFR Part 423, Appendix A, exclusive of zinc and chromium) apply only if 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 calculations which demonstrate that the regulated pollutants are not detectable in the final discharge by the analytical methods in 40 CFR Part 136 All primary industries are required to submit a priority pollutant analysis in accordance with 40 CFR Part 122 with their application for permit renewal This outfall is not authorized to discharge directly to the Mayo Reservoir Permit NC0038377 A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [002 without FGD wastewater] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 002 (Ash Pond Treatment System) Such discharges shall be limited and monitored by the Permittee as specified below PARAMETER LIMITS MONITORING REQUIREMENTS Monthly Daily Average Maximum Measurement Sample Sample Frequency Type Locationl Flow Weekly Pump Logs or similar readings Effluent Oil and Grease 15 0 m /L 20 0 m /L Monthly Grab Effluent Total Suspended Solids 30 0 m /L 100 0 m /L Monthly Grab Effluent Total Selenium2 3 8 lbs/day 2 / Month Grab Effluent Acute Toxicit 3 Quarterly Grab Effluent Total Arsenic4 Quarterly Grab Effluent Total Copper Quarterly Grab Effluent Total Iron Quarterly Grab Effluent pH > 6 0 and < 9 0 standard units 2 / Month Grab Effluent Notes: 1 Samples taken in compliance with the monitoring requirements listed above shall be taken prior to mixing with other waste streams 2 See A. (8). 3 Acute Toxicity (Fathead Minnow 24hr) No significant mortality at 90%, February, May, August, and November, See A. (7). 4 See A. (13). After the FGD treatment system is used to treat FGD wastewater, the effluent limits in Conditions A. (4) and A (5) apply 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 waste may be discharged to the ash pond There shall be no discharge of polychlorinated biphenyl compounds such as those commonly used for transformer fluid Permit NCO038377 A. (4) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [002 with FGD wastewater] During the period beginning upon commencement of the FGD treatment system to treat FGD wastewater and lasting until expiration, the Permittee is authorized to discharge from Outfall 002 (Ash Pond Treatment System) Such discharges shall be limited and monitored by the Permittee as specified below PARAMETER Monthly Average LIMITS Weekly Average Daily Maximum MONITORING REQUIREMENTS Measurement Sample Type Sample Frequency Locationl Flow Weekly Pump Logs or similar readings Effluent Oil and Grease 15 0 m /L 20 0 m /L Monthly Grab Effluent Total Suspended Solids 30 0 m /L 100 0 m /L Monthly Grab Effluent Total Selenium 3 8 lbs/day Weekly Grab Effluent Acute Toxicit 2 Quarterly Grab Effluent Total Mercury3,5 0 012 Ng/L Weekly Grab Effluent Total Arsenic4 Weekly Grab Effluent Total Ber Ilium5 0 0068 Ng/L Weekly Grab Effluent Total Cadmium5 2 0 pg/L Weekly Grab Effluent Total Chlorides 230 m /L Weekly Grab Effluent Total Chromium5 50 0 pg/L Weekly Grab Effluent Total Copper Weekly Grab Effluent Total Fluoride5 18 mg/L Weekly Grab Effluent Total Lead5 25 0 Ng/L 33 8 Ng/L Weekly Grab Effluent Total Man anese5 200 0 Ng/L Weekly Grab Effluent Total Nickel Weekly Grab Effluent Total Silver Weekly Grab Effluent Total Zinc Weekly Grab Effluent Total Barium5 10 mg/L Weekly Grab Effluent Total Thallium5 0 35 Ng/L Weekly Grab Effluent Total Vanadium5 24 0 Ng/L Weekly Grab Effluent Total Iron Quarterly Grab Effluent H > 6 0 and < 9 0 standard units 2 / Month Grab Effluent Notes- 1 Samples taken in compliance with the monitoring requirements listed above shall be taken prior to mixing with other waste streams 2 Acute Toxicity (Fathead Minnow 24 -hr) No significant mortality at 90%, February, May, August, and November [see A. (7)] 3 The mercury limit will take effect one year after commencement of the FGD system to treat FGD wastewater 4 See A. (13). 5. The limit becomes applicable 24 months after the commencement of the FGD system After the FGD treatment system is used to treat FGD wastewater, the effluent limits in Conditions A. (4) and A (5) apply Progress Energy shall inform this office as well as the Raleigh Regional Office, via phone call and via letter, as to when the FGD treatment system will be used to treat FGD wastewater 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 waste may be discharged to the ash pond There shall be no discharge of polychlorinated biphenyl compounds such as those commonly used for transformer fluid Permit NCO038377 A. (5) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [009] During the period beginning upon commencement of the FGD treatment system to treat FGD wastewater and lasting until expiration, the Permittee is authorized to discharge from Internal Outfall 009 (treated FGD wet scrubber wastewater) Such discharges shall be limited and monitored by the Permittee as specified below PARAMETER LIMITS MONITORING REQUIREMENTS Monthly Daily Measurement Sample Sample Average Maximum Frequency Type Locationl Flow Monthly Instantaneous E Total Suspended Solids Weekly Grab E Total Mercury Weekly Grab E Total Selenium Weekly Grab E Total Arsenic Weekly Grab E Total Beryllium Weekly Grab E Total Cadmium Weekly Grab E Total Chlorides Weekly Grab E Total Chromium Weekly Grab E Total Copper Weekly Grab E Total Fluoride Weekly Grab E Total Lead Weekly Grab E Total Manganese Weekly Grab E Total Nickel Weekly Grab E Total Silver Weekly Grab E Total Barium Weekly Grab E Total Thallium Weekly Grab E Total Vanadium Weekly Grab E Total Zinc Weekly Grab E Notes: 1 E — Effluent from the FGD treatment system prior to discharge to the Ash Pond A. (6) STORMWATER MONITORING REQUIREMENTS/ Qualitative Monitoring Qualitative monitoring requires a qualitative inspection of each stormwater outfall, regardless of representative outfall status, for the purpose of evaluating the effectiveness of the Stormwater Pollution Prevention Plan and assessing new sources of stormwater pollution No analytical tests are required Qualitative monitoring of stormwater outfalls does not need to be performed during a representative storm event Stormwater Discharge Characteristics Measurement Fre uenc 1 Sample Location Color Semi -Annual Stormwater Discharge Outfall Odor Semi -Annual Stormwater Discharge Outfall Clarity Semi -Annual Stormwater Discharge Outfall Floating Solids Semi -Annual Stormwater Discharge Outfall Suspended Solids Semi -Annual Stormwater Discharge Outfall Foam Semi -Annual Stormwater Discharge Outfall Oil Sheen Semi -Annual Stormwater Discharge Outfall Other obvious indicators of stormwater eollution Semi -Annual Stormwater Discharge Outfall Notes: 1. Measurement Frequency Qualitative monitoring will be performed twice per year, once in the spring (April - June) and once in the fall (September - November) Permit NCO038377 A. (7) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (Quarterly) Outfall 002 (Ash Pond) The permittee shall conduct acute toxicity tests on a puarlerlu basis using protocols defined in the North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions) The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test The effluent concentration at which there may be at no time significant acute mortality is 90% (defined as treatment two in the procedure document). Effluent samples for self-monitoring purposes must be obtained during representative effluent discharge below all waste treatment The tests will be performed during the months of February, May, August and November. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter code TGE6C. Additionally, DWQ Form AT -2 (original) is to be sent to the following address Attention. North Carolina Division of Water Quality Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemical/ physical measurements performed in association with the toxicity tests, as well as all dose/response data Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until such time that a single test is passed Upon passing, this monthly test requirement will revert to quarterly in the months specified above Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits NOTE- Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring A. (8) SELENIUM STUDY The Permittee shall conduct biological and physical/ chemical studies on selenium and its effect in the reservoir The results shall be submitted each year by May 1 for the prior calendar year. The plan of study shall be submitted to the Director of the Division of Water Quality for approval Permit NCO038377 A. (9) CRUTCHFIELD BRANCH There shall be no direct discharge of wastewater from the ash pond to Crutchfield Branch There shall be no violation of water quality standards in Crutchfield Branch due to any indirect discharge from the ash pond The Permittee shall monitor the waters cf Crutchfield Branch, 100 yards downstream of the dike, once per year by grab sample for the following arsenic, copper, and