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HomeMy WebLinkAboutNC0003417_Application_20190607 (4)(� DUKE ENERGY. August 31, 2016 Ms. Julie Grzyb North Carolina Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Re: NPDES Wastewater Permit Application Submittal Duke Energy Progress, LLC. HF Lee Energy Complex Permit #: NC0003417 Wayne County Dear Ms. Grzyb, Harry K. Sideris Senior Vice President Environmental, Health & Safety 526 S. Church Street Mail Code: EC3XA Charlotte, NC 28202 (704)362-4303 Duke Energy Progress, LLC (Duke) is submitting herewith three copies of supplemental information in support of the NPDES renewal application submitted in November 2012 for the subject facility. This update is in addition to the previous updates and requests submitted dated October 31, 2014, March 11, 2015 (Form 2C update for Outfal1002), March 11, 2015 (ash basin dewatering update), and May 2, 2016. Please include this supplemental information and the information in the previous submittals in your review. This submittal is intended to provide an update of modifications that will be necessary to comply with recently enacted laws and regulations including the Federal Steam Electric Effluent Guidelines (ELG), Federal Coal Combustion Residual (CCR) rule, the North Carolina Coal ash Management Act of 2014 and HB 630 of 2016. With numerous federal and state requirements to coordinate and implement in a short time for the site, planning and sequencing of work are paramount and dynamic. As such, final scope and sequence for all work is not complete at this time. Where scope is still not finalized, Duke has provided a range of options that are being evaluated and provided various alternate scenarios in an attempt to limit the number of subsequent submittals necessary. As there are no requests for new external outfalls to waters of the United States and all proposed modifications contained herein are internal to our wastewater process flows, it is Duke's belief that the information provided in this submittal is of sufficient detail to allow for review and issuance or renewed NPDES permit for the HF Lee Energy Complex. This is consistent with the guidance received from DEQ staff in a meeting on November 20, 2015 and follow up correspondence dated January 11, 2016 and January 28, 2016. HF Lee Energy Complex NPDES application update NCO0034 l 7 Wayne County Page 2 of 2 1. Option for wastewater currently routed to Outfall 003 for discharge to the Neuse River to have the option to be discharged to the Cooling Pond Duke intends to construct new piping to allow for discharge from the collection sump at the new Lee Combined Cycle Plant to discharge from either outfall Outfall 003, (which it is currently permitted to discharge, will be seldom used) or to the cooling pond and thus to Outfall 002. An updated Form 2C, Water flow diagram, flow descriptions and narrative are attached for your review. Estimated analytical data for the discharge from the collection sump was submitted in the November 19, 2012 permit application. 2. Option for treated landfill leachate to be routed to Outfall 001 should the option of on -site landfill for the excavated ash be constructed Duke is considering both off -site and on -site disposal options for the ash removed from the basins. If selected, the on -site landfill option would require provision for leachate treatment — either by an off -site treatment plant or an on -site treatment plant. Duke would like to include reference in the permit to allow for the discharge of treated leachate should the option of an on -site coal combustion product (CCP) landfill and on -site treatment of leachate be pursued. 3. Area of wetness (AOW) Permit coverage Disposition Duke has evaluated the list of AOW's submitted to the DEQ for permit coverage. Based upon further review, Duke withdraws the request for coverage from the area previously identified at S-01, 5-02, 5-03, S-03A, as these were sampling points that have no seepage flow associated with them. Duke also withdraws the request for coverage from the previously identified AOW's S-05, 5-19, S- 20 and S-21 as these were previously sampled and have no seepage associated with them. This request is based on location of the respective AOW and/or review of sampling data that confirms the lack of pollutants associated with plant activities being released, to Waters of the State from this point. Several of these points were simply monitoring points along a channel with no seepage detected at the monitoring point. Duke requests that DEQ provide concurrence or acknowledgement of this request in the NPDES Fact Sheet for the permit. Duke requests that permit coverage for AOW's identified as LOLA -01 and LOLA -01A be combined in the same effluent channel with a single monitoring point at LOLA-01A. Duke also requested that newly identified seeps S-27 and 5-28 be combined in the same effluent channel with a single monitoring point at 5-28. In addition Duke requests permit coverage for HF Lee Energy Complex NPDES application update NCO003417 Wayne County Page 3 of 3 AOW's identified as S-06, S-07, S-08, and S-09 be combined in the same effluent channel with a single monitoring point at S-09. All of these points commingle in an effluent channel east of the ash basin dam and discharge to the Neuse River at the point identified as S-09. These seeps are currently being routed back to the ash basin through a seepage collection system. Similarly, Duke requests that permit coverage for AOW's identified as S-04 and S-26 be combined in the same effluent channel with a single monitoring point at S-26. Duke requests that DEQ provide concurrence or acknowledgement of this request in the NPDES Fact Sheet for the permit. 