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HomeMy WebLinkAboutNC0004987_Regional Office Historical File Pre 2018 (3)Paul omovftc^RE, Sevicl,vice President cnvironnenb,/He,a/r? &Sanet,y and Ovena,k,nmSupport mb88»�eF��{r _ o//a.�� 980) December 19.2Ol9 Mr. Bob Sledge North Carolina Department ofEnvironmental Quality 16l7Mail Service center Raleigh N[27699-l6l7 RE: Response toNOV-2*l9'SP'OQU8 Duke Energy Carolinas, LL[, Marshall Steam Station Special Order by Consent WQS17-009 Dear Mr. Sledge, Duke Energy Carolinas, LLC (Duke Energy) appreciates the opportunity to provides this response and supporting information tgthe subject Notice ofViolation, Duke Energy continues to progress with activities at the Marshall Station in efforts to safely close the station's ash basin. This response provides supporting and background information to demonstrate Duke Energy's position that the noted exceedencemfwater hardness was due tocircumstances and events beyond the reasonable control of Duke Energy and therefore further penalties and actions should not bedue imaccordance with condition 5 ofthe subject order. Background and claim Duke Energy asserts that the xvate, hardness levels were not related to any inappropriate action or inaction on the part of Duke Energy and were a result of "on extronrd/ crycvent beyond Duke Energy's control". /\ quarterly sample was taken asrequired from the location identified as S-lon September 25' 2019. This sample test result was reported ashaving a "water hardness~ of316 nnQ/[ The subject Consent Order establishes an interim level for this location of28Omg/i Duke Energy contends that the levels of water hardness in the sample is primarily a function of drought related conditions atthe time ofthe sample and therefore beyond the control nfDuke Energy, As noted during the sampling event, the Omvv of the tributary was as |om/ as has been observed during the term ofthe Consent Order. Table 1presents the data collected atlocation S'I since the effective date of the consent order, This data Shows the genera/ correlation between concentration ofwater hardness and flow. Chlorides values are also presented asan additional calibration point. Mr. Bob SIedge Response to NOV SP 2019-0008 December 19, 2019 Table 1. Flow and Hardness comparison Date 6/7/2018' 9/11/2018 10/31/2018 3/27/2019 5/7/2019 9/25/2019 11/22/2019 Approximate Flow (gpm) 13.46 4.94 15.71 Not recorded No flow recorded 4.75 Not recorded Hardness (mg/I) 159 195 137 138 166 316 205 Chloride'. (mg/I) 66 84 50 53 63 170 97 12/5/20194 1 Chloride data presented as an additional reference 2 First sample event after the effective date of consent order EMC WQ517-009 13 1693 63 3The only difference in operating conditions between the 9/25/19 sample and the 12/5/19 sample is meteorological conditions. 9/25/19 was taken during dry conditions and 12/5/19 was taken after a return to more normal rainfall levels. Samples taken evaluating various treatment between September 25 and December 5 will be submitted under separate cover. As demonstrated in Table 1, when flows are generally below 5 gpm, hardness levels are around 200 mg/I or greater. When flows are higher, the hardness concentrations are generally lower. This supports the position that the hardness concentration was primarily caused by lack of rainfall and therefore beyond the control of Duke Energy. This reduction in flow volume during dry periods means that groundwater impacted by the ash basin makes up a larger proportion of the base stream flow than at other times and while the groundwater is likely carrying no more (and possibly even less) mass of pollutants than historically, the concentration increased above the listed Interim Action Level (IAL). This was an event that was not foreseen during the development of the IALs and was beyond the reasonable control of Duke Energy. Duke Energy is undertaking an expedited schedule under the subject consent order to lower the water levels in the ash basin to address this very type of situation in the long term. As of December 8, 2019, the water level has been lowered by 10 feet. Because of the review of hardness data, Duke Energy has submitted a request to modify the subject consent order to amend the interim action level for hardness. Duke Energy has previously submitted a report detailing specifics as to the influence of drought on the sampling event. This report was required to be developed and submitted by condition 2.(c).(1) of the Consent Order. Duke Energy includes the details and supporting information in that report by reference and has attached a copy of that report as a part of this submittal. A second, independent evaluation of the water hardness levels at location "5-1" in relation to rainfall was undertaken as a result of the Notice of Violation and is also attached. This evaluation documents the inverse relationship using a 6-week precipitation total and measured water hardness at location "5-1". An additional potential minor factor that led to increased hardness concentrations in the ash basin is the facility's requirement to cease all flows to the ash basin under the Federal CCR rule. Flows to the ash basin were terminated in April 2019 in accordance with the Federal CCR rule. This led to the removal of a service water flow necessary to protect the former wastewater wetland treatment plants but also appears to have resulted in increased hardness levels in the ash basin itself. Table 2 illustrates the ash basin hardness levels before and after the removal of wastewater flows as required by the Federal CCR rule. It appears, based on sampling data, that the cessation of flows to the basin led to an increased Mr. Bob Sledge Response to NOV SP 2019-0008 December 19, 2019 hardness concentration level in the ash basin after the April 11, 2019 wastewater cessation date. Duke Energy was required by Federal law to remove these flows in order to comply with the Federal CCR rule. However, based on review of well data near S-01 it is concluded that the ash basin increase in hardness would have a minor effect on the increase in hardness at 5-1, with the drought still being the main cause of this issue, Table 2. Measured ash basin hardness levels T Ash basin discharge hardness (rng/I) 1/7/2019 404 2/4/2019 625 3/4/2019 493 4/1/2019 683 /3/2019 5/8/19 mm 7/1/2019 8/5/2019 9/3/2019 10/7/2019 889 767 827 858 900 Ash basin discharge hardness (mg/!) Mr. Bob Sledge Response to NOV SP 2019-0008 December 19, 2019 Additional support and mitigating factors 1. There was no harm associated with the water hardness level measured on September 25, 2019. Water hardness itself is not an environmental concern. The North Carolina Environmental Management Commission has not established a criterion for water hardness in Class "C" waters but only in waters classified as "water supply". The criteria in "water supply" waters is intended to protect against the scale buildup in pipes and appurtenances and in aesthetic conditions that can be exacerbated by hardness of water (e.g. difficulty in lathering of soap, etc). Water hardness can also reduce the bio-availability of certain metals and thereby reduce toxicity from metals. The following excerpt is taken from the DEC. document Summary of North Carolina surface water quality standards dated April 2015. The calcium and magnesium ions that contribute to water hardness are known to lower the toxicity of some metals by competing with the dissolved metal ions for binding sites on an aquatic organism. Toxic impacts to aquatic organisms occur when the metal ions bind to these sites on the organism (such as on the gills of a fish). The higher the water hardness (indicating more hardness related ions ore present) the lower the toxicity of some metals. The hardness ions are able to out - compete the metal ions for binding sites on the aquatic organisms; therefore, the organisms are ultimately exposed to less metal. 2. While the hardness of the small tributary to Lake Norman did have a sample result above the JAL in September 2019, the water hardness in Lake Norman has remained consistently low and unimpacted. Table 3 lists the measured water hardness in Lake Norman below the S-1 location and above any drinking water intake. Table 3. Measured water hardness in Lake Norman Date 6/7/2018 9/11/2018 10/31/2018 3/27/19 5/7/19 8/8/19 12/5/19 Upstream Water hardness (mg/I) 13.5 14.6 14 12.8 14.8 15.9 19.2 Downstream Water hardness (mg/I) 13 14.3 14.4 12.7 15 16.4 19.3 3. Duke Energy will soon be submitting a groundwater corrective action plan for the site. In this plan Duke Energy will provide more details as to proposed measures to address impacted groundwater influences at the location termed "5-1" in the consent order. Duke Energy requests that the Department review those proposed Tong -term measures prior to forming a decision as to whether or not to demand a stipulated penalty for the exceedence of water hardness IAL at sampling location "S-1". Mr. Bob Sledge Response to 'NOV SP 2019-0008 December 19, 2019 if you have any questions regarding this letter, please contact Mr. Robert Wylie at (704) 38 4669 or robe i t,w V� .m.''duke-energ co l 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. l am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Senior Vice President Attachments cc: MRO DEQ WQ Supervisor w/enclosure 610 East Center Avenue, Suite 301 Mooresville, NC 28115 Robert Wylie - via email Shannon Langley - via email Chris Hallman -via email Richard Baker via email Rick Roper - Marshall Station Manager FINDINGS OF D EVALUATION 0 UNDER PECIAL c -ASSESSMENT EMECIAL ACTII DER BY CONSENT 17 AT MARSHALL STEAM STATION 8320 NC HIGHWAY 150 TERRELL, NORTH CAROLINA 286 2 NOVEMBER 2019 PREPARED FOR: DUKE ENERGY CAROLINAS, LLC PREPARED BY: FINDINGS OF REASSESSMENT AND EVALUATION OF REMEDIAL ACTIONS UNDER SPECIAL RQER BY CONSENT E C ,I d 1 —OO9 AT MARSHALL STEAM STATION 8320 NC HIGHWAY 150 TERRELL, NORTH CAROLINA 28682 NOVEMBER 2019 PREPARED FOR DUKE ENERGY. DC KE ENERGY CAR©LINAS, Findings of Re -Assessment arii; Eva➢irate rt f,:it Actiu Special Order by Consent EM SO W SI. Duke Enti r er r to a . � L� Marshall �lto �,.. � �r h�zJl Stearn Station TABLE OF CONTENTS SECTION TLO INTRODUCTION__ 10 RE -ASSESSMENT" APPRO. CI1. .—,a.mas„s�ff,, 10 RE -ASSESSMENT ,AC"TIV(I iES AND FINDINGS—.,,.....om,.,.__ .1 5tre. am C4(riditioi'14 ....,. ,.. Surface''"trwIr�lir'1 3.3 Groundwater Sat i IE i r Asr7 basin C:z,}riclltl rt, iri ^ 3.5 Local E/r,'rtecipit:��tltl.rt Ion Exchange R ";" in Eva" nd D-r 4.0 PRELIMINARY Ct)NCl..,USION5...,,..ose.,,.,,,,... 5.0 'PROPOSED REMEDIAL OPTIONS.,—,. ....... 1 Short -Term ,.__..e.......... .. 5.. I. 1 No:rm d 7t reaS'f`" flow C 1pt ; . . Normal St ear„ftItt Capture, Stre aI , Charinei ate In ectic)r'i .. n,-�errn...,._........ Impoundment I Treat TreTIC Stream Channel Dew a -rung, T='iimp arid Treat E.xtracti,.'>.ti Wells is . ..... d Treat E,atr actlon S tE with 1 A.sh Basin '. BaS.LO REMEDIAL EITECTIV 1ESS MO\ ORING AND REPORTING t:,..o,,.,, .Action . PAS€: 3-4 4-1 1 Rec LIST OF TABLES Res J6tOHz/ Hardness Ley/saw A Cl e4 LIST OF FIGURES Findings of Pe -Assessment at d E Edluation ot t emedia! Actions Under SJ ecial Order by Consent -• EMC SOC WQ S17-009 Duke Energy" Carolinas, LLCC, MarshaIISteam Sta tion 1.0 INTRODUCTION Duke Energy, iN=°[anagemen.t Commissi@n entered into Sp ciai Order Bs, Consent SOC No. 17 (R)9, which was approved on April 18„ 7018, (Duke Energy) a.tad the North C.`arolina Environmental I\'lunzt rz°rr la slfled Gvaters o, found its Attach 8 of the aSOC, and r completed as ret.. eritn ac Samples L 0lI cttJ it ? I Wan di hardness at percent This dot remeci non -constructed seeps„ been were established in t 0 standard units (S.lr, by Duke En' S.rnent. 2(7r:*. in Cr �tr: f ha r lcl,c' 7tcc.ecl ,P`?'L r;,.. r r St' a Ere', [trope' Findings r ()lint's, Li -halt Stearn lipOed tgit ntengtar C len earl Warr Fsndin s rrt E e-Assessment and Evaluatir. Actions Under Special : rs sr l C's ns rat EMC SOC WQ S17.0 Duke Energy Carolinas, I.LC, Marshall Stearn Station 2,0 RE -ASSESSMENT APPROACH Plaintrs f wr tfa rr ss Bement of kl .. Seep began on Se naher receipt of the lr3hor,3tor report corrta rrl.he third quarter September 25, 20'4 same lhefaili«i develop preliminary required by the SC.)C Evaluate conJ medial opt Collect surface water" st: SOC quarterly Ocilla'( t ra n Cl Sil it, rien. Rev' and d e�°: ll Review .and t'vafnit' ?a 9r1C" De "rota preli;rL'r are cori„l`td` De velop cone ep"ti.ral rPx"sT1e^n{➢= ! nd ern o mitigate off rnber2a)19 fitic:)r1S and ek ui waters, as: r~eriL1a gs t l ar. s s resit r�fld Specual Order by Consent EMC Duke Energy Cjrolin."s,, LAX:, Ma atiun of Remedial, Actions Cinder 17009 hull Stearn Stano.n 3.0 RE -ASSESSMENT ACTIVITIES AND FINDINGS ssment fief rforrned multi 5.1 and rert.t gin. Surface water and g of the stream reach,, is bench- and field-testing of sites °twartdition°s was ;gathered. 'ember 2019 SvriTe rra g3n on October .10 201.9., Duke Ene, and 5yn quickly evaluate current condlhran affecting the tions tor mitigating the hardness levels at the sample r°trirndwater samples were collected, wpisual reconnaissance cent wetlands and upland drainage ww-as c:orrw~ u ted, i,'hTan e resin was performed and information on Stream Conditions assessment of iipstrea inand dow and upland drnLringe area ,-vas i"1C"it • char,acteri.zed "ircontrol ns was estimated at 1-2 gallons lre; g u,i:tures and da 2t2.i1feet ups a Dnditions from natural rn l i pia>r.c` beaver activity the teach, w'o°dais .g stream. conditions and pools 0 that the turbi ntlt'ticros ranging from schaarges r,f thrrirn dr to dr rr did not indicate dered to impact Juw n:strea r. wi,iticr, quality 3.2 Surface Water Sampling and Data Evaluation Surface water sampling d was conducted on October 10,, 201..9 to pro the re -assessment work, whiw'n Sin .Giied process Control and evaluation samples aim at assess", ag the effectiveness of lertat potential remedial options. Samples were olle fed at 2 lc ail r;as upstream of the -1 seep and 3 locations considered backgrr: and �l.e., ya-nd the influence of groundwater containing cabal Page. 3 1 Findings of Re -Assessment and Evaluation of Remedjal Actions Under Special Order by, Consent EMC, SOC bVQ., Si 7-009 November 20119 Duke Energy Carolinas., LL,C, Marshall Steam Station SvnTerra constituents), Tie sample locations upstream cif 5-1 were 'S-1 In Process' and '5-1 5pringheadU The background locations were the previously sampled 501-7 and 5W-8 (which are located on small strea.rns o the northwest of the ash ha s,;n1 and a Dei,aii location fiG-200, Figure 1 illustrates the sampling' locations along the tributary to Lake Norman, :Monitoring wells in the vicinity of Sul that were sampled as part of this re- assessment are also shoi,vn on Figure 1. Figure 2 illustra (-es the three background surface water k ations that were sampled VVater quality data collected during the re -assessment sa mpling„ indicate an increase ot historical hardness levels at all locations. Data provided through inonthly and later quarterly samples at S-1 collected under NPDES permit NC000,1987 (Outiall 101) from October 2016 to .A 2.018 and quarterly Sal samples collected under the 50C since 4tile 2018 indicated an average ha alnetsis of 03 mg/L As shown in Tables 1 a mil 2., 0,10 SOptettlber 25 2019 sarnple result (or hardness t 31,6 mg/t, represents a increase compared to the average hard nes.s .ana lvtica I results ot 203 mLand 1 12'e increase from the highest 5arnpic result .(,2.817 ing/L on 10/6/2016 and 8/712017).: found in the N P D ES arid .50C dataset. lt should be- noted that doting the. period or coverage of 5-I ili„)all 101L. discharges by the NPDES permit, a pH limit be.tween 6-0 S.L and 9.0 511 iivas requited, To maintain complince, the seep Sul flotic Wa5 actively treated using limestone. 'fihe use of limestone Lin tile. ormarrIt'd tributary: above 5-1 appare.ntly increased the ha concentrations fia.7 those :sample events, Therefore., the elleviatect hardness valuesduring the period of NED ES coverage were not considered when determining the SCK: I A Ls for 5-1, Any, increases and averages noted in this report were derived using the ha.rolness data collected during tine 'Nil:1ES coverage perio.d disolISSed above November TABLE 1 H1 TORIC AND RECENT HARDNESS RE U TS COMPARISON Sample ID Sampie ID TF.(.L, her 19 Hardness (m -Ass ssmen = NPOES and Sampling SOC Average, 201E October 10, ( tober 2016 Average 2019t: Maya 2019) 213 TA E 2 TRJCAL HARDNESS LEVELS AND AVERAGE / ) Collection 1aatti 142 might attect hardness at S-1 were noted. on "Tale 3 ngs ot 1t-AssesSnent and. Eva ►u tona t s medial ,M lr r by Consent.- Eh1C SOC WQ S1"°•U09 Ccrarias, LL `. Marshall St/ -am Station TABLE 2 HISTORICAL HARDNESS LEVELS AND AVERAGE Sample ID S"01 Sample Collection 09,' 11l2018 �i0 51 >t11S... 03 `27/201 9 05/07/2019 AVERAGE November 2019 Sy nTerr.3 Hardness (mg/L) 195 137 li �t d 1,'. * dell �:C1� 1 Ctt.� gat �t�< I"C1und 7�,.�a��Bi"�ia �. �'it -��w ds��tri�"� t"8r' t��£ith Cl ..t Table 1, the October r lei, +"SAC 19 s 1 rlple res;alt l in a hardness teaser where compared tc the average 2018 hardness analytical FiVe samples had been co August 2018. As shown l"1;ardnt=.55 1 ;1"_cl variations Lll sllrt'`ce water a pledr to lae seasor'lil hr<<u11tirss'irr*lher. rnmrr and ral@ months. to he ,in mks l.er,lte to severe Li Additional information one {tn pre-' be found t 7te,riiber afC Secnon 3,3 Groundwater Sampling and Data Evaluation Ground water samples were e collected t f don F � on October ;=1. ?e�l'�� r"��r� £"l o considered to he proximal to the, S 1 loctition, 'Tin following do°e%C assess water t U ality condition` i e ,_2 i8 1 i.1.1 err;a: �� � S�r�R, GWAY.��� �',�.•ii1',="L7,f'13R,/`F3Ri�, Gti'ti l.10S/ , A L 1y,•"D l R/BRI.,. GINA--`I 1ti,''' ;..==TAR GWA 15 /D. Thy r 1retdwat .r samples were analyzed for IMP parameters, including calGr'r r14i a€'1,'a gneslun, The monitoring ing well locations are shown on Figure 1. [ a sa r i`i k'b'' and i:o part_ n with th hr t lncal Jataset indicate stable groundwater gqualit ' con{ltltlrls L.£1 the S-1 w 1i. ewes in constituent concentrations that ndwtiter quality data are summarized Cember 2016 ks) Findings oi Re -Assessment and Evaluation of Rernedial... Actions Linder Special Order by Consent EN1C SO( WQ S17-009 Nov'ember 2019. Duke Energy Cardinas, LL.C_ NlarshaH. Steam :Station SynTerra 3.4 Ash Basin Conditions and Decanting To accommodate closure of the a,sh basin, decanting of free water from the basin via gravityflow commenced on July 16„ 2019 from a pond elevation of 787.94 fe.et. lechanical decanting commenced on September 13, 2019 from a pond elevation of 786,44 f eet„Or October 15, 2.019 tile dare of the initial. retassessment site visit, the pond level was 783,10 feet and decanting operations had removed 8,3,61 million gallons of water from the ,iish basin for discharge, Visual conditions of the ash basin during the re -assessment sampling reflected the decrease ill. pond elevation pond 'surface area appeared diminished and additional coal ash was exposed compared to pro; icras site observations. At nearby monitoring well (AleIS the water elevation decreased mere than 3 feet since gray ity-rlow decanti„ng began. 3.5 Local Pt.:cipitation Data Approximately. 2 years of regional and lanai precipira on data was reviewed as part of this re -assessment. According to date available from the U.S. Drought Monitor (httiLstaildritiii&qhtitionitof. on1cdti/Nleivs!ILlapAreilivC%a), a 'proiu t prod uced by the National Drought Mitigation Center, Natidnal ()ceanic and Atmospheric Administration and United States Department' et Agriculture, the. Marshall Steam Station area,, during the following time periOdS shown in Table 4, was characterized by the indicated drcrught conditions! TABLE 4 DROUGHT CONDITION SUMMARY Marshall Steam Station Area Time Period October 2016 November 2016 - Janualy2017ffirst 3 Februar - 4ir11 2017 Drought Condition Abnormaq Dry 1 Moderate Abnormally Dry oderate Mid-Novernber to December 2017 Abnorma January to February (First 2018 Moderate Fete Februa Second Week to March First Week 2018 Abnor September eeks 2 and 3) 2019 Abnormally Dry September (Week 4)Qoberwk 1 2019 Moderate October (Weeks 2 - 4) 2019 Severe October (Week 5) 2019 Moderate — repared by: cli_C Checked by: Findings :t t sesir est a.t�d l valuati. eraal Order by= tilt Energy t;,y CarC Data collected by a Duke Energy aLt1c)naated weather stab Steam Station indicated decreased pre historical, regional .rainfall records and ge published by the Drought Monitor, 3.6 ion Exchange Resin Evaluation and Deployment Preliminary evaluation of remedial options was performed as part of the sua e t r assessment effort. A raatiot exchange resin,, widely utilized in water -softening and demineralization treatment, v as selected for bench -testing to determine the in addressing tl1 t, Anthori :.a li`ts. Division November 2019 7nrneiata at Engineers to place cafe above the i"s_1 1ocanon. On October l 6 sample te�t�t r tp 24 liotirs,., on naf'nt effect rshali otr'ls when compared to average ed with the drought conditions dness levels i the 5r71. tvaters. Test results in fa«at. i a rticeiv*e41 frocrl the North Carolina Department IZts }urces and United States Army Corps c .s a tcl related materials in tlatr stt' sm ter . :7 , :..?l LNpstream location to increase 9, a tote. hardness field screen test was trttlized to evaluate treatment 5-1 location ',Two o separate hardness test Sr 't t'ed 160 and 200 rrt .'L at a rl. A sample was collected at y- -l. and analyzed per quarterly SOC pi meters, 1n additional sample '5.1 Above' (up t['' iraa t?t tl`le tr'atirient socks„, i l a'`7ed for hardness. Analytical results indicated hardness at r' valg L at 5-1 :and :110 rra ' „ at'S-.1 Above', .Rellabtlrt\ of the field hardness screening'inr rrraat' era was reconsidered alter rece t n tla-, October 18 sample d ata'se=t Atter conferring w `a f'' tbe.' cation e'\ 'hare socks in an ahgnrner initially° deployed. On October location parallel rnflotiwr and the parallel vw tt.h the streaam channel, as well, sampling (e,g„, flow and turbidity.. normal rded to a. epoy re an erp d'i.uartotowM°as r°7eaw° setc'ks w,vere deployed jut above the S 1 previat.tsl,v'-deployed socks vk°erep repositioned Once stream conditions were suitable for zed f approximately' 1 hour after sock r 3-r Findings of Re-Asses,iment and Evaluation of Reme.disl Actions Lir Special Order by Consent EIVICSCX:: WC! S17-009 Duke Energy Carolinas, Marshall 1;tiiami Station November 2019 SynTerra installaiicm„ samples ere collected at 5-1 and LInalyzed per quarterly SOC parameters and '5-1 Above' for hardness. Analytical results indicated hardness at 5-1 at 122 ritigli„ and 'S-1 Above' at 272 trig/1„: In addition to the SOC parameter sampling described above, 4 hourly 'hardness samples were collected at 5-1 on October 2 2019„: to assess the effectiveness of the ion exchange socks over time, Sample results are listed below: Time 12:10 Result- 1 Ll mg/L Time 13:10 Result 145 mg,1: Tirne14:10 Result:149 mg/L lime 15:10 Result: 155 thgol The resin socks remained in -place to allow for continued treatment ot seep waters. Upon determining the effectiveness0 the resln to reduce hardness to levels below the estabfishe,c1 SOC. interim action levels, ke Energy ordered aC.!ditiOnal s,_ipplies to maintain file tratitment rhaterials„ vdirle rm..:)re sTLstainable remedial opt iOnS are evaluated, designed anti implemented Findings of Re -Assessment and Evaluation of Remedial Actions Under Special Order by Consem t EMCSOC WQS17009 .November 2019 Duke Energy Carolinas, LI,C, Marshall Steam Satan SynTerca 4.0 PRELIMINARY CONCLUSIONS Recent and historical dataevaluated for the re -assessment of seep Sol, indicate. -the reported exceedance of hardness from Q3 SOC (9/25/1.9) s,ample at S-1 (316 mg/L) exceeds historical hardness concentrations at this location. Groundwater data collected on October 14, 2019 indicated generally stable conditions across all well locations and did not reveal any increases in constituents that might have affected the hardness levels. at Sol, (Table 3) Ash basin mechanical decanting operations; which began on September 13, 2019, decreased the ash, nasin free water elevation by 4.84 feet as of October 15, 2019 biyi the removal of over 83 million gallons of water. Decanting of the ash basin th as source of the elevated, hardness Concentrations) is part of the longsterm corrective action to reduce groundwater migration from the basin -toward 5-1„ Correlation between hardness ievelsa tSod (Ou tfa 1 01) and seasonal effects due to precipitation variation is evident, Eis h0 ;71 Table 2. Severe. droi.ight 1 to in reduce natural infiltration to ground wa(ter and are likely a contributory factor in the recent increase in hardness at S-1, Based on historical trends, hardness levels at SA would be expected to decrease during the late winter, early spring months when precipitation increases, [framed i.Eite actions were Pin 'pi/ Duke Energy to reduce hardness levels at Sol and to mitigate affects to receiving waters. Further remedial ',action development and implementation will be, require.d to develop a .more permanent remedy, The exceedance oi the [At_ for hardness in the S In a 1 I low -flow tributary„ has no known detrimental effect on the environment. There N n .11 Itman health or aquatic life concern with increased hardness. Water quality standards (WQ)I'll) tor hardness ha only been established in waters classified as Water Sipply where hardness is considered undesirable for economic or ,aestnetic reasons( Hardness levels recorded in Lake Norman as part of SO(, sampling requirements indicate hardness Levels well below- WQS. Hardness concentrations recorded at the SOC Lake Norman sample locations have been 20 7 ring/l.„ or ICS'S, Finding of Re-Ase;,r,iiiient and Ev-aluilhon of Rernedial Action,; Under Special Order h Ccamto.nt EMC SOC WQ 51'7,009 November 2019 Duke Energy Carol Mas L127 NiArha i St,earn Station SvilTerra 5.0 PROPOSED REMEDIAL OPTIONS Re -assessment actions conducted ,per the SOC requirements included evaluation of remedial options for treatment and or control of the S-1 seep to quickly mitigate possible affects to receiving waters. After receiving, the data from the September 25„, 2019 sampling event, Duke Energy immediately puraiuted mi itcn OptiOT1S to reduce hardness levels at the 5-1 seep location„ Duke Energy tat identified the option to utilize the cation eixchange resin socks and began procurement of the materials to conduct bench -scale and field -scale testing. As described in Section 3.6., use of treatment socks did prove acceptable to decrease hardne,,s levels; however only for short durations, Operation and maintenance requirements are very high due to frequent replacement needs and their 'use can increase TD5 levels in the treated area Thus, treatment using resin socks is riot considered a viable solution Evaluation of short-term and longsterm proposed remedial actions is mad CW-3 the alternatives being considered described below, All option:5 under consideration require further analy.sis of local hydroiogv and hydrogeology; planning and engineering, whlch will be completed in the upcoming, phase cif the response, before selection at the :most effective and implementable remedial option, Once approval of the:selected remed la tion system has been received, permitting, final designs and planning will begin, followed by implementation it trie remedial selection, 5.1 Short -Term Ash basin decanting„ a part of ash basin closli re, is currently .undervvay and will reduce the hydraulic head near the topographic divide, located to the west of 5-1,, that separates the basin from the stream., The reduction Li hydraulic head in the ash, basin 11 reduce the hydraulic driving force for potential constituents of interest (COI) migration in groundwater from the basin toward 5-1, supporting short-term remedial efforts, Currently„ development of long-term corrective action plans for the Marshall Steam Station are underway, The short-term remediation approaches below are expected t'r) address the hardness levels in excess of the SOC interim action levels until alternate remediatiun efforts are implemented. Findings of Re,Assess Special Order by Cons Duke Energy n o rn aal Ac ins Under SOC WQ S't J -w019 November 20'1 rshall Steam Station S n1 Capture 1 trk r"C cimannel flow or control ott m I tei iu sty r to the stream channel ira the c ictrtrty of S•1 were considered the two iuost reliahle and effective methods to rein di3te the ,hardness, Under both approaches, the collected water wouid he conveyed to the Marshall Stearn Station wastewater treatment system. 5.1.1 Normal Streamflow Impoundment pprr,ach cltilizs are zrr°rp Lrpstre3rn of tl rnecha treatment system. Dam s elevated pre- 5,1.2 Normal Th approach 1Tti ea titr arr3'C.i ,radierlt lot 1.d contain '?rOtl,s material wafer would he collected via ,a mechanical. F ti strap 3 trtion wastewater treatment system. Capture, Pump and Treat °UCture to capture dOrmal stream b ;ntnate (or r'$li1° ntl '' reduce) th waded water would be collected w is a rhh;all Steataa Station wastewater flow Capture, Pump and Treat Trench dace trench to capture normal stream base flow elevated preci i ,duce) discharge to r'.°ndic:tilar to the Captured the ti?; rsh3il 5..1.3 Stream Channel Dewatering, Pump and Treat - Extraction Wells �rli� cearlo p[ual approach utilizes a Imo of the stream valley adjacent: scent: to the the belo"rV". Extracted groundwater would be collected 'via sa rec.I'1anrcal mean„, 3 delivered to the Marshall Steam „Station wastewater treatment system 5.1.4 Stream Channel Dewatering, Pump and Treat Extraction Wells with Clean Water Injection As of the date of this report, the basin closure plan and groundwater corrective acti-m plain have not 'been 5 Emitted tc NCD Q. 'T 3eret'ore, groundwater Findings of Re -Assessment and Evaluation of Remedial Actions Under Special Order by Consent EMC SOC WQ 517-009 Dule Energy Caro • 35, [IC, Marshall Steam Station No,,ember 2019 SynTerra remediation alternatives have not been finalized. However, a robust groun.dwater remedial design is being prepared as part of the Corrective Action Han Update to con.trol migration c.).1 dissolved phase constituents or interest beyond theash basin compliance boundary at concentrations above the respective 02L standards The eastern portion of the Marshall Steam Station site,. between the Phase I Dry Ash Landfill and the unnamed tributary, is included in the remedial design. The groundw.ater remedy in this: portion of the site is comprised of a network of vertical groundwater extraction wells and clean water inf ilt rationlrechat g v1ka.s.sociateci pumps, piping an.d ctintrol systems It is: recommended Haat srouncitvati,r tome+, installed to address,- I Al e \ceedance in the tributary be compatible with the Remedial Alternative design in the CAP Update fin progress) Accelerated implementation of portions. of the site -wide groundwater remeilial design along the ea:stern side of ash basin, ,hetween the. unnamed tributaryird the Dry Ash Landfill (Phase I) could also help address the discharge of groundi,vater to the tributary with elevated concentratioris ot hardnes,s. Based on the groundwater remedial 1t niate being proposed in the CAP Update, it is estimated that 10 ex tr-action wells and 10 dean water innitrationfrecharge wells wotrld be installed. Installation of all active groundwater extraction and infiltration system should result in short-term affects to strirface water quality in the tributary. Before implementation of a groundwater remedy, additional field investigations , aquifer pumping tests and groundwater/surface water interactions from both banks of the Stream) S.hOuld be Rerformed to MtOrrit the design: 5,2 Long -Term 5.2,1 Ash Basin Decanting and Dewatering Ash basin decanting a part of ash an (leisure, is is:Lit-tenth( !andel-wily and will reduce the hydraulic:head near the topographic divide, located to the west of that separates the basin from the stream: The reduction in hydraulic head in the ash basin redirZe the hydraulic dritci„rig force for potential Cc„:).1 migration in g 1'01,111d Water from the basin toward S--1. 