selenium A. (10) DOMESTIC WASTEWATER TREATMENT PLANT The domestic wastewater treatment plant shall be properly operated and maintained to ensure treatment of domestic wastewater to secondary levels A. (11) STORMWATER POLLUTION PREVENTION PLAN The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as the Plan The Plan shall be considered public information in accordance with Part Il, Section E 10 of this permit The Plan shall include, at a minimum, the following items a Site Plan- The site plan shall provide a description of the physical facility and the potential pollutant sources which may be expected to contribute to contamination of regulated stormwater discharges The site plan shall contain the following (1) A general location map (USGS quadrangle map, or appropriately drafted equivalent map), showing the facility's location in relation to transportation routes and surface waters, and the name of the receiving water(s) to which the stormwater outfall(s) discharges. If the discharge is to a municipal separate storm sewer system, the name of the municipality and the ultimate receiving waters, and accurate latitude and longitude of the point(s) of discharge must be shown (2) A narrative description of storage practices, loading and unloading activities, outdoor process areas, dust or particulate generating or control processes, and waste disposal practices (3) A site map (or series of maps) drawn to scale with the distance legend indicating location of industrial activities (including storage of materials, disposal areas, process areas, and loading and unloading areas), drainage structures, drainage areas for each outfall and activities occurring in the drainage area, building locations and impervious surfaces, the percentage of each drainage area that is impervious. For each outfall, a narrative description of the potential pollutants which could be expected to be present in the regulated stormwater discharge (4) A list of significant spills or leaks of pollutants that have occurred at the facility during the 3 previous years and any corrective actions taken to mitigate spill impacts (5) Certification that the stormwater outfalls have been evaluated for the presence of non- stormwater discharges. The certification statement will be signed in accordance with the requirements found in Part II, Section B.11. b. Stormwater Management Plan- The stormwater management plan shall contain a narrative description of the materials management practices employed which control or minimize the exposure of significant materials to stormwater, including structural and non-structural measures. The stormwater management plan, at a minimum, shall incorporate the following - (1) A study addressing the technical and economic feasibility of changing the methods of operations and/or storage practices to eliminate or reduce exposure of materials and processes to stormwater. Wherever practicable the permittee should consider covering storage areas, material handling operations, manufacturing or fueling operations to Permit NCO038377 prevent materials exposure to stormwater In areas where elimination of exposure is not practicable, the stormwater management plan shall document the feasibility of diverting the stormwater runoff away from areas of potential contamination (2) A schedule to provide secondary containment for bulk storage of liquid materials, storage of Section 313 of Title III of the Superfund Amendments and Reauthorization Act (SARA) water priority chemicals, or storage of hazardous materials to prevent leaks and spills from contaminating stormwater runoff If the secondary containment devices are connected directly to stormwater conveyance systems, the connection shall be controlled by manually activated valves or other similar devices [which shall be secured with a locking mechanism] and any stormwater that accumulates in the containment area shall be at a minimum visually observed prior to release of the accumulated stormwater Accumulated stormwater shall be released if found to be uncontaminated Records documenting the individual making the observation, the description of the accumulated stormwater and the date and time of the release shall be kept for a period of five years. (3) A narrative description of Best Management Practices (BMPs) to be considered such as, but not limited to, oil and grease separation, debris control, vegetative filter strips, infiltration and stormwater detention or retention, where necessary The need for structural BMPs shall be based on the assessment of potential of sources contributing significant quantities of pollutants to stormwater discharges and data collected through monitoring of stormwater discharges (4) Inspection schedules of stormwater conveyances and controls and measures to be taken to limit or prevent erosion associated with the stormwater systems C. Spill Prevention and Response Plan. The Spill Prevention and Response Plan shall incorporate a risk assessment of potential pollutant sources based on a materials inventory of the facility. Facility personnel (or team) responsible for implementing the plan shall be identified in the plan A responsible person shall be on-site at all times during facility operations that have the potential to contaminate stormwater runoff through spills or exposure of materials associated with the facility operations d Preventative Maintenance and Good Housekeeping Program A preventative maintenance program shall be developed The program shall document schedules of inspections and maintenance activities of stormwater control systems, plant equipment and systems Inspection of material handling areas and regular cleaning schedules of these areas shall be incorporated into the program e Training schedules shall be developed and training provided at a minimum on an annual basis on proper spill response and cleanup procedures and preventative maintenance activities for all personnel involved in any of the facility's operations that have the potential to contaminate stormwater runoff Facility personnel (or team) responsible for implementing the training shall be identified in the plan f The Stormwater Pollution Prevention Plan the overall coordination, development, Responsibilities for all components of assignments provided. shall identify a specific position(s) responsible for implementation, and revision to the Plan. the Plan shall be documented and position(s) g Plan Amendment The permittee shall amend the Plan whenever there is a change in design, construction, operation, or maintenance which has a significant effect on the potential for the discharge of pollutants via a point source to surface waters. The Stormwater Pollution Prevention Plan shall be reviewed and updated on an annual basis. The director may notify the permittee when the Plan does not meet one or more of the minimum requirements of the permit Within 30 days of such notice, the permittee shall submit a time schedule to the Director for modifying the Plan to meet minimum requirements The permittee shall provide certification in writing (in accordance with Part III, Standard Conditions, Section B 11 ) to the Director that the changes have been made Permit NCO038377 h Facility Inspections. Inspections of the facility and all stormwater systems shall occur at a minimum on a semiannual schedule, once in the fall (September - November) and once during the spring (April - June) The inspection and any subsequent maintenance activities performed shall be documented, recording date and time of inspection, individual(s) making the inspection and a narrative description of the facility's stormwater control systems, plant equipment and systems. Records of these inspections shall be incorporated into the Stormwater Pollution Prevention Plan. Visual monitoring as required in A(4) Stormwater Monitoring Requirements/ Qualitative Monitoring shall be performed in addition to facility inspections Implementation Implementation of the Plan shall include documentation of all monitoring, measurements, inspections, maintenance activities and training provided to employees, including the log of the sampling data. Activities taken to implement BMPs associated with the industrial activities, including vehicle maintenance activities, must also be recorded All required documentation shall be kept on-site for a period of five years and made available to the Director or his authorized representative immediately upon request. A. (12) STORMWATER MINIMUM MONITORING AND REPORTING REQUIREMENTS Minimum monitoring and reporting requirements are as follows unless otherwise approved in writing by the Director of the Division of Water Quality• a If a facility has multiple discharge locations with substantially identical stormwater discharges that are required to be sampled, the permittee may petition the Director for representative outfall status If it is established that the stormwater discharges