4. CWA Section 316(b) alternate schedule. Duke requests an alternate schedule for compliance with Section 316(b) of the CIean Water Act. Specifics of the request can be found in Attachment 3. 5. Duke intends to construct a groundwater extraction well system east of the 1982 ash basin. The extraction well system is needed to remediate groundwater in the area of the ash basin, it is expected to discharge up to 1.8 MGD. The extracted ground water will require additional treatment before being released to the environment. Additional treatment of the extracted groundwater water may be completed via chemical and/or physical processes prior to discharge to Outfall 001. This treatment system may require the addition of a coagulant and/or flocculent to enhance solids removal. Attached are groundwater monitoring data and expected flows from the extraction well system. 6. Duke intends to install a wastewater treatment system to treat ash basin bulk water and interstitial water within the 1982 ash basin. The treatment system for Outfall 001 will be installed on a constructed pad within the basin with a similar flow path to the permitted outfall. Duke requests that this flow be listed as a contributing flow to Outfall 001. Additional treatment of the for the dewatering process may be completed via chemical and/or physical processes prior to discharge to Outfall 001. This treatment system may require the addition of a coagulant and/or flocculent to enhance solids removal. An updated Form 2C, flow diagram, flow description and flow narrative is provided in attachment 1. An updated sampling point aerial photograph is provided in Attachment 5. HF Lee Energy Complex NPDES application update NC0003417 Wayne County Page 4 of 4 We appreciate your attention to these requests and look forward to finalizing the NPDES permit for the HF Lee Energy Complex in the near future. Should you have any questions regarding this letter or require additional information, please contact Mr. Steve Cahoon at (919) 545-7457 or at steve.cahoon@duke-energy.com. "! certify, under penalty of law, that this document and all attachments were prepared tender my direction or supervision in accordance with a systent designed to assure that qualified personnel properly gather and evaluate rite information submitted Based on my inquiry of the person or persons who manage rite systent, or those persons directly responsible for gathering the information, the information submitted is, to the best of eny knowledge and belief, trite, accurate, and complete. ! ant aware that there are significant penalties for submitting false information, including the possibility of fines and intprisonnient for knowing violations. " Sincerely, Harry Sideris SVP - Environmental, Health & Safety Enclosures Duke Energy cc: Jeff Hines, Steve Cahoon, Mike Graham, Austin Mack, Cedric Fairbanks Attachment 1 Revised Form 2C, flow diagram and descriptions NPDES Permit Narrative, and Revised Chemical List HF Lee Energy Complex NPDES permit Application update August 31, 2016 NC0003417 EPA I.D. NUMBER (ralmfnnn Item I of Form 1) Form Approved. NCI3000830661 OMB No 204"086. Please print or type in the unshaded areas only. Aooroval exoires 3-31-98 FORM U.S. ENVIRONMENTAL PROTECTION AGENCY FOR PERMIT TO DISCHARGE WASTEWATER 2C vEPA EXISTING MANUFACTURING,uCOMMERCIAL, MINING AND SILVICULTURE OPERATIONS NPOES Consolidated Permits Program I. OUTFALL LOCATION For each outfall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water A. OUTFALL NUMBER On) S. LATITUDE C. LONGITUDE D RECEIVING WATER (name) 1 DEG. 2. MIN. 3. SEC. 1 DEG. 2. MIN. 3. SEC, 001 35 22 16 78 04 09 Neuse River 002 35 22 09 78 05 06 Neuse River 003 35 22 02 78 04 60 Neuse River 11, FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES A. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater to the effluent. and treatment units labeled to correspond to the more detailed descriptions in Item B. Construct a water balance on the line drawing by showing average flows between intakes, operations treatment units, and outfalls. If a water balance cannot be determined (e.g., for certain mining activities), provide a pictorial description of the nature and amount of any sources of water and any collection or treatment measures. B. For each ouHall, provide a description of: (1) All operations contributing wastewater to the effluent including process wastewater, sanitary wastewater, cooling water, and storm water runoff; (2) The average flow contributed by each operation; and (3) The treatment received by the wastewater Continue on additional sheets if necessary. 1. OUT- 2.OPERATION(S) CONTRIBUTING FLOW 3 TREATMENT FALL NO. (less) a. OPERATION (iist) b. AVERAGE FLOW (include units) a. DESCRIPTION b. LIST CODES FROM TABLE 2C-1 001 Ash pond discharge 2.5 MGD tbistoric flows) Discharge to surface waters 4.A Ash Transport waters 0 MM Sedimentation, neutralization 1.0 2 K Precip.6 air preheater wash water 0 map Sedimentation, neutralization 1•U 2 K Filter Plant Wastewater 0 MGD SedimenCation. neutralization 1-U 2 K Wayne County site Wastewaters 0 MGD Sedimentation, neutralization 1-U 2 K Miscellaneous Waste a MGp Sedimentation 1-U treated bulklinteratital ash basin Eat. 0.8 MUD {future) water treated Landfill LeaChaCe Eat. 0,01.0.1 MGD (future) Treated extracted Ground water Eat. 0.9 MGD (future) 002 cooling pond discharge 0.00 mgd• discharge to surface waters 4 A recirc. condenser cooling water 369 Mon Evaporation, recycle 1 P 4 Coal Pile runoff 0.02 ihiatorici Sedimentation, neutralization 1 U 2-K sewage treatment system 0.004 MGb Anaerobic treatment, sand filtration 3 C 1-V Low Volume Waste water 0.07 11GA Sedimentation, neutralisation 1 U 2.K combined cycle plant processes 133 CAN eat Evapoation, discharge to surface