5.2.2 Ash Basin Closure and Groundwater Corrective Action As presented in Section 5.1 sil„ above„ as of the date of this report,. the basin closure plan and groundwater corrective action p1an. have. not been submitted to ment and E't,ii 1iit.lc: sent EMC 5Oc WQ 5I 7- Co rrect nts he hove the respective a unnamedtributary, is remedy in this portion o groundwater extraa::tion associated pumps, p p It is recommended that any ground e. ceedance in the tributary be r th CAP Update (aril progress), s.s;t. A cot, clesi the tribur a.tic would have a long -fern cor!sti.tr,It to ate to co �I the ash bast t beefa prepared as of dissolved rt compliance boundary at 021, standards. The eastern portion ot the e Phase I Dry Ash Landfill and the design. `he a rc und%vater network of vertical at eata `rr r�har a r eits. n.tenta.ti n u portions .yt ae 'w sty to sash, basin, d fill (Phase installed to address IAL Remedial Alternative Based.of) Hndings of Re-Assessinent and EvaIllation Rernedial Actions hider Special Order by Consent. EC SOC WQ 7OuQ N Velll bet 20i Du lQ Energy Carofirtas, LLC, Marshall Steam Station SynTeria 6.0 REMEDIAL EFFECTIVENESS MONITORING AND REPORTING Following remedy selection and system startup„ monthly system ettctiveness updates will he provided to NCDEQ. Monitoring for e f fee ti v en es s would begin after system startup and. would potentially include the volume of water collected and conveyed tor treatment, groundwater elevation monitoring data and stream water finality data If system performance is not actequate„ optimization of existing corn pone n t S and utilization of additional methods woulid be considered., Modifications or additions to treatment i,vould. be implernitmted and reported in a timely manner. 1 ldIng,3 *IN IVO. SA, WO,. W.I.... .04.44 mkoaK, 40. .065, 4,n4a. weveo".... at,irrx Sa`tts ids c s-e R SaN4 SOCKS ASF4 BASIN WELL Li " MVP E S EEP "ASH ^^'y.' 'A22 L19 {PLIANd E 9(24222122222H L4 aLy COMPUANCE V 4Nr SIPIE42224 SVE M KHA 22PE222) t DUKE ENERGY CAROLINAS 22204 c c.,AT , x,. t . ;r OATS:,2 t.&0.2O. rp.c,o m FIGURE 1 S-1 RE -ASSESSMENT AREA OF INVESTIGATION MARSHALL STEAM STATION TERRELL, NORTH CAROLINA Technical Memorandum Antchar QF,,A of J nth rciEna, Pi.,t,C; 231 Haywood Street 8,38 281 3330 To: Richard E Baker, Jr„ Duke Energy From: Michael Gefell, PG, Anchor QEA, LLC cc. Scott Davies and Matt Hanchey, Duke Energy ANC- OR OE December 17, 2019 Re: Marshall Steam Station S-1 Hardness and Hydrologic Evaluation At the request of Duke Energy, Anchor QEA, LLC, reviewed information pertaining to hydrology and water hardness concentrations at Seep ID Number S -1 (S-1) at the Marshall Steam Station (MSS) in Terrell, North Carolina and evaluated the potential influence of hydrologic conditions on measured hardness at S-1, The S-1 sampling location is along a small intermittent stream that has measured flow rates up to approximately 15 gallons per minute This memorandum summarizes the results of Anchor QEA`s evaluation, specifically focused on three questions that Duke Energy posed in an email dated November 22, 2019 (Baker 2019). Did MSS Enter a Drought? Anchor QEA downloaded drought severity data from the National Drought 'Mitigation Center's tJ.S. Drought Monitor for the period coinciding with available 5-1 hardness data. the Drought Monitor synthesizes data including precipitation, soil moisture, streamflow, and other drought indices and classifies drought conditions in weekly intervals (NDMC et as 2019), The Drought Monitor's drought severity index includes the following classiflca'tions,, with increasing drought intensity: No Drought Conditions; Abnormally Dry; Moderate Drought, Severe Drought; Extreme Drought and Exceptional Drought. During the periods shown in bright red and dark red in Figure 1, the Drought Monitor classified the conditions in the MSS area as moderate and severe drought, respectively. '-cwje _t N L Tch etcat Memo+a.rd,, 20 123_t2„:, ,2:a,-x December 17, 2019 Paget The yellow periods were also abnormally dry but not classified as drought, Did the Drought Cause or Contribute to the Increase in Hardness at S-1? Figure 1 compares 5-1 hardness values to drought severity index. S-1 hardness data show seasonal fluctuations with relative peaks in late summer to autumn, and relative lows in the late winter to spring. During the period from October 2016 to April 2018, the S-1 seep was treated with limestone to adjust pH, which may have increased 5-1 sample hardness values during the same period. Four seasonal hardness data peaks have exceeded the S-1 hardness interim Action Level of 200 milligrams per liter (mg/L): 1) in 2014 during a period with no drought; 2) in 2016 during abnormally dry conditions; 3) in 2017 with no drought and 4) in 2019 during moderate drought. The abnormally dry period in 2016 and drought conditions in late 2019 may have contributed to the S-1 hardness peaks in October 2016 and September 2019 However, the 2014 and 2017 data indicate that increases in hardness at S-1 can also occur without drought conditions, as classified by the drought severity index, The drought severity index accounts for a large amount of data that may be important for agronomic purposes but may not be hydrologically relevant to surface water quality in the 5-1 stream. Anchor QEA also evaluated historical daily precipitation data recorded at the MSS weather statiion. Precipitation data for a range of periods were graphically compared to S-1 hardness trends, A general inverse relationship was identified using a 6-week moving total precipitation, where each precipitation data point indicates the total precipitation of the preceding 6-week period. All four hardness peaks above the Interim Action Level occurred during or near times preceded by 6 weeks ofrelatively low precipitation, The 6-week period is somewhat arbitrary, but suggests that sustained periods of low precipitation likely cause elevated S-1 hardness, as expected based on fundamental hydrologic principles. Hardne- 9a"ite� A Action le ti 4 December 17, 20'1'9 During dry periods, stream hardness is dominated by minerals dissolved in discharging groundwater. However, stream hardness can decrease significantly due to direct runoff from precipitation, which has low hardness, Direct runoff includes overland flow and subsurface stormflow, and has relatively low mineral content compared to groundwater (Freeze and Cherry 1979). The S-1 stream setting should promote significant subsurface stormflow because of the following characteristics: 1) steep, convex surrounding slopes; 2) a narrow valley bottom; 3) permeable soil; and 4) forested slopes with leaf fitter (Freeze and Cherry 197'9), We interpret that direct runoff from precipitation would significantly decrease S-1 stream hardness levels during extended rainy periods_ However, the converse would also apply; in extended periods with little or no precipitation, subsurface stormflow would abate and stream concentrations would increase to those that are dominated by discharging groundwater concentrations. This relationship would produce an inverse relationship between precipitation and 5-1 hardness, as generally observed in Figure 2, The inverse relationship between S-1 hardness and 6--week running total precipitation also suggests the influence of another mechanism with longer duration than direct runoff from individual storms. Changes in relative groundwater recharge and discharge from either side of the strear r could' also influence hardness at 5-1, Based on October 2019 groundwater analytical results, the average groundwater hardness measurement southwest of the stream (approximately 270 mg/L at well clusters AL-01 and MW-14) was higher than that measured northeast of the stream (approximately 150 mg/L at well cluster GWA-10). Using only the shallow monitoring well data,, the hardness contrast is more significant: approximately 340 mg/L southwest of the stream versus 40 mg/L to the northeast, Therefore, during periods of relatively high groundwater elevation on the southwest side of the stream and relatively low groundwater elevation on the northeast side, as may occur in the late summer or fall, the total groundwater contribution of hardness to S-1 would increase. A detailed groundwater flow and transport evaluation could help clarify the relationship between relative groundwater flow contributions from both sides of the stream to 5-1 hardness. Has MSS Recovered from the Drought? US Drought Monitor data indicate the following recent drou +� October 15-22: severe drought • October 29-November 12: moderate drought • November 19. abnormally dry • November 26: none * December 3. none • December 10: none cond ons at MSS (dates in 2f319): Based on these data, MSS had recovered from the late 2019 drought as of November 19 or 26, 2019. As shown in Figure 2, when the 6-week running total precipitation increased in late 2019, the S-1 hardness concentration dropped to below the interim Action Level. December 17, 2019 Page 4 References Baker, Richard E.,, Jr. (Duke Energy), 2019. Email regarding: Marshall S-1 _,. Request for Technical Evaluation, November 22, 2019. Freeze, R, A., and J A. Cherry, 19'79, Gr©undwoter. Englewood Cliffs, New Jersey: Prentice -Hall. NDMC(National Drought Mitigation Center at the University of Nebraska -Lincoln), USDA (U,S. Department of Agriculture), and NOAA (Nation& Oceanic and Atmospheric Administratio 2019, United States Drought Monitor open access data; historical data collected by state: North Carolina, Accessed November 26, 2019, Available at DUKE ENERGY, Certtfled Mall: 701 0910 0001 0 Augu`ti 4'202 '\1s. Linda Culpepper, Director North Carolina Department of E;n•xitcann Division of, Water Resources 512 N. Salisbury Street Raleigh, NC 27f 04 Duke Energy \ICGOare \Ut:kaur SLIE i0c1 2700 Hager,. r5 terry Ft.a,asi Hummo. le. N(,' 3s078 Subject: Duke. Energy Carc lincas 1_aLC /McGuire Nuc,.lear Sttrtion Renewal ApplNPDES Permit No, NC 0024392 Part 1 Condition (A)(22) A Clean Water Act Section 316(b) Reports Mecklenburg Count Dear ls. Culpepper: Duke Energy Ca- olinas E I_C' (Dtake E:net° prepared this sunan1ary of the reports requited, 'NPDES Pcrnut tNo NO. 192 The reports enable the Director to make a. Best °Tcchnolo` et pe evatluat iderin`, the ,site -specie cement coin liaince preference is als( the. A entrainment decisi n oi. the yINS et Nuclear Sta.atitan (1NS) has. ted per the 31 ta(h) Rule and ,idc detailed information which should Available (E3TA) entrainment factors and other information, Although presented in these repons„ final selection n. 'I"he enclosed reports provide ow eater intake structure with consideration of the facility9 source water -body, and potentially feasible compliance measures, Duke Energy respectfully requests that the Director concur with our proposed irnpingerraent a entrainment compliance t'neasures t.o ff.!� Folio64I review. closed 3. Extstira Facilit.y316(h) Rule Si.nni isla 1:3TA at the MNS. The C�`SEaE A. published the Clean Water Act 3 lfi(hp Rule for ex cti�;e daatc�. of October 11, 2014. Although there are exception requires that a NPDES permittee w th a cooltn# water intake structure (C capacity of ` MCgD or greater to submit the followin reports based on the (actual) flow; <1�5 MGD-40CFR § li >125 M.GD — 40 CFR § 122.2 NeW unit at an existing, reports reports 40CFR 122 2►(r)(2) (S) Band (14 DEQ DWR®s h ,an he Rule design `WlS average rreports Pag c Q 017 Main Intake Low Level Intake (LLI) Nuclear safety related ("RN system") service water. (Note 1) Invert Elevation (ft msl) 715 Depth (from full pond elevation) (feet) Depth of Water Withdrawal (ft msl) Structure linear length (feet) 247 Number of intake Bays 8 (4 per unit) 16 traveling water screens (8 per unit) 3/8 1.2 8 (4 per unit) 254,000 2,969 2,631 644 116 654-670 118 3 9 fixed panel screens 3/4 0.06 4 (note 2 & 3) 17,500 43.2 27.0 Based on the NPDES Permit Director review of these reports, a site -specific entrainment decision is made to establish BTA and then the permittee selects the appropriate complementary impingement compliance alternative(s). The MNS CWIS ("Main Intake") has a design capacity greater than 2 MGD and an average intake flow of greater than 125 MGD. Therefore the 40 CFR § 122.21(r)(2)-(13) reports are enclosed with this submittal. MNS Coolin;Water Intake Structure Summary The MNS consists of two identical pressurized water nuclear reactors, each with a net electrical generation of approximately 1,158 MW. Unit I began commercial operation during 1981 with Unit 2 following in 1984. The MNS carbon free generation is critical for meeting Duke Energy customer needs. MNS has two separate CWIS to provide cooling water for various plant purposes, including the steam turbine condensers and nuclear safety -related systems. The Main Intake is a shoreline structure located in a small cove near Cowans Ford Dam on Lake Norman. The Main Intake bay center is approximately 30 feet below the Iake pool elevation. The Low Level Intake (LLI) is located near the base of Cowans Ford Dam and withdraws water from Lake Norman with the center of the structure approximately 100 feet below the pool elevation. Sections 2, 3, and 5 of the enclosed reports provide a comprehensive description of the MNS CWIS. The following table provides a summary of the major characteristics for each CWIS: Purpose Once -through cooling water and other plant requirements Number of Screens and Type Screen Mesh (inches) Through -screen velocity (fps) Number of Pumps Pump Rating (gpm) Total Design Flow (MGD) Average Flow (MGD) Note I: LLI is also the routine makeup water source to the safety -related Standby Nuclear Service Water Pond. 45 715-745 Page 2of7 } Note 2: There are four RN pumps with 17.500 gpm capacity each: however only two are typically operated with two for redundancy. Note 3: There are also 3 pumps with 150.000 glim capacity each with one or two pumps operating intermittently for once to five weeks per year as dictated by plant operations for MNS thermal discharge limitation compliance. The area of influence (AOI) for impingement is defined as the area encompassed by the 0.5 fps velocity contour at the intake structure. For the Main Intake, using the theoretical design flow of 2,969 MGD and the Lake Norman authorized maximum (non -emergency) drawdown water elevation of 751 ft msl (which is nine feet below normal pool elevation of 760 ft msl), the estimated AOI extends 80 feet from the CWIS and encompasses an area of 0.68 acres. Section 2.3 of the report provides information used to conservatively estimate the AOI. CWIS Source Water Summary The MNS source waterbody, Lake Norman, was expressly created to provide cooling water for electrical generation facilities including MNS and to power generators at the Cowans Ford Hydroelectric Station. As part of the Catawba-Wateree Hydroelectric Project (FERC No. 2232), Lake Norman is subject to licensing by the Federal Energy Regulatory Commission (FERC). Lake Norman is an impoundment on the mainstem Catawba River and is bracketed upstream by Lookout Shoals Lake and downstream by Mountain Island Lake. Lake Norman is characterized as an "inland sea" with 538 miles of shoreline, a surface area of more than 32,475 acres, and an impounded volume of nearly 1,100,000 acre-feet. Lake Norman supports a balanced fishery, provides recreational opportunities, and is aesthetically desirable. Water quality, including fishery information, is well documented at Lake Norman. Routine source waterbody assessments have occurred prior to and after MNS operations and currently continue. The Lake Norman fishery studies have included electrofishing, purseseine sampling, hydroacoustic surveys, and creel surveys. None of these studies have attributed any adverse impact to operation of MNS including the cooling water intake structure. The North Carolina Wildlife Resources Commission (NCWRC) manages Lake Norman through periodic fish stocking programs and assessments. The Lake Norman fish population is diverse and many species were artificially introduced by the NCWRC and/or the public. An established forage fishery exists to support important recreational sportfishing species such as catfish black bass, and temperate bass. Much of the forage base consists of shad and alewife, which are considered by the Rule to be a fragile species. As presented in Sections 2, 4, 7, 9, and 11 of the enclosed reports, there are no threatened or endangered species that could be impacted by the MNS CWIS. Two years of impingement and entrainment field data was collected at the Main Intake with discrete 24-hour samples occurring at one week intervals for impingement and two week intervals for entrainment. The following tables provides a summary of these two sampling efforts: Page 3 of 7 MNS Main Intake Impingement 2016 Flows — Estimated Annual impingement 2017 Flows — 2016-2017 Average Estimated Annual Estimated Annual Impingement Impingement (Note 1) Threadfin Shad 890 886 888 Alewife 336 313 324 Gizzard Shad 56 53 54 Bluegill 143 138 140 White Bass 77 75 76 Striped Bass 77 72 74 Channel Catfish 63 60 62 Unidentified Fish 54 54 54 Others 479 462 470 Total Fragile 1,295 1,263 1,279 Total Non -Fragile 880 850 865 Note 1 — Average annual impingement represents simple arithmetic average between 2016 and 2017. MNS Main Intake Entrainment 2016 Flows —Estimated 2017 Flows — 2016-2017 Average Annual Entrainment Estimated Annual Estimated Annual Entrainment Entrainment (Note 1) Shad and Herring Family 114,497,612 299,678,462 207,088,037 Shad Species 69,574,216 3,985,796 36,780,006 Sunfish Species 10,141,792 2,363,843 6,252,818 White Perch 7,836,624 61,829,106 34,832,865 Unidentified Fish 6,620,757 948,137 3,784,447 Alewife 4,445,066 3,169,191 3,807,128 Gizzard Shad 3,826,455 683,839 2,255,147 Threadfin Shad 1,998,006 999,003 Others (Note 2) 5,453,780 2,063,051 3,758,416 Total Fragile 194,341,355 307,517,288 250,929,322 Total Non -Fragile 30,052,953 67,204,137 48,628,545 Note 1 — Average annual entrainment represents simple arithmetic average. between 2016 and 2017. Note 2 — The anomalous collection of Inland Silverside in 2016.is not included in the 2016 data presented. Fragile species comprised approximately 60% of the estimated impingement and 84% of the estimated entrainment at the MNS Main Intake. Section 11 of the enclosed report presents an evaluation of the entrainment impacts using models such as Equivalent Adults (EA) and Production Foregone (PF) which account for the natural survival of each organism, trophic transfer, and its potential to become an adult that could be of benefit to the Lake Norman aquatic system or provide a recreational opportunity. Based on the EA and PF modeling, the monetary value of the MNS entrainment on an annual basis ranges from $818 to $24,168. Page 4 of 7 1ipinementand Entrainment. Compliance The 316(b) Rule requires the hypothetical evaluation of a closed -cooling and fine mesh screen retrofit. The closed cycle cooling retrofit was evaluated using mechanical draft cooling towers (MCDT), The fine t-inesh screen retrofit was evaluated using 2.0 mm .fine mesh. "fish friendly- traveling screens (FMS). Section 10 of the enclosed report provides the engineering evaluation, including costs, for the MCDT and FMS scenarios, It should he noted that a closed cycle cooling retrofit at an existing facility presents many challenges which.may not he fully defined, in the presented evaluation. Although tine mesh screens are less chaliengin,g to retrofit, there could be unforeseen issues that are not incorporated in the presented evaluation. Sections 11 and 12 of the report presents the benefits, and costs of each technology, including. the .currently configured CWIS, Conversion to closed cycle cooling at McGuire WOU Id result in the loss of v iter fishing opportunities and commensurate local economic impacts at Lake Norman. The following table (Table 11-17 in the report) and figure (Figure I-11 in the report) summarizes the net benefits of each evaluated technology: impingem r Impingement and Entrainment ...............................................................„„„„„„„„ .......... De Minimis $457 2,0-mm FMS $51 2M Closed -Cycle $IAM Retrofit Note: "Nl- $0 $0 $0 -$457 $457 $0 5M $0 5M -$50 7M $, 97 $0 3M $0 3M -$147B Page 5 47 Total Social Costs and Benefits(S) s 5.00t,i impingement Compliance Option ce 9rn r §125.9.4w,'11Y Net Benefits (5) ro fits ttainus Costs) Bore t IEntlreinntera Compliance Alternatives The -Total Sociaa `aa:s( in the aabo e table a., between the costs and benefits is negative for each potential scenari existing McGuire CVVIS configuration ("De Mrnimir") has a markedly srnaafler in pate than the other two tec.hnoli r=ies. The 3I6(b) Rule at 40 CFR 125.98(0(=) states that the Director can determine that no additional controls are necessary beyond the currently installed technologies and implemented measures where costs are substantially disproportionate and do not justify the social benefits or result in unacceptable adverse impacts that cannot be mitigated, This is exactly the case for the MNS C\'IS, and therefore Duke Energy respectfully requests the Department concur with our analysis that no additional controls ;arc:, reaestablish BTA With consideration of the follow S5'1 �2wY 50.54 2.0-mm Fine -Mast, Screens St.47B Mecha.r:caii Draft + ili er fake Norn at is a rraanaged waterbody MNS has no impact on arny threatened or endangered species 6 of7 Impingement rates are very lo (many days would likely have no reasonably anticipated impingement) • Entrainment is mostly associated with prolific, reproducing forage fish considered by the EPA to be fragile species • The costs to install any technology are wholly disproportionate to any benefit • Numerous prior studies have confirmed that the MNS CWIS has no impact on the Lake Norman aquatic community The estimated S1,850,000,000 compliance cost for a MDCT retrofit results in an approximate 75„000:1 cost to benefit ratio, MDCT and EMS are unjustified based on il above factors and therefore the existing CWIS should be considered as BTA per the 316(b) Rule, Duke Energy will be contacting NC DEQ DWR staff in the near future to request a meeting to provide an overview of these documents, Should you have any questions concerning this 3 1.6(b) submittal in the interim, please contact Mr, John Ballard, .MNS Site Environmental :Field Support, by phone at 704-875-5227, or via e-mail at John,Ballard@duke-energy,com, Specific 3 16(b) technical aspects can be addressed by Mr. Michael Smallwood at 704-875-5227 or via email at \I1 1.$01.allwood 1uk griel:0:',ec. 411, 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 cornplete 1 am aware that there ore significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Sincerely, Thomas .D, Ray Site Vice President Duke Energy Carolinas LLC kle,Guire Nuclear Station Enclosures cc: M. Julie Grzyb, NPDES Complex Permitting Unit Mr, Corey Basinger, Mooresville Regional Office Mr, John Ballard, Duke Energy MNS Site Environmental Field Support Mr, Don Safrit, Duke Energy Carolinas Permitting & Compliance Page 7 cwf 7 'AL, OFFICE 1100 October 15, 2019 Mr. Jeff Poupart North Carona Department of Environmental Quality Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Marshall Stearn Station NPDES Permit NC0004987 Request for minor NPDES permit rrwadification Closing of ©utfall 004 Dear Mr. Poupart: The Flue Gas Desulfurization (FGU) at the subject facility system ceased discharging into the FGD constructed wetland treatment system (CWTS NPDES internal outfall 004) in April 2019E In March 2019 the new FGD wastewater treatment system (WWTS - internal outfall 006) went into operation replacing the CWTS. Some flows continued to discharge and were monitored from outfall 004 as activities in preparation for final closure occurred from April into September. These activities included removal of gypsum from the initial equalization settling basins and the removal of mushroom compost from the vertical flow wetland cells. Qutfall 004 was permanently grouted shut on October 11, 2019, A minor NPDES permit modification is therefore requested to rernove outfall 004 from NPDES permit NC0004987. Enclosed is a check for $260 in order to process the minor modification request. The rainfall runoff from the area of the retired CWTS drains into the ash basin and discharges out NPDES outfall 002. The CWTS was originally built in a pennisula area within the ash basin and was an integral part of the WWTS, The final cells are within the ash basin compliance boundary, Thus Duke Energy considers the footprint of the CWTS to be part of the ash basin and final closure of the CWTS is planned to be implemented as determined by the final approved ash basin closure plans. In the interim the final cells of the CWTS have been breached to allow for storm water to be managed within the ash basin and discharge via NPDES outfali 002, If you have questions please contact Robert Wylie at (704) 382-4669, Sin Rick Roper, General Manager Ill Marshall Steam Station cc: Wes Bell w DEQ Mooresville Office Enclosure: Check for Minor Modification Fee E OnOv OUS E ti Of4VICE c L d00 tatOli 1U:k EFT CC COUICC5 pA,KARLE - Scl-P•ill COMO._ CPC TE.„ 900002 R3 K1 ,SD A NORTH CAROL iN,4 OFPAR'InENOIV T ENVIRONMENTAL Du,4 [BY CF WATER RESOURCES 1611 MAIL SERV cr RALEIGH NC -1 /599 Involice. role Invoice 19/0Y/2919 t4( 09049 ai LEETA,CH BEEORE DEPOSITING CHECK SHADED AREA MUST GI-4AtnEM ukigE EeERGY tAttsltl..st; SEttvECES C .44,cso. TOcCalt STREET ACCOUNTS PAY E CHAR", CUTE; WC 2 aEL.. DUKE ENERGY, Remittance Advice Pay Exacliy Two Hundred Sixty and 00/100 -US Dollars — `'T EHE ORDER OFE NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY ,.EP MORGACH,ASE3ANK, N.A. YRACUSE, NY 1320.6 Date: 10/08/2019 Check #: 1„000178947 Payment Amount: 2.60 00 Vendor # 0900071949 RECOVED A.:A:NR/OVIOR '1. WOROS MOORES ViLLE Firi8lONAL OFFICE Voucher ID v oic Gror4. Amt Discount Amount ; Irrtvoce Net Amp 0.00 DUKE E ERGY, AT BO sc,213 Date: 10/08/2019 Check #: 1000178947 Amount rm-260 00 D AFTER RAYS rpiusShip - United States Page 1 of 1 UPS CampusShip: ViewlPrint Label 1. Ensure there are no other shipping or tracking labels attached to your package. Select the Print button on the print dialog thatbox appears. Note: if your browser does not support this function select Print from the File menu to print the label. 2. Fold the printed label at the solid fine below. Place the label in a UPS Shipping Pouch. If you do not have a pouch. affix the folded label using clear plastic shipping tape over the entire label. 3. GETTING YOUR SHIPMENT TO UPS Customers with a Daily Pickup Your driver will pickup your shlpment(s) as usual. Customers withouta Daily Pickup Take your package to any location of The UPS Store, UPS Access Point(TM) location, UPS Drop Box, UPS Customer Center, Staples® or Authorized Shipping Outlet near you. Items sent via UPS Return Services(SM) (including via Ground) are also accepted at Drop Boxes. To find the location nearest you, please visit the Resources area of CampusShip and select UPS Locations. Schedule a same day or future day Pickup to have a UPS driver pickup all your CampusShip packages. Hand the package to any UPS driver in your area. UPS Access Paint*. MICHAELS STORE M 3710 590 RIVER H WY MOORESVILLE ,NC 28117 FOLD HERE UPS Access Poi 1 THE UPS STORE 51643 RIVER HWY MOORESVILLE ,NC 25117 1-4 fs1 O1-1 0 1 4.4 UPS Access Point*. THE UPS STORE 19701 BETHEL CHURCH RO CORNELIUS ,NC 28031 0' rn 0 c�v rn 0 0 00 o VD0 BILLING: P/P Eir(_] 827 1 D'6 . V vr Er- e11 >v � 0c a ac https://www.campusship.ups.com/cship/create?ActionOriginPair=default PrintWindo... 10/15/2019 UPS ACCMS uPS ORE 7oroNER25,11 tit."tr UPS Chop pox, UPS UPS Acc:e$s THE UPS STCRC UPS Ca psShip: View/Print Label Ens ure there are r,o other shipping or tr,.trkitarp labels attached tra ytrur paa kage,. Seiect the Print be itor, oft the print t±id'=cg box ttla aippears, Note: It your browse( duels. riot support this' tuncis=on ae•iei:.t Print from the Fite menu t print the Labe€. Surd. the pr it i b bel at the solid limn below, Place lhc iabel en to UP; Shipping Pooch if you do nol have a roucch a33ix tt t feel Eatst:d e.rsuh cierar plritilrc shipping tape: over the erttrr 3 GETTWNCG YOUR SHPME14T TO UPS Customers with a gaily Pickup Your driver wwiii pickup your shipmrrit(s) as Li5uat Customers without a Daily Pickup Take your package: to any loci rbon of The UPS Stare"-, UPta A . es,s Pain in Cl ist(. m +r Center.. Stapios..i or Authorize:1 ;hipping 0 lief near you, items sent xia tit="r,S i u tc,rr Ser i ,r L1M;, (including via Ground) are : s»accepted at Drop Boxes ,'To find the location nearest you pie - area of CanpusShrp and seer( UPS Locations Schedule a same Gay or future day Pickup ckup to have a UPS S driver pickup ail your C om,pe,:;Shrp packages Hind the package to any UPS Orrver in your area jps Access Poor. *JrEs;•�ritrr Sri"`€ORE „riu eireix FOLD HERE. 0.4 DUKE ENE July 3, 2019 NC Department of Environrnental Quality Division of Water Resources - WO Perrn tting Sr ction NPDES Attn: Sergei Chernikov, Pht . 1617 Mail Service Center F Leigh, NC 27699.1617 Subject: EPA Form 2C mm Duffel l 005 NPDES Permit Number NC9994957 Duke Energy Carolinas,, LLC - Marshall Steam Station Catawba County With reference to Part A. (9) of NPDES permit NC( 90t4997, attacl r d is the completed EPA Form 2C tor Qutfalt 005, Should you have any guesti ns regarding this submit contact Robert Wylie at 704 382-4669, 0 'eguire additional inorrnaton, please l certify, under penalty of Paw, that this document and all attachments were prepared under my direction or supervision in accordance with a system design to assure that qualified personnel properly gather and evaluate the irtforr,atfon submitted. Based Ova my ingctiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the inform_ tion .submitted is, t the best of my knowledge and belief, tn.e. accurate, and complete. 1 am aware there are significant penalties for submitting false i`rtformation, inclerding the possibility of fines and imprisonment for knowing violations, Rick Roper General Manager lli, a °shalt Steam Station Fossil/Hydro Qperatio ; Carolinas Coal Generation Attachment: EPA Form 2C - Outfall 005 cc: Wes Bell - NCDEQ Mooresville be: Scott La Sala (Marshall) Robert Wylie (P&C) UPS Tracking; Sergei Cheri kov Raleagl) — 1Z8955;XXO397932779 Wes Bell (MRO) -a 1Z8955X4O395553389 TEATS LCd ATI EXISTING MA Fans AL) OMR No m �.'FI SvaVx U S ENVIRONMENTAL PROT'E.C1"pprq AGENCY .%Y APPLICATION ETION FOR PERMIT TO DISCHARGE WA '"EWATER ACTTURING, COMMERCIAL, aIININDG AND SILVICULTURE OP CorL4d/idated Rem Prpgfee T@"I'uD ICT4 TIUDE MN( des to Y r#T is is as xCIE `IM t s, rn a3 Ir ITS x IC. ( Is' FLY4� an kI't 6:e Yt .¢ fib. s ATIONS p,EcEtS++Ipi<3 4V+'kTER (sxr`aJa, WaSTILINISTINI 4.d3-=, -Liter Continue on 2 OP RAOStem b GONTRIELITING FLOW <, b AVERAGE 4 TREATMENT 'CONT+NIAI ON REVERSE chhx`f f.T)G3 tTr,i,a F A Does tot A,rr y"A'iOu fet trnent pm ft,Aor, by EPA under Section : St4 of fl Ce 3a Act apOy to your frta;,t>.ty t ) (12ENIASASAT2ON OF CONDINOrE 2 A F"ECrE'D OLPFALLS AGREEMENT, FTC OPTIONAL,' E^ May arasr tbschlopes tow Save anderws - or a Q FAARK 'y, * :aESC EPA Form 361ta 2 t`y410,+ PAGE A t F AI 2)at 1tJ�VI t.C;NTF{;NE, E=RO 4 8.9, EE DESCR4PTION 0,F PNOJEC- a F�:•>a,� erbdfs,azrpaia) 4 EtE'A. COMPLIANCE °ATE aOty sift.ct tau E ra aisiRL%t 1 c r,+'T bolE ON pAci AK E ANL1E 'LUEta°T ap PAC" aa Ra A. Sept t,T�;; �At a Tr�reaaaa ., A at NT: T yr E a r�� t�ta s:t't e r� c tot t ratty r T abve 2rw:< fr d #t 4rsaRm cwe: t, a ti aar t t ssc t ei Ti p ANT TWA R t ANALYSIS EPA "'omt 5-10-2t:,,, vt PAGE 3 of 4 PCTLP„LP'aANT a SOURCE CONTINUE ON REVERSE' (% N'E`(NUO FROM 'I'P1F; F FTONT giOLa' G ",At "Ss3XCGTv' TE VOW DATA ,son tsab'tievetintgin. A NAME At.'TITLE (Ape (4,444E PLEASE PRINT OR TYl-f= IN THE UNSHADED AREAS* ONLY, You may rc ,prrn some, or* € [ this information on separate sheOs (u=e the same, forov,/P rtstead of r,orrOetirau thew pages, SFE PNSTRUCTI .JNS NT AK ,AND EFFLUENT CHARACTEgLSTICS fr„ tina rf 3 r pac w:^; of Fr,tnaa 2 €;.) ART A You must provide the r suPt of M West one ana SLLL&TAN D CAS NO dPt[VMWC DAIL- VA L UE A N`t DAY VALUE s O.ONG TERM AVID, VAl,.l E EPA ILA, NUk9F3FR (copy trorn Item 1 of Pao t arch ouffuH, S6,art i WAiPst,4 ` a ra waa r lar¢gt;`* 4. Vtara ° X" it rc tgTttt ?b tnr kWh POP Yurart fi tle"' at; catg�#ir trtt t prasf� th a r %ffs rt f t 4t> xt r a fi rr c3 4P? tiu t r ssh . kh OI,I! 4t c.hOrg t i t tP 11e onc, tat 7 O 1,,PO,LJ ND L',AS -7440-41 BYE 7,133. x.4.5„6) AiA1Lkt At . VALE. E % A 57121,4 41,2 1.0 2.13 1.0 10312 4,1 4.80,2 Gil(' 04 A4 .AE�+ ° . LC?NC 'TER VG. VAt,JFL rnrii Vaay v "•t` 1E,9rrltY as- trsr tat$ •LPt,h C`aC.yt tlr lrad a ry tan fC)t ryR„l. f4";�rct rtir'tL&1"i r,",Sa3i"lttlra at8d iota # yx9t Ftct1*i< 6,1 `itr4,G tarn xu t xwxsazx rsaasa rroriprrsrc; s4 wa, stetr 5t6c oriliallssi a t r1r rlto nrtt't l 1 6f r Pra t6R as,6, a w rft 3n 3 i Iu S -f t r tmc pt f6u'1t ht y 6 is know or have 444n„,pis to Cel xFx" i, r * sst t N t `X' 'in coiu ren . f .r i G .zt ttathrl you behove i5 abseii.. 