are substantially identical and the permittee is granted representative outfall status, then sampling requirements may be performed at a reduced number of outfalls. b Visual monitoring for color, odor, solids, foam, outfall staining, visible sheens and dry weather flow shall be performed at all stormwater discharge outfall locations All visual monitoring shall be documented and records maintained with the Stormwater Pollution Prevention Plan The initial visual monitoring event shall be performed during the Spring of 2006. C. For purposes of the stormwater sampling required in this permit, all samples shall be collected from a discharge resulting from a representative storm event (See definitions in Part II, Section A). Failure to monitor storm events in accordance with the specified frequency shall constitute a violation of this permit If the stormwater runoff is controlled by a detention pond, the following sampling requirements shall apply (1) If the detention pond detains the runoff generated by one inch of rainfall for 24 hours, visual observations for color, foam, outfall staining, visible sheens and dry weather flow are required, but analytical sampling shall not be required (2) If the detention pond discharges only in response to a storm event exceeding a 25 - year, 24-hour storm, the pond shall be considered a non -discharging stormwater control system and not subject to NPDES requirements, unless the discharge causes a violation of water quality standards d. Samples analyzed in accordance with the terms of this permit shall be submitted on forms approved by the Director no later than January 31 for the previous year in which sampling was required to be performed Analytical results from sampling during the final year of the permit term shall be submitted with the permit renewal applicat-on. This permit regulates stormwater discharges associated with industrial activity. Non- stormwater discharges which shall be allowed in the stormwater conveyance system are: Permit NCO038377 (1) All other discharges that are authorized by an NPDES permit (2) Foundation drains, air -conditioner condensate without added chemicals, springs, waterline and fire hydrant, water from footing drains, flows from riparian habits and wetlands, fire -fighting training and fire system testing, wash down water without added chemicals (3) Discharges resulting from fire -fighting. g If the storm event monitored and reported in accordance with this permit coincides with a non-stormwater discharge, the permittee shall separately monitor and report all parameters as required under the non-stormwater portion of this permit and provide this information with the stormwater discharge monitoring report. No analytical monitoring is required by the permit A. (13) FISH TISSUE SAMPLING Progress Energy shall conduct fish tissue sampling for Arsenic on an annual basis The fish tissue sampling plan shall be approved by the Division's Environmental Sciences Section prior to commencement of sampling w Progress Ener 9 9Y File 12520 B-1 Sergei Chernikov NC Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 EC EHE 1 111q F E B 2 8 2007 DcNR - WATER QUALITY F E B 2 S 2007 °�'1NT CDUPCF V,,\rICH Subject: Carolina Power & Light Company d/b/a Progress Energy Carolina, Inc. Mavo Electric Generating Plant NPDES Permit No NCO038377 Comments on Draft Permit Dear Dr. Chernikov: Enclosed are our comments on the subject draft NPDES permit. We appreciate the opportunity to comment. If you have any questions please contact Steve Cahoon at (919) 546-7457. I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations Sincerely, �a Larry E. Hatcher Plant Manager Mayo Electric Generating Plant Progress Energy Carolinas, Inc Mayo Steam Plant 10660 Boston Road Roxboro, NC 27574 Mayo Electric Generating Plant Draft NPDES Permit Comments PART Section A(4). — Effluent Limitations And Monitoring Requirements Progress Energy (PE) requests that the monitoring frequency be reduced to bi- weekly for all parameters with weekly monitoring required. Bi -weekly monitoring will be sufficient to demonstrate the performance of treatment facilities without being overly burdensome given the number of additional parameters being analyzed with the addition of the FGD blowdown. PE requests that the limits for Total Beryllium, Total Cadmium, Total Chloride, Total Chromium, Total Fluoride, Total Lead, Total Manganese, Total Barium, Total Thallium, and Total Vanadium become effective two years after commencement of the FGD system to treat FGD wastewater. • PE also requests an additional one year compliance period for mercury Progress Energy understands that the DWQ believes these limitations fall under the purview of 40 CFR § 122.47(a)(2), which states the following: The first NPDES permit issued to a new source or a new discharger shall contain a schedule of compliance only when necessary to allow a reasonable opportunity to attain compliance with requirements issued or revised after commencement of construction but less than three years before commencement of the relevant discharge. Progress Energy believes that the above referenced CFR section does not apply to the situation at hand and a schedule of compliance is allowable. The rationale for this belief follows. Section 122.47(A)(2) Is Not Applicable To Mayo Regardless Of New Source Or New Discharger Classification § 122.47(a)(2) provides an allowance for the following situation - An owner or operator is constructing an industrial facility that will generate a wastewater discharge; • He is issued his first [original] permit that contains applicable standards of performance'; • He commences construction of the facility including wastewater treatment for compliance with the standards of performance contained in the first permit, The applicable industrial categorical standards of performance are "issued or revised" within three years before the "commencement of the relevant discharge." Considering these events, the allowance in §122.47(a)(2) recognizes two issues, 1) an owner or operator should not be penalized if, during construction of the industrial facility, the minimum standards of performance are modified thereby presenting the owner with a moving target for compliance, and 2) the owner cannot start and stop the construction of his facility for a period of eight years for example, and still not be subject to performance standards that have been revised in year five of his construction timeline. Taking this concept a step further, once the discharge commences the facility becomes an existing source and is subject to subsequent standards of performance and their associated promulgated schedules of compliance. This allowance under §122.47(a)(2) is applicable to an industrial facility in total that is under construction for the first time (1 e. new source or new dischargers) and must comply with categorical standards of performance. This is not the situation at the Mayo facility. The Mayo facility has been in existence for over 20 years. § 122.47(a)(2) would be applicable should Mayo install a totally new, independent generation unit and associated structures at the site Definition of New Source Is Not Applicable The FGD wastewater stream is not anew source in regard to §122.47 In general a new source is an industry that is subject to categorical standards of performance and that is beginning its operation and associated discharges.2 Specifically a new source is defined in 40 CFR 122.2 as any building, structure, facility, or installation from which there is or may be a "discharge of pollutants," the construction of which commenced after promulgation of standards of performance under Section 306 of the CWA which are applicable to such source, or after proposal of standards of performance in accordance with Section 306 of [the] CWA which are applicable to such source, but only 1f the standards are promulgated in accordance with Section 306 within 120 days of their proposal. 1 Standards of Performance are the technology-based effluent limitations applicable to new sources under §306 of the CWA. Refer to definition of New Source at 40 CFR§ 122 2 2 § 122.29 (b)(2) states A source meeting the requirements of paragraphs (b)(1) (i), (u), or (ill) of this section is a new source only if a new source performance standard is independently applicable to it If there is no such independently applicable standard, the source is a new discharger. 40 CFR § 122 29 serves to expand on the definition of new source and new dischargers. § 122 29(a)(5) defines facilities or equipment as " buildings, structures, process or production equipment or machinery which form a permanent part of the new source and which will be used in its operation, if these facilities or equipment are of such value as to represent a substantial commitment to construct." Clearly the definition focuses on the industrial process (i.e. generation of electricity using a steam cycle fueled by coal) rather than any certain stream of wastewater (i.e FGD wastewater stream). Furthermore, § 122.29(b) lists the criteria for new source determination If the activity meets one of the following three criteria it can be considered a new source. 