waters 1 P 4-A 003 combined cycle plant processes 133 gpm avg eat Evaporation, discharge to surface waters 1 F 4 A 003 OY Filter plant wastewater 15 gpm avg eat 002 equipment and containment drains 70 gpm avg eat RQ reject and filter backwash 25 gpm avg eat Quenched MG alcwdown 23 gpm avg eat OFFICIAL USE ONLY (effluent Auideline..urh-cnrege)rirs) EPA Form 3510-2C (8.90) PAGE 1 of 4 CONTINUE ON REVERSE CONTINUED FROM THE FRONT C Except for storm runoff leaks, or spills, are any of the discharges described in Items II•A or B intermittent or seasonal? ❑ YES (camplerr rhefothitring tahle) m NO (tat ra.tiec+rnu 11f) 3. FREQUENCY 4 FLOW a. DAYS PER 8 TOTAL VOLUME 2.OPERATtON(s) WEEK b. MONTHS a. FLOW RATE (inmx4 srrr{f3-.ahnmr.; 1 OUTFALL NUMBER (list) CONTRIBUTING FLOW (list) (srrceh• mrnw) PER YEAR (srec+h mrmrrr) `- DURAT!CN (:nday- 1 LONGTERM 2 MAXIMUM 1 LONGTERM 2 MAXIMUM AVERAGE DAILY AVERAGE DA LY i 002 discharge from cooling p=nd is rare. 0 0 These occurrences may be caused by extreme Strom events. III PRODUCTION A. Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility? ® YES (complelc Them 111-8) ❑ NO (Sro rn Smaan 111) B. Are the limitations in the applicable effluent guideline expressed in terms of production (orother measure of operation)? ❑ YES (compte+e Item 111-0 ® NO (stir to,kruan 1[I C If you answered'yes to Item III-6, list the quantity which represents an actual measurement of your level of production. expressed in the terms and units used In the applicable effluent guideline, and indicate the affected outfalls. 1. AVERAGE DAILY PRODUCTION 2 AFFECTED OUTFALLS (fist nutfall numbers) a. QUANTITY PER DAY b. UNITS OF MEASURE c. OPERATION, PRODUCT, MATERIAL, ETC (.speeds') N/A IV IMPROVEMENTS A Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operations of wastewater treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited to, permit conditions, administrative or enforcement orders, enforcement compliance schedule tenets stipulations, Court orders, and grant or loan conditions YES ❑ NO (W, fir hem 11 -11) 1 IDENTIFICATION OF CONDITION, 2- AFFECTED OUTFALLS 3, BRIEF DESCRIPTION OF PROJECT 4 FINAL COMPLIANCE DATE AGREEMENT, ETC, a. NO b. SOURCE OF DISCHARGE a, REQUIRED b PROJECTED Selenium compliance 001 ash pond retire coal units nitrogen compliance 001 ash p-nd retire coal units B OPTIONAL. You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your discharges) you now have underway or which you plan Indicate whether each program is now underway or planned• and indicate your actual or planned schedules for construction ❑ MARK -X- IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATTACHED EPA Form 3510-2C (8-90) PAGE 2 of 4 CONTINUE ON PAGE 3 EPA I.D. NUMBER (copyfhmmItem I rfl•orm 1) CONTINUED FROM PAGE NCD000830661 V INTAKE AND EFFLUENT CHARACTERISTICS A, B, & C See instructions before proceeding — Complete one set of tables for each outfall —Annotate the outfall number in the space provided NOTE Tables V-A, V-B, and V-C are included on separate sheets numbered V-1 through V-9 0. Use the space below to list any of the pollutants listed in Table 2c-3 of the instructions, which you know or have reason to believe Is discharged or may be discharged from any aulfall For every pollutant you list, briefly describe the reasons you believe It to be present and report any analytical data in your possession 1 POLLUTANT 2 SOURCE 1 POLLUTANT 2 SOURCE Asbestos Trace amounts in insulation Strontium Trace amounts in coal Uranium Trace amounts in coal Vanadium Trace amounts in coal Zirconium Trace amounts in coal VI. POTENTIAL DISCHARGES NOT COVERED BY ANALYSIS Is any pollutant listed in Item V-C a substance or a component of a substance which you currently use or manufacture as an intermediate or final product or byproduct? ® YES (list all such prrllutams helow ) ❑ NO {4ro ru Hcm VI•H) The following substances may be present in coal: Antimony Arsenic Beryllium Cadmium Chromium Copper Lead Mercury Nickel Selenium Silver Thallium Zinc EPA Form 3510.2C (8-90) PAGE 3 of 4 CONTINUE ON REVERSE CONTINUED FROM THE FRONT VII BIOLOGICAL TOXICITY TESTING DATA Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in relation to your discharge within the last 3 years? © YES (ldent fi- the test(s) anddewrihe rheirpurpuses below) ❑ NO (g,, w Seniors vill) Outfall 001 - Quarterly acute toxicity testing, all testing has been passed during this permit cycle. OUtfall 002 there has been no discharge since approximately 1998. No tox tests have been conducted. VIII CONTRACT ANALYSIS INFORMATION Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm? ❑ YES (hv the Warn, address. and telephone numher ref and prrlluianu anal):ed ki ❑ NO (yqr rn .Acrinn 1,11 twch such lahnrahr{l fir firm hdow) A. NAME B ADDRESS C. TELEPHONE D POLLUTANTS ANALYZED (anw nude R• na.) (fist) IX CERTIFICATION l terrify 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 property 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 theta are significant penaldas for submitting false information including the possibility of One and imprisonment for knowing violations. A. NAME & OFFICIAL TITLE (tjyte or print) B. PHONE NO. (anw rude d- no.) Harry K. Sideris, SVP Envirmental, Health and Safety 004j 382-4303 C SIGNATURE t D DATE SIGNED 08/31/2016 EPA Form 3510-2C (8-90) PAGE 4 of 4 Duke Energy Progress, Inc. Attachment 3. Water Flow Line Drawing HX Lee Energy Complex Collection Tanks Wayne Co CT Site and Drain Tanks Plant Processes Collection Sump Fw A.O. Reject Wayne Cc CT Site RO S stem Lee CC K Plant Processes P K V F HRSC blowdown to Cooling paud Neuse River X Outfnll 003 or cooling pond 7Nc'w Collection SumpOutfall 002 p 7 Y Filter Cake Filter Press Domestic Waste & Potable Water Drains:::: FLceDomc-slicResiduals