11 vri u rs`i' ail fat 6rw Wilton ,DU fa ur6 I'"+t'i�9ttckr tt 6 rr nits t'R u1 t' ; t 'nrr Sd'1z`dys tu; r 1t°`at °"aGlulrap7t., 0'g+': a rB'ar'rr t.`r 6itmn 201r"+3"rrn pcilu66M, �p"Caaa roust provide the res:uftts o1 at least one r aitysis f r tlist pollutran0 if you Know e'tr na,. r, roosian to tvii11 it pub or re alke l u tzt r1 r1t rr it,srt n > da t y D ttcroteln, atuylonttnter, 2, 4 dnuirophenol: a`rr ?-tri by*I 4 6 rda`nflrophenol, you most provide the results o1 t 1 st one anaNsrs tot ouch ref these po6@a 9 L+ts thigh you F: o it tt rtw r r t n tr E ?da ,r 9firai yr at discharge an cc+nck nlrtatk rrs rO 100 py b or granter. Othtrrw e. toy p0IPuf hls tor which you r a;78ratth. 2b, Ycaui mar rithtr a 01Nr 6t .al leac,4 one analyst or bsipiyr 6,r ybtztx= the rx'c;"x.-srx rt ew^.4ts. a an xt..m...a:.F i, 7 pages to thus part; please. review each care:tufty. F otrtpDrrr NV lrablc tail 7 pages) artt each oullettl : ata r idsrii i A MY a3s a a. 'r xarrrttrr: rn.:rq !,xn,ra +rt At, , t t'A pft AN TO A 44) VAL ANALYSE `s name. Ir t4 to %tN s it Nty t n 1`6twfi A t%a. VAL 4 ANAt NTINU «POLLUTANT ND CAS NO, ,_ FRACTQN.v G y A NC0 0498 YS w Mass vLITAN Ca AS NC), 'IA. P,Mitootwor7 ?F �AFtW, °'h" `84 ',6,m1 t MAX4v75 d' AIL'u" VAL&.tk Tsc" kC° VOLATftE UN NC0004 r 0 A:' a"AL ttE ., R °NCI TERM A. d OP t iG Nl"`Ak E ! LONE 7" ; w Vb A 'Rog rotr a 48 �` vsc . rrr�atitA AC;T€ON Aa NUT AL 0MaoOS 0,03 NCOO 4VALLJ i�; N iv T RM AVG, A AxDav qtAtAnv mrant A C?NNNUED FR£`3 PA E V-6 OLWTAN"f' 2. BARK a"X ND GAS NO, V91aow' FSAT?F#.M9 w L AN 10110400 a e: ofuend f4 1-14- I, Ngumene AX 43U $ A6L'4° VA 0,t?`:s" 0.02 0,19 NC0004 7 005, V_AL.LF , LONC TE § ,r AV , V ALI) a1h ALY EO mar L46 N�.5 NTAKEE�al VA tlaZINZ AC, r ,APyB CAS NO, AIC,r AIIMi aza„� $ hJS a r PVALUE FRA ,,. I )N A S/NEL/ A MPO r !h•t?ay IN A,c ��:pli yra C� O'FERM AVG. 'v, r. Lake Noonan it) Fan Cont101 House Non -contact Cooling Water iritake .Screen Backwash 4 err Flue Gas Destalfurizet ion (FGD I —Tar, Wet Scrubber WasteWater Projected Future Marshall Steam Station Flow Diagram NPDES Permit #NC0004987 vnt,,,,,a.000,4003-1 Catawba County 0,2mGo Submerged Fag h.T risramor Grata MGD FGD Wastewater Treatment Sv.stern (PhysiChern & Bird Heat Exit hanger Cooling Water Air P ire heet.er VVDter, Precipitator & Boller Wo.sti Waters, Misr. Cleaning Westewaters Raw VVeter Treatment (Misr, Eon (omen( Cooling Bolter and Tor bline Room Sumps T,ra Oncre-through Cooling Water r 15 t Ut5ttrti Wet larld5 outtaii 001 Lake 103 rGDN *ma Dente Stk.': Viteste.wator Sanitary ((sternal ()atoll (Xlitt 0,8 MGD Fly a„sh Sc &milt 0.53 MG —-- MGD Storrowater 4T 4, 1.9 Yard Drain Sumps MGD (2 flows To 1A) Stormwater Holding Bain Leachatv — 0,04 MGD .„. Alternate Route 2.4 MGD Retention Bain internal Outtall Mire Storm Watet As h) (Q7.1q ri Ou Dells 002A and ta12E) Yard .Su cur) Overflow no flow respecter:1:i 4o-?il0'401102 5M,5, 545555,555, r-555555505.-5."-^5'55455".÷ 054000 '505 55.555-5› 00(0 N050515,0 ate -fall 002 1.0 MG D Retention Betels Overflow fro flour expected) Grattail OOFT MGD Lake Norther, Lake Islornion Lake Simla -ago Marshall Steam Station 8320 East NC Hwy 150 Terrel8, N(, 28682 .828.-178,7 00 June 27, 2019 Mr, Wes Bell Department of Environmental Quality State of North Carolina 610 East Center Avenue, Suite 301 Mooresville, NC 28115 Dr, Sergei Chemikov Water Permitting Section Division of Water Resources Department of Environmental Quality State of North Carolina 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Marshall Steam Station NPDES Permit NC0004987 Notification for Start of Decanting and Construction of Temporary Waste Water Treatment System With reference to the subject NPDES permit, the start of decanting is scheduled to begin with the removal of stop logs from the ash basin discharge structure the week of July 8, 2019. This will allow the ash basin water to be initially removed by gravity. To lower the ash basin water level further, a pumping operation will be implemented. It is planned that a pumping system and temporary wastewater treatment system will be installed and begin operation in August 2019. If have questions or need additional information please contact Robert Wylie at (704 382-4669, Rick Roper Marshall Steam Station, Station Manager General Manager III FHO- Carolinas Coal 'tEC .VE[)1Nt*DFNRs.Wk WO ROS MOf1FsESV1t l k. R YI NAkw or-oc.`r :. bc: w/attachment J.S. La Sala — Marshall Record Type Code: ENV-50-02 Document Number: 8-6 UPS Tracking: Wes Bell (MR0) - 1Z8955X40391231644 Sergee Chernikov (Raleigh) - 1Z8955X40393117050 Marshall Steam Station Duke Energy 8320 E. Hwy 150 Terrell, NC 286E32 828 478-7820 V 'it. Jeff Pr upatt. NC DWR Permitti 1617 Mail Service Raleigh, NC 27699-1617 Cl1f(C)57 hdr Count zind strhnait EPA For sch rge. here are any questit ns about th Rick Roper General 14Tt Marshall Steam Station Pig' Generation Carolinas \Vest Statit} Maria(-r nponent ,startup Section Duke Energy Marshal Steam Station 8320 East N( Hwy 150 L` t. ges s dependent on E)din Sd! As required, Duke Energy Kt) days of the commencement of the n, please c«rtt ac.t ,Brad Loveland at (I()=1^f 373-282.() ,prENERGY cc: Wes Bell - DEQ Mooresville Regional Brad Loveland/Filenet - via email Scott LaSala UPS Tracking: DEQ Raleigh- 1Z8955X40398872627 DEQ Mooresville - 1Z8955X40398298230 Annual Certification Non-Stornnrater Discharges Page 2 DUKE • ',P14# EERGY, tsso,,Rost?iiso,s November 28, 2018 Attn: Jeff Poupart Division. of Environmental Quality Division of Water Resources 1617 Mail Service Ce, ter Raleigh, NC 27699-1611 riEcco,froiNeclemnin vvoROS MOORESVILLE REGIONAL OFFIICrI Subject: 90 Day Closure Notification for Wastewater Treatment Unit Duke Energy Carolinas, LLC., Marshall Steam Station (NC0,004987) - Catawba County Dear Mr., Poupart, Duke Eneegy 52fi, 'South Church Street Chariot:re: NC 28202 Maihni Address' E.: G I 3K P.O. Box 100f3 Charlotte.. Nth 28.201- 1006 In accordance with the requirements of Part Section D of the NPDES Wastewater permit NC0004987, Duke Energy Carolinas, LLC (DEC) is hereby providing notice of closure for wastewater treatment components at Marshall Steam Station in Catawba County, NC„ As part of a Water Fie -route project being undertaken to assure compliance with the North Carolina Coal Ash Management Act (CAMA) and the federal Coal Combustion Residual (CCR) rule for this facility, DEC will be starting the closure process for the Constructed Wetlands (and Internal Outten 004) by end of February 2019, The ongoing flows from FGD will be redirected to the newly permitted FGD WWTP (internal outfall 006). More details regarding final removal of the Constructed Wetlands will be communicated via email once plans are finalized, Please accept this letter as meeting the permit requirement to provide 90 day notice, of closure for a wastewater treatment system. If you have any questions regarding the closure of these treat ent u its, please contact Brad Loveland at 704-373-2820, or via e lea at Bradioveland@Duke-Ener ,com, "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 ir»prisonment for knowing violations.'" Rick. Roper General Manager Hi Marshall Steam Station CC: Shannon Lang Wes Bell (NCR Q) k g: Jeff Poupart ( EQ-DWR 1Z 955X40399639575 Wes Be (Mooresville) - 1Z8955X4O396100188 DUKE ENER November 28, 2018 Dr. Sergei Chernikov, PhD Division of Environ iental Quality Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: NPDES Permit Application Wastewater Treatment Additive update Marshall Steam Station NPDES Permit NC0004987 Catawba County Dear Dr. Chernikov, Marshatt Steam Station Doke Energy 8320 F. Hwy 150 Terron„ NC 28682 828 47822820 .t:ITECEPJ ENRIDWR MOORESVO 188188.13NAL. OFFtCe In a submittal to NCDEQ dated August 22, 2017, Duke Energy updated it's NPDES permit application including a list of chemicals that were to be used as part of Marshall Steam Station Hazardous and 'Toxic Substances List. Below is a summary and reasoning for this updated lists submittal. Sodium Hydroxide (Caustic Soda) — The previously submitted table 5,1 lists "'Caustic Acid" which was a typo, and should have been listed as "Caustic Soda". This chemical will be used in the new FGD WWTS, for pH adjustment in the Submerged Flight Conveyors (SFCs), and for pH adjustment at the Retention and Holding Basins. Sodium Carbonate (Soda Ash) — This will be used for pH adjustment in the Submerged Flight Conveyors (SFCs), Included in the submittal are the 'following: Updated Marshall Steam Station Hazardous and Toxic Substa ees Table The SDS sheets for Sodium Hydroxide and Sodium Carbonate, vv‘v -c nergy cum Duke Energy does not anticipate or requests modification to the permit as a result of this submittal but is providing this update to assure the NPDES permit application is up to date, If y u have questions or need additional information please contact Brad Loveland at (704) 609-5637 or brad,toveland@duke-energy. corn, d t certify, under penalty t " tha accordance with a system des Based an my inquiry of the person information —the information .sutrrrls"tted is, there ;are ,sr'graiik,a.rat penaqtes tor . ut rutr+r Yours truly, 14, Rick Roper General Manager ID Marshall Steam Station FHO- Carolinas Coat attachments CC: Atarshati Steam Station Duke Energy S120 E. Hwy 160 'OrretO NC 28682 828 418-7820 Brad Loveland/FileNet, EHS CCP Scott LaSala Wes Bell (NCDEQ) Record Type Code: ENV-50-02 Document Number 8-6 UPS Tracking: Dr, Sergei Chernikov (DEQ-DWR)-1Z8955X40399015748 Wes Bell (Mooresville) - 1Z8955X40396353790 W duke-e Lily „COM sh v Ste rT S a o° Haza Rdousa d mox c Substances s R sed 11/18) l . 5 . • Acid o c Acid Nutrient r Ft m Sulfide Telex, ,` Hydro Ca i rn Car r cut tic Soda 4 Ace ide B`EN TAG r fd ntgtrcat on Product identifier Other means of ide„rtst'trat rr Recommended use : esotr merada,d restrict drs Manufa :;tu ecarnporte,rtSeatr ,ti Manufacturer Corrapar,y, name Telephone E =•tea a it Er arigenc y F arrar'd(s) identification Phyak:at hazards Health hazards OSHA defined haze rats Label elements tiattard .taterr! ent Pr°ai..astt��r�at'= ata Prevention Reath r sa Storage Sa.,p Perrrervtat information atio SAFETY DATA SHEET $ODUJM ROXt E: 2 % Rena. ALL PROPANDLTA R None tiros,r Not a etchier Take ott immediate* all s Composstb rn[!nformatUon on Ingredients Mixrdrear CAS number 5Jq 1310-.7 -2 a, r a 4Pirst-did rrt':east.res Inhalation Skin contact Ei e contact Most irnpaartaa't s rnpttsaare/effeatra: acute and de€ay'etf (indication of uttFr*rrc diale magical att'e,ntiata assail spacial treatment needed led General information 5.. Far 4i hting rne, es Suitable arxt nguishing media Unsuitat to e,stitma a atstr ar media Specific hazards artsin a freer a the rhea leaatI Special. pr( er::tive equipment and precautions for firefighters i jhtsng "instructions Specific rrsothods t3eanerth firms haazarda 6, Accident rs Personal preartttraa,. protectiveecuiftment and errs rgency probedLr, Move n'e to literati air (,tall a phys c Take tali it r^a ratas.a recall tter;ter ir,,rrec;ztata tieing before re se It sar x: ecs'4' a°i a phyt vomiting occurs. Burning path argil severe itorrF t.v e akin carnage, Clauses ser OuS t e carnage t,_stgr a fediaide stinging, tearing. redness ""ayeering aria pile C ea yi Wetness torrid result Seigooriteired No ccos;tat fire e. Freiman est eye ca °t age tinctliding rec safes Keep ineleceseary e.tsar 9'at u"nay Keep decade away itiorri arid upearie c: hiv""x appropriate proleptic ea uax art as a clothing d during pie s r70t breathe mast or vector col touch itemageri contain + sa V}�;a ra:ter'r toat. protective siothicp Meftlt`srds and materials fair Containment and cleaning Shp 7. Handrin and strait Preca otin ns for safe earthing Conditions for aafa; afaasa ea; oPtrtcint3 array into ngatible:a€es ,6,3679,3 Venetia per ate ventilating he r Avoid :r?oi t at x fr;. at: ,.,, Stiritirt hygiene practices t a� het Pi .. Exposure contrc s'person rrotetct rt Occupatir r'°e: t eapossrs US„ OSHA Table i. I globs kr Air Conforranants R9 CFR 191 ,ttlQO4 Components Type 3Dt4llwt arii(DROXiDS ,t. Srw"ptt. H11 (GAS 1310-73-2 US.. ACGlet Threshold Limit Values Components US, 1\00 SEP Pocket Ganda teaCi'r Components SODIUM riftelDROX ,` 1AtOirl j (CP S Biological limit salr,tes Appropriate engineering, controf T yea arbor Type Or ther e%igiesee P poritz e > to exposure Omit% wink facet adorns individual protection pleasures, such ae personal tomer"at Tee following aro recommenotaigensfor >r•3Yx..,Jr".?£" of Protective�'i.:, ui S`�.ent (PPE) Hazard rsee st. eri of Sate workplace according. to OSHA `eg at:t e s .,.' CFR , while performing any task ;ai°e,t-„ ',"-t tt;2kF z gra to this t;,,rottu Ryerfar:,r protection Wear safely s :SA in biotech n Hand protection eµ rp`asts Respiratory protection Thermal hazards General hygiene considerations h'y°'t t ttt't ptr A.ppearraatre Physical state Form Color Ori Or Odor threshold pH Melting point/freezing paint ira. tlat h il'Rrr point and boiling g range Flasitt, t' ttt ta:Nt Evaporation rate r,ryt Flammability (solid, cues$ Upper'a'tow r'flam lability or explo.e:iv rh,miatahality ltrt [t n dE,vyFm ,. % Flammability israrit - upper tea) Valais Vallee Value he€°.get protendive citothi t when ecesse 9f. "t "'4.a personal , keglers free Satre spot as ana.st It i ktr e e s''st ie smoking «eking Ractinge,y` CLEAR COLORLESS ODORLESS tttt i apace rae tufts prate t map. sow ray V. H.YDR a ^>r;•;a'"s:«xrh 't,+e a.aYs1#. 05. Rt-iM03,1 .sat $f ;t'r 205 w. 1 pro s.v intailligi 660793 latori FIRENNTAre 01116-601671111 [NC PRooRliss ENERGY CAROLINAS Frelay June 111117 Explosive limb i lower fie) Not avagiatie Explosive limit - upper (56) Nel available Vapor pressure Not available 'Vapor density Nct avalettle Relative density Not avallanla Sol unitityties) Solubility (Water) Nat avalie Cis Partition coefficient Net available giro eta no tierater) Autnition temperature Nidi available ,Deisoryippieition temperature available Viscosity Not a va debts Other inforitto fot Density 10,66 ihriatel explosive properties exichisive Ox id eel g properties Not caliettrig Pent volatile 75 et esiersideaci ,Specific gra Vity 1„28 1:0,, Stabilityand re -activity Reactivity Tes produce is states ancl noreseadlive tercet rlornli,i,t coreliters of kiss storage arid transport Chemical :stability Mate Pia stable urger rOrria! co r, Possibility cif hazardous hazardous colymerizatie dlea5 nC,t OC=r reactiords Conditions 10 avoid GCrita Nigh incompatialts el et le ;' incompatible materials Strong acido Hazardous decomposition No haze n10 eco rrnp0 SMO n prOdUCti are known products 11 Toxicological information tntormation on likely routes ,of exposure inhalation May cause irritation to ilea reschatery SyS(eril Proterged linialat on may Ne somata Skiontact Caches se,,,,en4 ye contact n'ethIeti serious eye, Cla mope Ingestion leta Lissa olearsity a tract burrs Symptoms related to iris altering pale add arrests costoialve skin sadirons Corress sera:tits sys Carriage Symbioses May phycaChemical and imeatile stireging, teafilitg redness :,%rielfirg and therran vision mermadant eye darnalie imzito,:ntrti toxicological thiristreso could re SkA ch a recteristice Information on toiticiatogiCal affects - Acute toxicity Nal available ;Skin toreasibrairrirattaa Causes severe lit burns end eye Carnage Se rioula stye dame geleye Ceases socidus eye damage irritation Respirattyry uskin sensitization Respiratory sensitization Nisi a reshiettitty sensitizer Skin sensitization This ciactuct la not expectedt ause skirt ormailibeede Germ coif mutageoldity Nor data dee liable mitierdie product or any. Corrpore,r15, pintrIt Bt. greater tina,', 1%, aris meraceric garioicsio Carcinogenicity This proceed, is ret ecosistaraitt to ris eacierioder by AMC Ahearn tifIlis C,XiniA ARC Monographs, Odic:tali Evaluation of Carcinogenicity Not listed „„-- MaterAc name SOnsidedi gognineetta 685793 tiliticed fir 05 Ressiori date; 2,6151 lapis gala 05-10 lege 7 OSHA Sp US, Notional Toxico€aqy Prograrn ( TFtt Report Nat tilted toxic ty get organ yr° r 1 ill„ sing€c exposure 'get organ iet•s{f sts,rrs€"is y Reyral ;te,d Substances (2$ CFR xPtsrrre Aspiration hrazarrl Chrogw e!'t "t 12, Ecological inf 7rrrl tt as cat r^S Estimates tot rest P sstst rar rind rttagrad ahs( RiOaccumulative potential Mobility in soil Other adverse effects 13, Disposal conside Disposal instructions Local disposal regu ataoe•aa; Hazardous waste code Caret r ae7 TemdRealt othea° adverse eretr r, potP tir"ar. k`rnsto„„<a'f.r?e rifre€"wza¢r=?+, 'ions Cornett and reclaim a,.r s,°,a`isr. s,;:' in sealed Ponta€aae cr?r,ferrts'rontairter are accordance with local rag. inr pose in accordance vote all aocticente regutatt The acts code s"rw,ad .,„srtteseci sterrsro o rt. between the Lla" h p my ,shet r 4 w , _.._K _.. � nut . Waste from residues unused products Contaminated pactozpinci 1 Tran'spa tt forrrt atj r DOT" UN number UN proper shipprn. Travisport hazer<t Class Subsidiary B 'a k Packing group Special precautions for uncle Reast s;afel,,. ERG rpjrnbtr 15 tDOT informs tiort on packs OD 0.X. Es; Ei detests tersei SODOM HY Die DM w s r� 6''8s * n fe ar ;a a Ora„ 4'21 aax_, It -201 5 en,s,„ .a r. Re r disposal site Dispose of roe co iiirotiten '6-56793 FtOn. i3RENNTAf..:..i PROGRISs cAR0LINAs hz,„ 201-7 DOT 15 Re uatory informa US tedefal regulations lo This product is a thiazaccistis Chemitist as. defined by lee OSHA. Hazard Commairicalion Standard 29 ORR 1910 1200 FSCA Section 12(b) Export :Notification (40 CFR 701, Sabot Or Nat re:goted. CER.OLA Hazardous Substance List (40 CFR 002t44i SID)RJM HYDROXIDE (CAS 1310 732) Listens SARA 304 Emergency release notification Net regulated OSDA ,spectftcady Regulated Substances (2S 'CFR 1910;10LO 4050) Not tabulated Suderfund Amendments and Reautiaoriz.ation Act of 1966 (SARA) Hazard categories immediale Hazard Delayed Hazard , No hire Hazard - Pressure '"i4ZETC; Reed:Mb( Hazard r Net SARA 302 Extremely hazardous substance Not doted' SA ,3S11312 Hi 1u Yes chemical SARA 31 (TR! reporting) Not regulated Other tederat regulations Clean Air Act (CAA( Sestina( 112 1rco Air Pollutants diitAPs) List Nal regulated, Clear! Alt Act (CAA) Section 112.(r) Accidentizi Release Prevention (49 CFR 68,130) Nal regulated, Safe Drinking Water Act Nut regulated CSDWA) US state regulations California Contro4c,2$ $1.417.5tanCeS, cA Deportment sit Justice CC anforni'a He2,11.11 'and Safe Code Section 11100( Not Pstraor US, California, Candidate Chemicals List. Safer Consumer Products Flegulations (Cal, Code Rags, tit, 22, 69602,3, subdi (a))) SODKAI HYDROX0DE (NA(C2-20 (CAS 131043-2) US„ Massaehrusetts RIK Substance List SODIUM i-iYaROXODE NA(C2H)). US, New Jersey Worker and Community RightstrsKru.us Act SOEIDM HYDROXIDE blA(OHlti ICAS 312i43--2) US, Permsy4vania Worker and CommurUty Right,to,,Know Caw SODIUM 'HYDROXIDE (NA,600-4)) (CAS 11310-73-2i DiS, Rhode Istand RTK or soikii etyDROXIDE (NA (STsit, t SA S 31 0;73-.2 Valer.11 SODIUM HvDROME 25)b 35C223 22-%tol t2S R.222).)),1 ete ,04-7016 CID e 6 7 Sfincieurri in '666793 iners BRENISTAfir MITSSOUTLE RCN To „PROGRESS, EKEROC CAROLINAS firieerreders fit 20 7 US, California Proposition St California Sale Drinking Water and Trixic Enforcement Act of 19E6 teficaposition ErS7 This reersinal is not knows to sorter any chernicsis currently Shied os dersinegers dir reproductive iceire Lnternalionat InveotraliecA' Country( s) or regiOn inventory name Op inventory (yeSitlOr A ustriinis Australian iriverripsy of Stre,arthel Substances WC% Yee Canada Domestic Sebstaricea List Pint) Ye5 Seriada NociDarreastis Substddiges List (NOEL) Crane Inds morf Existed:is Shamir:ZS Saffialarices ir Chins ECSC Yes Europe European rive Mary of Existing Cs needraid Chestiest Yea Substances (E11111ECS) Eurose European, List of Notified Chemical Substances (ELSNICSt No Apar inventory of Stearinti add New Cherricee Sobalioness NCS) Yes Korea Existing Cderificais Psi ifiCip 'Yes NSW Zearand New Zealand tovertnry "Ses Philippines phsippise nos rap irs of Chemicals dr a rit.herriicai Substances Sas fPICCS Crated Stales & Pada* Rex Toxic Eirboisfices Cid* or Act ififiSCA1, vase ifilsra yes as 'dad' reassierti Mat ceene:nreeres te! Ves orostior comp y vete meteeeere ,eeiethetheree a tirrthestetheel by tie sot seurdryfai A 'rah indicates her Dna mord cornsonsfire altos orodurt eae srao 0, exempt rem eethei3 51 the memory ariethesteeed by the cpve,n,rtg cotintrOk 6, Other r n Wor ucluding date of preparation or last revision issue date 05- I 0-20 Revision date 1-04 - 20 Version Pi 05 H101 r stings risen', 2 fiki rdefoility Pifysicai passed 0 SPA ratings noriabilny Sista bait)/ 1 Disclaimer White Brenntag believes the information corealned herein to be accurate, Breentspi makes re representation Or WelflaPty eepre,SS Or impasse tegarefing, and sesames no tisbialy too the bourece or corrisiateneso of the information Ins Buyer sesames di) reoperate% for hardring using eritheir receding the Prodecil ir dectordaries vein aspirate* races& state a red lobe fast This SSE shad rot in any way Chat or ereologe the operation dna effect of aria tre ref Ceneee05$ hiconstageri terms and coriditions of sere Oro t.10'7"6" SC: ow al itscortharH:e5 25% See tratififird Version a CS Reirdori dere' it iiits Pei 6 Sods sae' Care di' 21116 7 r Product exam Altttatat : Commercial ;am ('hcml,c8l Name 4a nutty,. tits I<tom tFla hcrtttcal luan 1 Rectum mantled rasa Matuufacturer lffMC sAfyciming Corporal Dm Alkali Chemicals 1}t`t [shin 1735 Market Street Philadelphia, 1'A 1910e P L: k1 2151299600 lai Safe ,° • Sodium C'at°Ix►tt.ttr, „Anil Snd rof lea,. 18001 421 9300 1 703 r 527 38li7 4001 - 204937 (cH1.:° All t ttla I 307 X7 0 2452 1P1anI - Green River. WV 1 303 > ltlnl 1 1 ic'a l 1".' - t"ail Colleen, rhonate, lydrous Skin tarr€tart Flash Point Hazardous a:nrrukrustirr, equipment and prerau `4 aSil 6V t i2. RQ.h rip ‘saier .iiit soap. GO rnedieal ai.r en is .artfrt 34tw41 arar•:It cpa isurainarnad r lu1hing, heti:ire rsus . Reran k a p atatd €a� l0�:.9 E,Fif, if sigios's:i rnpiiaarrn.. coon 4 i fC4r. "°ra"i, LVp. 9lnJ P.a"sadY..a:t!< a i rt attar i 1;a 't E Tars O +-2(i ,O2 Sod ttttt arbonate, = rt t °drolls gated atiiinal expoS0re ton lords protecin prop* Apltearanee Color Physical state Odor Odor `litres/told Mathanxntlaa Freezing point 13oihnp Point/Rang Flash point Lvaporan rate FIa°tttneunitnte^ propert Oxidizing pt'nntrdi Explosive properti Vapor pressure X'aptnr density Relative density rural Rubhea'. 'Cash o`rrta^ Iov Qcopali I 'IS11S #. 497-19.8 Revision ')are: 2013-03-26 Hulk rlensatt 'Vlrrld ulatr Weight Water solubility Percent volatile Partition coefficient; Viscosity 9,2 Other thcirutltos '1.uta=u,;netira u nl Skin irrtateuu 1AA50 Oral 1,1)50 l}e marl l,(' tl Inhalation: Sensitization dttu t0 0 not ae pl caahl ENT¢eastra'=' at¢r° u r rraea¢ itrr �w,�.°r ttaP� ¢�t�.ai l�cr¢i�t9 l a_ita zdoatal aluminum Sodium o \ ides. nateAnhydrous d degr dlity None k sn y»& APwa _dads w / Comphes. Rol MSSMS:DS w 497 9 $ Date: mU±; . 2 rhITnate, Anhydrous edera Toning rtiiit d (:"ate C'hrtmni ! ire Ila.tard Sudden Release ul`Pressure Hazard Rea: ire (laarard (`I�ItI�'➢'ark This auate tta i, ,;a .set 1. s.1)0FI . Regulations tions t1 Reauthorization Act eel' 19'86 (SAR.i1). st! 40 or ifte code of Federal Her! Mridertile i`l"5a . iriKte . C°ana.ala 'Phis product has heat classi:fre tat a rni contains all the information required by t iri;°I➢ HS ➢➢aeara! (:bass D21' "(us"st: materials \l`! .•(f➢➢bfS Raatiaa s ➢,e % errs 4n Si it ns 3: t Rea=is(ion ➢)aatei. Reason fot rr;s Disclaimer 111(.° Corporation believes that I#e . hereof, .NO 1t _t.RR,t1"F'' OF 1I1`V F SS F" WARR„51"E`l', EXPRESSED OR I\EPI.111), relates only CO the specified product designated and may no process, Further, since the aOnd'itions and methods mmr use art Eirab6tily xs to any results obtained Or arising from am use of tha: tarot tie tin 110 t;<e aar#'criteria of time Co Prepared F1ms Rev ;els Regulations ((` tiding [ aia and smtementtii are ACC unite a tst tEsr date OF \II I- t'EE.t\ 1 13l in" OR.i1\'t'tF1'E1F:R P.i(tiDi'(Ei,9 E)1 1°,RI1\,. The inrirrrnatEan provided herein tMSDS #: 497-49-8 -26 orpmuratpammr 'rich inrtrt"nnatdryn, La Sala, Joseph Scott From: La Sala, Joseph Scott Sent: Friday, June 29, 2018 9:57 AM To: 'certadmin@ncdenr,gov' Subject: Marshall Steam Station - Change in Backup ORCs Attachments: Marshall_Steam_PC1_ChangelnBackupoRC pdf;. Marshal _ChangeinBackup0RC.pdt Jenee, 04. `xFF�'CE Please find attached the operator designation forms for change of backup ORC at Marshall Steam Station (NPDES WW permit NC)004987). Effective July 1, 2018, Marshall requests the following changes be made to the ORC/Backup ORC for PC1 and WW1 at the facility: Gregory Paul Phillips — Keep as ORC (WW/PC) Joseph Scott La Sala — Keep as backup ORC (WW/PC) Donald Scruggs — Remove as backup ORC (WW/PC) Steve Hodges — Add as backup ORC (WW/PC) Please let me know if you have any questions or concerns regarding this request of change for operator designation. Thanks! Scott Sr, EHS Professional 1 Marshall Steam Station Office 828.478,7820 ( Mobile 904,631.8042 8320 East NC HWY 150 Terrell, NC 28682 ioseph.Iasala c c u e• ener tyec orris DUKE ENERGY WATER POLLUTION CONTROL SYSTEM OPERATOR DESIGNATION FORM (WPCSOCC) NCAC 15A 8G .0201 Press TAB to enter information Permittee Owner/Officer Name: DUKE ENERGY CAROLINAS, LLC Mailing Address; 8320 E NC HWY 150 City: TERRELL Email Address: rick.roper duke-energy.com Signature: Facility Name: DUKE ENERGY-MARSHA L STEAM STATION County: CATAWBA State: Phone: (828) 478-7600 Zip: 28682 Date: Permit # NC0004987 YOU MUST SUBMIT A SEPARATE FORM FOR EACH TYPE AND CLASSIFICATION OF SYSTEM: Facility Type: acility Grade: PC OPERATOR IN RESPONSIBLE CHARG Print Full Name: Gregory P. Phillips Certificate Type: PC Certificate Grade: I Email Address: greg,phillips@duke-energy.com Signature: RECEIVEDiNGDENROWR „S,i1T4' WQR 0 S MOORESViLLE REGIONAL Or1t0E Work Phone: 828-478-7647 Certificate #: 28197 Effective Date: "1 certify that I agree to my esignation as the Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Print Full Name: Joseph Scott L Certificate Type: PC Email Address: joseph. Signature: Sala BACKUP ORC Certificate Grade: I duke -energy co Work Phone: 828-478-7820 Certificate tt 1002443 Effective Date: "1 certify that 1 agree to my designation as 0 8 k-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission" Mail, fax or email WPCSOCC, 1618 Mail Service Center, ORIGINAL to: Raleigh, NC 27699-1618 Mail or Fax Asheville a COPY to: 2090 US Hwy 70 Swannanoa, NC 28778 Fax: 828-299-7043 Phone: 828-296-4500 Washington 943 Washington Sq, Mall Washington, NC 27889 Fax: 252-946-9215 Phone: 252-946-6481 Fax: 919-715-2726 Fayetteville 225 Green St„ Suite 714 Fayetteville, NC 28301-5043 Fax; 910-486-0707 Phone: 910-433-3300 Wilmington 127 Cardinal Dr, Wilmington, NC 28405-2845 Fax: 910-350-2004 Phone: 910-796-7215 Enaii ce rtadmin ricde' lir. go v Mooresville 610 E. Center Ave„ Suite 301 Mooresville, NC 28115 Fax: 704-663-6040 Phone: 704-663-1699 Winston-Salem 45 W. Hanes Mall Rd, Winston-Salem, NC 27105 Fax: 336-776-9797 Phone: 336-776-9800 Raleigh 3800 Barrett Dr. Raleigh, NC 27609 Fax: 919-571-4718 Phone: 919-791-4200 Revised 412015 WPCSOCC Operator Designation Form (continued) Page 2 Facility Name: DUKE ENERGY - MARSHALL STEAM STATION Permit #: NC0004987 BACKUP ORC Print Full Name: Steve D. Hodges Certificate Type: PC Certificate Grade: 1 Email Address: steve.hodges@duke-energy.com Signature: Work Phone: 704-363-0819 Certificate #: 28173 Effective Date: 5/3ooig "1 certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. ! understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Signature: Certificate Grade: Select Work Phone: Certificate #: Effective Date: "1 certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Signature: Certificate Grade: Select Work Phone: Certificate #: Effective Date: "I certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Signature: Certificate Grade: Select Work Phone: Certificate #: Effective Date: "1 certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Revised 4/2016 WATER POLLUTION CONTROL SYSTEM OPERATOR DESIGNATION FORM (WPCSOCC) NCAC 15A 8G ,0201 Press TA8 to enter information Permittee Owner/Officer Name: DUKE ENERGY CAROLINAS, LLC Mailing. Address: 8320E NC HIWY 150 City: TERRELL Email Address: rick roper@duke-energycom Signature: Facility Name: DUKE ENERGY-MARSHALL STEAM STATION County: CATAWBA State: NC Permit Phone: (828) 478-7600 Zip: 28682 Date: NC0004987 YOU MUST SUBMIT A SEPARATE FORM FOR EACH TYPE AND CLASSIFICATION OF SYSTEM: Facility Type: 1 Facility Grade: V1W OPERATOR IN RESPONSIBLE CHARGE (ORC) Print Full Name: Gregory P. Phillips Certificate Type: WVV Email Address: Signature: Certificate Grade: I greg.phillips@duke-energy.com Work Phone: 828-478-7647 Certificate #: Effective Date: 47 "1 certify that 1 agree to my designation as the Operator in Responsible Charge far the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and foiling to do so con result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Print Full Name: Joseph Soo Certificate Type: WW _ Email Address: joseph.lasala@duke-energyco a Sala Signature: ACKUP ORC Certificate Grade: Work Phon Certificate #t: 1005114 828-478-7820 Effective Date: "I certify that 1 agree o my designationas a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission," Mail, fax or email ORIGINAL to: WPCSOCC, 1618 Mail Service Center, Raleigh, NC 27699-1618 Fax: 919-715-2726 Email r„e; ; ad mir" d=''',LLsr, gOV Mail or Fax Asheville Fayetteville Mooresville Raleigh a COPY ta: 2090 US Hwy 70 225 Green St., Suite 714 610 E. Center Ave., Suite 301 3800 Barrett Dr. Swannanoa, NC 28778 Fayetteville, NC 28301-5043 Mooresville, NC 28115 Raleigh, NC 27609 Fax: 828-299-7043 Fax: 910-486-0707 Fax: 704-663-6040 Fax: 919-571-4718 Phone: 828-296-4500 Phone: 910-433-3300 Phone: 704-663-1699 Phone: 919-791-4200 Washington Wilmington Winston-Salem 943 Washington Sq. Mall 127 Cardinal Dr, 45 W. Hanes Mall Rd. Washington, NC 27889 Wilmington, NC 28405-2845 Winston-Saiem, NC 27105 Fax: 252-946-9215 Fax: 910-350-2004 Fax: 336-776-9797 Phone: 252-946-6481 Phone: 910-796-7215 Phone: 336-776-9800 Revised 4/2016 WPCSOCC Operator Designation Form (continued) Page 2 Facility Name: DUKE ENERGY - MARSHALL STEAM STATION Permit #: NC0004987 BACKUP ORC Print Full Name: Steve D. Hodges Certificate Type: WW Certificate Grade: II Email Address: steve.hodges@duke-energy.com Signature: Work Phone: 704-363-0819 Certificate #: 26786 "/ certify that I agree to my designation as the rules and regulations pertaining to the Disciplinary Actions by the Water Pollution Effective Date: s/ , 'o/a Jo a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Signature: Certificate Grade: Select Work Phone: Certificate #: Effective Date: "1 certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Signature: Work Phone: Certificate Grade: Select Certificate #: Effective Date: "I certify that l agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth In 15A NCAC 0SG .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Signature: Certificate Grade: Select Work Phone: Certificate #: Effective Date: "1 certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Revised 4/2016 North Carolina Departn en ATTENTION. WPCSOCC 1618 Mail Service Center Rrleirtr. North Carolina 2 Environmental l Oua rt ,a 99_tb1Br Duke ,Ene;yy Ca rr . Operator In Responsible Charge Back-up Operator in Responsible Clrarge Marshall Steam Station - NC0004987 Catawba Go Pease find (attached) the corresponding WPCSOCC System Oper°ator 'Designation Forms tor change in operator in responsible charge (ORC) and backup ORC for Marshall Steam Station.. The designation forms were submitted to the WPCSOCC and Mooresville Rego Tonal Office on September 27.