1) It is constructed at a site at which no other source is located; or 2) It totally replaces the process or production equipment that causes the discharge of pollutants at an existing source; or 3) Its processes are substantially independent of an existing source at the same site. Addressing each criterion respectively: 1) The Mayo facility is an existing source and therefore has a source located at the same site as the FGD wastewater stream. Therefore the FGD wastewater stream does not meet this criterion. 2) The FGD wastewater stream is dust that, a wastewater component of pollution control at the existing process or production site. It certainly does not totally replace the electricity generation process at the site. Therefore the FGD wastewater stream does not meet this criterion 3) Again the FGD wastewater stream is dust that, a wastewater component of pollution control at the existing process or production site. It is integrally tied into the processes at the site and in not independent (it would not exist were it not for the ongoing processes). Therefore the FGD wastewater stream does not meet this criterion. Finally at the NC Codified Regulation 15A 2B § 0407(b) it is stated that a modification to an existing source will be considered a new source if the alteration is of such magnitude to, in effect, create a new facility. Since the creation of the FGD wastewater stream and treatment thereof certainly cannot be considered to "create a new facility," it should not be considered a new source Conclusively the FGD wastewater stream is not a new source by definition. Definition of New Discharger Referring back to § 122.29 (b)(2) if an industrial process meets the above criteria (which the Mayo FGD wastewater stream does not) but does not have an applicable categorical performance standard then it is a new discharger As outlined above the FGD wastewater stream does not meet the applicable critena and cannot be a new discharger. Schedule of Compliance The situation with the new limitations for the Mayo FGD wastewater stream does not constitute new source or new discharger issues but does involve the requirements of new water quality based effluent limitations. Both 40 CFR §122 47 and NC Codified Regulation 15A 2H §.0112(b)(2) allow a permit to contain a schedule of compliance for achieving compliance with water quality based limitations among other items. For water quality based limitations there are no statutory deadlines like there are with technology based performance standards. Therefore a reasonable amount of time can be allowed Progress Energy requests the DWQ use its latitude and allow a 2 year compliance period for the above referenced parameters. The compliance period is warranted because the effluent limitations are relatively numerous and very stringent and the wastewater treatment system being installed (Bioreactor) is a relatively new, innovative technology. Because of the stringent limits that will be applied to the discharge in the future, and the new technology used to treat to those low limits, Progress Energy believes it is reasonable to be granted time to allow the wastewater treatment system to acclimate, to evaluate the status of maintaining the lake as a water supply source which drives some of the limits, and to evaluate cost effective compliance alternatives if necessary in the future Construction Sequence Progress Energy received the final NPDES permit, which included the scrubber modification in September of 2006 The company has been busily working on a construction schedule for the FGD wastewater treatment system since receiving the final permit. Progress Energy expects to submit an Authorization to Construct for the waste water treatment system in March/Apnl of 2007, to begin its construction in the August/September 2007 timeframe. The FGD waste water treatment system is scheduled to be in service in the May 2009 timeframe to comply with the Clean Smokestacks Act. Section A.(5) — Effluent Limitations and Monitoring Requirements PE requests that the monitoring frequency be reduced to bi-weekly for all parameters with weekly monitoring required. Bi -weekly monitoring will be sufficient to demonstrate the performance of treatment facilities without being overly burdensome given the number of additional parameters being analyzed with the addition of the FGD blowdown. January 31, 2007 MEMORANDUM To: Michael Douglass, Regional Engineer NC DENR / DEH / Public Water Supply Section Raleigh Regional Office From. Sergei Cherenkov, Environmental Engineer II, NPDES-West, Division of Water Quality (fax -919-733-0719) Subject Review of the discharge locations for the following Mayo Steam Electric Generating Plant NC0038377 Person County Please indicate below by March 1, 2007 your agency's position or viewpoint on the facility listed above We cannot issue the permit without your concurrence. Please return this form at your earliest convenience. RESPONSE [i This agency has reviewed the draft permit and determined that the proposed discharge will not be sufficiently close to any existing or known proposed public water supply intake so as to create an adverse effect on water quality. We concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. Concurs with issuance of the above permit, provided the following conditions are met - Opposes the issuance of the above permit, based on reasons stated below, or attached Signed ' 1 1,- - Date- 2-111C cc: file STATE OF NORTH CAROLINA, PERSON COUNTY PRINTER'S AFFIDAVIT Vickie F Carver, being duly sworn, PUBLIC NOTICE deposes and says That she is Office Manager of STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSIONMPDES UNIT The Courier -Times, with Its principle P lace of business 1617 MAIL SERVICE CENTER RALEIGH, NC 27699.1617 ' NOTIFICATION OF INTENT TO ISSUE A NPDES located in the city of Roxboro, County of Person, State WASTEWATER PERMIT On the basis of thorough staff review and application of NC General of North Carolina, that the foregoing or attached Statute 143.21, Publiclaw92-500 and otherlawful standards and regulations, the North Carolina Environmental newspaper notice was published in The Courier -Times, Management Commission proposes to issue a National Pollutant Discharge Elimination , System (NPDES) once a week for I successive weeks, beginning with wastewater- discharge permit to the person(s) listed below effective 45 �( d '^ y-� L C)� days from the_ publish dale of this notice its issue of l ay of 20 Progress Energy; 10660 Boston 4h da of and ending with its issue of y Road, Roxboro,NC27574hasapplied for renewal of as NPDES discharge permit for Mayo Electric Generating p� `7 ►J t� 'L 2tT that The Courter -Times, is Plant (number NC003&377) discharging to the Mayo Reservoir in the Roanoke River Basin This facility operates twoouffalls,001(recirculated the sole owner and publisher of said newspaper, Pash coolinguicer),0 ter, cooling lower sluice water, cooling lower blowdown, coal pile runoff, FGD The Courier- T a blowdown, etc ) Currently total selenium, oil and grease, and TSS 11 are water quaility limited This ! discharge may affect future discharges �(Affiant) in this portion of the Roanoke River Basin Written comments regarding the proposed permit will be accepted until Sworn to and subscribed before me, 30 days after the publish date of this notice All comments received prior to �4 that date are considered in the final ons regarding the t the< da�� y of�20QI proposed permit The iirectr of the NC Division of Water Quality may Public) decide to hold a public meeting for the should the Division (1Votary proposed permit cc,, 7 receive a significant degree of public interest My commission expires theq day of�l 20 ` " ► `� Copies of the draft permit and other supporting information on file used to determine conditions present tom_, in the draft permit are available upon request and payment of the costs of i J (Publication Fee $) reproduction Mad comments and/or requests for information to the NC Division of Water Quality at the above (Notarial Seal) address or call the Point Source Branch at (919) 733-5083, extension 520or363 Please include the NPDES permit number in any communication Interested persons may also visit the Division of Water Quality at 512 N Salisbury Street, Raleigh, NC 27604- 1148 between the hours of 8 00 a m and 5 00 p m to review information on file Feb 7 DEN'R/DWQ FACT SHEET FOR, NPDES PE'RMI,T DEVELOPMENT NPDES No, NC0038377, Progress Energy Carolinas, Inc Mayo Steam Electric Generating Plant SUMMARY The Mayo Electric Generating Plant is a coal-fired electric generating plant with one uzzit rated at a maximum dependable capacity of 745 mw- Water for plant uses is withdrawn from the Mayo Reservoir as required to make up evaporative losses from the cooling tower, boiler water and drinking water needs This facility is subject to EPA effluent guideline limits per 40 CFR 423- Steam Electric Power Generating Point Source Category. The facility is not subject to the 316(b) Phase II regulations since it is a closed cycle cooling system and has a design flow of less than 50 MGD The permit was modified in 2006 to include blowdown from Flue Gas Desulfurization (FGD) system The FGD is essentially a scrubber system to remove SOx by mixing flue gas with a limestone slurry Outfall 009 was established to monitor the FGD blowdown. The facility operates the following outfalls' • Outfall 001 - Cooling tower system, This system is drained for ;maintenance approx,imately once a year to the reservoir The discharge is monitored and reported on the DMRs • Outfall 002 - Ash pond treatment system (including low volume waste, ash sluice water, cooling tower blowdown, coal pile runoff, FGD blowdown, etc) Facility Information Applicant/ Facility Name Progress `Energy Carolinas/ Mayo ,Steam Electric Generating Plant Applicant Address 10660 Boston Road, Roxboro, NC 27573 Facility Address (same) Permitted Flow Not limited Type of Waste. 