sent off site sludge Water Treatment K Evaporation & Seepage l \ ' I Oil Water Separator (Sludge) H. F. Lee Energy Complex NC0003417 Off -site H ResidualsDisposal from Retention Olher Low Volume Wastes CT Site secondary containment and fuel forwarding area SW Oil Water � Separator (sludge) Z Landfill leachale Storage Dnk5 tiuMfema W W+uexma Trca�mrn� Sludge GW extraction AA"r iwoffsite disposal miA"idmLKtnx malty nlrcn. irn wells stem �,d-1a rc�c+rc 1—. L files fr .unx".u�mene.yiW- Z,PA,B BB CC z Am NF fe.,'sc Ri�11] Ash pond tfall J Evaporation and seepage Neuse River Outffall 002 M I Y U Ncusc River A HRSC blowdown Cooling Pond $ River Make-up Intake R.O. Cleaning E Y Cooling water intake N Condenser., August 20113 Page A3-1 Duke Energy Progress, Inc. Attachment 3 H. F. Lee Energy Complex Stream Estimated Average Flow (New Lee Combined cycle site Comments A 12.7 MGD' Make-up water from Neuse River Make-up water to cooling pond B 12.7 MGD D 453 MGD Circulating Water withdrawal from cooling pond E 453 MGD Condenser cooling water return F - Lee Combined Cycle Plant Site wastewaters from oil/water separator (existing) Cooling pond evaporation & seepage (estimated) I 11.3 MGD' J 0.004 MGD Existing Lee site Sewage treatment system K 0.43 MGD Treated water to reverse osmosis system and plant processes M Rare Occurrence Cooling pond discharge to Neuse River (Outfall 002) N 453 MGD Condenser cooling water supply P Wayne County CT Site wastewaters from sump lift station Q 2,400 gal/event Collection and drains Tank Qnew 2,400 gal/event 0.048 MGD New Wayne County CC Site wastewaters from oil/water separator (for new Combined cycle) R Wastewater from filter plant, recirculated back to clarifier Raw water to filter plant (cycle makeup) New WCT CC plant process drains R.O reject stream U 0.48 MGD V 0.168 MGD 0.036 W X 0.3MGD avg. (est.) Outfall 003 to Neuse river Y 0.3MGD avg. (est.) Outfall 003 wastewater flows to cooling pond Z 0.01 — 0.1 Est landfill Leachate flow to treatment system AA 1.8 MGD Est GW extraction well flow to treatment system BB 0.8 MGD Bulk/interstrial ash pond water to treatment system CC 0.3 MGD Recirculated flow from treatment system to ash pond, 8/31 /2016 Duke Energy Progress, Inc. H. F. Lee Energy Complex stortnwater Z,AA,BB 1.8 MGD Est, flow from treatment system to Outfall 001 Nole: "MUD" = Million Gallons per Day 1. Makeup from the Neuse River to the cooling pond varies throughout the year. Makeup volumes will equate to losses from evaporation and seepage to maintain lake level. 8/31 /2016 Duke Energy Progress Inc. W.F. Lee Energy Complex NPDES Permit Number NCO003417 Attachment_ 4. Description of Operations Contributina to Wastewaters at OutfalI 001, Outfall 002 and Outfall 003 The H.F Lee Energy Complex has retired and demolished three coal-fired generating units and four simple cycle combustion turbines. Commercial operation of the site's newly constructed 3 X 1 combined cycle electric generation block began on December 31, 2012. The site now consists of five (5) simple cycle combustion turbines and the combined cycle unit. Total electric generation capacity for the site is over 1800 Megawatts. The site will continue to utilize the existing 545 acre off -stream closed -cycle cooling pond for condenser cooling and process water. Water is withdrawn from the Neuse River, as required, to make up evaporative, seepage, and discharge losses from the cooling pond. Makeup pumping rates are highly variable depending upon natural weather conditions, generation load and plant operations, quantity of water available in the river, and pond water levels. The maximum normal operating level of the cooling pond is maintained at a safe level below the crest of the spillway gates. Discharges from the cooling pond are rarely made, usually only during an extremely heavy rainfall event or a hurricane. The cooling pond last discharged in 1998. Chemical constituents contained in the cooling pond discharge are, for the most part, representative of the naturally -occurring chemical quality and quantity of the intake water. Upon retirement of the coal fired units, waste streams from processes which historically went to the ash pond or the cooling pond will either no longer be generated or will be redirected to new outfall 003 to the Neuse River. More detail on these specific wastestreams is provided below. In addition to the permitted outfalls, backwash from intake screening devices may be discharged into the Neuse River bypass canal associated with the Neuse River pursuant to NCAC 15A 2H .0106 (f) (2)• The combined cycle plant utilizes water from the 545 acre off -stream cooling pond as its source for fire water. Infrequently, flushing and testing of the fire system may result in releases of the fire water. The following is a description of wastewater streams that will be reflective of the new H.F Lee Energy Complex: Contributing Flows into the Ash Pond (NPDES outfall 001) The coal plant has been retired and no routine flows associated with coal fired generation are sent to the ash pond. Wastestreams from closure activities associated with the coal fired unit may still be sent to the ash pond until closure is complete. Duke Energy Progress, Inc. wishes to maintain outfall 001 as an active outfall to ensure permitted coverage of any incidental discharges which may occur associated with heavy rainfall events and to facilitate any needed groundwater remediation and dewatering for future closure of the wastewater treatment. Wastestreams that have been historically sent to the ash pond include: Ash Transport System Wastewater Fly ash and bottom ash from all three coal fired units were hydraulically conveyed by ash sluice pipelines to the Lee Plant ash pond. (Ceased) A4-1 