£ 201 7. via electronic mail and fax deliveries. Please make the follow changes to your database effective for October` f , 2017. Scott La Sala - Delete as ORC at Marshall Steam Station Greg Ph hips - Add as ORC at Marshall Steam Station Scott La Sala . Add as backup ORC at Marshall Steam St rtion ' Don Scruggs - Add as backup ORC at Marshall ll Steam Station Please direct any Corr rspc ndeuce or questions concerning the NPDES Program at MarshSteam Station to Scott La Sala at 828-478-7820. Rick. Roper Marshall Stearn Station, Station Manager General Manager IfI FHO- Carolinas Coal Oaac:hr nt t'4'Wi•4°°`.dukea€. rneri,ks.:iun A xc: lVtooresville Regional Office, DWF3 bc/ %vlattachment J 3 La Sala — Marshall RH, Stafford — l'\11G03A2 'Record Type Gad' ENV-50-.02 UPS Tracking: ,,';'41PCSOCC, - itsv5.5x40.39.12(,„4/72 MRO - izo.55x-to39x25-Two'; Miie$,ThaV Steaal Station 1,54' WdukL-energy WATER POI,m1. - :1NCONTROL TEM U RA OR DESI(NAT ON NCAC 1.5A 8G .0201 ORM 4OCC) Press TAB toenter PE rrnitt*re Owner/Officer Name: Duke Energy Carolinas, 11,C mailing A.eieiress: 8320 East Hwy '150 otv: Terrell risk.mr er@drIke-ne Facility Name: Duke E. County,: Catawba YOU MUST SUBMFF A SEPARATE FORM i R E ACHi, TYPE AND WAS Print F u Name: Greg Certificate Type: PC 'Email Address: greg phil€ip Signature: l Cerbly that l agree to my design aticari rrs /he Vpe.rtator- in Respans;b rules and rearriation,S, pertaining to the re, pr:pnsibil tic s o1 the CRCas r: Disciplinary Actions by the Water Pollution Control System Operators tit: tt:: NC Permit fr rat FKAT1O OF SYS1'°E OPERATOR tN R SPONS1BLECHAR (er -nergy,cornT Pr°rat: Full Name: Donald F. SCrage s (rrtiilc tr Type, PC Email Address: don scrugg Signature: l certify} that l agree to my designation os ,up Operate in Re pnrrsible the tales and regulations pertaining to the resprarrsxlr'Idles ot, the OR( Disciplinary Actions, by the Water Pollution (c>ntroi System Operators Cer;tr. Mail, fax or email ORIGrNAL to: Mail or Fax COPY to. .rPCSOC;'i 1618 Mid Service Center, Raleigh, NL. 2'7699461.8 Asheville 2090 € 5 Hwy '70 Swarzndnea, NC 287.7.8 Fax: 828w299-7043 Phone: 828-296-4500 Washington 943 Washington Sq Mall Washington, NC 27889 Fax: 252-96-9215 Phone- 252-946-6481 (ORC) Work. r It. Phone. (0rtit Cr CAC 08S 0201 828-4 78- 78 28682 4787647 rid and will abide by the Work Phcme 704-400- 3005 Certificate #: 27892 ark 7ar tare faostaty rrratttrt. t understand arg it a6ic7o by h in 15, !0KAC 08t: 0204 Cana failing to do so ti°rw result i'rr Fax 91' -115 2726 Fayetteritie 225 Green St., Suite 71a1 Fayetteville, NC 28301r51)43 Fax: 910-486-0707 Phone: 910-433- 3300 Wilmington 127 Cardinal Dr. Wilmington,, NC 28405 2845 Fax: 910- 350.2004 Phone: 910 796-721.5 Mo rr`eswUe 610 E. Center Ave., Suite 301 Mooresville,, NC 7 115 Fax: 704--663-6040 Phone: 704-66.3-1699 Winston-Salem 45 W, Hanes Mail Rcl, Winston-Salem„ INC 2'7105 Fax. 336-776-9797 Phone: 3 36-7'76-9800 Raleigh 3800 £Tattett Dr. Raleigh, NC 27609 Fax: 919.571 4718 Phone: 919-791.4200 Real t 44 f6 Permit #r NC0004987 Facility Name: Duke Energy -Marrs Steam Station ate, Type : PCt.vertifir:cy BACKUP ORC Operator tr). Resno sill le Chiar . "'t?i r '..a BACKUP ORC Certificate Typ Email Address: Signature: r r certify that I ogrcr:x to ayr designation ',id' regatta ions pertaining to the, ra sponslbidin rirorr by the Water Pollution, Control Systcrrn CJpe ran it Name: Certificate' Type i iect Email Address: Signature: certify that the rt:ale.s and agive to my' deSnrq utitr. as rr gt`rCk uta r)peratar ira ReSpa,r!Jtiible gulcrtions pertaining to the responsibilities of the ORC cis set forth in 1 bA ,NCAC'.0204 and f erili. Disciplinary Actions bra that Water t:°ontrt l Sys tern Operators Ce rtisCornma siO . ” 4i -7 :? 6443 'Jl(rk Phone,: A NCA 08G rid foga rn iss iora. Ftfectuv Print Full Name: Certificate Type: Select Email Address: BACKUP ORC Certificate Grade: Select tyfro tee, it Work Phone: Certificate #: d will slide by do.sca can result in Signature: Effective Date,: 'I certify that I agree to my de.siq.ncatioo as o Rack up Operator in Responsible Charge for the facility noted I understand and mvill abide by the rutes and reguiaticans pertaining to the responsibilities of the ORC as set forth .in 25A NCAC 08G tt0204.and failing to do so can result are Disciplinary Actions by the Vtrater Pollution Control System Operators Certification Commission,' Revised 42076 WAixrE 1TION CO tTR( YSTE OPERATOR D SIGN NCAC 15A 8G u0701 N PR County; Press T413 tr:r er}.C.ec Permittee Owner/Officer Narrate: Duke Energy Carolinas, 't_L.0 Mailing Address: 8320 East Hwy 150 City, Terrell ris<k.roper'tt Facility Name; DiA e [nergr' Catawba YOU MUST SUBMIT SEPARATE FOR tt'ar"11 Station rn c Permit NCO 049u;k" R EACH TYPE AND CLASSIFICATION OF SYSTEM: OPERATOR !i RESPO ut ttnli Name: 1regry E. t'ollitas ti scat 1'ypt- VVW ant Address: grog,„phdlip Sgnataure: certify that l agree to m, rules and reage.alotr'ons pertcfnr,rnt- Disciplinary Actions Print Full Marne: Cert:ktcate Type Email ldress: don.scruggs Signature. ke--e n e lion es the 1 the re:spans r y,t-orn 'StLE CHARGE OC Work. Phone: : Cect.@f pcatk crawl' io lie.°sp sr'dle Char BACKUP ORC energy.coni de: f1 `°'I certify that l agree to my designation as a Roc:'. ,up Operator in Responsible Charge, the rules and regulations pertaining to the responsibilities Of'the ORC as Set fi.'irtla in 1.5A Disciplinary„ Actions by the Water Pollution mt tion Ctrof System Operators Ceti u0on Comm,_A� LRW�a Malt„ fax or email WPCSOtwC„ 1618 Mail Se rm ic r.t Center,, ive Date: nea.tedl 1 understood end will abide by the 'CAC 08G .,0t)4 and foiling lirtq to do 4o can result irk ORIGINAL to Mall or Fax a CorPY tor. Raleigh, NC 276 r9.1618 Asheville 7090 tJS Hwy 70 Swannanoa,, .NC 28778 Fax: 828-299-7043 Phone; 828-296--4500 Washington 943 Washington Sq, Mall 'Washington, NC 27889 Fax: 252 946- 92 1.5 Phone: 252n946• 6481 Fayetteville 225 Green 5 , Suite 7'14 f=rayetteville,, NC 28301 SO4.3 Fax 910-486-?'707 Phone.; 910I 4.33-3300 Wilmington 127 Cardinal Dr, Wilmington, NC 2840 5-2845 Fax: 910-350-2004 Phone; 91:0 796-7215 715- 721 mai Moore 610 E., Center Ave., Suite 301 Mooresville, , NC 281.15 Fax: 704 ,663-6040 Phone: 764 663. 1699 Winston-Salem 45 W. Banes Mall Rd, Winston-Salem, NC 27105 Fax: 336-776-9797 Phone: 336-776-9'8,00 e 704 40 10696 actht,y noted, r understood and will abide by NC AC 08G .0204 land /4rc",lintl to tiaa sea r'rtaa result in Raleigh 3800 Barrett Dr. Raleigh, NC 2760 Fax, 919•571-4718 Phone: 919-791-4200 4/`2t?rF ignition Form Tray (r"r:ar, °`teas et Facility Name: Duke Energy -Marshall Name: Certificate 'Fyne: On Erna ri Address: Signature: earn Station BACKUP ORC r.. ,n, rd" rn BACKUP ORC Permit #; N00004 87 `k Phone: it; Eve Date° t certify that my des. r!lricr Lora cr l rrs: _ul as ra tr r in es ¢ansibie Charge f a tits ftar.:aY,rtyn0ted, l .u,nderrstond and wiai ralaaa e try he rules and regulations pertaining to the responsibilities of the OR r s sit forth in 15r7 NCAC 08G .0204 and to dose cap r'es taasc'plinar %Actions by the VVrat r Pollution Control system Operators (Cr ificrataaa r Commission, -47i- r 8 20 BACKUP ORC Pwrit full Name: e: rtiftte 'type: . S ill Address: Signature„ certi,N that 1 u€ t'cr° tt) my ryesignatinrl 05 0 Back-up up Opero tot rrc Per" rrstb the rules and regrsleations pertwnrng to the itis pansibalities a; Disciplinary Actions by the Water Pollution C:ontrio/ System t)p rotors Cr r tifico Print lull Narale: erfificate 'Type: Select kt'ail Address: Signature: tificate Grade: Select ➢Vork Phiene: to ft. Effective Date: ty nrtta°. l arc tSA NCAC 086 .,0204 anti failing to dos': Ar'7 Cora➢nrrhtitan7.'�, Work Phone: Certificate #; 'e Date ' i certify that t agree to my designation -uta Operot rn lra staaansible t hwgn for the ft callty noted. P understand and will wade by the rules and regulations pertaining to the responsibilities of tice ORC as set forth ari 15A NCAC 08o _0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control Systems Operators Certa'fire tara,n Commission,' Ptosea1::'Jrg Bell, Wes From: La Sala, Joseph Scott <Joseph.LaSala@duke-energy.com> Sent: Wednesday, September 27, 2017 4:55 PM To: SVC DENR.certadmin Cc: Bell, Wes; Scruggs, Don; Philips, Greg; Loveland, Brad P Subject: Marshall Steam Station - Change of ORC, Permit #NC0004987 Attachments: ORC Change 9272017.pdf Dear Sir or Madam: Please find the attached Water Pollution Control System Operator Designation Forms for Marshall Steam Station's wastewater permit (no. NC0004987), for the wastewater system located at 8320 E NC Hwy 150, Terrell, North Carolina in Catawba County. Duke Energy has received notification from the NCDEQ regarding reclassification of the wastewater system to Bio- Wastewater I and Physical/Chemical I status effective June 1, 2017. In response, Duke Energy is submitting this update and change of Operator of Responsible Charge within 120 days of the new classification, pursuant to 15A NCAC 08G .0201(3)(b)(i), North Carolina Administrative Code. Please contact me at the below phone number if you have any questions regarding this submittal and change of ORC for Marshall Steam Station. Thanks, Scott //ape At 0,eae Sr. EHS Professional I Marshall Steam Station Office 828.478.7820 I Mobile 904.631.8042 8320 East NC HWY 150 Terrell, NC 28682 joseph.lasala cr.duke-energy.com DUKE ENERGY. CA[O It1A5 1 DUKE ' ENERGY, Date: /72 7 J/ To: s- 7ee,b4qi Fax: 7 64 .$ j3 Coh/o Company: ,�` Phone: -70 11 75.6 3 i From: s—cale Fax: cF�� ,7e. 777 c Location:Ai cs--5 -� - Company: Duke Energy Phone: ? ? 4/7 e 7E.20 Number of pages including this cover page: 5 Subject: /q 4je Acti/54`c9(.19,) -- 1aer`/42I Li9eF? This facsimile contains information which (a) may be LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) is intended only for the use of the Addressee(s) named above. If you are not the Addressee, or the person responsible for delivering this to the Addressee(s), you are hereby notified that reading, copying or distributing this facsimile is prohibited. If you have received this facsimile in error, please telephone us immediately. • DUKE Ne ENERGY, Date9/27// To: W p �--®C Fax: 57 17 - 7 f5 _ D.7 2,6 Company: ��.� Phone: From: C--- / 4q. /G. Fax: F L 7c� 7 7-7 6 Location: 1/ gi\d, Company: Duke Energy Phone: Fe56-7F Number of pages including this cover page: 5 Subject: 01QC CAI /1/6-1Y'i C9'1bq )6Le7-A1,=7I 44 /1/c 0°0 y 07 This facsimile contains information which (a) may be LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) is intended only for the use of the Addressee(s) named above. If you are not the Addressee, or the person responsible for delivering this to the Addressee(s), you are hereby notified that reading, copying or distributing this facsimile is prohibited. If you have received this facsimile in error, please telephone us immediately. WATER POLLUTION CONTROL SYSTEM OPERATOR DESIGNATION FORM (WPCSOCC) NCAC 15A 8G .0201 Press TAB to enter information Permittee Owner/Officer Name: Duke Energy Carolinas, LLC Mailing Address: 8320 East Hwy 150 City: Terrell Email Address: ricksoper@duke-energy.com Signature: Facility Name: Duke Energy- Marshall Steam Station County: Catawba State: NC Phone: 828-478-7600 Zip: 28682 Permit # NC0004987 YOU MUST SUBMIT A SEPARATE FORM FOR EACH TYPE AND CLASSIFICATION OF SYSTEM: Facility Type: WVV Facility Grade: OPERATOR 1N RESPONSIBLE CHARGE (ORC) Print Full Name: Gregory P. Phillips Certificate Type: ViIW Certificate Grade: I Email Address: greg.phillips@duke-energy.com Signature: Work Phone: 828 478-7647 Certificate #: 13347 Effective Date: 911-zQ/7 1 certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Donald L. Scruggs Certificate Type: WW Work Phone: 704 400-3005 Certificate Grade: Il Certificate it: 10696 Email Address: don.scruggs@duke-energy.com Signature: Effective Date: f! 7 ;0/7 "I certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 1SA NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Mail, fax or email ORIGINAL to: WPCSOCC, 1618 Mail Service Center, Raleigh, NC 27699-1618 Fax: 919-715-2726 Email: certadmin@ncdenr.gav Mail or Fax Asheville Fayetteville Mooresville Raleigh a COPY to: 2090 US Hwy 70 ' 225 Green St, Suite 714 610 E. Center Ave., Suite 301 3800 Barrett Dr. Swannanoa, NC 28778 Fayetteville, NC 28301-5043 Mooresville, NC 28115 Raleigh, NC 27609 Fax: 828-299-7043 Fax: 910-486-0707 Fax: 704-663-6040 Fax: 919-571-4718 Phone: 828-296-4500 Phone: 910-433-3300 Phone: 704-663-1699 Phone: 919-791-4200 Washington Wilmington Winston-Salem 943 Washington Sq. Mall 127Cardinal Dr. 45 W. Hanes Mall Rd. Washington, NC 27889 Wilmington, NC 28405-2845 Winston-Salem, NC 27105 Fax: 252-946-9215 Fax: 910-350-2004 Fax; 336-776-9797 Phone: 252-946-6481 Phone: 910-796-7215 Phone: 336-776-9800 Revised 412016 WPCSOCC Operator Designation form (continued) Page 2 Facility Name: Duke Energy -Marshall Steam Station Permit #: NC0004987 `BACKUP'_ORC Print Full Name: Joseph Scott La Sala Certificate Type: WW Certificate Grade: 1 Email Address: joseph,lasala©a duke-energy.com,I Signature: Work Phone: 828-478-7820 Certificate #:1005114 Effective Date: /f 'z f f 1 certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." .BACKUP ORC Print Full Name: Certificate Type: WIN Email Address: Signature: Certificate Grade: 1 Work Phone: Certificate #: Effective Date: "l certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution, Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Signature: Certificate Grade: Select Work Phone: Certificate #: Effective Date: "I certify that I agree to my designation as a Back-up Operator in Responsible Charge far the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as forth in 15A NCAC 08G.0204 and foiling to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Signature: Certificate Grade: Select Work Phone: Certificate #: Effective Date: "1 certify that! agree to my designation as a Backup Operator in Responsible Charge for the facility noted. l understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 1SA NCAC 08G .0204 and failing to do so can result in DisciplinaryActions by the Water Pollution Control System Operators Certification Commission." Revised 4r2015 WATER POLLUTION CONTROL SYSTEM OPERATOR DESIGNATION FORM (WPCSOCC) NCAC 15A 8G .0201 Press TAB to enter information Perrnittee Owner/Officer Name: Duke Energy Carolinas, LLC Mailing Address: 5320 East Hwy 150 City: Terrell Email Address: rick.roper@duke-energy.com Signature: Facility Name: Duke Energy- Marshall Steam Station County: Catawba State: NC Phone: 828-478-7600 Zip: 28882 Date: Permit # NC0004987 YOU MUST SUBMIT A SEPARATE FORM FOR EACH TYPE AND CLASSIFICATION OF SYSTEM: Facility Type: PC Facility Grade: `QPERATOR,IN'RESPONSIBLE. CHARGE (ORC) Print Full Name: Gregory P. Phillips Certificate Type: PC Certificate Grade: I Email Address: greg.phillips@duke-energy.com Work Phone: 828 478-7647 Certificate #: 28197 Signature: p ,,,�_ P P. Effective Date: 7_29_20/7 "I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. ! understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Donald L. Scruggs Certificate Type: PC Certificate Grade: I Email Address: don.scruggs@duke-energy.com Work Phone; 704-400-3005 Certificate #: 27892 Signature:0.01,4e47 Effective Date: 72744/7 "I certify that I agree to my designation os o Back-up Operator in Responsible Charge for the facility noted. f understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NC4C 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Mali, fax or email ORIGINAL to: Mail or Fax a COPY to: WPCSOCC, 1618 Mail Service Center, Raleigh, NC 27699-1618 Asheville 2090 US Hwy 70 Swannanoa, NC 28778 Fax: 828-299-7043 Phone: 828-296-4500 Washington 943 Washington Sq. Mall Washington, NC 27889 Fax: 252-946-9215 Phone: 252-946-6481 Fax: 919-715-2726 Email: certadniin@ncdenr.gov Fayetteville 225 Green 5t., Suite 714 Fayetteville, NC 28301-5043 Fax: 910-486-0707 Phone: 910-433-3300 Wilmington 127 Cardinal Dr. Wilmington, NC, 28405-2845 Fax: 910-350-2004 Phone: 910-796-7215 Mooresville 610 E. Center Ave., Suite 301 Mooresville, NC 28115 Fax: 704-663-6040 Phone: 704-663-1699 Winston-Salem 45 W. Hanes Mall Rd_ Winston-Salem, NC 27105 Fax; 336-776-9797 Phone: 336-776-9800 Raleigh 3800 Barrett Dr., Raleigh, NC 27609 Fax: 919-571-4718 Phone: 919-791-4200 Revised 412016 WPCSOCC Operator Designation Form (continued) Page 2 Facility Name: Duke Energy -Marshall Steam Station Permit #: NC0004987 BACKUP ORC Print Full Name: Joseph Scott La Sala Certificate Type: PC Certificate Grade: 1 Email Address: joseplasala@duke-energy.co Signature: Work Phone: 828 478-7820 Certificate #: 1002443 Effective Date: 9/i2//f 7 "I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and foiling to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Certificate Grade: Select Work Phone: Certificate #: • Signature: Effective Date: "? certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 1SA NCAC 08G.0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Certificate Type: Select Email Address: Signature: Certificate Grade: Select Work Phone: Certificate #: Effective Date: "I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. ! understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so con result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." BACKUP ORC Print Full Name: Work Phone: Certificate Type: Select Certificate Grade: Select Certificate #: Email Address: Signature: Effective Date: "1 certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 1SA NCAC 08G .0204 and failing to do so can result In Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Revised 42016 �a DUKE �: ENERGY® August 4, 2017 Mr. Jeff Poupart, Section Chief NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Paul Draovitch Senior Vice President Environmental, Health & Safety 526 5. Church Street Mail Code: EC3XP Charlotte, NC 28202 (980)-373-0408 RECEJVED/NCI] ENR/DWR AUG 14 2017 WQROS MOORESVILLE REGIONAL OFFICE Subject: Owner Affiliation and Facility Contacts for North Carolina NPDES Correspondence Duke Energy NPDES Permitted Facilities Dear Mr. Poupart: As discussed with you by Richard Baker and Shannon Langley on July 5, 2017, Duke Energy has recently noted an increased number of documents and correspondence from your agency being directed to the attention of incorrect staff persons for our NPDES permitted facilities. A few recent examples include the annual NPDES inspection report for the Mayo Steam Station and a Notice of Violation for the Cape Fear plant being sent to the Vice President of Harris Nuclear Plant; as well as correspondence for the Allen Steam Station sent to the South Carolina Director of Environmental Policy. In each case, this has led to delays in the permitted facility receiving information and impacts our ability to provide time sensitive responses to the Department of Environmental Quality (DEQ). Duke staff have discussed this situation with DEQ staff in the central and various regional offices. Based on our conversations and a review of information captured in your BIMS system, we believe the best way to address this is with the following included information: 1. A single name/ownership change form to request that the "owner affiliation" for entities Duke Energy Progress, LLC (DEP) and Duke Energy Carolinas, LLC (DEC) be updated with my contact information. There appear to be numerous obsolete contacts listed as "owner contact persons" in your BIMS database- that field can be updated to include my name and the others removed. 2. The "permit billing contact person" should be updated for all facilities to name Cynthia Winston, Manager, 410 S. Wilmington Street, NCRH15, Raleigh NC 27601. She can be reached at (919)546-5538 and cynthia.winston@duke-energy.com. 3. The "facility contact person" for each facility should reflect the Station Manager at the site. A list of current Station Managers for all DEP and DEC facilities is attached to this correspondence. 4. The fields for "permit contact person" and "persons with signatory authority" have been recently updated as part of the e-dmr registration process and appear accurate as of this time. Based on this information, I would envision that general correspondence applicable to more than one Duke Energy facility, such as groundwater information or other programmatic issues, should be directed Mr. Jeff Poupart August 4, 2017 to my attention, while station specific communication should be directed to the Station Manager for the site. Duke Energy will continue to routinely update the DEQ in a timely manner when facility contacts change. If you think it would be helpful, we would be available to meet with your staff to discuss the best way to assure accurate delivery of correspondence. We are providing copies of this letter to each of the regional office supervisors responsible for NPDES permit oversight. If there are any questions relating to this request please contact Anne Pifer at (980)-373-1609 or at anne.pifer(alduke-energy.com. Sincer PI Draovitch Senior Vice President Duke Energy Environment Health and Safety Attachments Cc: Bob Sledge/NCDEQ 1617 Mail Service Center Raleigh, NC 27699-1617 Landon Davidson/NCDEQARO 2090 US Highway 70 Swannanoa, NC 28778 David May/NC DEQ WaRO 943 Washington Square Mall Washington, NC 27889 Corey Basinger/NC DEQ MRO 610 East Center Ave, Suite 301 Mooresville, NC 28115 Jim Gregson/NC DEQ WiRO 127 Cardinal Drive Ext. Wilmington, NC 28405 Sherri Knight/NCDEQ WSRO 450 West Hanes Mill Rd, Suite 300 Winston-Salem, NC 27105 Trent Allen/NC DEQ FRO 225 Green Street, Suite 714 Fayetteville, NC 28301-5095 Danny Smith/NC DEQ RRO 1628 Mail Service Center Raleigh, NC 27699-1628 Bethany Georgoulias Stormwater Program, NCDEQJ DEMLR 1612 Mail Service Center, Raleigh, NC 27699-1612 Anne Pifer/Duke Energy FileNet FACILITY CONTACTS (STATION MANAGERS) FOR DUKE ENERGY FACILITIES - AUGUST 4, 2017 - - OwnerName . - - - . "Facility Name - .. Station Type: - • N_ PDES Stormwater PermitNumlier, .. _ - -, NPDES Wastewater , 'Permit Number. , . " General -C Permit. •. � 'Number �_' Facility Contact ' .. - - - - _ -- - FacilityCoontact'Address' - - - - Duke Energy Carolinas, LLC Allen Coal NC5000546 NC0004979 Brent Dueltt, Station Manager 253 PLANTALLEN RD, EELMONT NC 28012 Duke Energy Progress, LLC Asheville Coal/CT _ NCS000575 NC0000396 Garry A. Whisnant, Station Manager 200 CP&L DRIVE, ASHEVILLE NC 28704 • Duke Energy Carolinas, LLC Bear Creek Hydro NCG500124 Preston H. Pierce, General Manager 165 BAD CREEK R0, SALEM SC 29676 Duke Energy Carolinas, LLC Beiews Creek Coal NCS000573 NC0024406 Regina! D. Anderson, Station Manager 3195 PINE HALL ROAD, BELEWS CREEK NC 27009 Duke Energy Progress, LLC Blewett Falls Hydra NCG500190 Michael T. Brlssle, General Manager 257 DUKE LANE, STANLEY NC 28164 Duke Energy Carolinas, LLC Bridgewater Hydro NCG500102 Mic ha el T. Brissle, General Manager 257 DUKE LANE, STANLEY NC 28164 Duke Energy Progress, LLC Brunswick Nudear NC5000590 • NC0007064 William R. Gideon, Site VP 8470 RIVER RD. SE, SOUTHPORT NC 28461 Duke Energy Carolinas, LLC Bryson Hydro NCG500129 Preston H. Pierce, General Manager 165 BAD CREEK RD, SALEM SC 29676 Duke Energy Caralinas,LLC Buck Coal/CT NC0004774 Henry A. Botkins, Station Manager 13E15DUKEVILLE ROAD, SAALISBURYNC28146 Duke Energy Progress, LLC Cape Fear Coal/CT NC5000574 N00003433 lssa J.7arzar, Station Manager 411 FAYETTEVILEL STREET, RALE1GH NC 27601 Duke Energy Carolinas, LLC Cedar Cliff Hydro NC6500125 Preston H. Pierce, General Manager 165 BAD CREEK RD, SALEM 5C 29676 Duke Energy Carolinas, LLC Cliffside Coal NCS000571 NC000.5088 Dave Barnhardt, Station Manager 573 DUKE POWE ROAD, MOORESBORO NC 28114 Duke Energy Carolinas, LLC Cowans Ford Hydro NCG500139 Michael T. Brlssle, General Manager 257 DUKE LANE, STANLEY NC 28164 Duke Energy Carolinas, LLC Dan River Coal/CT _ NC5000572 N00003468 Lawrence D. Sparks, Station Manager 864 5 EDGEWODD RD, EDEN NC 27288 Duke Energy Progress, LLC Harris/HEEL Nudear NC0039586 Benjamin C. Waldrep, Site VP 400 5 TRYON ST, CHARLOTTE NC 28202 Duke Energy Progress, LLC Lee/Wayne County Coal/CC NC0003417 Jeffery D. Hines, Station Manager 1199 BLACK JACK CHURCH R0, GOLDSBORO NC 27530 Duke Energy Carolinas, LLC Lincoln C7 NC0080781 Henry A. Batklns, Station Manager 1385 DUKEVILLE ROAD, SAUSBURY NC 28146 Duke Energy Carolinas, LLC Lookout Shoals Hydro NCG500I20 Ml hael T. Brlssle, General Manager 257 DUKE LANE, STANLEY NC 28164 Duke Energy Progress, LLC Marshall Hydro NCG500591 Preston H. Pierce, General Manager 165 BAD CREEK RD, SALEM SC 29676 Duke Energy Carolinas, LLC Marshal! Coal _ NCS000548 NC0004987 Rick R. Roper, Station Manager 8320 EAST NC HWY 150, TERRELL Nt 28682 Duke Energy Progress, LLC Mayo Coal NC5000580 NC0038377 Tom Copolo, Station Manager __ _ 10660 BOSTON ROAD, ROXBORO NC 27574 Duke Energy Carolinas, LLC McGuire Nudear NCS000020 NC0024392 • Steven D. Capps, Site VP 12700 HAGERS FERRY RD, HUNTERSVILLE NC 28087 Duke Energy Carolinas, LLC Mission Hydro NCG500128 Preston H, Pierce, General Manager 165 BAD CREEK RD, SALEM SC 29676 Duke Energy Carolinas, LLC Mountain Island Hydro NCG500131 Michael T. Brlssle, General Manager 257 DUKE LANE, STANLEY NC 28164 Duke Energy Carolinas, LLC Nantahala Hydro NCGS00136 Preston H. Pierce, General Manager 165 BAD CREEK R0, SALEM 5C 29676 Duke Energy Carolinas, LLC Oxford Hydro NCG500119 Michael T.8rissle,General Manager 257 DUKE LANE, STANLEY NC 28164 Duke Energy Carolinas, LLC _ Rhodhiss — Hydro CC— NCG500108 Michael T, Brlssle, General Manager 257 DUKE LANE, STANLEY NC 28164 Duke Energy Progress, LLC Richmond County NCG500594 Thomas Hanes, Station Manager 198 ENERGY WAY, HAMLET NC 28345 Duke Energy Carolinas, LLC Riverhead Coal/CT NC5000549 NC0004961 Tim Hill, Station Manager 400 S TRYON ST, CHARLOTTE NC 28202 Duke Energy Carolinas, LLC Rockingham CT NC0086665 Lawrence D, Sparks, Station Manager 864 S EDGEWOOD RD, EDEN NC 27288 Duke Energy Progress, LLC Roxboro Coal NC5000581 NC0003425 Jason V. Haynes, Station Manager 1700 DUNNAWAY ROAD, SEMORA NC 27343 Duke Energy Progress, LLC Sutton Coal/CT NC0001422 Jesse E. Huntley, Station Manager 801 SUTTON STEAM PLANT RD, WILMINGTON NC 28401 Duke Energy Carolinas, LLC Tennessee Creek Hydro Hydro _ NCG500123 Preston H. Pierce, General Manager 165 BAD CREEK R0, SALEM 5C 29676 Duke Energy Carolinas, LLC Thorpe NCG500127 Preston H. Pierce, General Manager 165 BAD CREEK RD, SALEM SC 29676 Duke Energy Progress, LLC Tillery Hydro NCG500189 Michael T., Brlssie, General Manager 257 DUKE LANE, STANLEY NC 28164 Duke Energy Carolinas, LLC Tuskasegee Hydro NCG500126 Preston H. Pierce, General Manager 165 BAD CREEK RD, SALEM SC 29676 Duke Energy Carolinas, LLC Tuxedo Hydro NCGSC0110 Michael T. Brlssie, General Manager 257 DUKE LANE, STANLEY NC 28164 Duke Energy Progress, LLC Walters -_-__ Weatherspoon Hydro Coal/CT _ _ _ NC5000589 NCG500188 Preston H. Pierce, General Manager 165 BAD CREEK RD, SALEM SC 29676 Duke Energy Progress, LLC NC0005363 Thomas Hanes, Station Manager 198 ENERGY WAY, HAMLET NC 28345 • Water Resources ENV1RONF1ENTAL OUALiTY ROY COOPER MICHAEL S. REGAN S. JAY ZIMMERMAN PERMIT NAME/OWNERSHIP CHANGE FORM I. CURRENT PERMIT INFORMATION: Permit Number: NC00 / / / / or NCG5 1 / / 1 A9 Duke Energy Progress LLC and Duke Energy Carolinas LLC 1. Facility Name: II. • NEW OWNER/NAME INFORMATION: 1. This request for a name change is a result of: a. Change in ownership of property/company b. Name change only X c. Other (please explain): Owner Affiliation Contact person 2. New owner's name (name to be put on permit): No change to permit holder 3. New owner's or signing official's name and title: Paul DraOVItCh, P.E. (Person legally responsible for permit) Senior Vice President, EH&S (Title) 4. Mailing address: 526 South Church Street -EC3XP City: Charlotte State: NC Zip Code: 28202 Phone: ( ) 980-373-0408 E-mail address: Paul.Draovitch@duke-energy.com THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION UNLESS ALL OF THE APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL. REQUIRED ITEMS: 1. This completed application form 2. Legal documentation of the transfer of ownership (such as a property deed, articles of incorporation, or sales agreement) [see reverse side of this page for signature requirements] State of North Carolina [ Environmental Quality 1 Water Resources 1617 Mail Service Center' Raleigh, NC 27699-1617 919 807 6300 919-807-6389 FAX httpsa/deq.ne.gnv/aboutldivisio ns/waler-resources/water-resources-perm itslwastewater-branch/npdes-wastewater-permits NPDES Name & Ownership Change Page 2 of 2 Applicant's Certification: Paul Draovitch , attest that this application for a name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required su orting information and attachments are not included, this application package wil a re rned'as1n omplete. Signature: \ t - --O.- \ Date: '-f4` ! L7 THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION & MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDDRESS: NC DEQ / DWR 1 NPDES 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Version 7/2016 `a+ direct r any ponders argue«6n5 m [e and Co m %once to Brad Loveland A 7O 9 5GJ2 Sin Rick Roper General Manager m Marshall Steam Station Power Generation Carolinas West Cr: ENV5O2 Erlergy LIPS TRACKING: NCIDEQ (Mooresvillo Regional) qI± c:» m Station NPDES Perm Bell, Wes -- From:- - : - Loveland; Brad P <Brad1oveland@duke-energy. n>- - Sent: Thursday, May 18, 2017 4:11 PM To: - Pitner, Andrew Cc: Bell, Wes Subject: Marshall Steam Station Follow Up Andrew, 1 wanted to follow-up on the notification made via phone earlier today. At approximately 8:30am on 5/18/17, Marshall Steam Station noted overflow of <1000 gallons of clear sanitary wastewater onto the pavement as a result to a blocked gravity drain pipe. The water then collected into an adjacent wastewater drain, conveyed to the #1 yard sump and then pumped to the ash basin (NPDES Outfall 002). Marshall Station has restricted use of bathroom facilities, sinks and showers immediately following the discovery of the overflow and alternate bathroom facilities have been provided. Repairs to the sewage line are underway. A 5 day follow up notification will be made per the NPDES permit NC0004987. Let me know if you have questions or need additional information please let me know. Thanks, Brad DUKE ENERGY& Brad Loveland, CPESC, CFM EHS CCP- Permitting and Compliance Environmental Health and Safety Department 526 South Church Street f EC13K I Charlotte, NC 28202 Office: 980 373 2820 Cell: 704 609 5637 1 IKE March 21, 2017. 1t„ lti 0frefir t'l. Poupaui Df '( .. I:y "VR, ltr 7 Maail Se Raleigh, North Carolina 7( 99- i 61 ` Subject: Seep Pollutant Analysis Report submittal in accordance witb Permit. ("'audition Marshall Steam Station - NPDES Permit NU0004987 - Catawba (. Duke F.ratrgy° �a ata�s'#e af1 Steam Swoon 329 East NC flv 4 150 "1`t.rrelt. NC" Pursuant to Part 0, Con flitiaara a\:f30 demonstrate that the rater quaaiit st<uida contravened d in the receiving stream. This rlc°uatanstraati i effectieAe date of the subject permit using in -stream s areal monitoring prcrgraataa. This submittal fulfills the retlttiremetat. TWO Seeps at Marsha ll Steam Star permitted as effluent leis to Li. body (Lake Norr i) obtained from February 2017, is provided as an aaua Outfit!! 102 do not Casten: erns' tcautr°arse A.(29). If you have any questions, 704-600- 6,l7. l'°A°fe a fb ere Sincerely, General Manager Ill Marshall Steam Station Attachment Nurtnan. ✓'; s+ ta�tb�ra vases m Outfit!! 10 to uent.s listed in pet s aa..a:aaairad tar be seal atnplang to suits t:aations ut f c:.<iaa"Ua '(`here resitlts eta hu ,1.luv° requited to (29) are not days oldie Alt the 1:3IF' nd i tit .an. ath of t.he reee urn that esa f rrrtrxrtsoarme nI 016 and and onditi•Ora www.duke-energy.com Cc: Serge: C. t t ttil ctr NC'1)F 'IF )) 1617 N1ai1 Sc:t ac a ; . nt Ra l.eicA, NC 2 6<)t)_ lt` 17 Cc: We » Bell -NC l.)WR MRU 61 f11~ East Center' Are e Suite 301 'Moores eal] ^, NC 28115 Filet et Ric tat '%1 Baker %1)atke Energy) Brad Loveland tI)uke Fnert_= Scou La Sala (1.)ttl,e I tter� 1 Shannon l..angle) (1)ttke Eno' NCDEQ-DWR,) - IZ:8955X4 3 ttDl<S11 (NC D Q-Per fitting) _ 1Z8955X40965St.17„ .R. )) _ 1 /,`i955,\-1()„t9(5 63 Duke Energy t$ rrsIrca/t Steam Station 8 29 fat NC Hwy t: 150 Terra, NC 2'6J www.duke- erterno ATTACI-1MENT 1 INSTREAM MONITORING RESULTS MARSHALL STEAM STATION NIMES Permit NC0004.897 Condition A.