99 8 % Industrial,, 0 2% - domestic Facility/Permit Status Existing County Person Miscellaneous Receiving Stream Mao Reservoir Regional Office RRO Stream Classification CJS -V Quad A2.3SW 303(d) Listed No Permit Writer Sergei Chernikov Subbaszn 030205 'Roanoke Date January 25, 2,007 Drainage Area mit Lake ` - V s 6 Summer 7Q 10 cfs 30Q2 (cfs) Average Flow cfs IWC (%) 100610 (assumed, no modeling info Primary SIC Code SUMMARY The Mayo Electric Generating Plant is a coal-fired electric generating plant with one uzzit rated at a maximum dependable capacity of 745 mw- Water for plant uses is withdrawn from the Mayo Reservoir as required to make up evaporative losses from the cooling tower, boiler water and drinking water needs This facility is subject to EPA effluent guideline limits per 40 CFR 423- Steam Electric Power Generating Point Source Category. The facility is not subject to the 316(b) Phase II regulations since it is a closed cycle cooling system and has a design flow of less than 50 MGD The permit was modified in 2006 to include blowdown from Flue Gas Desulfurization (FGD) system The FGD is essentially a scrubber system to remove SOx by mixing flue gas with a limestone slurry Outfall 009 was established to monitor the FGD blowdown. The facility operates the following outfalls' • Outfall 001 - Cooling tower system, This system is drained for ;maintenance approx,imately once a year to the reservoir The discharge is monitored and reported on the DMRs • Outfall 002 - Ash pond treatment system (including low volume waste, ash sluice water, cooling tower blowdown, coal pile runoff, FGD blowdown, etc) NPDES PERMIT FACT SHEET Page 2 Progress- Mayo NPDES No. NCO038377 Cooling tower blowdown is usually mixed with bottom and fly ash prior to discharging into the ash pond. Outfall 008 (internal) - Cooling tower blowdown is directly discharged to the ash pond. Cooling tower blowdown is usually mixed with ash sluice water prior to discharge to the ash pond. Cooling tower blowdown is indirectly discharged to Mayo Reservoir via the ash pond treatment system (Outfall 002). Outfall 009 (internal) - FGD blowdown. Outfalls 004, 005, and 006a: b, c, d, e - stormwater outfalls. TOXICITY TESTING: Current Requirement: Acute P/F at 90%, February, May, August, November. Proposed Requirement: Acute P/ F at 90%, February, May, August, November. The facility has passed all chronic toxicity tests during the previous 4.5 years. COMPLIANCE SUMMARY: BASED ON THE PREVIOUS 5 YEARS There are no outstanding and/or chronic compliance problems related to the NPDES permit. A compliance evaluation inspection conducted on 03/31/05 found that facility is in compliance. The only Notice of Violation that was issued during previous 5 years was for TRC (10/ 13/2003). Letter from Environmental Sciences Branch (ESS) that was issued (05/09/2005) concurred with the latest report from Progress that chemical and biological characteristics of Mayo reservoir are similar to prior years. Letter from ESS (05/30/2006) concurred with the 2005 Environmental Monitoring Report prepared by Progress Ene_ gy that operational effects of the plant (on Mayo Reservoir) continue to be minimal. PROPOSED CHANGES No changes are proposed. PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to Public Notice: 1/31/07 (est.) Permit Scheduled to Issue: 3/30/07 (est.) STATE CONTACT If you have any questions on any of the above information or on the attached permit, please contact Sergei Chernikov at (919) 733-5038, extension 594. CHANGES IN THE FINAL PERMIT: The compliance schedule of 24 months was added for the following parameters: Be, Cd, Cr, F, Pb, Mn, Ba, T1, Hg and V. REASONABLE POTENTIAL ANALYSIS Mayo Steam Electric Plant < NCO038377 Time Period 2001-2005 Qw (MGD) 7.3 7Q10S (cfs) 0 7Q10W (cfs) 0 30Q2 (cfs) 0 Avg Stream Flow, QA (cfs) 0 Rec'uing Stream Mayo reservoir WWl-P Class < WWrP Class > IWC (%) @ 7Q10S 100 @ 7Q10W 100 @ 30Q2 100 @ QA 100 Stream Class C PQL Outfall 001 Ow = 7.3 MGD *Legend C = Carcinogenic NC = Non -carcinogenic A =Aesthetic "Freshwater Discharge 38377 -RPA -2005, rpa 1/25/2007 STANDARDS & PARAMETER TYPE CRITERIA (2) PQL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION (1) NCWQS/ %FAV/ Chronic Acute n #Det MaxPredCw AllowahleCw Arsenic NC 50 ug/L 17 17 5346 Acute N/A �� fr, ................ _/ t Chronic 50 Acute 56 , a L�- �j Selenium NC 50 56 ug/L 37 37 152 / (J _ _ _ Chronic 50 C" /r *Legend C = Carcinogenic NC = Non -carcinogenic A =Aesthetic "Freshwater Discharge 38377 -RPA -2005, rpa 1/25/2007 REASONABLE POTENTIAL ANALYSIS 38377 -RPA -2005, data - 1 1/25/2007 Arsenic Date Data BDL=1/2DL Results 1 640 640 Std Dev 414365 2 193 0 193 0 Mean 591176 3 1050 1050 C V 07009 4 680 680 n 17 5 80 80 6 r 13 0' 130 Mult Factor = 27700 7 350 350 Max Value 193 0 ug/L 8 310 310 Max Pred Cw 534 6 ug/L 9 420 420 10 600 600 11 660 660 12 450 450 13 450 450 14 560 560 15 620 620 16 410 410 17 710 710 18' 19 20 21 22 ( 23 24 25 LLi4' 26 27 28 29, , 30 31 32 33 34, 35 36 37 38 , � 39 ' 40 41 42 43 44 45 46 47` 48, 49, 51 52 53' 54, 55 56 57 , 58 59, 60 199 200 38377 -RPA -2005, data - 1 1/25/2007 g'n�' Progress Energy 9Y File: 12520 B-1 Mr. Gil Vmzam, PE North Carolina Department of Environment and Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: CP&L d/b/a Progress Energy Carolinas, Inc. Mayo Electric Generating Plant NPDES Permit No. NCO038377 Re -issuance Application Dear Mr. Vmzani: SEP 2 5 2006 flD'ECEoVE S E P 8 20V UO 6W DENR - WATER QUALITY SURFACE WATER PROTECTION SECTION The current NPDES permit for Mayo Electric Generating Plant located in Person County expires on March 31, 2007. Progress Energy hereby requests that the NPDES permit for the facility be reissued. Enclosed are EPA Application Form 1 — General Information, EPA Application Form 2C — Wastewater Discharge Information, and EPA Application Form 2F — Stormwater Discharges Associated with Industrial Activity, all in triplicate. If there are any questions regarding the enclosed information, please contact Steve Cahoon at (919) 546-7457. I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qual f ed personnel properly gather and evaluate the information submitted Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete I am aware that there are significant penalties for submitting false information, including the possibility offines and imprisonment for knowing violations Sincerely, # La E. Hatcher- Manager Mayo Electric Generating Plant Attachments Progress Energy Carolinas, Inc Mayo Steam Plant 10660 Boston Road Roxboro, NC 27574 0 1 2 3 I i Kilometers 0 1 2 Out OC r r r r ' Ash r r Pond i i ' C r — PIS r Si r r Outfall 001 r r r i SFZ1512 , . t' i i i i i r i 'r r .