8/31 /2016 Duke Energy Progress Inc. H.F. Lee Energy Complex NPDES Permit Number NCO003417 Precipitator and Air Pre -heater Wash Water Water from washing the interior of the precipitators and air heaters is typically routed to the ash pond via the ash transport system but could be routed directly or indirectly to the cooling pond. The wastewater from the Rotamix treatment system added to Unit 3 for NOx removal is also routed to the ash pond. (Ceased) Filter Plant Wastewater Blowdown and filter backwash wastewater generated in the filter plant is discharged into the ash sluice transport system which flows to the ash pond. (To be redirected to outfall 003, recirculated or directed to Outfall 002) Wayne County Combustion Turbine Site Wastewaters The containments around the accessory module, liquid fuel, and atomizing air modules and the wash water drain empty into collection tanks. Once there is a quantity of liquid collected in the tanks, the wastewater is removed by pumper truck and transported offsite. The wash water drain tanks collect the water and detergent used to clean the CT compressors. (To be redirected to outfall 003, Outfall 002 or disposed of offshe after ash pond closure) Miscellaneous Wastes Cooling tower basin sludge, circulating water tunnel sediment, and boiler vacuuming sediments are sent to the ash pond. Other residuals from the low volume wastes retention basin and the coal pile runoff retention basin and other miscellaneous low volume wastes from plant processes are also transported to the ash pond. Storm water from the ash line trench flows into the ash pond. There may be seepage in the vicinity of the ash pond. Some seeps may be seasonal. Bulk water decanting/Interstitial Dewatering Bulk and interstitial ash basin water will be decantedldewatered from the 1982 ash pond through Outfall 001. Additional wastewater equipment will be brought onsite to assist in the bulk and interstitial decanti ng/de watering. The additional wastewater treatment consists of. • Ballasted flocculation; • Catalytic oxidation media filters; • Coagulant, polymer, and additive feed systems; • Ion exchange resin; • Reverse osmosis system; • Filter press trailers and sludge holding tanks Low volume wastes from the wastewater treatment system (WTS) as well as stormwater from the WTS pad area are recycled back to the ash pond. Sludge is removed from the system. The WTS will only discharge through Outfall 001. Landfill Leachate In the future, Duke Energy plans to discharge wastewater from an onsite coal ash landfill. Landfill leachate from the lined Iandfill will be collected in two 500,000 gallon tanks and routed to the WTS for additional treatment and discharge through Outfall 001. Non contact stormwater will be collected in A4-2 8/31/2016 Duke Energy Progress Inc. W.F. Lee Energy Complex NPDES Permit Number NC0003417 retention ponds and permitted initially as construction stormwater under the NC construction general permit NCG120000. Once the landfill is capped, non contact water will also be routed along the ground surface to the retention ponds. The ponds are designed to capture the 25 year, 24-hour storm with an additional 1 foot of freeboard. Groundwater Extraction Well System Duke Energy is currently designing an extraction well system to provide accelerated groundwater remediation. The groundwater will be treated prior to discharge through outfall 001. Treatment of the discharge may be provided by introducing the groundwater as a waste stream to the ash ponds (for treatment through the WTS), direct treatment through the WTS, or direct treatment through a dedicated groundwater treatment system. Contributing Flows into the Cooling Pond Closed Cycle) NPDES outfall 002 Re -circulated Condenser Cooling Water This flow will provide condenser cooling water for the 3x I combined cycle generation units. The total flow is re -circulated into the 545 acre pond from the condensers, routed through the pond by baffle dikes to achieve maximum surface cooling efficiency before reaching the condenser cooling water intake to be again introduced to the condensers for cooling. Cooling of the recirculated water in the pond is achieved primarily by evaporation from the pond surface, which is estimated to consume approximately 3-5 MGD above natural evaporation rates during times the units are in full operation. Some flows from stormwater drains on the Lee plant site will still be directed to the cooling pond. Sewage Treatment System (limited use) Domestic waste is treated in a septic tank and sand filter bed system. Flow from the system is dependent upon fluctuating demand due to variations in the number of personnel on site. Residuals are disposed of off -site by a licensed contract disposal firm. The sand in the system is periodically changed to ensure system effectiveness is maintained. The spent sand is disinfected and disposed of in a landfill. Coal Pile Runoff Until the coal pile is completely removed, runoff will still be directed to the cooling pond. The coal pile area is surrounded by a drainage ditch that is routed to a clay -bottomed, asphalt and concrete -sided settling basin. The settling basin is sized so as to adequately store runoff and allow suspended solids to settle before the supernatant is discharged by overflow to the cooling pond. During routine maintenance of the basin, any solids removed will be disposed of in the active ash pond. (Ceased) Other During routine maintenance, the water treatment plant clarifier may be drained to the cooling pond to allow for inspection of the clarifier. This activity typically occurs annually but may occur more frequently. Additionally, should the filter press not be operational, clarifier solids may temporarily be directed to the