(30) Iciompliance demonstration MARCH 21,. 2017 il 1 0 1i**Cilliiin$*00: 0Oke Ncrrnpri_ .Marshall SS 2/1/2010 DCnknstreen frAamhe 55 8/2/2iT16 — iirrel3r° Isilart hall SS Marshall SS 211/201' / ,Ocovniareari - 6 S • 0,0 ' el l <1 UpstrroT .ion _OA 67.0,9,,o_ 1,00 . A • ,, 10.04(l, • 2s,o'i4A/L' ' <i:::1 68, 0071 : 11i1 1 70 _ 7011, :7,0- 771 • 002 — , ,,,,,,:;< ,,,A'A_ : ,,, A OtwAvad" :, 55,2.4:::10,., A "'0**.:.:.1'.1610.01,d .' 011solved 1531f, DisAorved ..1 RAmierable , Qhs.:011;e1t. A'505 ,:' :1t.14;i114t7,7:si'< ' 1'8)14: rt.lie,' AtIlit l 44,1141,014441 1155,q,t,P1,41_411111511 lil (PO4 ' 15.5 " t.' 515.411145., '51 Atli , 56111114/5) idil4 1 'ti.tgiV fliat, :irtrit0, ' , Arit<' I A "14AA1C " 0.02 <.1 : <A Al. 'T 7 22222— . cadmh4m< . <1 f..5 2' "150AN2.,, t#A 4.?,_ :,:, 65 41 . , ..T.,,,,,—,5. throrrvuoi 5, co;,:" 3A . „ <1, <1 <1 NiA !1.2<.0 rill< N/A I 5 urd'i ,, ,.0,87 el 3,70 1,80 el 01 .7,1 7' 2 7.4. 2 ;23222 2 2222:22 1 254 2.22 22222i/A 2 22242Xi 220 .02 .122362712222 2222 2 .4.',7 MaiAlhallSS Marshall SS yostroxin IlIcArstream t — 0,02 002 el cll <1, 2.22122 221 .2.22222 02? . .0,1 47 1.,,,,,,_ 707 1.• 7 4,7 ii,1 0,4 ,,— .,, I,c13 00i, 011,11 0.8.3 1 i <1 'rng/L , Milligrams per liter (parts. ner million) icigil_ : tnicrogram$ per liter Ipactii per Pillion1 nil - nelograrp5, per liter (parts per trilliani WA 7 riP applicable 29 Standard for anolv2e0 conititunnt 113_, 1 .S 1111 • • creor,ed b 13/1L page 3 mf www<loyAlmor.gyA:Arn Loveland Brad P<B/ad.Loveland@dmke'energy.cmm` Thursday, April 27'2O17]:Z4PM Pitner, Andrew [hernikov, Sergei RE: Marshall Sewage Lagoon Closure Marshall Sewage Lagoon C|osurexjocx:Letter from Duke to K1RO re closure ofdomestic ww lagoon Oct 272OI6.pdf Andrew' | wanted Toupdate you tolet you know this project iscomplete, Marshall isconnected toCity Sewer and the sewage lagoon �s permanently closed, Attached are photnstaken during the process of this dosure operation to use as a reference. Let, meknow ifyou need anything further, Thanks, Brad DU E Brad Loveland, [PES[ [FM EHSC[P-Permitting and [ompUance EnOronnnenta|Health and Safety Department 526 South Church Street | E[1]K ! Charlotte, N[ 28202 Office: 9803732820 Fromm:Pitner Andrew andrev»piLoer@ncdenr.gov] Sent: Wednesday, March 2Z,Z01712:O5PM To: Loveland, Brad P Subject: RE: Marshall Sewage Lagoon Closure Exercise caution, — This is an EXTERNAL email.— ---- NOT —r~~-'' ��_^ ��r�� � click links ��~� �� ,�f�^�� ^� attachments . .��[l�� ��� C�/���� H�m� from ��������� ���M����� ��� ������K���^~o�u ������U _ _ __. ._ -_. � � unexpected email. .,� - You sure about that date? From: Loveland, BradP[����8�.L�|an Sent: Wednesday, March 22'2Q17lJ�[BPk4 To�P|tner,Andrew <andrew,pitmer@ncdengq2v> Subject: Marshall Sewage Lagoon Closure Andrew, | had ManshaUSteam Station mail you a package that was delivered n|youroffice on I0/27/I7, This was the closure letter submitted for sewage lagoon at Marshall, | can't find it anywhere and hoping you cou|d help me out. Thanks in advance, DUKE ENERGY Brad Loveland, CPESC, CFM EHS CCP - Permitting and Compliance Environmental Health and Safety Department 526 South Church Street I EC13K I Charlotte, NC 28202 Office: 980 373 2820 Cell; 704 609 5637 2 Marshall Sewage Lagoon Closure Lagoon solids removal Containr ent for dewatering bag Pressure washing liner Solids Removal Dewatering bag inside container Pressure washer Liner Removal Removing top soil from curbing Partially filled Inlet pipe removal Partially filled Dewatering bag in containment Continuing to fill the lagoon Completely filled and compacted patting soil PrDUKE ENERGY. CAROLINAS October 20, 2016 ECE ELEVEN EDE :N WEENT4 VIECE,i(E:; MOORESViLLE EoRIMA L it Attn: Andrew Pitner North Carolina Dept. of Environmental Quality 610 East Center Ave Suite 301 Mooresville, NC 28115 Subject: Duke Energy Carolinas, LIC, Notice of Closure of Wastewater treatment system Marshall Steam Station (NC0004987) — Catawba County Dear Mr. Pitner, EFIS CCP Environmental Programs Duke Energy 526 South Church Street Charlotte, NC 28202 Mailing Address; EC t3K P,C). Box 1006 Charlotte, NC 28201-1006 In accordance with the requirements of Part III of NPDES wastewater permit NC0004987, Duke Energy is hereby providing notice of closure for a wastewater treatment system at Marshall Steam Station in Catawba County, NC. Duke Energy will be closing the Biological Wastewater Lagoon System used to treat domestic wastewater. Upon closure of the wastewater lagoon, domestic wastewater from the Steam Station will be sent to the municipal system owned and operated by Catawba County. Start-up and commissioning of the planned wastewater lift station to send wastewater to the municipal system of Catawba County is scheduled for December 2016 with proposed wastewater lagoon closure activities scheduled to begin in January 2017. The domestic wastewater lagoon closure activities include a complete Site Reclamation. Remaining lagoon liquid will be sent to a publically owned treatment works (POTW) for disposal. Sludge removal and disposal will also be discharged to a permitted facility. No sludge will be left in place. The lagoon liner will be disposed of at a permitted facility. The area where the domestic wastewater lagoon is currently located will be re -purposed to locate components for handling bottom ash to comply with various environmental requirements. Please direct any correspondence or questions concerning the Marshall Steam Station NPDES Permitting and Compliance to Brad Loveland @ 704-609-5637. "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. I am aware that there are significant penalties for submitting false information, Including the possibility of fines and imprisonment for knowing violations." Rick Roper General Manager III Marshall Steam Station Power Generation Carolinas West CC: Brad Loveland Scott LaSala Y7' ENFRCY SOUIr SOcet; NR::, 26202 ,BacoNN,B, B e NC a32 -1 Cg.)13 October 12, 2016 North Carolina Dept. of Environmental Quality Attention: Central Files Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Duke Energy Carolinas, LLC Removal of outfall Marshall Steam Station (NCS000548) - Catawba County In accordance with Part II of the above reference Stormwater Permit Duke Energy Carolinas, LLC is hereby notifying DEQ in writing that former Stormwater Outfall 001/001A has been deemed an effluent channel, therefore monitoring requirements for storm water activity will no longer apply. Effluent channel designation was determined by NCDEQ and noted in the NPDES Waste Water Permit NC0004987 as ()Wall 102. Monitoring will continue per Waste Water Permit requirements effective 10/1/2016 See attached map showing Storm Water Outfall, Waste Water Outfall and Effluent Channel Please direct any correspondence or questions concerning the Marshall Steam Station NPDES Permitting and Compliance to Brad Loveland ( 704-609-5637. "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 an 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.'" Rick Roper General Manager III Marshall Steam Station Power Generation Carolinas West attachment CC: Brad Loveand Tina Woodward Erika Tuchbaum UPS Tracking - DWR IZ895X40399.4)8347 4-1.7,11 • , r 1 1 1,f t if Gicioste:,earth 1 2'1 3 STORMWATER OUTFALL MAP swopiiswooiALocation Marshall Steam Station Catawba,County, NC Permit #NCSQ00548 Legehd Ash Pond indiistrial SW Outfall 001/001A NPDESWW Outfall 102 cto Outfall Flow Path ustri a I .SW I I 0 () lino 1,3, co! P D ES \V \V @Leal' I 02 A N 1 00 ft UPS CampusShip: Shipment Label Page 1 of 1 UPS CampusShip: View/Print Label 1. Ensure there are no other shipping or tracking labels attached to your package. Select the Print button on the print dialog box that appears. Note: If your browser does not support this function select Print from the File menu to print the label. 2. Fold the printed label at the solid line below. Place the label in a UPS Shipping Pouch. if you do not have a pouch, affix the folded label using clear plastic shipping tape over the entire label. 3. GETTING YOUR SHIPMENT TO UPS Customers with a Daily Pickup Your driver will pickup your shipment(s) as usual. Customers without a Daily Pickup Take your package to any location of The UPS Store®, UPS Access Point(TM) location, UPS Drop Box, UPS Customer Center, UPS Alliances (Office Depot® or Staples®) or Authorized Shipping Outlet near you. Items sent via UPS Return Services(SM) (including via Ground). are also accepted at Drop Boxes. To find the location nearest you, please visit the Resources area of CampusShip and select UPS Locations. Schedule a same day or future day Pickup to have a UPS driver pickup all your CampusShip packages. Hand the packae to any UPS driver in your area. UPS Access Point THE UPS STORE 516-DRIVER HWY MOORESVILLE ,NC 28117 FOLD HERE w O 1111111 ILLING: P/P https://www.campusship.ups.com/cship/create?ActionOriginPair=default PrintWindo... 10/11/2016 From: To: Subject: Date: UPS Quantum View La Sala, Joseph Scott UPS Delivery Notification, Tracking Number 1Z8955X40399478347 Friday, October 14, 2016 10:43:43 AM *** Exercise caution. This is an EXTERNAL email. DO NOT open attachments or click links from unknown senders or unexpected email. *** Your package has been delivered. Delivery Dater Delivery Time: Friday, 10/14/2016 10:38 AM At the request of DUKE. ENERGY CAROLINAS, this notice alerts you that the status of the shipment listed below has changed. Shipment Detail Tracking Plumber: Ship To: UPS Service: Number of Packages: Weight: Delivery Location: Signed by: Reference Number 1: Reference Number 2: OIT L1®I 1X8955)(40399478347 Attn: Central Files NC. Dept. of Environmental Quality 3905 REEDY CREEK RD RALEIGH, NC 27607 US UPS GROUND 1 1.0 LBS MAIL ROOM WILLIS MS00 20003 Get the UPS My Cholce.app for Facebook Download the UPS mobile apo Bell, Wes From: Sent: To: Subject: Just FYI... Pitner, Andrew Tuesday, November 15, 2016 12:10 PM Costner, Brandy F; Bell, Wes; Basinger, Corey FW: Follow up request to October 6 letter From: Poupart, Jeff Sent: Thursday, November 10, 2016 4:02 PM To: Langley, Shannon <Shannon.Langley@duke-energy.com> Cc: Chernikov, Sergei <sergei.chernikov@ncdenr.gov>; Baker Jr, Richard E <Richard.Baker@duke-energy.com>; Pitner, Andrew <andrew.pitner@ncdenr.gov>; Loveland, Brad P <Brad.Loveland@duke-energy.com> Subject: RE: Follow up request to October 6 letter DWR concurs with Duke Energy's interpretations below as restated from October 6 letter regarding; floating pumps and intakes, DIP sampling frequency, flow measurement and sampling coordinates. 1. The Marshall NPDES permit condition limiting ash basin drawdown to three feet above the ash refers to the point where the pump suction is located and not three feet above the ash in the entire basin. Additionally, any references to "floating pumps" in our permits refers to "floating intake suction points". Duke requests concurrence with this interpretation and that this interpretation be applicable to all of our NC coal fired facilities. 2. Duke requests concurrence that once the permit is issued, that separate samples referenced in the DIP are not required as Duke will be taking seep samples monthly/quarterly under the terms of the permit. Also, in accordance with our SOP's and terms developed in the DIP, Duke will not be taking any seep samples under the NPDES permits within 72 hours of a rainfall event of greater than 0.5 inches or within 48 hours of a rainfall event of greater than 0.1 inches. 3. Duke request that DEQ review and approve the alternate flow measurement procedure provided as an attachment to our Oct 6 letter and this email, as a method that can be used to measure seep flows at any of our sites with requirements to measure and report seepage flows. 4. Duke requests that concurrence with the sampling coordinates identified in our attached letter. As discussed in our letter, these points are the areas determined to be representative access points within the designated effluent channels. From: Langley, Shannon jmailto:Shannon.Langlev@ duke-energy.comj Sent: Wednesday, October 19, 2016 8:25 AM To: Poupart, Jeff <jeff.poupart@ncdenr.gov> Cc: Chernikov, Sergei <sergei.chernikov@ncdenr.gov>; Baker Jr, Richard E<Richard.Baker@duke-energy.com>; Pitner, Andrew <andrew.pitner@ncdenr.gov>; Loveland, Brad P <Brad.Loveland@duke-energy.com> Subject: Follow up request to October 6 letter Jeff, i As discussed in our 10/11/16 meeting, this email note is provided to request concurrence with several items listed in the attached letter sent to you dated October 6, 2016. This email is intended to make it easier to respond. Duke requests concurrence with the following items: 1. The Marshall NPDES permit condition limiting ash basin drawdown to three feet above the ash refers to the point where the pump suction is located and not three feet above the ash in the entire basin. Additionally, any references to "floating pumps" in our permits refers to "floating intake suction points". Duke requests concurrence with this interpretation and that this interpretation be applicable to all of our NC coal fired facilities. 2. Duke requests concurrence that once the permit is issued, that separate samples referenced in the DIP are not required as Duke will be taking seep samples monthly/quarterly under the terms of the permit. Also,. in accordance with our SOP's and terms developed in the DIP, Duke will not be taking any seep samples under the NPDES permits within 72 hours of a rainfall event of greater than 0.5 inches or within 48 hours of a rainfall event of greater than 0.1 inches, Duke request that DEQ review and approve the alternate flow measurement procedure provided as an attachment to our Oct 6 Metter and this email, as a method that can be used to measure seep flows at any of our sites with requirements to measure and report seepage flows. 4. Duke requests that concurrence with the sampling coordinates identified in our attached letter. As discussed in our letter, these points are the areas determined to be representative access points within the designated effluent channels. Thanks. Please let me know if any of these items need clarification or further discussion. Shannon 0C $, wnn©n Otantyla# Lead Environmental Specialist Duke Energy Corporation. Office: (919) 546-2439 Cell: (919) 219-0905 410 South Wilmington 15th floor, Raleigh, NC 27601 DUKE 2 DUKE ENERGY. CAROLINAS is C I 3P i=',C,i l c5r i€ ii Ic. fit?6. NC 28201-1006 October 20, 2016 Attn: Andrew Pitner North Carolina Dept, of Environmental Quality 610 East Center Ave Suite 301 Mooresville, NC 28115 Subject, Duke Energy Carolinas, LLC. Notice of Closure of Wastewater treatment system Marshall Steam Station (NC0004987) — Catawba County Dear Mr. Pitner, In accordance with the requirements of Part III of NPDES wastewater permit NC0004987, Duke Energy is hereby providing notice of closure for a wastewater treatment system at Marshall Steam Station in Catawba County, NC, Duke Energy will be closing the Biological Wastewater Lagoon System used to treat domestic wastewater. Upon closure of the wastewater lagoon, domestic wastewater from the Steam Station will be sent to the municipal system owned and operated by Catawba County, Start-up and commissioning of the planned wastewater lift station to send wastewater to the municipal system of Catawba County is scheduled for December 2016 with proposed wastewater lagoon closure activities scheduled to begin in January 2017. The domestic wastewater lagoon closure activities include a complete Site Reclamation. Remaining lagoon liquid will be sent to a publically owned treatment works (POTW) for disposal. Sludge removal and disposal will also be discharged to a permitted facility, No sludge will be left in place. The lagoon liner will be disposed of at a permitted facility. The area where the domestic wastewater lagoon is currently located will be re -purposed to locate components for handling bottom ash to comply with various environmental requirements. Please direct any correspondence or questions concerning the Marshall Steam Station NPDES Permitting and Compliance to Brad Loveland @ 704-609-5637, "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervlsa`on in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based an 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 of fines and imprisonment for knowing vioiatiorts. Rick Roper General Manager III Marshall Steam Station Power Generation Carolinas West CC: Brad Loveland Scott LaSala Bell, Wes From: Pitner, Andrew Sent: Monday, July 11, 2016 2:02 PM To: Loveland, Brad P Cc: Bell, Wes; Basinger, Corey Subject: RE: Marshall #1 Yard Sump - Permitted Civil Overflow, 7/7/16 The highlighted info appears to be accurate; no additional steps need to be taken. Thanks for the heads up. Andrew From: Loveland, Brad P [mailto:Brad.Loveland@duke-energy.comj• Sent: Friday, July 08, 2016 8:53 AM To: Pitner, Andrew <andrew.pitner@ncdenr.gov> Subject: FW: Marshall #1 Yard Sump - Permitted,Civil Overflow, 7/7/16 Good morning Andrew, My understanding is that this is non reportable but rather just an FYI. See highlighted areas below and please advise an any additional steps that need to be taken if any. By the way, were you able to visit Riverbend yesterday? Thanks, Brad DUB:. EN Brad Loveland, CPESC EHS CCP- Permitting and Compliance Environmental Health and Safety Department 526 South Church Street I EC13K I Charlotte, NC 28202 Office: 980 373 2820 Cell: 704 609 5637 From: La Sala, Joseph Scott Sent: Thursday, July 07, 2016 3:07 PM To: Loveland, Brad P Cc: Scruggs, Don; Roper, Rick R; Tuchbaum, Erika B;. Parks, Scott; Garver, Scotty P; Young, Sherri Wegner; Cornelius Jr, Ernest J; Hynes, Jennifer Dilworth Subject: Marshall #1 Yard Sump - Permitted Civil Overflow, 7/7/16 Brad, Per our discussion this morning,'I am following up with a summary of this morning's permitted civil overflow from the #1 Yard Sump at Marshall. At 0430 I received a phone call from operations indicating that the civil overflow alarm had been achieved and that the gate valve (newly installed Priority 1 improvement) needed to be opened to allow permitted discharge. After verifying with operations that no visible oil sheen was present on the sump water, I approved their opening of the gate valve which initiated time To for the civil discharge. I arrived onsite and inspected the sump at 0510. The gate valve was found in the open position and there was no water discharging to the civil effluent pipe. Estimates from operations indicate that flow was less than 0.5-inch over the civil overflow wall while discharging. After meeting with operations team, I returned to the sump at 0520 and noted flow 1 over the civil wall beginning to return. Discharge remained less than 0.5-inch in height for three additional episodes totaling 10 minutes before pumping was re-established by Scott Garver and Scott Parks. We estimate the maximum civil overflow time to be 50 minutes with a maximum measured elevation over the wall at 0.5-inch. The #1 yard sump is rated at 69.81 gpm discharge at 0.5-inch in water above the wall. Consequently, our maximum estimated discharge from this morning's overflow is 3,500 gallons. l$ rtd tr n a ntl eacNng the F i r d sch thr. In response to this permitted discharge, I am uploading the flow rate (0.0035 GPD) to our To my understanding, there is no additional reporting to the state required and, per our discussion, en environmental went. I le a e confirm thatthis I accurate. roe I appreciate everyone's help this morning. Thanks, Scott J. Scott La Sala, P.G. Sr. ENS Professional Marshall Steam Station Office 828,478,7820 I Mobile 904,631.8442 8320 East NC HWY 150 Terrell, NC 28682 Joseph.LaSala@Duke-Energy.com DUKE 'les 'ENERGY. cm CA N A KEG E RGY A. OL1 A5 March 14, 2016 North Carolina Department of Environment and Natural Reso Division of Water Resources Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1.617 Subject: Duke Energy Carolinas, LLC Marshall Steam Station (NPDES Permit NC000iiii0 Groundwater Quality Monitoring: Compliance Report Form Dear Sir or Madam: Duke Energy Carolinas, LLC. (DEC) sampled the twelve compliance wells around the ash basins at the Marshall Steam Station (NPDES Permit 'NC0004987) on February 4, 2016, Attached are two copies o the ,results on DEC, approved electronic version of Form GW-59CCR. All values reported on the attached reports are dependent on the accuracy of approved analytical methods used to measure parameters. Should you have questions regarding this report, please contact Tyler Hardin at (980) 373-5697, f ceriif, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with o system designed to assure that qualified personnel properly gather and evaluate the information submitted, Based on my inquiry of the person ar 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 ther-r are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Sincerely, Rick R, Roper GM I! Regulated Stations Marshall Steam Station cc: Debra Watts E E E GY CAR O l,, iN A S Addresses: State of North Carolina Department ofEnvironmental Quality Division of Water Quality Information Processing Unit 16,17 Mail Service Center Raleigh, North Carolina 27699-1617 Debra Watts Division of Water Resources North Carolina Department of Environment& Quality 512 N. Salisbury Street Raleigh, NC 27699-1363 919-807.6338 Internal cc: Kim Witt Tyler Hardin Ed Sullivan Christopher Randazzo Tim Russell Tim Hunsucker Scott La Sala Erika Tuchbaum Rick Roper Catherine Butler NCDEQ UPS - 1.Z8955X403977O5327 DWATTS UPS- 1Z8955X40399640938 GROUNDWATER QUALITY MO I tTO COMPLIANCE REPORT F RM F° t tit I9 utt (if difterent�; Fcll1t t AdtIr+PSs: 1 ae61 itet9t Ifi Irulsws lattd surf MeasuN'n q, Pal� Well Diameter Screen Top ,,ti be Sere en ttdettaEn If Relative Aitposirrsrri Point Elevation Specrff't: Co asd - fitelti (tidttlS4 Water" Le Analysis Date AT TIME OF SAR' 3PUN n(82S4 FS - Tmxtll C%- Staa (703f8 CI, Chtorvd ( 941 As - ArSenit. [02DCR2) 504-SuHa1e(t4S) Nitrate NO3() ns N (00E20) CdCadmium (01027) Cr, Chromium (01034) Cu - Copper (01042) .. he • Froat (D 104S) &#p w SiercurX490l ... ts4ea,,., +Tang:"ct+ese (410SS) .....,_ � AIkallnity. (00410) �...�_ A(01105 ) 012) tS-7cffie'Suzsp.Solids stadium (01.087) IISA-21. per fA s$fuarizetl IMACs noted on the A Iti tlrs.0 dnat P S" k�..rC7a3PY�Y'dat E"C rt1rcted rtsxr%alltorod: and field acidified: Water Resources ENVIRONMENTAL QUALITY March 4, 2016 CERTIFIED MAIL 7013 2630 0001 8998 4247 RETURN RECEIPT REQUESTED Mr. Harry K. Sideris, Senior Vice President - Environmental, Health & Safety Duke Energy 526 South Church Street Mail Code EC3XP Charlotte, North Carolina 28202 PAT MCCRORY Governor DONALD R, VAN DER VAART secretary S. JAY ZIMMERMAN Director MRCS MOORESEELLE REGIONAL OPPICE SUBJECT: Notice of Violation and Recommendation of Enforcement for Violations of NCGS 143-215.1(a) — Unauthorized Discharge of Wastewater NOV-2016-DV-0098 Duke Energy Carolinas, LLC — Marshall Steam Station WVVTP Catawba County Dear Mr, Sideris: This letter transmits a notice of violation and recommendation of enforcement for violations of the subject general statute. Review of submitted documents and other records indicates there are unauthorized discharges of wastewater from the area around the subject facility's coal ash basin, Please note that additional violations may be identified should these discharges be found to have caused exceedances of water quality standards, This letter is to advise you that the Division of Water Resources (DWR) is considering the issuance of civil penalties to address these violations. If you have any explanation or mitigating information that you wish to present that may be considered during the determination of any civil penalty assessment, you are requested to present such materials to DWR within thirty (30) days of your receipt of this letter. Please send your response to the attention of Bob Sledge at the letterhead address. Thank you for your prompt attention to this matter. If you have any questions about this letter, please contact me at (919) 807-6309. Sincerely, Jeffrey O. Poupart Water Quality Permitting Section Chief cc: Mooresville Regional Office — Water Quality Regional Operations NPDES Compliance/Enforcement Files Central Files State of North Carolina I Environmental Quality I Water Resources 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 919-707-9000 Division of Water Resources November 19, 2015 iO 1DUlvi To: Michael Parker Water Quality Regional Operations, MRO Through: Cindy A. Moore From: Supervisor, Aquatic Toxicology Branch (ATB) Carol Hollenkamp �++ Quality Assurance fi er, Aquatic Toxicology. Branch (ATB Subject: Whole effluent toxicity test results Duke Energy Marshall Steam Station NPDES Permit # NC0004987/002 Catawba County The aquatic toxicity test using grab samples of effluent discharged from the Duke Energy Marshall Steam Station has been completed. Duke Energy Marshall Steam Station has a permitted effluent discharge of 5.3 million gallons per day (MGD) entering the Catawba River (7Q10 of 60 CFS). Whole effluent samples were collected on November 3rd and November 5th by Wes Bell and facility representative Scott LaSala for use in a chronic Ceriodaphnia dubia pass -fail toxicity test. This test passed. Toxicity test information follows. Test Type 3-Brood Ceriodaphnia dubia chronic pass fail Test Concentrations 12% Test Result Pass Control Survival 100% Control Mean Reproduction 30.7 neonates Test Treatment Survival 100% Treatment Mean Reproduction 32.9 neonates First Sample pH 7,05SU First Sample Conductivity 959 micromhos/cm First Sample Total Residual Chlorine <0.10 mg/L Second Sample pH 7.25 SU Second Sample Conductivity 1045 micromhos/cm Second Sample Total Residual Chlorine <0.10 mg/L Test results for the above samples indicate that the effluent would not be predicted to have water quality impacts. These samples were split with Environmental Testing Solutions, Inc. The test conducted by Environmental Testing Solutions, Inc., also passed. Please contact us if you have any questions or if further effluent toxicity monitoring is desired. We may be reached at (919) 743-8401. Basin: CTB32 cc: Central Files Wes Bell (MRO) Aquatic Toxicology Branch Water Sciences Section Bell, Wes From: Hollenkamp, Carol Sent: Thursday, November 19, 2015 1:22 PM To: Parker, Michael Cc: Bell, Wes; Moore, Cindy Subject: Toxicity Test Reports Attachments: Duke Allen Steam Station_1015.pdf; Duke Marshall Steam Station_1115.pdf Attached are the toxicity test reports for Duke Energy Allen and Marshall Steam Stations. If you have any questions, please let me know. Thanks, Carol Hollenkamp Environmental Specialist Aquatic Toxicology Branch/Water Sciences Section/Division of Water Resources Department of Environmental Quality 919-743-8440 office Carol.hollenkamp@ncdenr.gov Mailing: 1623 Mail Services Center, Raleigh, NC 27699-1623 Physical: 4401 Reedy Creek Road, Raleigh, NC 27607 othfng Compares.--,. .,. Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. 1 North Car©l na Department of Environmental Qua. Pat McCrory Donald van derVaart Governor Secretary November 10, 2015 Mr. Rick Roper, General Manager III Duke Energy Carolinas, LLC 8320 E NC 150 Hwy. Terrell, North Carolina 28682 Subject: Compliance Biomonitoring Inspection Duke Energy Carolinas/Marshall Steam Station NPDES Permit No. NC0004987 Catawba County Dear Mr. Roper: Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on November 3, 2015 by Mr. Wes Bell of this Office. Please inform the facility's Operator -in - Responsible (ORC) of our findings by forwarding a copy of the enclosed report. The results of the effluent toxicity samples collected on November 3 and 5, 2015 will be forwarded to you under separate cover. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bellOencdenr.gov. Sincerely, Michael L. Parker, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure: Inspection Report cc: MSC 1617-Central Files/Basement Catawba County Health Department Mooresville Regional Office Location° 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663%1699 \ Fax: (704) 663-6040 \ Customer Service:1-877-623-6748 Internet: www,ncwaterquality.org An Equal Opportunity \ Affirmative Action Enmptoyer - 30% Recycled/ 10% Post Consumer paper I EPA United States Environmental Protection Agency Washington, Q.C. 20480 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type 1 L.1 2 L=J 3 1 NC0004987 111 121 15111/03 117 18 (o i 19 11.1 201 1 211111II 11IIll1 1111111111111L111 11111111111166 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67 12.Q 70 (d 1 71 ir, I 72 1 ti 1 731 1 174 751 1 I I 1 I 1 180 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Marshall Steam Station NC Hwy 150 Terrell NC 28682 Entry Time/Date 09:20AM 15/11/03 Permit Effective Date 11103101 Exit Time/Date 01:40PM 15/11/03 Permit Expiration Date 15/04/30 Name(s) of Onsite Representative(s)/Tities(s)/Phone and Fax Number(s) 1r1 Gregory Paul Philrps/ORC/828-478-7805/ Joseph Scott La Sala1EHS Professional Sd828-478-7820 /8284787776 Name, Address of Responsible Official/Title/Phone and Fax Number Rick Roper,8320 E NC 150 Hwy Terrell NC 28682/General Manager I111828-478-76001 Contacted No Other Facility Data Section C: Areas Evaluated During Inspection (Check only those areas evaluated) ▪ Permit • Flow Measurement Operations & Maintenance 111 Records/Reports ▪ Self -Monitoring Program 1. Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters • Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspe or(s) Agency/Office/Phone and Fax Numbers Date Wes 8011 MRO WQIf704 663-1699 F_x12192/ 1 / 9 715 Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editians are obsolete. Page# 1 NPDES NCt}o@4987 yrlmo/day 12 15/11/03 Inspection Type 18 t l Se 'a C7: Summary of Finding/Comments (Attach additional sheets of natt'ative and checklists as necessary) Page* 2 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 11103/2015 Inspection Type: Bioassay Compliance Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? III ❑ ❑ ❑ ▪ ❑ ❑ ❑ •❑ ❑ ❑ • ❑ ❑ ❑ 111 ❑ ❑ ❑ Comment: The Division received the permit renewal package on 12/19/2014. No biocides are added to Outfalls 001 and 003 (once through non -contact cooling water). The last compliance evaluation inspection was performed at the facility on 12/18/2013. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? • ❑ ❑ ❑ Is all required information readily available, complete and current? • ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? • ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? • ❑ ❑ ❑ Is the chain -of -custody complete? • ❑ ❑ ❑ Dates, times and location of sampling • Name of individual performing the sampling 111 Results of analysis and calibration � Dates of analysis • Name of person performing analyses • Transported COCs • Are DMRs complete: do they include all permit parameters? •❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ 1 ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24R with a certified operator ❑ ❑II El on each shift? Is the ORC visitation log available and current? • ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? • ❑ ❑ ❑ is the backup operator certified at one grade less or greater than the facility classification? • ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? MOOD Facility has copy of previous year's Annual Report on file for review? ❑ ❑ � ❑ Page# 3 Record Keeping Owner - Facility: Marshall Steam Station Inspectkon Type. Bioassay Compliance Yes No NA NE Comment: The records reviewed durin the in coon were onized nd w it maintained. Di char e Monitorinq`Reports (DMRs) were reviewed for the period September 2014 through,August 2015. No limit. violations were reported and all monitoring frequencies were correct. The facility staff must ensure that the collection and analysis times for the effluent pH measurements (Outfall 002) are documented. No discharges were reported from © utfalls 002A and 002B (yard sump overflows) during the review period. Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at Celsius)? Incubator (Fecal Coliform) set to 44,5 degrees Celsius+l 0,2 degrees? Incubator (B0Q) set to 20.0 degrees Celsius +l- 1.0 degrees? s than or equal to 6.0 degrees Ve No NA NE II ❑0 ■ ❑ ❑ ❑ ❑ ❑ IN ❑ ❑ ❑ IN ❑ ❑ ❑ ■ ❑ Comment: The facility is certified to perform on -site field analyses (pH and temperature) under laboratory certification #5155. Duke Energy's Environmental Services Laboratory. Certification #248 and the contracted services of Sheal Environmental Services tnc. low level mercury) and ETS, Inc. (toxicity) provide analytical support, The pH meter appeared to be property calibrated and documented. This office recommends including the buffer value (following standardization) along with the millivolt reading as part of, the pH meter calibration data. Influent Sampling # Is composite sampling flow proportional? Is sample collected above side streams? Is proper volume collected? Is the tubing clean? # is proper temperature set for sample storage (kept at less than or equal to 6,0 degrees Celsius)? Is sampling performed according to the perrnif? Comment: The subiect permit requires grab samples at the internal Outfatt 004 (F effluent) prior to entering the ash basin. E a uent Sarnlplinq Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? D Yes No NA NE ❑ ❑ � ❑ N. ❑ ❑ ❑ MI 0 El 0 ❑ ❑ ■ ❑ ❑ 0 II ❑ ■ ❑ ❑ 0 eatment system Yes N4 NA N ❑ ❑ ■ ❑ ■ ❑ ❑ 0 • D ❑ ❑ Page# 4 Permit: NC0004987 Inspection Date: 11/03/2015 • Owner - Feallity: Marshall Steam Station Inspection Typo: Bioassay Compliance Effluent Sampling is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: The subject permit requires effluent grab samples. Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Yes No NA NE ❑ ❑ ❑ ❑ ❑MI ❑ ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ ❑ ❑ � ❑ Comment: The ash basin and FGD wastewater treatment system (WTS) appeared to be properly operated and well maintained. The FGD WTS is connected to a computer monitoring system to assist the on -site staff in the operation of the treatment units/processes. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ 0 ❑ Is flow meter calibrated annually? 0 ❑ • 0 Is the flow meter operational? ❑ 0 � ❑ (If units are separated) Does the chart recorder match the flow meter? 0 0 • 0 Comment: Outfall 001 flows are measured by pump curves/logs. Outfall 002 flows are measured by staff guage/elevation readings and supporting flow calculations. The flow measurement system for FGD WTS effluent (Internal Outfall 004) is calibrated/verified annually and was last calibrated/verified on 5/15/2015 by Duke Energy's Instrumentation Group. Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Yes No NA NE II ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: The effluents for Outfalls 001, 002 and 003 appeared clear with no floatable solids or foam. The receiving stream did not appear to be negatively impacted. Fish were observed at the stop loq tower for Outfall 002 and the discharge outfall for Outfall 001. DWR staff split effluent chronic toxicity samples with the facility on 11/3/2015 and 11/5/2015. The results will be forwarded under separate cover. Solids Handlinq_Equipment Is the equipment operational? • Yes No NA NE ❑ ❑ ❑ Page# 5 Permit: NC0004987 Owner • Facility; Marshall Steam Station Inspection Date; 11/03/2015 Inspection Type: Bioassay Compliance Solids Handling Equipment Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Yes No NA NE ▪ ❑ ❑ ❑ • ❑ 1 ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ El 0 El ■ ❑ ❑ ❑ Comment: The FGa WTS is equipped with two operational filter presses; however, these units were not in service at the time of the inspection. The dewatered sludge and fly ash are disposed. at the on -site landfill. The sluiced ash is either disposed in the on -site landfill or reused in the construction market. The gypsum material from the FG© WTS system is also reused by an outside company .(National Gypsum) in the dry wall market Page# 6 Bell, Wes From: La Sala, Joseph Scott <Joseph.LaSala@duke-energy.com> Sent: Thursday, November 05, 2015 12:03 PM To: Bell, Wes Cc: Phillips, Greg Subject: FW: Ash Pond GWR Transmitter Calibration Requirements or recommendation Wes, Per our discussion today, I am forwarding you a response to our inquiries regarding calibration requirements on the basin water level indicator at 002 as well as Prism's quarterly sampling procedure for O&G. A response from the water level indicator vendor (provided below) indicates that this technology does not require calibration once it is emplaced and the output data stream is set relative to the benchmark (spillway tower). What I recommend we do is provide a gauge reading and meter output reading on a monthly form in the file to document that we are verifying accuracy of the indicator. Secondly, l spoke with Prism and the sampling tech indicated to me that the samples are collected directly into a glass jar and they are not using a plastic intermediary container for dipping the grab sample. It was a real pleasure meeting you this week. Please let me know if there is anything else I can help you with. Thanks, Scott J. Scott La Sala, P.G. Sr. EHS Professional i Marshall Steam Station Office 828.478.7820 i Mobile 904.631.8042 8320 East NC HWY 150 Terrell, NC 28682 Joseph. LaSalaaDuke-Energy.com 4 ENGY. C ROLINA5 From: Marshall, Tim Sent: Wednesday, November 04, 2015 7:32 AM To: La Sala, Joseph Scott Cc: Wolfe, Kris S; Marshall, Tim Subject: Ash Pond GWR Transmitter Calibration Requirements or recommendation Scott, See Emerson's response below relative to your question about calibrating the Ash Pond Level transmitter. Let me know if you need anything further. gcsse_ 7IIxr.AGI►1 Marshall Steam Station t Duke Energy Corporation 8320 East NC H ►y 150 Terrell, NC 28682 828-478-7769 office 704-664-0429 cell tirn,marshall(cduke-energy.com DUKE ENERGY. CAROLINAS From: Briani!!icNitta.ernerson,corn [niai0to Brian.McI itt' nerson.com] Sent: Tuesday, November ©3, 2015 11:37 PM To: Marshall, Tim Cc: Wolfe, Kris S; Christenbury, Chris III Subject: RE: GWR Transmitter Calibration Requirements or recommendation #4* Exercise caution, This is an EXTERNAL erroail. DO NOT open attachments or click links fro unknown senders or unexpected email. *** Tim, One of the nice things about radar level transmitters is there is no need to calibrate them. in fact there is no such thing as a radar calibration you couldn't do it even if you wanted to, it's a time of flight measurement, You send out a microwave signal and then you wait for it to come back in. We know how fast microwaves travel (speed of light)so the transmitter just calculates the distance to the product by how Bong it took that signal to come back, So basically the transmitter "re -zeros" every time it sends a pulse, You always restart at "zero time" so there is no way to change that nor would their ever be a reason to. Hope that makes sense, thanks. !IcNitt Emerson Pr Cetl (704) 778-2588 erent From: Marshall, Tim [ma lto:Tim Marshall(a Sent: Tuesday, November 03, 2015 3:31 PM To: McNitt, Brian [PROCESS/RMT/CHAR] Cc: Wolfe, Kris S; Christenbury, Chris III Subject: GWR Transmitter Calibration Requirements or recommendation Importance: High ke energy c9 ] 2 - AGENCY CONTACT MEMORANDUM & Release Notification t as r5©/D Title: Senior Environmental Specialist Department/Facility Name: Environmental Services / Permitting / Compliance Carolina Duke Energy Contact: Robert C Sapp Phone Number: (980) 373-7900 office (980) 219-9990 mobile Regulatory Agency: NC Mooresville Regional Office of DENR (Division of Water Quality) Regulatory Contact: Wes Bell Date/Time of Contact: 08/14/20 0957 Type of Contact: (Check all that apply) Phone Number: 704-663-1699 Agency Inspection wn....ting Telephone Conversation Regulatory Interpretation Other: email Description: This is a courtesy notification of a spill of sump water (process water) to the environment. On August 13, 2015 at 10:15 am Marshall Site Operations was notified of a leak in the "B" water transfer line. The plant was utilizing the "B" (bravo) line as a backup to Yard Sump #2 during scheduled repairs when the transfer line cracked. At no time was any bottom ash in the line as this line was being utilized to transfer water from Yard Sump #2 to Marshall's ash basin under permit. The B line was inspected at 10:00 am prior to the release. At 10:15 am the line was inspected again and the rupture was noted. The pumps were shut off upon discovery of the leak at 10:15 am. The leak was secured at this time and a maximum 15 minutes of leakage is estimated. Approximately 3,000 gallons of sump water was released to the environment. The release came in contact with the environment while gravity draining to the plant's containment system. None of the released water reached the waters of the state. Actions Required: Entity: Marshall Steam Station Entity Type: Fossil Fuel (coal) Power plant Spill Discovered Date and Time: August 13, 2015 at 10:15 Page 1 of 2 AGENCY CONTACT MEMORANDUM & Release Notification Spill Address: Marshall Stearn Station 8320 East NC Hwy 150 City: Terrell State: NC County: Catawba County Directions: Approximately 9 miles west on highway 150 from Mooresville, NC Description: Transfer fine cracked releasing process water to soil Cause of Spill: Crack in Transfer fine What was spilled? Process water from Yard Sump #2 Estimated Quantity Released ('gallons) 3,000 gallons Environmental Mocha Impacted: Soil, Gravel Equipment Type: Size: Manufacturer: Serial Number PCB Determination: If applicable No PCB Is any of the following available?: -Green/Blue Dot? -PCB Concentration < 50 ppm -Manufacturer statement that equipment is non -PCB -Negative Clor-n-oil -Negative Analytical Results Brief description of clean-up operations/emergency response. Who conducted cleanup? Water gravity drained to containment Estimated volume of contaminated media removed. Unknown at this time Date/Time cleanup completed. Ongoing Page 2 of 2 4-1-2014 Bell, Wes From: Sapp, Robert C <Robert.Sapp@duke-energy.com> Sent Friday, August 14, 2015 10:09 AM To: Bell, Wes Cc: La Sala, Joseph Scott; Tuchbaum, Erika; Todd, Shannon; Winston, Cynthia Subject: FW: Written report to NC DENR about spill yesterday Attachments: Report to NC UST SectionAgency Contact and Memorandum and Release Notification for Marshall wastewater spill August 13, 2015.docx Sorry neglected to attach the document. Thanks Robert C. Sapp CHMM, MS Duke Energy Permitting and Compliance Carolinas Environmental Services Duke Energy EC13K 1526 South Church Street Charlotte, NC 28202 office - (980) 373-7900 mobile - (980) 219-9990 fax - (704) 382-6240 Robert.Sapp@duke-energy.com DUKE ENERGY., Whatever your hands finds to do, do it with all your might From: Sapp, Robert C Sent: Friday, August 14, 2015 10:06 AM To: 'wes.bell@ncdenr.gov' Cc: La Sala, Joseph Scott; Tuchbaum, Erika; Todd, Shannon; Winston, Cynthia Subject: Written report to NC DENR about spill yesterday Good morning This is the written report of the spill that I spoke to you on the phone about. Thank you sir for your help on this issue. Thanks Robert C. Sapp CHMM, MS Duke Energy Permitting and Compliance Carolinas - Environmental Services Duke Energy EC13K 1526 South Church Street Charlotte, NC 28202 office - (980) 373-7900 mobile - (980) 219-9990 fax - (704) 382-6240 Robert.Sa0DPd uke-energy.com DUKE ENERGY. Whatever your hands finds to do, do it with all your might 2 DUKE ENERGY. July 7, 2015 North Carolina Department of Environment And Natural Resources Water Pollution Control System Operators Certification Commission 1618 Mail Service Center Raleigh: North Carolina 27699-1618 SUBJECT: Duke Energy Carolinas, LLC Operator in Responsible Charge Back -Up Operator in Responsible Charge Marshall Steam Station — NC0004987 Please make the following changes to your database effective July 1,, 2015. • Gregory P. Phillips — Add as ORC at Marshall Steam Station G Donald L. Scruggs — Delete as ORC at Marshall Steam Station • Donald L. Scruggs — Add as Back -Up ORC at Marshall Steam Station Envirorzmnntal Senii'cijs Duke Energy t326 $butte C,hurcn Street Chearlo`.te, NC2_8202 P'a.iiing A (1ress ;'..41ail Code ECC13KJ P.O. Sox 1006 Charlotte, NC 28201.1006 All other information remains current and no other changes are necessary at this time. Should you require additional information, please contact Steve Cahoon at 919-546-7457. Yours truly, Rick Roper General Manager ill Marshall Steam Station Fossil Hydro Carolinas West Attachment Don Scruggs Rick Roper Greg Phillips Record Type Code: ENV-50-02 Document Number: 8-6 UPS Tracking Number: 1Z X67 601 03 9346 5993 Water Pollution Control System ORC Designation Form WPCSOCC NCAC 15A:08G .0201 General Information: Permittee Owner/Officer Name: Marshall Steam Station Mailing Address: 8320 East NC 150 Hwv. City: Terrell State: NC Zip: 28682 Telephone Number: (828) 478-2121 Signature: Date: 7/?/ Facility lnforrnation: Facility: Marshall Steam Station Permit Number: NC0004987 County: Catawba r SUBMIT A SEPARATE FORM FOR EACH TYPE OF SYSTEM ! Mark (X) Type of Faci lity Class (1 — 4) Class Wastewater Plant Spray irrigation NIA Physical/Chemical X 1 Land Application NIA Collection System Subsurface NIA Operator in Responsible Charge: Print Name: Gregory P. Phillips Certificate Type and Grade: Grade 1 Physical/Chemical Certificate #: 28197 Work Telephone: (828) 478-7647 Signature: Back -Up Operator in Responsible Charge: Print Name: Donald L. Scruggs Certificate Type and Grade: Grade 1 Physical/Chemical Certificate #: 27892 1,3 Work Telephone: (704) 400-3005 Signature:()ifii ( (5r.)" Mail or Fax to: WPCSOCC 1618 Mail Service Center Raleigh, N.C. 27699-1618 Fax: 919/733-1338 • Revised 10/2000 JJ \ Bell, Wes From: Scruggs, Don <Don.Scruggs@duke-energy.com> Sent: Monday, July 20, 2015 1:53 PM To: Bell, Wes Subject: FW: Scanned from a Xerox multifunction device Attachments: Scanned from a Xerox multifunction device.pdf Good talking to you Wes. Please confirm receipt. Don Scruggs Environmental Field Support Carolinas West 704 829-2423 Office 704 400-3005 Cell Original Message ----- From: ms2fladm@duke-energv.com [mailto:ms2fladm@duke-energv.coml Sent: Monday, July 20, 2015 2:43 PM To: Scruggs, Don Subject: Scanned from a Xerox multifunction device Please open the attached document. It was scanned and sent to you using a Xerox multifunction device. Attachment File Type: pdf, Multi -Page multifunction device Location: Marshall 2nd floor - Admin bldg Device Name: MS2FLADM For more information on Xerox products and solutions, please visit http://www.xerox.com Bell, Wes From: Scruggs, Don <Don.Scruggs@duke-energy.com> Sent: Friday, April 17, 2015 1:52 PM To: Bell, Wes Subject: FW: Marshall Sheen Wes, based an observations of Outfall 003 discharge area, we are calling the recent Marshall Station oil spill event complete. Please contact me at the numbers below if questions arise. Thanks, DC14 Seira994 Environmental Field Support Carolinas West 704 829-2423 Office 704 400-3005 Ce1I From: Scruggs, Don Sent: Friday, March 20, 2015 12:44 PM To: 'wes,bell@ncdenr.gov' Subject: Marshall Sheen Wes, just a note to follow up on the sheen we observed on Sunday March 15th at Marshall Steam Station. Booms and pigs were already deployed and in place from the initial spill on Wednesday March 3rd and were successful in confining any observable sheen to a location just south of the intake structure in the vicinity of Outfall 003. A&D Environmental mobilized to the site on Wednesday March 18th and vacuumed the remaining observable sheen. A&D, with the assistance of Regional Utility Services proceeded to flush the roof drain line in an effort the remove any residual oil which may have been hiding out. A&D also worked the adjacent shoreline vacuuming organic material at the water line which may also have trapped some oil. One assumption is that the rain event on Saturday March 14th flushed out some residual oil in the roof drain line. The lake level also rose a few inches over the weekend and organic material which had previously contacted oil was exposed to the water and possibly resulted in a release of the slight sheen. We are constantly monitoring this area and our discharge outlet and there is no observable sheen currently. However, we are reluctant to call the event over, due to the possibility of another rain event or pond level increase resulting in an observable sheen and requiring NRC notification. Your guidance related to this situation would be appreciated. Vila S Environmental Field Support Carolinas West 704 829-2423 Office 704 400-3005 Cell i Bell, Wes From: Scruggs, Don <Don.Scruggs@duke-energy.com> Sent: Friday, March 20, 2015 12:44 PM To: Bell, Wes Subject: Marshall Sheen Wes, just a note to follow up on the sheen we observed on Sunday March 15th at Marshall Steam Station. Booms and pigs were already deployed and in place from the initial spill on Wednesday March 3rd and were successful in confining any observable sheen to a location just south of the intake structure in the vicinity of Outfall 003. A&D Environmental mobilized to the site on Wednesday March 18th and vacuumed the remaining observable sheen. A&D, with the assistance of Regional Utility Services proceeded to flush the roof drain line in an effort the remove any residual oil which may have been hiding out. A&D also worked the adjacent shoreline vacuuming organic material at the water line which may also have trapped some oil. One assumption is that the rain event on Saturday March 14th flushed out some residual oil in the roof drain line. The lake level also rose a few inches over the weekend and organic material which had previously contacted oil was exposed to the water and possibly resulted in a release of the slight, sheen. We are constantly monitoring this area and our discharge outlet and there is no observable sheen currently. However, we are reluctant to call the event over, due to the possibility of another rain event or pond level increase resulting in an observable sheen and requiring NRC notification. Your guidance related to this situation would be appreciated. a Sa€499-4 Environmental Field Support Carolinas West 704 829-2423 Office 704 400-3005 Cell 1 DUKE ENERGY: ,AR LINA;: July 21, 2014 State of North Carolina Department of Environment and Natural Resources Division of Water Resources Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Subject, Duke Energy Carolinas LLC — Marshall Steam Station Groundwater Quality Monitoring — Compliance Report Form Duke En tlarrs'Jiull 8329 East NC (trrel1 NC 286 X28-178 7700 y 150 Please find attached the completed Groundwater Compliance Report Form (GW-59CCR) for the Marshall Steam Station ash basin (NPDES Permit #NC0004987)e As required by the GW-59CCR form, parameters exceeding the generic standards published at 15A NCAC 02L 0202(g-h) have been bolded. However, per 15A NCAC 02L.0202(b), where naturally occurring substances exceed the generic standards, the appropriate 2L standard shall be the naturally occurring concentration as determined by the Director, All values reported on the attached reports are dependent on the accuracy of approved analytical methods used to measure parameters. Should you have questions regarding this report, please contact me at (704) 382-4309. Sincerely,. Allen Stowe Water & Natural Resources cc: Debra Watts www.duke-energy.corn GROUNDWATER QUALITY MONITORING: COMPLIANCE REPORT FORM ;Mail original' .,and 1;zopy-! to. -, DEPARTMENT OF ENVIRONMENT & NATURALRESOURCES DIVISION OF WATER QUALITY.:INFORMATION PROCESSING UNIT 1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 Phone (919) 7334221 , FACILITY INFORMATION Please Print Clearly or Type Permit Type: PERMIT Number: TYPE OF PERMITTED OPERATION Expiration Facility Name: Permit Name (if different): Facility Address: Marshall Steam Station NPDES Date: I 4/30/2015 Duke Energy Carolinas, LLC 4 _ NC0004987 8320 East NC 150 Hwy. BEING MONITORED (street) Ash Impoundment Groundwater Terrell I NC 28682 County Catawba (city) Contact Person: Well Location/Site Name: (State) (Zip) Alien Stowe Telephoned 704-382-4309 Marshall Ash Basin No. of wells to be sampled: ' 12 (from Permit) r Monitoring Well Construction lnforn ation` Units Well ID Number (From Permit} MW-4 MW-40 MW-10S MW-10D MW-115 row-noMW-12S MW-12D MW-13S MW-13D MW-14S MW-14D MW- MW- MW- Well Depth (ft below land surface] ft 48.04 60.82 26.91 85.43 _ 51.42 90.55 22.47 95.79 18.45 46.03 43.95 59.84 Measuring Point (toc) (ft above land surface] ft 2.16 3.36 2.30 2.04 2.70 2.55 2.63 2.51 2.43 2.52 • 2.92 2.76 Well Diameter in 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 Screen Top [ft below land surface] ft 38.04 55.82 11.91 80.43 36.42 85.55 7.47 90.79 3.45 41.03 28.95 54.84 Screen Bottom (ft below land surface] ft 48.04 60.82 26.91 85.43 51.42 90.55 22.47 95.79 18.45 46.03 43.95 59.84 Relative Measuring Point Elevation _..... ft 866.42 866.74 772.05 772.04 884.99 884.67 871.86 871.88 847.49 847.05 811.291 811.43 ._Samp.haag Inform and FieldAnalysis a. ,.... CHECK IF DRY WELL AT TIME OF SAMPLING 0 DRY ❑ DRY ❑ DRY ❑ DRY ❑ DRY ❑ DRY ❑ DRY 0 DRY ❑ DRY 0 DRY 0 DRY ❑ DRY 0 DRY 0 DRY ❑ DRY 15A-2L Units MW-4 MW-4D MW-10S MW-10D MW-115 MW-11D MW-125 MW-12D MW-135 MW-13D MW-14S MW-14D MW- MW- MW- Sample Date 06/04/2014 06/04/2014 06/04/2014 06/04/2014 06/04/2014 06/04/2014 06/04/2014 06/04/2014 06/04/2014 06/04/2014 06/04/2014 06/04/2014 Water Level [ft below measuring pt.] (82546) .. . ft 36.30 36.11 14.57 14.22 43.51 43.12 9.72 10.66 4.75 2.33 36.17 36.76 Volume of Water pumped/bailed gal 3.25 14.75 2.55 5.35 0.70 2.55 1.20 30.50 0.55 5.20 1.30 6.10 Temperature (00010) deg. C 16.2 16.0 15.8 15.8 17.1 17.0 15.3 15.4 15.1 15.2 16.1 15.8 Odor (00085) None None None None None None None None None None None None Appearance Normal Normal Normal Normal Normal Normal Normal Normal Normal Normal Normal Normal Specific Cond - field (00094) umhos/cm 46 79 17 60 42 53 16 65 87 91 749 597 pH - field (00400) 6.5 -8.5 SU 5.5 5.9 5.1 6.3 6.0 - 6.7 5.1 6.1 6.0 6.1 5.4 5.5 Laborato.ry'Information Laboratory Name. Sample Analysis Date Duke Energy Analytical Laboratory Certification # NC DENR 0 248 Samples for metals were collected unfiltered: 0 Yes ❑ No and field acidified: ID Yes ❑ No June 5 - 17, 2014 15A-2L Units MW-4 MW-4D MW-105 MW-10D MW-115 MW-11D MW-125 MW-12D MW-13S MW-13D MW-145 MW-140 MW- MW- MW- Sb -Antimony (01097) 1 ug/I <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 As - Arsenic (01002) 10 ug/1 <1 <1 <1 <1 ' <1 <1 <1 <1 <1 <1 <1 <1 Ba - Barium (01007) 700 ug/I 48 42 46 20 33 62 22 25 41 45 26 36 B - Boron (01022) 700 ug/I <50 <50 <50 <50 <50 <50 <50 <50 <50 <50 3190 2750 Cd - Cadmium (01027) 2 ug/I <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 CI - Chloride (00940) 250 mg/I 2 1.5 1.1 1.4 2.6 2 1.3 1.1 4,3 4.6 44 16 Cr - Chromium (01034) 10 ug/I <5 <5 <5 <5 <5 7 <5 <5 <5 <5 <5 <5 Cu - Copper (01042) 1 mg/I <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 Fe - Iron (01045) 300 ug/I 190 25 616 137 92 287 34 478 221 18 393 85 Pb - Lead (01051) 15 ug/I <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 Mn - Manganese (01055) 50 ug/I 9 <5 24 7 <5 <5 11 11 6 <5 77 40 Hg - Mercury (71900) 1 ug/I <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 I Ni - Nickel (01067) 100 ug/I <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 55 26 Nitrate (NO3) as N (00620) 10 mg/I <0.023 <0.023 <0.023 0.35 0.54 0.26 <0.023 <0,023 1.5 1.6 0.15 0.1 Se - Selenium (01147) 20 ug/I <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 6.25 4.35 504 - Sulfate (00945) 250 mg/I 0.11 1.4 0.11 2.9 0.37 1.3 0.74 7.6 0.47 0.55 280 230 Tl - Thallium (01059) 0.2 ug/I <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 TDS -Total Diss. Solids (70300) 500 mg/I 46 83 <25 79 46 75 25 82 91 95 580 450 Zn - Zinc (01092) 1 mg/I <0.005 <0.005 0.011 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 0.009 0.011 <0.005 AI -Aluminum (01105) ug/I N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/Ar N/A BOLD values equal or exceed the corresponding 2L standard • f certifycertifY that, to theibest of my knowledge and belief, the information submitted in this.report'isanle,.accurate, and complete„aridahat,the taboratory'analyticaL.data was produced using approved methods ofanalysis by a D1NQ=certified for knowing violations: 1 latiorafory i amraviare;that ahere are significant ' 7/( S ZON penalties for submitting -false infi rmatiori , Including the°possibility of fines'and,imprisonment Brian R Weisker, GM Ill. - Marshall Steam Station „„41511111111117 Permittee (or Authorized Agent) Name and Title -Please print or type Signature of Permittee (or Authorized Agent) Date GW-59CCR 01/2011 Water Resource ENVIRONMENTAL QUALUY March 31, 2016 Michael Ruhe Duke Energy Carolinas LLC PO Box 1006 Charlotte, NC 28201-1006 PAT: CC ORY Dt NA'LD R. VAN DER VAART Subject: NPDES Electronic Reporting Requirements and Sixty Day Notice of Minor Modification of the NPDES Permit Marshall Steam Station NPDES Permit Number: NC0004987 Dear NPDES Permittee: S. JAY ZIMMERMAN The U.S. Environmental Protection Agency (EPA) recently published the National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule, The rule requires NPDES regulated facilities to report information electronically, instead of filing written paper reports. The rule does not change what information is required from facilities. It only changes the method by which information is provided (i.e., electronic rather than paper -based). EPA is phasing in the requirements o key milestones, are: ule over a 5-year period, The two phases of the rule, and their Phase 1—Starting on December 21, 2016, regulated entities that are required to submit Discharge Monitoring Reports (DMRs) will begin submitting these reports electronically, instead of on paper. If you are currently reporting your DMR data electronically using eDMR, then you simply need to continue reporting in the same way as you are now, The key change is that, starting on December 21, 2016, electronic reporting of DMRs will be required, instead of voluntary. Phase 2 —Starting on December 21, 2020, regulated entities that are required to submit certain other NPDES reports will begin submitting these reports electronically, Instead of on paper. Reports covered in the second phase include Notices of Intent to discharge in compliance with an NPDES general permit, Sewer Overflow/Bypass Event Reports, and a number of other NPDES program reports. For more information on EPA's NPDES Electronic Reporting Rule, visit http://www2,epa.gpv/com,plianceJ»na6l-natiional-pollutant-discharge-elimination-system n ,des- electranie-reportin,g-rule. For more information on electronic reporting to NC DWR, visit de nc.gov/about/div s o_ ns,/watwer-resources/edmr•n des-electronicrt ng or contact Vanessa 'nuel at 919-807-6392 or via email at Vanessa ManuelPncdenr,g 1. StAte tafNoatlr Carolina l Environmental (�xcaltty l aiet llesou 161 I Mail a °vu 7C Center i :Raleigh, North Carol' 77699-1611 919 707 9000 Sixty Days' Notice of Minor Modification of the Subject NPDES Permit ^ The NPDES Electronic Reporting Rule requires authorized NPDES programs to incorporate electronic reporting requirements into NPDESpermits beginning December ZI,2O15. Under the new rule, the electronic reporting process supersedes the paper reporting process outlined in your existing permit. To bring your permit up-to-date with the new reporting requirements, this letter serves to notify you that in sixty days your NPIDES permit will be modified to incorporate the new electronic reporting requirements, The modification will require electronic reporting in place of paper -based reporting. Electronic reporting will berequired beginning asindicated above for Phases land 2reporting, Please attach the enclosed NPDES PermitStandard Conditions Port 8/—Addendum to your permit. This permit modification becomes effective onJuly 1, 2016. All other terms and conditions in the original permit remain unchanged and in full effect, This modification is issued pursuant to the requirements of North Carolina General Statute 143-215A and the Memorandum of Agreement between North Carolina and the U.S, Environmental Protection Agency dated October l5,ZOO7. If any parts contained in this modification are unacceptable to you, then you have the right to file a petition for a contested case with the Office of Administrative Hearings within thirty (30) days following receipt of this letter. This petit�on must conform to the requirements of Chapter 150B of the North Carolina General Statutes, Petitions must be timely filed with the Office of Administrative Hearings, Post Office Drawer 1166G,Raleigh, North Carolina 276Q4, |fyou donot file apetition within the required time, the agency decision shall befinal and binding. |fyou have questions concerning this permit modification, please contact Tom Be\nickattelephone number gl9'8O7-639U. SincereIy, {l for S.Jay Zimmerman, R6 Enclosure: NPDES Permit Standard Conditions Part III - Addendum Cc: NPDESFUe Central Files NCDENR Marshall Notification Mr. Parker, Duke Energy would like to make a follow up report from the discovery of the back -pass bolter wash water reported to you in October 2014. In order to identify potential risks associated with routine station operation, Marshall Steam Station personnel were conducting camera inspections to ensure that piping and drainage flowpaths were correctly identified. A courtesy notification, prior to the testing activities, was given to your office on November 24, 2014. During the testing it was discovered that a condensate line that infrequently receives demineralized water from the boiler does not discharge to the ash basin as previously understood. The testing showed that this line discharges through Outfall 003 and hence to Lake Norman. The condensate fine, which discharges demineralized water during stages of the start-up process, is only used after extended outages. This is generally only once every one to two years. The demineralized water is treated with a small quantity of Ammonia for pH control. We believe that this infrequent discharge does not contain ash residue or any other pollutants. Upon learning this, station personnel immediately instituted a corrective action which entailed no further use of the line for start-up chemistry control. A study is being conducted to identify a permanent solution to close the line. During the time the station was conducting the verification tests several other issues were identified. One issue identified was the overflow of the Water Tower. The site has a water tower used for fire protection water. The water tower contains untreated lake water. The tower may occasionally overflow during filling, sending some of the lake water in the tower back to the lake. Duke Energy will amend Marshall Plant's NPDES Permit application to reflect this possible occurrence. Another issue identified is the discharge stormwater from the limestone settling basin directly to Lake Norman. The basin receives stormwater runoff from the limestone pile. The stormwater is routed through two pipes. One goes to the yard sump and then to the ash basin. The other pipe goes directly to the lake. This discharge point to the lake will be capped off so it can no longer occur. The capping of the line should be completed by 1/23/15. Duke Energy does not believe that the historical infrequent discharge of the condensate water, water tower overflow, or the stormwater discharge from the limestone settling basin had any adverse impact to human health or the environment. As noted above Duke Energy is actively pursuing measures to close out these discharges. Rev. 1 Bell, Wes From: Stowe, Allen [Allen.Stowe@duke-energy.com] Sent: Wednesday, May 28, 2014 12:58 PM To: Bell, Wes Subject: Marshall SW Release �4t: -20i 0/037 Wes, Our summary of the Marshall stormwater release is listed below. Please contact me if you have any additional questions. Thanks At approximately 5:18 p.m. on 5/26/14, Marshall Station experienced a heavy rainfall event that caused a generation trip and loss of half of 4160 volt loads on Unit 3, resulting in a power failure to the ash silos yard sump station. The ash silos yard sump receives approximately 1 acre of stormwater runoff and this rainfall event produced over 1" of rain in a short amount of time. Norma! operation for the ash silo sump pumps is to route the stormwater runoff and service water for wash down to the ash basin; however, with the power outage these pumps were not operational and the service water line used for agitation in the sump had a small amount of isolation valve leak by. Lake water is used to supply the plant service water. Station operations started conducting site inspections of the area multiple times during the night shift with the last inspection at 4:00 a.m. and reported that although water was observed in the ash silos containment, no water had overflowed. On 5/27/14 the ash sumps area was inspected at 7:00 a.m., and a small trickle of water from the ash silo area into the lake was identified. The estimated flow from the ash silo area was approximately 100 gallons of stormwater/service water. A smaller volume of water may have actually reached the lake due to the flow having to cross a gravel road and heavily vegetated bank before reaching the lake water. Although this water had the potential to come in contact with coal ash residuals, it was observed to be clear, with no visible particles. By 8:00 a.m. site vendors were vacuuming the water out of the containment and by 8:30 a.m. the flow had stopped. All water has been removed from the containment and the area. Operations monitored the ash silo sump area until power was restored. While the sump pumps were still inoperable, a vacuum truck to remove standing water from containment area was placed on standby to respond if a rain event occurs before the pumps were reenergized. Allen Stowe placed a notification call to NC DENR DWR (Wes Bell - Mooresville Regional Office) at 12:52 p.m. on March 27th An additional procedure is being developed to address the loss of the 3TA1 electrical loads. At 9:00 p.m. on 5/27/14, power was restored and the sump pumps are again operational. Allen Stowe Water & Natural Resources Duke Energy 704-382-4309 (Office) 704-516-5548 (Cell) Allen.Stowe@duke-energv.com 1 DUKE ENERGY. March 25, 2014 North Carolina Department of Environment and Natural Resources Division of Water Resources Water Quality Program 161' 7 Mail Service Center Raleigh, NC 27699-1617 Subject: Duke Energy Carolinas, LLC Marshall Steam Station NPDES Permit No. NC0004987 Ash Pond Riser and Decant Piping - Unwatering Project Attention: Mr. Thomas A. Reeder, Director Dear Mr. Reeder: Environmental Services Duke Energy 526 South Church Street Charlotte, NC 28202 Mailing Address: Mail Code EC13K / P.0, Box 1006 Charlotte, NC 28201-1006 This letter is in reference to a request from Mr. Steven McEvoy to Mr. John Elnitsky of Duke Energy [dated March 5, 2014] requesting information relating to the Company's ash pond decant structures in North Carolina. The letter specifically requested that we provide a schedule for completing and reporting results from camera inspections of decant structures containing Corrugated Metal Pipe (CMP) or concrete pipe. Mr. Elnitsky responded to Mr. McEvoy in a letter dated March 14, 2014 with an inventory and status of the Company's subject pipes. Our purpose with this letter is to inform you of Duke Energy's interest in beginning this work at the Marshall Steam Station soon, to meet the March 31, 2014 requested deadline. The project will involve temporarily unwatering a section of pipe and all activity will be confined to the immediate area of the pipe within the ash basin and at the pipe outfall. The facilities to be inspected are the ash pond outlet riser and pipe (State ID CATAW-054) at the Duke Energy Marshall Steam Station. A single 42" diameter CMP (corrugated metal pipe) conveys flow from the ash pond to Lake Norman. The length of the pipe is approximately 320 feet. The 42" CMP was previously slip -lined with a 30" outside diameter HDPE (high density polyethylene) pipe. Slip -lining was performed in 1987. The riser is a concrete structure with access gained via an elevated walkway which is approximately 80-feet long. From the riser tower, the outlet pipe extends approximately 320 feet underneath the pond bank to a small inlet off of Lake Norman. The pipe outlet is submerged approximately 3-5 feet. The pipe outlet is approximately 15 feet from the bank of Lake Norman. Prior to commencement of the work, engineering staff will determine if a buoyancy analysis is required for proposed structures and pipes to be inspected. The following sequence summarizes the tasks needed to complete the inspection: 1. Stage equipment, placing spill containment under areas that contain petroleum. 