� Public E— boat 7 ramp r r r i i r i r Enclosure 1 – Item XI Carolina Power and Light Company Mayo Electric Generating Plant Person County, N C Page 2 of 2 September 2006 16 Ouffail 002 11 Cooling Towers 10 Mayo Reservoir Outfall 001 14 1 14 2 IF Misc Equipment Heat — Intake Structun Exchangers 18 Alternate 13 Outfall 008 Condensers Fire Ash Sluice Protection Water 12 Stormwater 3 —� Raw Water Treatment 5 6 4 Potable & Sanitary Water Storage I I Sewage treatment Boder & Turbine Condensate Ion Exchange Oily Waste Storage Treatment 9 7 Ash Pond 19 15 17 Secondary Containment FGD Blowdown Coal Pile For anhydrous ammonia Runoff tanks Misc low Volume Progress Energy Carolinas, Inc. Mayo Electric Generating Plant National Pollutant Discharge Elimination System Permit Number NC0038377 Attachment 2 Form 2C - Item II -A Flows, Sources of Pollution, and Treatment Technologies Stream Estimated Average Flow Comments 1 14 MGD Make up water from Mayo Reservoir 2 13 7 MGD Cooling Tower make up Maximum rate is 23 7 MGD 3 0 36 MGD Raw Water treatment 4 0 002 MGD Sewage treatment plant 5 0 00175 MGD Raw water treatment backwash 6 0 36 MGD Treated water to water storage 7 300 GPM (Max rate) Oily waste (infrequent) to ash pond 8 1 5 MGD Low volume waste to ash pond 9 0 05 MGD at start up Boder blowdown to ash pond 10 2 MG/event 1/yr. Cooling Tower basin drain to Mayo Reservoir 11 9 MGD Evaporation from Cooling Tower 12 5 MGD Ash Transport 13 Variable as needed (blowdown) Intermittent blowdown of circulating water from heat exchangers 14 8 5 MGD (recirculating flow) Heat exchanger (primary route) 15 0 0135 MGD (annual daily average) Coal pile Runoff 16 7 3 MGD Ash Pond discharge to Mayo Reservoir 17 Variable as needed Secondary containment for anhydrous ammonia tanks 18 2 1 MGD During Cooling Tower out of service Heat exchanger (secondary route) 19 0 253 MGD FGD Blowdown Progress Energy Carolinas, Inc. Mayo Electric Generating Plant National Pollutant Discharge Elimination System,Permit Number NCO038377 Attachment 3 Form 2C - Item II -B Flows, Sources of Pollution, and Treatment Technologies The Mayo Electric Generating Plant is a coal-fired electric generating plant with one unit rated at a maximum dependable capacity of 745 mw. The plant is located in Person County, North Carolina and uses No 2 fuel oil for start up and stabilization of the boder flame Water is withdrawn from the Mayo Reservoir as required to make up evaporative losses from the cooling tower, boiler water and drinking water needs Makeup pumping rates from the reservoir are highly variable depending upon natural weather conditions, generation load, plant operations, and evaporative loss Chemical constituents contained in the discharges from this facility will, in part, be representative of the naturally occurring chemical quality of the intake water The discharges will also have chemical constituents of such quality and quantity associated with similar discharges for fossil generating facilities of this size, type, and in this geographical location Either all or part of the elements enumerated in the Periodic Table, either singularly or in any combination, may from time to time be contained in this discharge. More detailed descriptions of the individual discharges described below. OUTFALL 001 - COOLING TOWER SYSTEM Approximately once per year the cooling tower basin and circulating water system is drained by gravity (the majority of the water drains to the ash pond) approximately 2 MG is drained to the reservoir to dewater the system for maintenance That discharge is monitored and reported to the state through the monthly Discharge Monitoring Report (DMR). OUTFALL 002 — ASH POND TREATMENT SYSTEM The ash pond receives ash transport water, coal pile runoff, storm water, cooling tower blowdown, and various low volume wastes such as boder blowdown, oily waste treatment, wastes/backwash water from water treatment processes, plant area wash down water, and equipment heat exchanger water The sewage treatment plant also discharges to the ash pond The ash pond provides treatment by sedimentation, oxidation, neutralization, equalization, and adsorption A standpipe allows for overflow release to a small secondary -settling basin for release into Mayo Reservoir Due to alga blooms, the pH of ash pond discharge canal is adjusted at the standpipe as needed Ash Transport Water — Water for sluicing fly ash and bottom ash to the ash pond is withdrawn from the closed circulating water system. Some fly ash is handled dry by a pneumatic system and is transported off site The water in the closed circulating water system is treated with a dispersant for protection of the cooling tower fill Coal Pile Runoff — The coal pile runoff is routed to the ash pond. Flow volumes are related to rainfall frequency and intensity The annual daily average flow presented previously is based on a coal pile area of 5 acres, an annual average rainfall of 44 inches and a runoff coefficient of 1 0 Cooling Tower Blowdown — Normally, ash transport water withdrawal from the closed circulating water system is sufficient to control total dissolved solids (TDS) in the cooling water During periods of maintenance, some molybdate waste from the closed cooling water system is routed to the ash pond Also during periods of maintenance, the cooling tower basin is drained to the reservoir Progress Energy Carolinas, Inc. Mayo Electric Generating Plant National Pollutant Discharge Elimination System Permit Number NC0038377 Low Volume Wastes Oily Wastes — Drains containing oily wastes or water are routed to the oily waste basin. The discharge from the oily waste basin is routed through the oil—water separator where the oil is removed and contained The treated water is then discharged to the ash pond The fuel oil storage tank is in a containment area with a valved drain The drain is routed to the oily waste basin Boiler Blowdown — Boiler make-up water is withdrawn from the lake, treated by various processes and stored in tanks until needed. The boiler water is treated with ammonia continuously when the boilers are in service. Sodium hydroxide is used when needed during abnormal conditions Boiler blowdown is routed to the ash pond via the low- volume waste conveyance. Water Treatment Wastes — Water is withdrawn from the lake and is treated by clarification sand filtration, carbon filtration, and demineralization Various wastes such as filter backwash, and spent regeneration chemicals such as sulfuric acid and sodium hydroxide are routed to the ash pond via the low volume waste conveyance Miscellaneous — Other miscellaneous sources such as wash down water, water from various plant drains, secondary containment drains, laundry activity and temporary hand washing stations are routed to the ash pond via the low volume waste conveyance Miscellaneous equipment heat exchanger water can be routed to the ash pond via the alternate cooling tower blowdown line if needed The air preheaters are water washed infrequently Then the air preheaters wastewater is discharged to the ash pond. Sewage Treatment Plant (STP) — Sanitary wastes are treated on-site by an extended aeration treatment plant The plant is designed for 0 0125 MGD and consists of a screen, comminuter, surge tank, aeration tank, clarifier, chlorine contact chamber, and a sludge holding tank Flow from the system is dependent upon fluctuating demand due to variations in the number of personnel on site When needed, residuals are disposed of off-site by a licensed contract disposal firm. The STP is routed to the ash pond via the alternate cooling tower blowdown line Flue Gas Desulfurization Blowdown — The Flue Gas Desulfurization (FGD) system directs flue gas into an absorber where a limestone (calcium carbonate) slurry is sprayed Sulfur dioxide in the flue gas reacts with the limestone slurry to produce calcium sulfate (gypsum) This system reclaims any unreacted limestone slurry to be reused in the absorber A small blowdown stream is used to maintain the chloride concentration in the reaction tank The blowdown stream will be discharged to a gypsum settling pond where suspended solids will be reduced prior to entering a bioreactor. The bioreactor utilizes microbes to reduce soluble contaminants to insoluble forms that then precipitate from solution The treated wastewater will enter the ash pond secondary settling pond prior to outfall 002 Storm water from Limestone and Gypsum Piles — Storm water that falls on the limestone and gypsum storage piles will be directed to the ash pond ASH SLUICE WATER Fly ash and bottom ash is hydraulically conveyed by an ash sluice pipeline to the ash pond. Water for the transport of ash is withdrawn from the closed circulating water system Some fly ash is handled dry by a pneumatic system and transported off site The water in the closed 2 Progress Energy Carolinas, Inc. Mayo Electric Generating Plant National Pollutant Discharge Elimination System Permit Number NC0038377 circulating system is treated with a dispersant (acrylic acid polymer) and water based non - oxidizing agent for protection of the cooling tower fill ASH MANAGEMENT AND RECLAMATION From time to time fly and bottom ash in the ash pond may be stacked or relocated within the diked boundary of the ash pond system. As this pond management activity does not alter the chemical character of the pond contents, no change in the nature of the discharge to the ash pond is anticipated In the event a practicable market becomes available, Progress Energy may exercise the option of reclaiming ash from the ash pond system In consideration of the scope of such an operation, no additional discharges are expected to result from ash reclamation efforts. HERBICIDE AND PESTICIDE USAGE IN THE TREATMENT SYSTEM POND Herbicides may be used as needed to control nuisance aquatic vegetation These