wastewater cooling pond for a short duration until the filter press can be repaired. This is expected to be infrequent and will not be a routine operating mode. Wastewater associated with the cleaning the plant process reverse osmosis process unit will be taken A4-3 813112016 Duke Energy Progress Inc. H.F. Lee Energy Complex NPDES Permit Number NC0003417 offsite or directed to the cooling pond. If directed to the cooling pond an antifoam chemical may be added to the wastewater. A blowdown stream from the combined cycle Heat Recovery Steam Generator is directed to the cooling pond. In the near future the Lee Plant plans to construct piping to allow for all of the flows listed below which contribute to Outfall 003 to be discharged into the cooling pond. Including filter plant wastewater and existing Wayne County Combustion Turbine Site Wastewaters, which are described below. Filter Plant Wastewater Existing water treatment plant clarifier blow down and filter backwash wastewater generated in the filter plant was previously discharged into the ash sluice transport system and to the ash pond. Filter backwash and clarifier alum solids will be treated via a gravity thickener and filter press. Filtrate from the filter press was previously commingled with other waste streams and directed to outfall 003. This flow has been rerouted and is now back to the water treatment plant clarifier. Solids from the filter press will be disposed of at an offsite location, or on rare occasion in the cooling pond. Existing Wayne County Combustion Turbine Site Wastewaters Water from the cooling pond passes through a clarifier, dual media sand filters and then through a five - micron cartridge pre -filter before entering either of two reverse osmosis (RO) units. The two RO units may be operated in parallel or series depending on operational needs. The treated water is stored in a tank until needed. Reject wastewater from the reverse osmosis process is sent to a sump where it will be routed to either the cooling pond (outfall 002) or outfall 003. In addition to the RO reject wastewater, excess evaporative cooling water, process drains, and waters from the oil water separator will be routed to the cooling pond (outfall 002) or routed to outfall 003. Historically, the containments around the accessory module, liquid fuel, and atomizing air modules empty into collection tanks. Once there is a quantity of liquid collected in the tanks, the wastewater is removed by pumper truck and transported and released into the Lee Plant ash pond. There is also a drain tank that collects the water and detergent used to clean the CT compressors. All of these wastewaters will be either pumped and hauled offsite or redirected to the cooling pond (outfall 002) or outfall 003 after the ash pond is no longer used. An oil water separator treats storm water from the containment areas around the facility's fuel oil storage tanks, the fuel forwarding pumps, and the fuel oil unloading area. Water from the oil water separator will be conveyed to the new collection sump and routed to outfall 003, or the cooling pond (outfall 002). Storm water collection containment areas around transformers and substations are examined for the presence of any oily substance; if oily substances are not present in the water, the water is drained to the ground. If oily substances are present nothing will be drained from the containments until that substance is properly removed. Outfall 003 will also contain a blowdown stream from the wet surface air cooler (WSAC). Wastewaters from routine cleaning, fuel oil/water condensate, false start materials, equipment drains containing potential oil, and compressor wash water may be routed to outfall 003. Any of these waters with a potential for containing oil are routed through the oil water separator before being sent to outfall 003. Incidental leaks associated with the routine operation of the combustion turbine heat recovery A4-4 8/31 /2016 Duke Energy Progress Inc. H.F. Lee Energy Complex NPDES Permit Number NC0003417 steam generator may occur and get to the ground surface. Other infrequent draining and cleaning of various process units during operation and maintenance activities may generate wastewater that will be routed to outfall 003. These wastewaters may also be routed to the cooling pond (outfall 002). Contributln flows to Outfa11003 Filter Plant Wastewater Existing water treatment plant clarifier blow down and filter backwash wastewater generated in the filter plant was previously discharged into the ash sluice transport system and to the ash pond. Filter backwash and clarifier alum solids will be treated via a gravity thickener and filter press. Filtrate from the filter press was previously commingled with other waste streams and directed to outfall 003. This flow has been rerouted and is now back to the water treatment plant clarifier. Solids from the filter press will be disposed of at an offsite location, or on rare occasion in the cooling pond. Existing Wayne County Combustion Turbine Site Wastewaters Water from the cooling pond passes through a clarifier, dual media sand filters and then through a five - micron cartridge pre -filter before entering either of two reverse osmosis (RO) units. The two RO units may be operated in parallel or series depending on operational needs. The treated water is stored in a tank until needed. Reject wastewater from the reverse osmosis process is sent to a sump where it will be routed to either the cooling pond (outfall 002) or outfall 003. In addition to the RO reject wastewater, excess evaporative cooling water, process drains, and waters from the oil water separator will be routed to the cooling pond (outfall 002) or routed to outfall 003. Historically, the containments around the accessory module, liquid fuel, and atomizing air modules empty into collection tanks. Once there is a quantity of liquid collected in the tanks, the wastewater is removed by pumper truck and transported and released into the Lee Plant ash pond. There is also a drain tank that collects the water and detergent used to clean the CT compressors. All of these wastewaters will be either pumped and hauled offsite or redirected to the cooling pond (outfall 002) or outfa11003 after the ash pond is no longer used. An oil water separator treats storm water from the containment areas around the facility's fuel oil storage tanks, the fuel forwarding pumps, and the fuel oil unloading area. Water from the oil water separator will be conveyed to the new collection sump and routed to outfall 003, or the cooling pond (outfall 002). Storm water collection containment areas around transformers and substations are examined for the presence of any oily substance; if oily substances are not present in the water, the water is drained to the ground. If oily substances are present nothing will be drained from the containments until that substance is properly removed. Outfall 003 will also contain a blowdown stream from the wet surface air cooler (WSAC). Wastewaters from routine cleaning, fuel oil/water condensate, false start materials, equipment drains containing potential oil, and compressor wash water may be routed to outfall 003. Any of these waters with a potential for containing oil are routed through the oil water separator before being sent to outfall 003. Incidental leaks associated with the routine operation of the combustion turbine heat recovery steam generator may occur and get to the ground surface. Other infrequent draining and cleaning of various process units during operation and maintenance activities may generate wastewater that will be routed to outfall 003. These wastewaters may also be routed to the cooling pond (outfall 002). A4-5 8/31/2016 H. F. Lee Energy Complex Duke Energy Progress, Inc. NPDES Permit Number NC0003417 Attachment S. Potential Discharges Not Covered By Analysis Estimated Quantity (used per Chemical ear) Frequency Purpose NALCO Stabrex ST-70 800 gal As required Wet Surface Air Cooler biocide NALCO 3D Trasar 3DT189 300 gal As required Wet Surface Air Cooler corrosion control NALCO BT 3000 150 lb As needed Boiler corrosion inhibitor Ammonium Hydroxide (19%) 1,200 gal As required Boiler condensate pH control NALCO Y302939.52 Sodium hypochlorite, 10-16% 34,000 gal As required Raw water biocide Winter alum liquid 36,000 gal As required Raw water treatment Caustic, 25% tech grade 21,000 gal Continuous Raw water pH control Caustic, 50% tech grade 12,000 gal Continuous Ash pond pH control Soda Ash 4,000 lb As required Ash pond pH control Connect 6000 280 gal As required Wayne County Combustion Turbine Site Turbine compressor cleaning NALCO PC-77 110 gal As required Wayne County Combustion Turbine Site RO System membrane low pH cleaner NALCO PC 98 400 gal As required Wayne County Combustion Turbine Site RO System membrane high pH cleaner NALCO PermaTreat PC-191 220 gal Continuous Wayne County Combustion Turbine Site RO System antiscalant NALCO 7408 (sodium bisulfite) 880 gal As needed Various water stream dechlorination NALCO PC 11 variable As required Biocide for Reverse osmosis system Miscellaneous laboratory solutions 2 gal As required Wayne County Combustion and reagents Turbine Site RO water testing Nalco 7465 < 1 gallon As required Foam Control Nalco 7468 < I gallon As required Foam Control Sulfuric Acid As required pH adjustment of ash basin A5-1 August, 2016 H. F. Lee Energy Complex Duke Energy Progress, Inc. NPDES Permit Number NCO003417 discharge Acetic Acid As required pH adjustment of ash basin discharge Citric Acid As required pH adjustment of ash basin As required discharge pH adjustment of ash basin Hydrochloric acid discharge As required pH adjustment of ash basin Alum discharge As required pH adjustment of ash basin C011 discharge Ash Pond Water Wastewater Treatment System Chlorine Dioxide < 500 As needed Biofouling control gallons Sulfuric Acid (98%) < 500 As needed Membrane cleaning allons ChemTreat P860E Polymer <1000 Continuous Polymer gallons Ferric Chloride 30,000 Continuous Wastewater treatment additive gallons Sodium Hypochlorite 30,000 Continuous Wastewater treatment additive gallons Sodium Bisulfite 2,000 Continuous Wastewater treatment additive gallons ChemTreat RL9004 <1000 As needed Antiscalant gallons Sodium Hydroxide <10,000 Continuous Wastewater treatment additive gallons A5-2 August, 2016 Attachment 2 Future Condition HF Lee CCP Landfill Data Comparison Untreated Mayo CCP Landfill leachate data HF Lee Energy Complex NPDES permit Application update August 31, 2016 NC0003417 TABLE 8 LEACHATE FIELD AND ANALYTICAL RESULTS MAYO CCP LANDFILL PHASE 1- PERMIT NO.7305 MAYO STEAM ELECTRIC PLANT DUKE ENERGY PROGRESS, LLC, ROXBORO, NC S&Yl* Dade: Aprg 6, 2016 Labormaty Cot?—aiz Codes Sy OMS Cvrpwstk.+ FWd f SW Rdd Swing paivtned by SynTerra Cnrpwww duke Bub AftWy kW Ltbwa=y Parameter SWS ID Utee�s [,_#ifiiGMz Code L� ROIL SWSL field pH 320 SU 5.591 7.9 NE Specific Conductance 323 umho/crn 51591 305 NE Temperature 325 "C 5,591 14 NE Arsenic 14 pot. 248 14.7 1 10 Barium 15 41. 248 61 5 100 Boron 428 41. 248 1.270 50 NE Cadmium 34 pglL 248 < 1 1 1 Chloride 455 µy/L 248 39 000 1 ON NE Chromium 51 poL 248 26 5 10 Capper 54 pVL 248 < 5 5 10 Fluoride 312 pot. 248 180 100 U00 1ron 340 pg/L 248 416 10 300 Lead 131 pg/L 248 < t 1 10 Manganese 342 pg/L 248 8 5 50 Mercury 132 pg/L 248 < 0 05 0.05 02 Nkiel 152 pg/L 248 34 5 50 Nitrate (as Nitrogen. 