herbicides are applied by licensed applicators, or persons under the immediate supervision of a licensed applicator, in accordance with the manufacturer's instructions. Pesticides may be used as needed to perform biological assessments. These Pesticides are applied by licensed applicators, or persons under the immediate supervision of a licensed applicator, in accordance with the manufacturer's instructions STORMWATER RUNOFF Outfall 004 — Drainaae from Outside Storaae Area Outfall 004 is located on the northeast side of the plant site and drains to the reservoir, using catch basins, storm sewer and vegetative conveyance 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 concrete unloading dock There is a storage shed in the back of the outside storage area This shed contains any chemicals or ods that would be stored in the area The hazardous waste central storage area is located in this same shed Sometimes during construction projects, a portion of the outside storage area is utilized for material storage which could consist of additional structural steel. Due to mobile equipment utilization there is a potential for petroleum release Outfall 005 — Drainaae from Industrial Area — Main Outfall 005 is located on the northeast side of the facility and is the end point of the plant's primary storm sewer system that drains the "power house block" of the plant using catch basins, storm sewer and vegetative conveyance 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, SCR and transformers Also draining to this outfall through sewers is the grassed area intended for Unit 2 at some time in the future The grassed Unit 2 area is sometimes utilized for fabrication of structural steel for construction / maintenance projects This area consists of gravel and grass areas For outfall 005 the potential pollutants could be coal, coal ash, sediment, and the chemical make-up of the rain water Due to mobile equipment utilization there is a potential for petroleum release 3 Progress Energy Carolinas, Inc. Mayo Electric Generating Plant National Pollutant Discharge Elimination System Permit Number NC0038377 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 budding and associated roads and parking areas using catch basins, storm sewer and vegetative conveyance In the cooling tower area, there are five separate outfalls These outfalls involve catch basins and storm sewers that drain to swales and then to reservoir. The cooling tower itself has a basin for re -circulating cooling water and therefore, does not directly contribute to storm water runoff For this outfall the potential pollutants could include sediment, mist from the cooling tower and chemical make-up of the rainwater. A malfunction of the cooling tower basin level and / or the cooling tower make-up system could result in a potential release of cooling tower water Due mobile equipment utilization there is a potential for petroleum release On rare occasions herbicides are used for ground maintenance at the cooling towers 4 Progress Energy Carolinas, Inc. Mayo Electric Generating Plant National Pollutant Discharge Elimination System Permit Number NC0038377 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 areas using catch basins, storm sewer and vegetative conveyance In the cooling tower area, there are five separate outfalls These outfalls involve catch basins and storm sewers that drain to swales and then to reservoir The cooling tower itself has a basin for re -circulating cooling water and therefore, does not directly contribute to storm water runoff For this outfall the potential pollutants could include sediment, mist from the cooling tower and chemical make-up of the rainwater A malfunction of the cooling tower basin level and / or the cooling tower make-up system could result in a potential release of cooling tower water Due mobile equipment utilization there is a potential for petroleum release On rare occasions herbicides are used for ground maintenance at the cooling towers 4 Progress Energy Carolinas, Inc. Mayo Electric Generating Plant National Pollutant Discharge Elimination System Permit Number NCO038377 Form 2C — Item VI — Potential Discharges Not Covered By Analysis Chemical Estimated Average Frequency Purpose Annual Usage Aluminum sulfate 1,000 gals. Continuous Improve clarifier floc Polymer 50 lbs. Continuous Improve clarifier floc Sulfuric acid 93% 79,000 lbs. As required Demineralizer regeneration Sodium hydroxide 170,000 lbs. As required Demineralizer regeneration Sodium molybdate 1,100 lbs. As required Corrosion control Aqua ammonia 25,000 lbs. Continuous Boiler water pH control Sodium bicarbonate 1,300 lbs. As required Sewage plant H control Sodium 100 gals. Continuous Potable water hypochlonte disinfectant Polyphosphate 55 gals Continuous Corrosion control 15 % Sodium 100 gals. Continuous pH control hydroxide Potable water Water based non- 7,000 lbs. As required Biofouling control oxidizing agent Cooling tower Silicone based 3,900 lbs. As required Defoamer treatment defoamer Cooling tower Dispersant (acrylic 17,000 lbs As required Biofoulmg control acid polymer) Cooling tower Anhydrous 450,000 gals As required Air pollution Ammonia treatment system Sulfuric acid 50,000 lbs. As required pH control in ash pond Sanunl Chlorine 100 lbs Continuous Sewage plant Tablets effluent treatment Limestone (Calcium 270,400 tons Continuous Flue Gas Carbonate) Desulfuization Mayo Plant North Carolina Attachment 5 - Form 2F - Item III - Map Carolina Power & Light Company Mayo Electric Generating Plant Person County Page 1 of 3 +4 Mayo Plant Outfalls 36'32' 02.989'N 7dSV 26.848'W Ashpond Outfa11002 �+ W vl 3d31' S0.324'N 76'53' 43.776"W Ash Pond Influent MVV/ 36°31' 45.498"N 78°53' 20.697'W Outfall 004 j6 4 Building o Outfalls. /A\ / Road. 38'31' 39 549'N 76'52' 65 505"W 78r53' 16 841-W ��Outfall 006C kie 7952'56 595'W Outfall 005 11(K 3fi 31' 28.919"N 36 31'28.162'N 8"52' S5.735'W 3d31' 36.042'N Cooling Tower Drain Outfall 006E J( 7e53'07 .236"W 36°31' 34 538"N Outfall 006A 7e63' 01.792'W Outfall 006B VV Adminstration Building cooling Towers 3631' 30 396-N 76'52' 65 505"W 36°31' 29.160'N ��Outfall 006C kie 7952'56 595'W Outfall 006D 3fi 31' 28.919"N 36 31'28.162'N 8"52' S5.735'W 78'52' S7 022"W Cooling Tower Drain Outfall 006E J( Outfall 001 vvw 500 0 500 1000 Meters C J:+_ _ , op J__ Aav_A SCHAR _ , _ — t OU IVC, T J .. E. 3 ASN S U:�:E:4TL•- u�r,f C r !. n !(Y/. APA -_ _TTI ISS c:i GI 3?,rfRIiL;1 y �C:)jFjl al sCP J VI pmW,lb -- r a :-ORE RCCr rnlNrCt.t NtC r -Cr' -J •� I LADORA T CFS L IIN``� G iT iC .41 t CD•"IS'RL[TI'.7N .ASE .OUSE '[POSENE 'AW J dULL UJ2ER StiED i� e FULL W.N[LING ",%TCNAN:'_ S.iCP ) I :Cr I7 Of. CIL STORAGE TANK ✓ARE HUUSc I� CIU 1111 t I WA ,i "it i N CIL' ',I I 4Ar,E ANE 4 C 1` P 1[ E {{ If 14,IAN SIWAL IANA YAR II ,. J 30-IL.L CAS SIDRA:,F CI L PAIN• •HDP I DC•'•17.`ERA Ii EP JA'fR 7R[A7K%T B_7G t - COaL'^S TOWER WATE4 TR_ATKLY B LL H CHENICA_ —D P0114 Q EN-PANCE RCAD �I PA -N. NG I I r�u r ddN I, 3[�E_zj� itiilF;Ff{I} . rE(,U:vufalut< r S',; I"CiavnP7 t Ut_r .AS TE / FA_sIN ;rt�� i I • Cr-Essli f I � � i � ✓nSFL �s} 3AStt: D [t °A,u %imAG[ SILT` PLANT COAL PI n zR STOP -GE '[POSENE 'AW ? u'.LCADEI !_ASO if C ANF {a CRUSHER I -[LSC i f V I I, N-.f.•I I R I Ia-,BIM M If IAN! J OIL DR' it,7a AGC J SV, t CHYAP[I N. ALLIIN Elul I I.I, ❑ L ELPNI NG ST A71 ON •i FULL HANGLING JAR Ht1U5t PERVIOUS SLPF'AC__S 7PAP.AGE AR_AS �HfkS ICP,JS S RF ALIS • LOADING AND UNLOADING AR=AS CSA ��. fF SC,y,M/ex�.f.OJGS�.IIS( SIVGS,tlil [v�ir ].� Q EN-PANCE RCAD �I PA -N. NG I I r�u r ddN I, 3[�E_zj� itiilF;Ff{I} . rE(,U:vufalut< r S',; I"CiavnP7 t Ut_r .AS TE / FA_sIN ;rt�� i I • Cr-Essli f I � � i � ✓nSFL �s} 3AStt: U 91 O IJ tiTORPG �1 UU I ALL TI � tC \,--UTFA ; k.. OMA MAh_UP I'f3 b UU I I AL m w. C) rr-at_L Cub :lUTFA t f ,1U6 UtJ 1I AI_r C06 }II J ISCIi AP'i,i NPi) JtIT: !,t JB+ A ,7IAINI:D -ffSS aCF 3US C5 ACPCS JDA R =, Rn1t.10 "7 c4 L, RES [JUS li A_R aab BC DE ,R'A JRAINEII ; It' dFYS LIUS C ACRi � PLANT �U39 CdflkF n zR STOP -GE {� f {a U 91 O IJ tiTORPG �1 UU I ALL TI � tC \,--UTFA ; k.. OMA MAh_UP I'f3 b UU I I AL m w. C) rr-at_L Cub :lUTFA t f ,1U6 UtJ 1I AI_r C06 }II J ISCIi AP'i,i NPi) JtIT: !,t JB+ A ,7IAINI:D -ffSS aCF 3US C5 ACPCS JDA R =, Rn1t.10 "7 c4 L, RES [JUS li A_R aab BC DE ,R'A JRAINEII ; It' dFYS LIUS C ACRi � 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 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 during 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 believe 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. In order to minimize dust and on as need basis, the boom is raised or lowered. The conveyor belt system has been evaluated for the 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 the coal is fed or reclaimed to the unit/boilers. 