303 pg/L 248 630 23 10 000 Selenium 183 pg/L 248 1.7 1 10 Silver 184 pg/L 248 < 5 5 10 Sulfate 315 pg/L 248 130 000 2.000 250,000 Total Disso)ved Solids 311 pg/L 248 330,000 25,000 NE Zinc 213 pg/L 248 204 5 10 •�—q nr a� .a.R„„a or at: 3• I] [�r� an agaal to ar purr men Nr SMN3 2.1H/ 0wzzfflbrYs M OPO b tr WNW mm m• M ft= 2a 9.r,etd W W beN rdcrbn a maw.. # Melt nr :.4 tanpa 3. t;� i -mw M eec,e0n pa nw 6WL k 4. 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WM Wd & pm UwAMFWdwd&nordLa pabe 1 d t Attachment 3 Clean Water Act Section 316(b) Alternate Schedule HF Lee Energy Complex NPDES permit Application update August 31, 2016 NC0003417 Alternate Schedule Request §316(b) of the Clean Water Act H.F. Lee Combined Cycle Station Final regulations to establish requirements for cooling water intake structures at existing facilities were published in the Federal Register on August 15, 2014 (i.e. regulations implementing §316(b) of the Clean Water Act) with an effective date of October 14, 2014. Per §125.91(a)(1)-(3) Applicability, the H.F. Lee Combined -Cycle Station (Lee) is subject to the requirements at §125.94 through §125.99 (316(b) requirements) based on the following: — The facility is defined as an existing facility; — The facility has a point source discharge; — The facility uses a cooling water intake with a design intake flow (DIF) of greater than 2 million gallons (MGD) to withdraw water from waters of the U.S.; and — Twenty-five percent or more of the water withdraws on an actual intake flow basis are exclusively used for cooling purposes. Per §125.98(6) Permitting requirements, 316(b) requirements are implemented through the NPDES permit. For Lee, the NPDES permit proceedings had begun prior to the effective date of the rule. Therefore, 40 C.F.R §125.98(g) Ongoing permitting proceedings, applies, which states: "... whenever the Director has determined that the information already submitted by the owner or operator of the facility is sufficient, the Director may proceed with a determination of BTA standards for impingement mortality and entrainment without requiring the owner or operator of the facility to submit the information required in 40 CFR 122.21(r).." Lee was not subject to the remanded 316(b) Phase II Rule because the station employs a closed - cycle recirculation cooling water system by utilizing a cooling pond not designated as waters of the U.S.; therefore, no information related to 316(b) has been previously submitted. As stated in the preamble to the rule, "In such circumstances where permit proceedings have already begun prior to the effective date of the rule, these facilities will still need to submit the appropriate permit application materials found at § 122.21(r) permit applications during their next application."' Furthermore, the regulation states the owner of a facility whose current effective permit expires after July 14, 2018, must submit the above information when applying for a subsequent permit and the owner of a facility whose current effective permit expires on or before July 14, 2018 may request an alternate schedule for the submission of the above information. As allowed under ,§125.95(a)(2), Duke Energy would like to request an alternate schedule for the submission of the applicable 316(b) information for Lee. Per §122.21(r)(1)(ii), the following information must be submitted for all existing facilities: 179 Fed. Reg. 48358 (15 August 2014) §122.21(r)(2) Source Water Physical Data §122.21(r)(3) Cooling Water Intake Structure Data §122.21(r)(4) Source Water Baseline Biological Characterization Data §122.21(r)(5) Cooling Water System Data §122.21(r)(6) Chosen Method(s) of Compliance with Impingement Mortality Standard §122.21(r)(7) Entrainment Performance Studies §122.21(r)(8) Operational Status As stated above, Lee employs a closed -cycle recirculating cooling water system by using a cooling pond not designated as waters of the U.S. The station, however, does have a make-up intake on the Neuse River with a DIF of approximately 35 MGD. With the DIF being significantly less than 125 MGD threshold, the additional information requirements under §122.21(r)(1)(ii)(B) Existing facilities greater than 125 MGD A!F are not applicable to Lee. Duke Energy is not planning on collecting any new biological data on the source water, or conducting impingement or entrainment studies at the cooling water intake structure and has not been requested to do so by North Carolina Department of Environmental Quality (NCDEQ). Existing biological data from available sources will be used to complete §122.21(r)(2) Source Water Physical Data and §122.21(r)(4) Source Water Baseline Biological Characterization Data. Furthermore, with the station utilizing a cooling water impoundment not designated as waters of the U.S. and only requiring minimal make-up from the Neuse River, Duke intends to demonstrate the existing technologies at Lee meet the best technology available (BTA) standard for both impingement and entrainment mortality. Attachment 4 Future condition HF Lee Extraction Well System Groundwater Data HF Lee NPDES permit Application update August 31, 2016 NC0003417 HF Lee GW Well Data Summary 14 wells sampled form 2010-2016 Parameter Units Average results from 14 wells 2010-2016 sampling events Aluminum ug/L 297 Arsenic ug/L 63.5 Cadmium ug/L 0.8 Cobalt ug/L 2.7 Copper ug/L 4.1 Manganese ug/L 209 Nickel ug/L 4.2 N itrate mg/L 0.2 Selenium ug/L 2.7 Total Dissolved Solids mg/L 231 Total Suspended Solids mg/L 7.3 Zinc ug/L 6.6 pH Std. units 6.0 Attachment 5 Updated Sampling Point Aerial Photo HF Lee NPDES permit Application update August 31, 2016 NC0003417 I rn o-CO :, �o- ~ � o11> d N �C? {' Q U) Q C' r -1 Q O co —i NU,0 U) Q 4 t, N O J) O N U) U) O { T C7 N N o �00� � U) U)k IN A k l '4 ti Ol � r h 4+ M1 l 4 00 T 0 9 [i7 U) to O