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 (via the ash pond) SWP3 Material Handling.doc revision 3 June 2005 DPP Outfalls Narrative Description Outfall 004 — Drainage from Outside Storage Y This outfall is located on the northeast 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 pants. Virtually the entire area is loose gravel, except for the concrete unloading dock. 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 the area. The hazardous waste central storage area is located in this same shed. During the SCR construction project, a portion of the outside storage area is being dedicated for a laydown area for material storage which consists of structural steel. Due to mobile equipment, on-site there is a potential for petroleum release. Outfall 005 — Drainage from Industrial Area The outfall is located on the northeast side of the facility and is the end point of the plant's primary storm sewer system that drains the "power house 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. During some construction projects, the Unit 2 area 1s occasionally utilized as structural steel and fabrication area. This area consists of gravel and grass areas. For outfall 005 the potential pollutants could be coal, coal ash, sediment, and the chemical make-up of the rain water Due to mobile equipment, on-site there is a potential for petroleum release. 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 areas In the cooling tower area, there are five separate outfalls All these outfalls involve catch basins and storm sewers that drain to swales and then to the reservoir The cooling tower itself has a basin for re -circulating cooling water and therefore, does not directly contnbute-to storm water runoff .For this outfall the potential pollutants could include sediment, mist from the cooling tower and the chemical make-up of the rainwater. A malfunction of the cooling fower basin level and / or 5WP3 Outfalls doe revision 4 June 2005 DFP Memo to file: 12520 R June 4, 2003 12576 Non-Stormwater flow in Stormwater Outfall 005 During dry periods, Stormwater Outfall 005 has a discharge that is non-stormwater related. During the time period of July — August 1996 an extensive investigation was conducted to try and resolve where any water might be coming from. This investigation included walking lines and catch basins loo1ji ng -for any flow into the drainage system, conducting visual observations dunng non -normal work hours, and reviewing drawings of both stormwater and non-stormwater drainage systems. In addition, dye was placed in nearby non-stormwater drainage systems to ensure no cross -connections existed. Samples of the water flowing from Outfall 005 during dry periods were collected and analyzed for pH, chlorine, appearance, odor and biocides. None of the analyses indicated any industrial water present. It was observed that the flow would almost stop after we had long period of no rainfall and the flow would increase if we had recent rainfall. The last catch basin before the outfall was observed not to have any flow entenng it, however, at the final outfall there would be a small amount of water. After several hours of researching the source of the water it was decided that it must be groundwater intrusion at a point between the catch basin and the outfall. During a site visit by Bradley Bennett, Supervisor of DWQ's Stormwater and General Permits Unit, and accompanied by Joanie Cooke (ESS), these investigations were discussed. He stated that this was not unusual and appeared not to be concerned. Mr. Bennett was informed that we document on the Preventative Maintenance Visual Monitoring Worksheet that we suspect groundwater as the source from this outfall (during non -storm periods). He appeared to be okay with the statement. Dulcne Phillips/��d 3 Progress Energy Carolinas, Inc. Mayo Electric Generating Plant National Pollutant Discharge Elimination System Permit Number NCO038377 Attachment 9 E-mail Documentation Allowing Sampling Results From 2005 Permit Renewal Application to be used in the 2006 Permit Renewal Application Page 1 of 2 From: Sergei Chernikov (sergei chernikov@ncmail net] Sent: Thursday, April 06, 2006 8 55 AM To: Cahoon, Steve Subject: Re: FW, Mayo NPDES Permit Renewal Steve, I have discussed this issue with Susan and we have decided that you can use those samples for permit renewal. Sergei Cahoon, Steve wrote. Sergei, I don't think I ever received an e-mail reply from you for the question below (email is based on a phone call we had the afternoon of Feb 27, 2006) Please reply and contact me if you have any further questions Thanks! Steve Cahoon Progress Energy Service Company - Environmental Services Section Supply and CCO (Carolinas/Georgia) Vnet: 770-7457 Bell- (919) 546-7457 Mail Code PEB4 steve Cahoon@pgnmail coin -----original Message ---- From: Cahoon, Steve Sent: Monday, February 27, 2006 3.54 PM To: 'sergei chemiK9,&ncmai net' Subject: Mayo NPDES Permit Renewal Sergei, As you are aware Progress Energy submitted an NPDES Permit Renewal application for its Mayo Electric Generating Plant on July 29, 2005 The new permit became effective on January 1, 2006 and expires on March 31, 2007 A new permit application package must be submitted 180 days prior to the March 31, 2007 expiration date The sampling event for our current NPDES permit was conducted on April 1, 2005 for the wastewater and June 2, 2005 for the storm water Progress Energy requests permission from the NPDES Unit to allow the Mayo Plant to use the data collected from the above referenced sampling events for our upcoming NPDES permit renewal package, that package must be submitted to the NPDES Unit by approximately October 3, 2006 Thank you for your consideration If you have any questions please contact me 9/18/200& Page 2 of 2 Steve Cahoon Progress Energy Service Company - Environmental Services Section Supply and CCO (Carolinas/Georgia) Vnet 770-7457 Bell- (919) 546-7457 Mail Code PEB4 steve.cahoon(a-pgnmail. com Sergei Chernikov, Ph.D. Environmental Engineer NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 phone: 919-733-5083 ext. 594 fax: 919-733-0719 9/18/2006 �� Progress Energy December 1, 2008 Mr. Gil Vinzani, Supervisor, Eastern NPDES Program Division of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Carolina Power & Light Company dba Progress Energy Carolinas, Inc. Asheville Steam Electric Plant NPDES Permit Number NC0000396 Cape Fear Steam Electric Plant NPDES Permit Number NC0003433 Lee Steam Electric Plant NPDES Permit Number NC0003417 _ Mayo Steam -Electric Plant NPDES Permit Number NC0038377 Roxboro Steam Electric Plant NPDES Permit Number NC0003425 Sutton Steam Electric Plant NPDES Permit Number NC0001422 Weatherspoon Steam Electric Plant NPDES Permit Number NC0005363 NPDES Permit Application Amendment Dear Mr. Vinzani: Progress Energy Carolinas, Inc. (PEC) proposes to amend the NPDES Permit application for the subject facilities to add three additional freeze conditioning agents. These facilities expect to receive shipments of coal treated with freeze conditioning agents during the winter months (November 15 through March 15). Freeze conditioning agents, needed depending upon expected weather conditions during transport to ensure coal does not freeze in railcars, will be applied at an approximate rate of 2 pints per ton of coal. The product names used by the various coal mines which supply fuel to Progress Energy Carolinas power plants could include one or more of the additional following products (MSDSs enclosed): Product Name Primary Composition FreeFlow SR -300 30-50% glycerin Flomin ST -944 SRA > 50% diethylene glycol mixture and polymer/surfactant blend Bio -Pro 55 55% glycerin Coal pile runoff at each of these facilities flows to a treatment system (e.g., ash pond, cooling pond, settling basin). However, since there is a slight potential that these chemicals could be present in the wastewater that is ultimately discharged via a permitted outfall, PEC requests that these products be appended to the NPDES permit application. Note that toxicity testing is a permit requirement at each power plant outfall which contains the coal pile runoff waste stream. Mr. Gil Vinzani, NPDES Unit December 1, 2008 Page Two Progress Energy Carolinas, Inc., appreciates the continued cooperation demonstrated by the Division of Water Quality staff in responding to its permitting needs. If you have any questions or comments regarding this information, please contact Robin Bryson at (919) 546-3962. 1 certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete 1 am aware that there are significant penalties for submitting false information, including the possibility offines and imprisonment for knowing violations Sincerely, Mr. Charles M. Gates Vice President—Power Generation Carolinas Progress Energy Carolinas, Inc. CMG/rb Enclosures c: Robin Bryson bc: Leigh Barr Larry Baxley Steve Cahoon Fred Holt Shannon Langley Ricky Miller Billy Milam Laurie Moorhead Dulcie Phillips Kent Tyndall P. (). 13ox l5, -5l NC 276021 r