2. install stop logs in riser structure. Place plastic along the outside of stop logs to reduce flow through the stop log gaps. 3. Remove 2-inch diameter sampling pipe installed at outlet of discharge pipe. 4. Lower submersible pump into the riser and pump water out of the discharge pipe to remove water to the extent practical. Water will be pumped into the ash pond. 5. Visually inspect the riser with CCTV equipment. Insert CCTV equipment at riser structure, using crane and hoist presently installed on top of the intake tower. Pan pipe joints and observed defects as it is lowered and inserted, stopping as necessary to view the condition of the riser and pipe. 6. Diver to install the CCTV equipment at outlet of discharge pipe. Visually inspect the discharge pipe with CCTV equipment, beginning at outlet of discharge pipe. The discharge pipe is expected to be full of water up to a point. If quality video is achieved, there will no further dewatering of the pipe or CCTV inspections. Remove CCTV equipment and proceed to Step 12. 7. If quality video referred to in Step 6 is not achieved, Steps 7 thru 11 will be performed. Divers will install a temporary plug at outlet of discharge pipe. The plug will include a flow -through port fitted with a valve/extension for attaching a vacuum truck or pump. 8, Pump water from the discharge pipe via the flow -through port as practical. 9. Visually inspect pipe with CCTV equipment from the riser structure. 10. Remove CCTV equipment. 11. Remove temporary plug at outlet of discharge pipe. 12. Reinsert 2-inch diameter sampling pipe at outlet of discharge pipe and secure to bank. 13. Remove equipment and perform site clean-up. 14. Remove stop logs and plastic sheeting from riser. Staging areas for work equipment are adjacent to both the intake structure and discharge pipe and are accessible via a combination of paved and gravel roads. It is anticipated that the proposed work can be completed in one day. Duke Energy believes that our proposed activities will not require NPDES permit modifications or other water permitting actions, If you concur, we would appreciate your acknowledgment of approval to proceed at your earliest opportunity. if you have any questions or concerns regarding our proposed course of action, please contact me at (980) 373-7308 or by e-mail at Jahn. Velte a duke-eneray.cocn. Sincerely, elte, Manager NPDES Compliance Environmental Services, Water & Natural Resources xc: Mr. Michael Parker — Division of Water Resources DWR Fayetteville Regional Office Mr. Zahlid Kahn — Division of Energy, Mineral & Land Resources — Fayetteville Regional Office Mr, Jeffrey Poupart — Division of Water Resources — Raleigh Central Office Mr. Steve McEvoy, PE — Division of Energy, Mineral & Land Resources — Raleigh Central Office Mr. Donald Vandervaart — Department of Environment and Natural Resources Pat McCrory Governor NCDENR North Carolina department of Environment and Natural Resources Division of Water Resources Water Quality Programs Thomas A. Reeder Director John E, Skvaria, III Secretary December 18, 20.13 Mr. Allen Stowe, Water Management Duke Energy Post Office Box 1006fEC 1.3K Charlotte, North Carolina 28201-1006 Subject: Compliance Evaluation. Inspection. Marshall Steam Station NPDES Permit No. NC0004987 Catawba County Dear Mr. Stowe: Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on December 13, 2013 by Mr. Wes Bell of this Office. Please inform the facility's Operator -in - Responsible (ORC) of our findings by forwarding a copy of the enclosed report. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell*cdenr.gov. Sincerely, Michael L. Parker Supervisor Water Quality Regional Operati Enclosure: Inspection Report cc: Catawba County Health Department Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-6040 Customer Service: 1-877-623-674 Internet: www.newaterquality.org 1 ion. I arthCarolina �latltraiiij An Eaual Oeecrlunoty %.Affrmurive Action Employer-30% Recycle 10arfk Posl Consumer ciaeer United States Environmental Protection Agency EPA Washington, D.C. 20460 Water;nmpJianr:e Inspect -inn Reprwt Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector FaclIType 1 I N 1 2 1 51 31 NC0004987 111 121 . 13/12/13 117 18l e l 19151 20 J Remarks 2111IIII1111IIIIII IIIII11IIII11III1III'IIII III1I1166 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA--------- —Reserved------------------ 671 1.5 169 701 41 711 N 1 72 I NI 731 1 174 751 1 1 1 1 1 I 1 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Marshall Steam Station NC Hwy 150 Terrell NC 28682 Entry Time/Date 09:00 AM 13/12/13 Permit Effective Date 11/03/01 Exit Time/Date 12:05 PM 13/12/13 Permit Expiration Date 15/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// George Brian Tolbert/ORC/336-589-4087/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Allen 5towe,526 S Chruch St Charlotte NC 282011002//704-382-4309/7043829840 No Section C: Areas Evaluated During inspection (Check only those areas evaluated) Permit." • Flow Measurement Operations & Maintenance IIII Records/Reports Self -Monitoring Program Sludge Handling Disposal • Facility Site Review Effluent/Receiving Waters Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Wes Bell q� f MRO WQ//704-663-1699 Ext.2192/ / 2/1 Cl A 5- S Marcia nature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers D ca MRO WQ//704-663-1699 Ext.2204/ to EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES yr/me/day Inspection "typ 11 12 1? NC0004987 1 13/12/13 J 18 LJ Section D: Burn nary crf Finding/Comments {Attach additional sheets of narrative and checklists as necessary) Page # 2 Permit: NC0004987 Inspection Date: 12/13/2013 Owner - Facility: Marshall Steam Station Inspection Type: Compliance Evaluation Permit Yes No NA NE (lithe present permit expires in 6 months or less). Has the permittee submitted a new application? ❑ n ■ ❑ Is the facility as described in the permit? ■ n n n # Are there any special conditions for the permit? ■ ❑ ❑ n Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? ■ n n n Comment: The subject permit expires on 4/30/2015. No biocides are added to Outfalls 001 and 003. The last compliance evaluation inspection was performed on 4/17/2012. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ ❑ ❑ ❑ Is all required information readily available, complete and current? ■ ❑ n n Are all records maintained for 3 years (lab. reg. required 5 years)? ■ ❑ n n Are analytical results consistent with data reported on DMRs? ■ n ❑ ❑ Is the chain -of -custody complete? ■ ❑ ❑ ❑ Dates, times and location of sampling ■ Name of individual performing the sampling ■ Results of analysis and calibration ■ Dates of analysis ■ Name of person performing analyses ■ Transported COCs ■ Are DMRs complete: do they include all permit parameters? ■ ❑ n 0 Has the facility submitted its annual compliance report to users and DWQ? n n ■ ❑ (If the facility is = or n 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? DONO Is the ORC visitation log available and current? ■ n n n Is the ORC certified at grade equal to or higher than the facility classification? . ■ n n n Is the backup operator certified at one grade less or greater than the facility classification? ■ n n n Is a copy of the current NPDES permit available on site? ■ ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? n n i■ n Page# 3 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 12/13/2013 Inspection Type: Compliance Evaluation Record Keeping Comment: The records reviewed during the inspection were organized and well maintained. Discharge Monitoring Reports (DMRs) were reviewed for the period October 2012 through September 2013. No effluent limit violations were reported and all monitoring frequencies were correct. No discharges were reported during the review period at Outfalls 002A and 002B, Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed bya certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOO) set to 20,0 degrees Celsius +/- 1.0 degrees? Comment: On -site field analyses (pH and temperature) are performed under Duke Energy/Marshall Steam Station's laboratory certification #5155. Duke Energy's Analytical Laboratory and the contracted services of Pace Analytical Services, Inc. (low level mercury) and ETS, Inc. (toxicity) provide analytical support. The pH meter appeared to be properly calibrated and documented. Yes No NA NE Yes No NA NE N DOO ■ n n n ■ nnn ■ nnn n n■❑ n n.n Influent Sampling Yes No NA NE # Is composite sampling flow proportional? Is sample collected above side streams? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is sampling performed according to the permit? Comment: The subject permit requires grab samples (selenium and zinc) at the internal ©utfall 004. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? n n■n O ONO ■ nnn O 0•0 orlon ■ non Yes No NA NE n n * n •n n n * nnn n n a n O 0150 Page # 4 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 12/13/2013 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type representative)? MOOD Comment: The subject permit requires effluent grab samples. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n Judge, and other that are applicable? Comment: The NPDES facilities appeared to be properly operated and well maintained. Process control measurements were being documented and maintained on -site. The FGD wastewater is treated through the following treatment systems prior to entering the ash basin: equalization basin, mushroom compost system (6 cells), and bullrush/cattail treatment systems (3 trains - 2 cells per train). The, ash basin is equipped with carbon dioxide (primary), sulfuric acid, and sodium hydroxide containers for pH adjustment that is provided on an as -needed basis. Both yard sumps (Outfalls 002A and 002B) are equipped with high water alarms monitored in the facility's control room. Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Comment: Outfall 001 flows are based on pump curves/supporting calculations. Outfall 002 flows are measured by a staff guage and suppporting calculations. The flows at Outfalls 002A and 002B would be measured by a staff guage and supporting calculations. Outfall 004 (internal outfall) is equipped with a flow measurement system that is calibrated annually and was last calibrated on 11/28/2012 by Duke Energy's Instrumentation Unit. Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: The discharges from Outfalls 001, 002, and 003 appeared clear with no floatable solids or foam. The receiving stream did not appear to be negatively impacted. No discharges were observed at Outfalls 002A and 002B. Solids Handling Equipment Yes No NA NE Yes No NA NE ■ nnn ■ O ❑ O nn■n Yes No NA NE Page # 5 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 12/13/2013 inspection Type: Compliance Evaluation Solids Handling Equipment Is the equipment operationai? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts andlor rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Comment: The FGD treatment system includes three plate/frame presses that were all operational; however, sludge dewatering was not being performed at the time of the inspection. Dewatered sludge is disposed into the on -site landfill. The gypsum (FGD process) is reused by a contracted company in the dry wall manufacturing process, The fly ash is disposed into the on -site landfill and the bottom ash is either disposed into the on -site landfill or reused in the concrete block manufacturing process. Yes No NA NE _w ■ ❑nn ■ nnn f_1 n n ■ union nun. ■ non Page # Beverly Eaves Perdue Governor NCDEPITI North Carolina Department of Environment and Natural Resources Division of Water Quality Charles Wakild, RE Director Mr. Allen Stowe, Water Management Duke Energy EC13K / Post Office Box 1006 Charlotte. North Carolina 2820 l-1006 Dear Mr, e: April 23, 2012 Subject: Compliance Evaluation inspection Marshall Steam Station NPDES Permit. No, NC0004987 Catawba County Dee Freeman Enclosed is a copy of the Compliance Evaluation inspection Report for the inspection conducted at the subject facility on April 17, 2012.by Mr. Wes Bell of this Office. Please advise the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding a copy of the enclosed report.. The report should be self-explanatory; however, should you .have any questions concerning this report, please do not hesitate to contact Mr, Bell at (704) 235-2.192, or at wes.bellAncdenr.gov. for Robert Krebs Surface Water Protection Regional Supervisor Enclosure: Inspection Report cc: Stephen Immel, Plant Manager, Marshall Steam Station Catawba County Health Department WB Mooresville Regional Office Location: 610 East Center Ave:, Suite 301 Mooresville, NC 26115 Phone: (704)663-1699 +i Fax: (704) 663-6040 +i Customer SeNice, 1-877-623,6746 Internet: www nowaterquality.org One NorthCarolina Naturally An Lquai Opportunity', Alrmakre Action Employer - 30% Recycledc10% Post Calsulner paper irUnited States Environmental Protection Agency EPA Washington, D.C. 20460 Water Compliance Inspection Report- Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection 1 I NI 2 IL 31 NC0004987 1 11 121 12/04/17 1 17 Type Inspector Fac Type 181 r I 191 c `! t 20 11 I I I I I IIII1111 II166 Remarks 2111II I 1 I I I1I111ILII1111II I11I I I I Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA 67 I 1.5 1 69 70 IA 71) N I 72 N �--I Reserved--- — 731 1 174 75[ 1 1 1 1 1 1 1 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Marshall Steam Station NC Hwy 150 Terrell NC 28682 Entry Time/Date 09:00 AM 12/04/17 Permit Effective Date 11/03/01 Exit Time/Date 12:50 PM 12/04/17 Permit Expiration Date 15/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /11 Donna Lee BurrelllORC/828-478-78201 Other Facility Data Name, Address of Responsible OfficialtTitle/Phone and Fax Number Contacted Jimmie Allen Stowe,526 S Chruch St Charlotte NC 282011002/1704-382-4309/7043829840 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement 111 Operations & Maintenance • Records/Reports Self -Monitoring Program • Sludge handling Disposal • Facility Site Review • Effluent/Receiving Waters ll Laboratory Section D: Summary of Findinq/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Wesley N Bell fliI � JO MRO WQl/704-663-1699 Ext.21921 `7' /,,z j `f Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Marcia Allocco MRO WQJ/704-663-1699 Ext.2204/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES yr/mo/day inspection Type NC0004987 111 121 12/04/17 117 18 _ I 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page # 2 Permit: NC0004987 Owner -Facility: Marshall Steam Station Inspection Date: 04/17/2012 Inspection Type: Compliance Evaluation Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: The subject permit expires on 4/30/2015. The last compliance inspection was performed on 6/7/2010. No chlorine is added to the discharges at Ouffalls 001 and 003. Yes No NA NE ■ nnn ■ ❑nn ■ nnn ■ nnn ■ nnn Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ' ■ 0 0 n Is all required information readily available, complete and current? ■ n n n Are all records maintained for 3 years (lab. reg. required 5 years)? ■ n n n Are analytical results consistent with data reported on DMRs? NOOD Is the chain -of -custody complete? • Q 0 0 Dates, times and location of sampling ■ Name of individual performing the sampling ■ Results of analysis and calibration ■ Dates of analysis ■ Name of person performing analyses ■ Transported COCs ■ Are DMRs complete: do they include all permit parameters? ■ 0 n 0 Has the facility submitted its annual compliance report to users and DWQ? Q ❑ ■ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? n n ■ ❑ Is the ORC visitation log available and current? ■ n n n Is the ORC certified at grade equal to or higher than the facility classification? ■ n n 0 Is the backup operator certified at one grade less or greater than the facility classification? EDDO Is a copy of the current NPDES permit available on site? ■ n n n Facility has copy of previous year's Annual Report on file for review? n n ■ ❑ Page # 3 Permit: NC0004987 Owner - Facility: Marshall Steam Station inspection Date: 04/17/2012 Inspection Type: Compliance Evaluation Record Keeping Comment: The records reviewed during the inspection were organized and well maintained. Discharge Monitoring Reports (DMRs) were reviewed for the period February 2011 through January 2012. No limit violations were reported and all monitoring frequencies were correct. Yes No NA NE Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ n n n Are all other parameters(excluding field parameters) performed by a certified lab? ■ n n n # Is the facility using a contract lab? ■ n n n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ n n n Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? 0 0 ! 0 Incubator (BOD) set to 20.0 degrees Celsius +r- 1.0 degrees? 0 0 • 0 Comment: On -site field analyses (pH and temperature) are performed under field laboratory certification #5155. Duke Power's Environmental Services Laboratory (Certification #248) and the contracted services of Pace Analytical Services, Inc. and ETS, Inc. provide analytical support. The pH meter and temperature measuring devices appeared to be properly calibrated and documented. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? n I] • ❑ Is sample collected above side streams? ■ n n n Is proper volume collected? • n n n Is the tubing clean? n n • n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? n n ■ n Is sampling performed according to the permit? ■ n n n Comment: The subject permit requires grab samples (zinc and selenium) at the internal outfall 004. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? n n • n Is sample collected below all treatment units? 'Irmo Is proper volume collected? ■ n n n Is the tubing clean? n n • n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? 0 0 • 0 Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ n n n Page # 4 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 04/17/2012 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Comment: The subject permit requires effluent grab samples. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ n n n Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n Judge, and other that are applicable? Comment: The FGD and ash basin treatment systems appeared to be properly operated and well maintained. The new six vertical flow wetland system (replaced existing wetland cells 1A, 1 B, 1 C) were placed into operation in December 2011. The ash basin system (prior to the effluent discharge) is equppped with sodium hydroxide and ferric sulfate containers for pH adjustment that is provided on an as -needed basis. Both yard sumps (OutfelIs 002A and 002B) are equipped with high water alarms connected to the facility's control room. Solids Handling Equipment Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Comment: The FGD treatment system is equipped with three plate and frame presses; however, the treatment units were not operating at the time of the site visit. The dewatered sludge is disposed on -site (permitted landfill). The gypsum (FGD process) is reused by a contracted company in the dry wall manufacturing process. The fly ash is disposed on -site (permitted landfill) and the bottom ash is either disposed on -site (permitted landfill) or reused in the concrete block manufacturing process. Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Yes No NA NE ■ n n n ■ nnn ■ 000 n nn■ n n■n n ❑ ❑ ■ ■ nnn Yes No NA NE ■ nnn ■ nnn ■ nnn nn■❑ Page # 5 Permit: NC0004987 Owner - Facility: Marshall Steam Station inspection Date: 04/17/2012 Inspection Type: Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Comment: Outfall 001 flows are measured by pump curves and supporting caluculations. Outfall 002 flows are measured by a staff guage and supporting calculations. Internal Outfall 004 flows are measured by a flow measuring device that was last calibrated/verified by Duke Energy staff on 11/9/2011. This flow meter is calibrated/verified annually. The flows at Outfalls 002A and 002B would be measured by a staff guage and supporting calculations. Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: The discharges from Outfalls 001 and 002 appeared clear with no floatable solids or foam. The receiving stream did not appear to be negatively impacted. No discharges were observed at Outfalls 002A and 002B. Yes No NA NE ■ nnn ■ nnn DDmEl Page # 6 From: Sent: To: Cc: Subject: Attachments: John: Nin5 1Nc,pe.-si . ZbIJc pS$ Burrell, Donna L [Donna.Burrell@duke-energy.com] Wednesday, October 05, 2011 11:08 AM Lesley, John Immel, Steve; Helderman, Rickey L; Reid, James W III; Hudgins, Gregory 0; Willis, George T; Herrick, Dayna J; Stowe, Allen 5-Day Follow-up Report for 9/30/11 Oil Spill at Duke Energy/Marshall Steam Station boat.JPG As you requested during your phone conversation with Allen Stowe on Friday, September 30, 2011, 1 am providing the following information to satisfy the 5-day follow-up report concerning the oil spill at Duke Energy's Marshall Steam Station,. Facility: Duke Energy Carolinas, LLC Marshall Steam Station The morning of September 30, 2011 around 8:30 am, the 50 hp Honda 4 cycle motor on Regional Utility Service's work boat (barge) that is used to clean the intake trash racks for the station Condenser Circulating Water pumps developed an oil leak. The work boat (barge) is 21' long, 7'6" wide and 30" deep and is constructed of metal (see attached photo). The oil dip stick came out of its seat about two (2) inches allowing a small amount of oil (<1 pint) to get into the water. The boat was taken out of service and the motor was wrapped with plastic bags and loaded onto a trailer to keep. any additional oil from getting into the water. Eddie Sines (Marshall Production Team Supervisor) was contacted to help evaluate the oil spill and agreed that less than a pint of oil was spilled. The oil sheen that was reported by Eddie Sines was about the size of a piece of notebook paper. The incident was reported to Donna .Burrell (Marshall's Principal EHS Professional) at 1:25 pm on September 30, 2011 and she in turn contacted Allen Stowe (Duke Energy EHS Water Management Group). Alien called the National Response Center (NRC) at 2:55 pm on September 30, 2011 and gave the information to John Dedeaux (incident # 991310 was assigned). Allen also notified John Lesley of NCDENR DWQ at 3:00 pm and provided him the spill details per the 24-hour notification state requirement. On October 3, 2011 at 9:00 am Marshall employees talked with the mechanic that will be the boat motor regarding what could have caused the motor to fail and he said it appears in the oil. Apparently the motor has an internal problem that allowed water to get in to the and float the oil out the dipstick hole. This will be verified whenever the motor is repaired. out of service until repairs are complete. working on to be water crankcase The boat is If there are any questions or if additional information is needed, feel free to give me a call. Donna Burred Principal EHS Professional Marshall Steam Station 828-478-7820 (office) 704-902-5153 (cell) 1 u , ms*rpw. — "ro,w r, A7A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary July 8, 2010 Mr. Allen Stowe, Water Management Duke Energy Post Office Box 1006/EC13K Charlotte, North Carolina 28201-1006 Subject: Compliance Sampling Inspection Marshall Steam Station NPDES Permit No. NC0004987 Catawba County, N.C. Dear Mr. Stowe: Enclosed is a copy of the Compliance Sampling Inspection Report for the inspection conducted at the subject facility on June 7, 2010 by Ms. Donna Hood and Mr. Wes Bell of the Mooresville Regional Office and accompanied by Ms. Autumn Romanski of the Raleigh Regional Office. PIease advise the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed report. The results of the analyses collected by DWQ Staff will be sent to you under separate cover. The facility has several stormwater outfalls that discharge into waters of the State. Although the facility operates under an internal stormwater management program, potential exposures to the stormwater runoff as a result of the facility's operations exist. Following discussions with the Division's Stormwater Permitting Unit, the stormwater discharges will need to be covered under an individual stormwater permit. A completed permit application and supporting documentation (including fee) should be mailed to the attention of Bradley Bennett, Supervisor, DWQ/Stormwater Permitting Unit, 1617 Mail Service Center, Raleigh, N.C. 27699- 1617. The permit application and supporting information can be found at the following website address: http://portal.ncdenr.org/web/wq/ws/su/rzpdessw-#General Permits NPDES. The application and supporting documentation (including fee) should be submitted to the Division within 30 days following receipt of this report. Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663.60401 Customer Service: 1-877-623.6748 Internet: ttttp:l/portaLncdenr.orglweblwq An Equal Opportunity 1 Affirmative Action Employer - 50% Recycled1l0% Past Consumer paper One NorthCarolina 7Va'turaI/f r Mr. Allen Stowe Page Two July 8, 2010 Should you have questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 663-1699 or Mr. Bennett at (919) 807-6378. Sincerely, 76i 6/0_, Robert B. Krebs Regional Supervisor ' Surface Water Protection Enclosure: Inspection Report cc: Catawba County Health Department WB United States Environmental Protection Agency EPA Washington. D.C. 2C460 Water Compliance Inspection Report Farm Approved. OMB No, 2040-0057 Approval expires8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yrlmo/day Inspection 1 1 Til 2 15! 31 N00004987 1 11 121 10/06/07 117 Type Inspector Fac Type 18I 51 191 $1 201 1 1 1 1[ 1 III 11 L 1 I I 1 166 ' Remarks I L 1[ 1 ILI I l III 1 III 1 1 1 1 1 1 1 1 1 1 1 1 1 Imp Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ----------------------------Reserved--- ----- ---- 671 1.5 169 70 141 71 1 N 1 721 N 1 73 11 174 751 1 1 1 1 1 1 1 80 ` Section B: Facility Data Name and Location of Facility Inspected For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Marshall Steam Station NC Hwy 150 Terrell NC 28682 Entry Time/Date 10:00 AM 10/06/07 • Permit Effective Date 09/07/01 Exit Time/Date 09.00 PM 10/06/07. Permit Expiration Date 10/09/30 Name(s) of Onsite Representative(s)[Titles(s)lPhone and Fax Number(s) /// Donna Lee Burrell/ORC/828-478-7820/ Jimmie A11en'Stowe//704-382-4309 / Other Facility Data Name, Address of Responsible OflicialfiitlelPhone and Fax Number Jimmie Allen Stowe,526 S Chruch St Charlotte NC Contacted 282011002//704-382-4309/7043829840 Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Records/Reports ® Effluent/Receiving Waters and checklists as necessary) Permit II Flow Measurement ' Operations & Maintenance Self -Monitoring Program ® Sludge Handling Disposal Facility Site Review Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative (See attachment summary) Name(s) and Signature(s) of Inspect (s) Agency/Office/Phone and Fax Numbers Date MRO WQ//704-663-1699 Ext.2192/ 7/740 Wesley N Bell (W .JQf--i1, Donna Hood MRO WQ//704-663-1699 Ext.2193/ Si nature of Management Q A evi wer Agency/Office/Phone and Fax Numbers Da0 1 Marcia Allocco MRO WQ//704-663-1699 Ext.2204/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES yrlmolday Inspection Type 31 NC0004967 f11 1z1 10/ 6/07 I „ 181sI igi (cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) SUMMARY SECTION cont'd: The facility has several stormwater outfalls that discharge directly into waters of the State. Potential stormwater exposures (from raw materials, by-products, metal storage dumpsters, etc.) as a result of the facility's operations were observed. The facility staff operate under an internal stormwater management program that includes the identification of all stormwater outfalls and their respective drainage areas. The Division's Stormwater Permitting Unit has indicated to MRO staff that the facility will need to apply for coverage under an individual stormwater permit. FACILITY SITE REVIEW: The Division issued an ATC on 4/27/10 for the installation of vertical flow wetland (VFW) cells containing spent mushroom compost for the removal of selenium. These VFW wetland cells will replace the existing wetland cells 1A, 1B, and 1C. These wetland cells (1A, 1B, 1C) have been taken off line and the vegetation from one of these wetland cells has already been removed. The facility staff indicated that the vegetation would be composted and placed back into an on-line wetland cell(s). SLUDGE DISPOSAL: Fly ash, clarifier sludge, spec and off spec gypsum, etc. are disposed into the permitted landfills located on -site. The spec gypsum is also reused in the National Gypsum Company's manufacturing process. Page # 2 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 06/0712010 Inspection Type: Compliance Sampling Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: The subject permit expired on 4/30/10 and a permit renewal application was received by the Division on 11/2/09. The facility is classified as a Physical/Chemical 1 treatment.system; however, the facility also uses a constructed wetland (biological) treatment system for the uptake/reduction of selenium. The Division's Technical Assistance & Certification Unit has been forwarded this information to determine if an additional classification (Grade I Biological) is warranted. The TACU staff will provide a decision following the review of the facility's treatment system. See "Summary" for additional permitting comments. Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (!ab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Yes No NA NE unnn ®nnn nn®n nnn u nnn Yes No NA NE u nnn unnn ®nnn nnn ®nnn nnn n7Ea7 nn®n con El Blinn ® nnn u nnn Page # 3 Permit: NC0004987 Inspection Date: 06/C7/2010 Owner - Facility: hlarsirsll Stearfr Station Inspection Type: Compliance Sampling Record Keeping Yes No NA NE n n■n Rae€lity has copy of previous year's Annual Repot on file for review? Comment: The facility's records were organized and well maintained. Discharge Monitoring Reports (DMRs) were reviewed for the period April 09 through May 10. No effluent limit violations were reported and all monitoring frequencies were correct. Laboratory Are field parameters performed by certified personnel cr laboratory' Are all other parameters(excluding field parameters) performed by a certified Ifab? # Is the facility us ng a contract lab? # is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius}? Incubator (Fecal Conform) set to 44.5 degrees Celsius-1-0- 0.2 degrees? Incubator (BCD) set to 20,0 degrees Celsius -I- 1 0 degrees? Comment; On -site field analyses (pH and temperature) are performed under laboratory certification #5155. The Duke Power Analytical Laboratory (Certification #248) and the contracted services of ETS, Inc. (Chronic Toxicity) also provide analytical support. The pH meter appeared to be properly calibrated (and documented). The thermocouples (temperature - Outfall 001) are also calibrated at a minimum of once per year (and documented). Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6,0 degrees Celsius;? Is the facility sampling performed as required by the permit (frequency, sampling, type representative)? Comment: The subject permit requires effluent grab samples. Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Yes No NA NE ■ nnn ■ nnn ■ nnn ■ nnn n_n■n Doan Yes No NA NE n n■n ■ n n n ■ n n n n n ■ n n n■n ■ nnn Yes No NA NE ■ nn Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Sol;bs, pH, DO, Sludge ■ n n n Judge, and other that are applicable? Comment: The treatment system appeared to be properly operated and well maintained. No chlorine is added to the once through cooling water (Outfall 001). The facility staff use either Sodium hydroxide or CO2 for pH adjustment (as -needed basis) in the ash basin discharge (Outfall 002). Process control monitoring includes pH measurements at different treatment processes/units and in the receiving stream adjacent to Outfall 002. Page # 4 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 06107/2010 inspection Type: Compliance Sampling Chemical Feed Is containment adequate? Is storage adequate? Are backup pumps available? Is the site free of excessive leaking? Comment: Primary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the sludge blanket level acceptable? Is the sludge blanket level acceptable? (Approximately'/. of the sidewall depth) Comment: A polymer (flocculent) is added prior to clarification to enhance settling. Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Comment: Effluent flows from Outfall 001 are measured by pump logs (calculations involving # of pumps, pump rates, pump run times, etc.). Outfall 002 flow is measured by staff gauge and weir (with supporting calculations) and Outfall 004 flow is measured by an ultrasonic flow meter and flume. Effluent Pipe Is right of way to the outfalt properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Yes No NA NE ■ nnn ninon ■ nnn u nnn Yes No NA NE n n■n ® nnn ®nnn ■ nnn n nn n nn nnpan. nnn ' nnn annn Yes No NA NE n mm0 ❑n■p CIDEO W HEW Yes No NA NE in❑n ®❑D❑ ❑❑min Page # 5 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 06/07/2010 Inspection Type: Compliance Sampling Effluent Pipe Comment: Outfall 002 effluent appeared clear with no floatable solids or foam. In addition, no floatable solids or foam were observed at Outfall 001. Yes No NA NE Page # 6 uke nergyy. Carolinas March 29, 2011 R'::CC€VUD DIVISION OF VVtTER QUALITY 24AL OFFICE Mr. Bradley Bennett Division of Water Quality Stormwater Permitting Unit North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: NPDES Stormwater Permit Application Marshall Steam Station Dear Mr. Bennett: CORPORATE EH S SERV/CES Duke Energy Carolinas, LLC 526 SOUTH CHURCH STREET CHARLOTTE, NC 28202 Mailing Address: EC13K / P. O. SOX 1006 CHARLOTTE, NC 28201-1006 Duke Energy requests a stormwater discharge permit for the Marshall Steam Station located in Catawba County, North Carolina. Enclosed is a check from Duke Energy in the amount of $860.00 for the subject stormwater permitting fee; and three sets of the following documents related to this permit request: a. EPA Form 1; b. EPA Form 2F; c. EPA Form 2F Supplemental Information; d. Available stormwater analytical data; e. DWQ ROS Request Form; f. ROS Form Supplemental Information; g. Site Location Map; h. Site Stormwater Plan Drawing Numerous stormwater outfalls are located at the Marshall Steam Station. The accompanying stormwater analytical data was obtained from samples collected at outfall SW007 on May 29, 2008. Please contact me at Mark.McGary©duke-energy.com or at 704-634-7098 if you have any questions or need any additional information, Sincerely, Mark McGary, P.E. Environmental, Health & Safety attachments ©Ill NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Mr. Ron Lewis Duke Energy Carolinas, LLC Mail. Code EC13K. 526 S. Church St. Charlotte, North Carolina 2202 Dear M.I. Lewis: Division of Water Quality Coleen H. Sullins Dee Freeman Director Secretary March .5, 201.0 SitI3 ECT: Acknowledgement of Request l r an. Authorization to Construct Duke Energy Carolinas, L.LC Marshall Steam Station W W"TP Improvements NPDES Permit No. NC0004987 The Construction Grants and Loans Section received your request for an Authorization 'to Construct and the supporting documentation on February 12, 2010. We will notify you and your engineer upon completion of our review. Your project has been assigned to Ken Pohlig., P.F. Ile can be reached at (919) 715-6221. If you have any questions concerning this matter, please co swc/dr cc: Jesse G. Hite, P.E. — Gannett Flemia Charlotte, NC 28204-2622 Mooresville Regional Office WQ Central Files Ken Pohlig, Steve Coffey, P.E, ATC File 004987A04 cerely, Seth. Robertson., P.E., Su Construction Grants and Design Management l ni mea (919) 715-6206. oans Section. g, Inc., Suite 1008, 301 S. McDowell St. '1633 Mail Service Center, Raleigh. North Cardin, Location 2728 Capital BIA. Raleigh, North Carolina Phone: 919+ r 33-69Q1 FAX 919 ?15-622S1 a Guslorr Internet www nirmaterpuality orq Ali Equal C)Ppsart rr//ty Af= isr,itve ActicT rrf?y.lfk,y . None orthCar li a � tin* Bever Governor NC endue NCDENR Carolina Department of Environment, and Natura Mr, Allen Stowe, 'titer velar t Duke Energy Post Office Box 1006/EC 13K Charlotte, North Caro Dear i r. Stove. 28201.-1006 Division of rNater Quality H. Sullins September 20, 2010 Rescurces Subject, Sampling Results Marshall Steam Station NPDES Permit No, NC00(. 11 7 Catawba C„ountv°, N.C. Enclosed please find the results from the laboratory an tlyses tvtt tl e samples eo sta'e .as tvf tlt.e FC;.D treatment system at .the Marshall Steam Station. The samples a.nal,yrr,.e samples collected during the Compliance Sampling Inspection performed on June 7, 20 Hood and Mr. Wes 'Bell of the Mooresville Regional Office. and Ms, Autumn Romanski Regional Office, The Outfall 002 effl Dee -r Se ted at. different ere all grab by Ms..Donna the. Raleigh were co pliant witlr the permitted effluent limits, Please be aware that the effluent total discs>lv°ecl solids value (896 mg, e:viceeded the vvttter quality stream standard for waters designated as a water supply (500 mg,/L). Although no ittstretrrrl samples were collected, the results of all samples collected during this inspection will be forwarded to the I iv°ision's. NPDES Permitting Unit for their review. Please attach this letter and the analytical rests➢ts sheets try the inspection report dated July 8, 2010 to complete your records on the inspection. Should you have questions conswerning this rep rt, please do not hesitate to contact ..Mr. Hell at (704) 663-1699, t tt.ctosure: Analytical Results Catawba County Health WB tntettt aresv lle regional Office tocatlent 610 Fast Center Ave., Suite 301 Mooresville, NO 9 t 15 Phone: (704) 663-16991 Fax: (704)) 863-6040 4 Cuslomer en+ic : 1-877 3.6748 Internet http.rtportal.ncdenr.or3Jwehiwq r quay Opportunity s Atrrrr>vo5e ACtkur rrr;ager SG% R;cyciettu 7% Post COnsumer pap r One filorthCa oh. Nllti/ra/ij Name of Fac Duke Energy ty arshall Ste Station Sample Date(s): June 7, 2010 YTICAIES _ T H E M NPDES Permit No.; N00004987 Sample Location: FGD Influent Prior to C9ariiier Biochemical Oxygen Demand (BOD5) Total Dissolved Solids County: Catawba <2 mg/L Sodium (Na) 2470 Nickel (Ni) 56 r`ng/L. 400 uglL Chemical Oxygen Demar d 150 mg/L Lead (Pb) Chloride 7600 mg/L Antimony (Sb) Fluoride Sulfate 100.0 mg/L* Selenium (Se) 260 gig/L 1000 prig!L* 4600 erg/L 1200 mg/L Tin (Sn) Silver (Ag) Aluminum (Al) 100 p.Eg/L" 170000 irgtL 1000 pig/12 Thallium (TI) Titanium (Ti) Arsenic (As) 230 _ig(L Vanadium (V) 1000 ,kg/L* 3600 ttg/L 440 kg/L. Boron (B) 160000 Zinc (Zngift_ Barium (Ba) 1700 p,g/L Total Phosphorus 3.4 rng/L Beryllium (Be) 12 erg/L Calcium (Ca) Cadmium (Cd) Cobalt (Co) Ammonia -nitrogen (NF1,39N) 6.7 mg/L 4400 mg/L Total Kjeldahl Nitrogen (TKN) 13 mg/L 11 prg/L 150 p.rg/L Nitrate/Nitrite-nitrogen (NO2 + NO3) 28 mg/L Total Nitrogen 41 mg/L Chromium (Cr) 320 tig/L Copper (Cu) Iron Fe) 330 trg/L 190000. Hg) 4.5 Egg/L Note: indicates elevated PQL due to matrix interference and/or sample dilution No Field Analyses were obtained Potassium (K) 80 mg/L ithurn Magnesium (Mg) 360 pig/L 1400 mg/' ganese (Mn) 10000 pig/L. Molybdenum (Mo) 1000 prg/l-* ANALYTICAL RESULTS SHEET Name of Facility: Duke Energy Marshall Steam Station Grab: ® Composite: ❑ Sample Date(s): June 7, 2010 NPDES Permit No.: NC0004987 Sample Location: FGD Clarifier Effluent County: Catawba Biochemical Oxygen Demand (RODS) <2 mg/L Sodium (Na) - 54 mg/L Total Dissolved Solids 17100 mglL Nickel (Ni) 180 µglL Chemical Oxygen Demand 120 mg/L Lead (Pb) <10 µg/L Chloride 5500 mg/L Antimony (Sb) 20'0 µg/L* Fluoride <100.0 mg/L* Selenium (Se) 390 µg1L Sulfate , 1100 mg/L Tin (Sn) 200 µg/L* Silver (Ag) 50 ug/L* Thallium (TI) 200 µg/L* Aluminum (Al) 380 µgIL Titanium (Ti) , 100 µg/L* Arsenic (As) 10 µgIL* Vanadium (V) <25 µgIL Boron (B) 170000 µg1L Zinc (Zn) 51 µg1L Barium (Ba) 610 µg/L • Total Phosphorus 0.02 mg/L Beryllium (Be) <5 µg/L . Ammonia -nitrogen (NH3-N) 6.6 mg/L Calcium.(Ca) 3100 mglL Total Kjeldahl Nitrogen (TKN) 10 mglL Cadmium (Cd) 7.8 µglL Nitrate/Nitrite-nitrogen (NO2 + NO3) 33 mg/L Cobalt (Co) 57 µg/L Total Nitrogen . 43 mglL Chromium (Cr) <10 µg/L • Copper (Cu) 20 µglL* Note: * indicates elevated PQL due to matrix interference and/or sample dilution Iron (Fe) 410 µg/L Mercury (Hg) 4.6 µg/L FIELD ANALYSES Potassium (K) 25 mglL Temperature 39.5°C Lithium (Li) 170 µg/L pH 6.5 SU • Magnesium (Mg) 1300 mg/L Dissolved Oxygen 3.67 mg/L Manganese (Mn) 9100 µg/L % Saturation 54 % Molybdenum (Mo) 200 µg/L* Conductivity 20900 umhos/cm ANALYTICAL RESULTS SHEET Name of Facility: Duke Energy Marshall Steam Station n Grab: Composite: Sample Date(s): June 7, 2010 NPDES Permit No.: NC0004987 Sample Location: FGD EQ Basin Effluent County: Catawba Biochemical Oxygen Demand (BOD5) <2 mg/L Molybdenum (Mo) 200 µg/L* TotahDissolved Solids 6970 mg/L Sodium (Na) 22 mg/L Chemical Oxygen Demand 33 mg/L Nickel (Ni) 71 µg/L Total Organic Carbon 2.7 mg/L Lead (Pb) <10 µg/L Chloride 2700 mg/L Antimony (Sb) 200 µgfL* Fluoride <40.0 mglL* Selenium (Se) 140 µg/L Sulfate 580 mglL Tin (Sn) 200 µg/L* Silver (Ag) 50 µglL* Thallium (TI) 200 µgIL* Aluminum (AI) 240 µg/L Titanium (Ti) <10 µg/L Arsenic (As) 10 µg/L* Vanadium (V) <25 µg/L Boron (B) 68000 µg/L Zinc (Zn) 18 µg/L Barium (Ba) 220 µg/L Total Phosphorus 0.02 mg/L Beryllium (Be) <5 µg/L Ammonia -nitrogen (NH3-N) 2.8 mg/L Calcium (Ca) 1100 mg/L Total Kjeldahl Nitrogen (TKN) 4 mg/L Cadmium (Cd) 2.6 µg/L Nitrate/Nitrite-nitrogen (NO2 + NO3) 14 mg/L Cobalt (Co) <50 µg/L Total Nitrogen 18 mg/L Chromium (Cr) <� 0 µglL Note: * indicates elevated PQL due to matrix interference and/or sample dilution Copper (Cu) 20 µglL* Iron (Fe) 220 µg/L FIELD ANALYSES Mercury (Hg) <0.20 µg/L Temperature 28.4°C Potassium (K) 11 mg/L pH 6.76 SU Lithium (Li) 65 µg/L Dissolved Oxygen 5.09 mg/L Magnesium (Mg) 480 mg/L % Saturation 77 % Manganese (Mn) 3500 µg/L Conductivity 8900 umhos/cm ANALYTICAL RESULTS SHEET Name of Facility: Duke Energy Marshall Steam Station ❑ Grab: 0 Composite: Sample Date(s): June 7, 2010 NPDES Permit No.: NC0004987 Sample Location: Outfall 004 County: Catawba Biochemical Oxygen Demand 2.9 mg/L Molybdenum (Mo) 200 ug/L* Total Organic Carbon 7.6 mg/L Sodium (Na) 21 mg/L Total Dissolved Solids 8070 mg/L Nickel (Ni) 69 jig/ Chemical Oxygen Demand 34 mg/L Lead (Pb) <10 µg/L Chloride 2500 mg/L Antimony (Sb) • 200 µg/L* Fluoride <40.0 mg1L* Selenium (Se) 94 µg1L Sulfate 580 mg/L Tin (Sn) 200 µgfL* Silver (Ag) 50 µg/L* Thallium (TI) 200 µg/L * Aluminum (AI) 52 µg/L Titanium (Ti) <10 µg/L Arsenic (As) 10 µg/L* Vanadium (V) <25 µg/L Boron (B) 70000 µg/L Zinc (Zn). 12 µg/L Barium (Ba) 190 µg/L Total Phosphorus 0.03 mglL Beryllium (Be) . <5 µgIL Ammonia -nitrogen (NH3-N) 0.65 mg/L Calcium (Ca) 1000 mg/L Total Kjeldahl Nitrogen (TKN) 2.3 mg/L Cadmium (Cd) 1.6 µg/L Nitrate/Nitrite-nitrogen (NO2 + NO3) 11 mg/L Cobalt (Co) �, <50 µg/L Total Nitrogen 13.3 mglL Chromium (Cr} <10 µg/L Note: * indicates elevated PQL due to matrix interference and/or sample dilution Copper (Cu) . 20 µglL* FIELD ANALYSES Iron (Fe) 220 µg/L Flow 906 gpm Mercury (Hg) 4.5 µgfL Temperature 27.9°C Potassium (K) 11 mg/L pH 6.12 SU Lithium (Li) 69 µg/L Dissolved Oxygen- 4.78 mg/L • Magnesium (Mg) 460 mg/L % Saturation 68.7 % Manganese (Mn) 4000 µgIL Conductivity 8200 umhos/cm ANALYTICAL RESULTS SHEET Name of Facility: Duke Energy Marshall Steam Station Sample Date(s): June 7, 2010 Sample Location: Outfall 002 (Final Effluent) Biochemical Oxygen Demand (BOD5) Total Suspended Solids Total Organic Carbon Total Dissolved Solids Chemical Oxygen Demand Chloride Fluoride Sulfate Silver (Ag) Aluminum (Al) Arsenic (As) Boron (B) Barium (Ba) Beryllium (Be) Calcium (Ca) Cadmium (Cd) Cobalt (Co) Chromium (Cr) Copper (Cu) Iron (Fe) Mercury (Hg) Lithium (Li) Magnesium (Mg) Manganese (Mn) <2 mg/L <6.2 mg/L 3.0 mg/L 896 mg/L <20 mg/L 220 mg/L <4.0 mg/L* 110 mg/L 50 µg/L* 3.70 µg/L 10 µg/L* 5500 µg/L 98 µgIL <5 µgIL 110 mglL <1.0 µg/L <50 µg/L <10 µg/L 20 µg/L* 120 µgIL <0.20 µg!L 69 p,glL 46 mg/L 820 µg/L Grab: El Composite: ❑ NPDES Permit No.: NC0004987 County: Catawba Sodium (Na) Nickel (Ni) Lead (Pb) Antimony (Sb) Selenium (Se) Tin (Sn) Thallium (Ti) Vanadium (V) Zinc (Zn) Total Phosphorus Ammonia -nitrogen (NH3-N) Total Kjeldahl Nitrogen (TKN) Nitrate/Nitrite-nitrogen (NO2 + NO3) 8.1 mg/L 20 µg/L <10 µg/L 200 µg/L* 50 µgIL* 200 µg/L* 200 µgIL* <25 µglL 22 µgIL <0.02 mg/L 1.0 mg/L 3.5 mg/L 1.1 mg/L Total Nitrogen 4.6 mglL Note: * indicates elevated PQL due to matrix interference and/or sample dilution pH Dissolved Oxygen Temperature % Saturation Conductivity FIELD ANALYSES 6.14 SU 5.22 mglL 28.6°C 77.6 % 1100 umhoslcm North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary April 27, 2010 Mr. Ron Lewis Duke Energy Mail Code EC13K 526 S. Church Street Charlotte, North Carolina 28202 SUBJECT: Authorization to Construct A to C No. 004987A04 Duke Energy Marshall Stearn Station Flue Gas Desulfurization WW1P Improvements Phase 2: Selenium Reduction System Catawba County Dear Mr. Lewis: A letter of request for an Authorization to Construct was received February 12, 2010, by the Division of Water Quality (Division), and final plans and specifications for the subject project have been reviewed and found to be satisfactory. Authorization is hereby granted for the construction of modifications to the existing Flue Gas Desulfurization (FGD) Wastewater Treatment Plant, with discharge of treated wastewater into the Ash Settling Basin (via Internal Outfall 004), which discharges into the Catawba River (Lake Norman, Outfall 002) in the Catawba River Basin. This authorization results in no increase in design or permitted capacity and is awarded for the construction of the following specific modifications: Installation of a new 6-way inlet flow splitter box; 8-inch gravity distribution piping; six (6) Vertical Flow Wetlands for selenium removal (to replace existing wetland cells 1A, 1B and IC) designated as VFW cells 1A, 1B, 1C, ID, 1E and 1F, with each cell consisting of a geosynthetic clay liner, 18 inches of liner cover material, 15 inches of coarse underdrain material with 8-inch perforated pipe, and 3.75 feet of spent mushroom compost (97,500 ft3); 18-inch and 24-inch gravity drain pipe to a new 3-way outlet flow splitter box; 12-inch gravity drain pipe to existing 2A, 2B and 2C wetland cells; and removal of the temporary 18-inch HDPE gravity bypass pipe between the equalization basins and wetland cells 2A, 2B, and 2C (installed under ATC #004987A03, issued February 18, 2010); in conformity with the project plans, specifications, and other 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St, Raleigh, North Carolina 27604 Phone; 919-807-6300 N FAX: 919-807-6492 1 Customer Service: 1-877-623-6748 Internet: MAY.ncwaterquality,org An Equal Opporiunity \ Affirmative Action Employer One NorthCarolina Naturally Mr. Ron .Lewis April 27, 2010 Page 2 supporting data subsequently filed and approved by the Department of Environment and Natural Resources. Phis Authorization to Construct is issued in accordance with Part III, Paragraph A of NPDES Peiniit No. NC0004987 issued June 15, 2009, and shall be subject to revocation unless the wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in Permit No. NC0004987. The sludge generated from these treatment facilities must be disposed of in accordance with G.S. 143-215.1 and in a manner approved by the Division. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take immediate corrective action, including those as may be required by the Division, such as the construction of additional or replacement wastewater treatment or disposal facilities. The Mooresville Regional Office, telephone number (704) 663-1699, shall be notified at. least forty-eight (48) hours in advance of operation of the installed facilities so that an on site inspection can be made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. Upon completion of construction and prior to operation of this permitted facility, a certification must be received from a professional engineer certifying that the permitted facility has been installed in accordance with the NPDES Permit, this Authorization to Construct and the approved plans and specifications. Mail the Certification to: Construction Grants & Loans, DWQ/DENR, 1633 Mail Service Center, Raleigh, NC 27699-1633.. Upon classification of the facility by the Certification Commission, the Perrnittee shall employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of the wastewater treatment facilities. The operator must hold a certificate of the type and grade at least equivalent to or greater than the classification assigned to the wastewater treatment facilities by the Certification Commission. The Perrnittee must also employ a certified back-up operator of the appropriate type and grade to comply with the conditions of T15A:8G.0202. The ORC of the facility must visit each Class I facility at least weekly and each Class II, III and. IV facility at least daily, excluding weekends and holidays, must properly manage the facility, must document daily operation and maintenance of the facility, and must comply with all other conditions of T15A:8G.0202. A copy of the approved plans and specifications shall be maintained on file by the Permittee for the life of the facility. r Mr. Ron Lewis April 27, 2010 Page 3 During the construction of the proposed additions/modifications, the permittee shall continue to properly maintain and operate the existing wastewater treatment facilities at all times, and in such a manner, as necessary to comply with the effluent limits specified in the NPDES Permit. You are reminded that it is mandatory for the project to be constructed in accordance with the North Carolina Sedimentation Pollution Control Act, and when applicable, the North Carolina Dam Safety Act. In addition, the specifications must clearly state what the contractor's responsibilities shall be in complying with these Acts. Prior to entering into any contract(s) for construction, the recipient must have obtained all applicable permits from the State. Failure to abide by the requirements contained in this Authorization to Construct may subject the Permittee to an enforcement action by the Division in accordance with North Carolina General Statute 143-215.6A to 143-215.6C. The issuance of this Authorization to Construct does not preclude the Permittee from complying with any and all statutes, rules, regulations, or ordinances which may be imposed by other government agencies (local, state, and federal) which have jurisdiction. One (1) set of approved plans and specifications is being forwarded to you. If you have any questions or need additional information, please contact Seth Robertson, P.E. at telephone number (919) 715-6206. Sincerely, Coleen H. Sullins kp: sr ` cc: Jesse G. Hite, Jr., P.E. — Gannet Fleming, Inc., Suite 1008, 301 S. McDowell St., Charlotte, NC 28204-2622 Catawba County Health Department DWQ Mooresville Regional Office, Surface Water Protection DWQ, Technical Assistance and Certification Unit DWQ, Point Source Branch, NPDES Program Ken Pohlig, P.E. ATC File No. 004987A04 Duke Power Marshall Steam Station Flue Gas Desulfurization WWTP Improvements Phase 2: Selenium Reduction System A To C No. 004987A04 Issued April 27, 2010 Engineer's Certification I, , as a duly registered Professional Engineer in the State of North Carolina, having been authorized to observe (periodically/weekly/full time) the construction of the modifications and improvements to the Marshall Steam Station Flue Gas Desulfurization WWTP, located at the intersection of NC Highway 150 and NCSR 1841 in Catawba County, hereby state that, to the best of my abilities, due care and diligence was used in the observation of the following construction: Installation of a new 6-way inlet flow splitter box; 8-inch gravity distribution piping; six (6) Vertical Flow Wetlands for selenium removal (to replace existing wetland cells 1A, 1B and 1C) designated as VFW cells 1A, 1B, 1C, 1D, lE and 1F, with each cell consisting of a geosynthetic clay liner, 18 inches of liner cover material, 15 inches of coarse underdrain material with 8-inch perforated pipe, and 3.75 feet of spent mushroom compost (97,500 ft3); 18-inch and 24-inch gravity 'drain pipe to a new 3-way outlet flow splitter box; 12-inch gravity drain pipe to existing 2A, 2B and 2C wetland.ceIls; and removal of the temporary 18-inch HDPE gravity bypass pipe between the equalization basins and wetland cells 2A, 2B, and 2C (installed under ATC #004987A03, issued February 18, 2010); in conformity with the project plans, specifications, and other .supporting data subsequently filed and approved by the Department of Environment and Natural Resources. I certify that the construction of the above referenced project was observed to be built within substantial compliance and intent of the approved plans and specifications. Signature Registration No. Date - _. Send to: Construction Grants & Loans DENR/DWQ 1633 Mail Service Center='' Raleigh, NC 27699-1633 1 � ;F fl'LL Memo To: DIVISION OF WATER QUALITY February 5, 2010 Ken Pohlig, PE, Project Review Engineer Design Management Unit Construction Grants and Loans From: Rob Krebs 60&, Fox' RK . Prepared By: Michael Parker OrP Subject: Duke Energy — Marshall Steam Station Authorization to Construct Flue Gas Desulfiuization NPDES Permit No. NC0004987 Catawba County Per your request, this Office has reviewed the subject ATC request and supporting documents received by this Office on January 27, 2010 from Duke Energy (DE) requesting authorization to modify the existing Constructed Wetlands Treatment System (CWTS) at Duke Energy's Marshall Steam Station. The modifications involve the installation of by-pass piping that will divert water from three wetland treatment cells (designated as 1A, 1B, and 1 C) so that the three cells can be converted from surface flow wetland cells to vertical flow wetland cells. This piping will allow de -watering of the cells during construction and convey the Flue Gas Desulfurization wastewater around the construction area. The remaining cells of the CWTS will remain online during construction, and DE is not expecting a significant drop in treatment efficiency nor compliance issues with the subject permit. Therefore, pending a final technical review and approval by CG&L, it is recommended that the request for an ATC be approved. H:latclatc101marshall. doc Governor NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality verly Eaves Perdue Coleen H. Sullins Dee Freeman Director Secretary January 25, 2010 MEMORANDUM TO: Rob Krebs, Regional Water Quality Supervisor Mooresville Regional Office, Division of Water Quality FRO Ken .Pohlig, Project Review Engineer Design Management Unit SUBJECT: Request for an Authorization to Construct Duke Energy, Marshall Flue Gas Desulfurization WWTP NPDES Permit No, NC0004987 Plans, specifications and supporting documents have been received for the subject project. It is requested that comments and recommendations, including the items listed below, received by February 25, 2010 from the Regional Office Staff: CAMA Compliance With NC Well Construction Standards Groundwater Comments X Recommendations for inclusion in the Authorization to Construct Recommendations for inclusion in the Non Discharge Permit Schedule for Issuance of the NPDES Permit SOC, or Other Schedules Which Must be Met. Standby Power Needs Status of Stormwater Permit Plan documentsdocurnents are submitted as follows for your reference, review, and comments on the above X Plans and Specifications Subsurface/Soils Report Power Outage Information Other If you have any questions, please contact ine at (919) 715-6221. Attachment swc cc: Ken Pohlig, P.E. Steve Coffey, RE. ATC File 004987A03 633 ii Sentice Center, Rale9h, North Ca tna 27*1633 °cation: 2728 Capital Btvd, Raleigh, North Carolina 27604 Phone: 919-733-6900 \ FAX: 919-715-6229 Customer Service: 1-677-623-6748 Internet: www,ncwalerguality,org AR Equai Opportunq Alfinatve Amon Empicyot One NorthCarohna aturaiij oo We7 3 rr . North Carolina Division Of Water Quality .' Construction Grants & Loans Section Authorization To Construct (ATC) Application or STAG (To Be Used On and After August 1, 2007 TIONGRANTS & LOAN SECTION BAN 14 MO Date: 1/8/2010 Permittee/Owner Name: Duke Energy Contact Person: Ron Lewis Address: Mail Code EC13K, 526 S. Church Street Charlotte, NC 28202 Telephone Number: (980) 373-5710 Professional Engineer of Record: Jesse G. Hite, Jr, P.E. Engineering Firm: Gannett Fleming, Inc. Address: Suite 1008, 301 South McDowell St. Charlotte, NC 28204-2622 Telephone Number: (704)375-2438 Please Note: The following items and information must be submitted to be considered a complete application package. If any applicable item is missing the package will be returned as incomplete. 1 2 3 4 5 6 7 8 9 10 11 12 13 Letter of request for ATC from Permittee/Owner or authorized agent with written authorization. Brief description of the proposed project. Complete copy of the NPDES permit or public notice of a draft NPDES permit. Design capacity in Million Gallons per Day (MGD). If new or expanding design capacity is greater than or equal to 0.5 MGD, include a copy of Finding Of No Significant Impact (FNSI). Two sets of plans: signed, sealed, and dated by a NC Professional Engineer and stamped "Final Drawing - Not Released For Construction". Two sets of technical specifications: signed, sealed, and dated by a NC Professional Engineer. Two sets each of process, design, buoyancy, and hydraulic profile calculations: signed, sealed, and dated by a NC Professional Engineer. Hydraulic profile and a flow schematic with sizes of major components on 8%" X 11" paper. Documentation that a Soil & Erosion Control permit application has been submitted to the Division of Land Resources. Residuals Management Plan for all new or expanding facilities producing residuals, or when modifying residual facilities. Construction Sequence Plan for all modifications. 110 volt GFCI receptacle and potable water source included on plans. Information Is Provided Remarks/Explanation Cover Letter to ATC Form Exhibit A Attached Exhibit B Attached 1.27 MGD Proposed VFW Modification does not expand current capacity of system Exhibit C Attached Exhibit D Attached Exhibit E Attached - Hydraulic calculations for temporary bypass pipe Exhibit F Attached All earth disturbance activities for Dewatering Plan will be within existing cells No residuals will be associated with the Dewatering Plan Included in Exhibits C and D Dewatering Plan does not involve treatment works or disposal system Please Note: The following items and information must be submitted to be considered a complete application package. If any applicable item is missing the package will be returned as incomplete. Information Is Provided Remarks/Explanation 14 Hydrogeologic information must be provided if a potential for groundwater contravention exists. El All earth disturbance activities will be contained within existing lined cells 15 16 17 18 19 20 21 22 23 24 25 26 For abandonment of WWTPs: a statement that the facility will be properly disconnected. All property lines, construction easements, permanent easements, and ROW shown. All wells within 200 feet of project shown. All houses and places of public assembly within 100 feet shown. Wetlands, watercourses, and drainage features within 50 feet of all wastewater treatment or storage facilities shown. Identify on the plans each water body's watershed classification. Plan sheets for all applicable disciplines. Reliability per NCAC 2T .0505 (I). Identify 100 year flood elevation on plans. North arrow on each plan sheet. Horizontal and vertical control. Subsurface investigation for new structures. Municipal/Public Facilities, also include the following: 27 28 29 30 31 32 Engineer's Certification signed, sealed, and dated by the Engineer Of Record stating that the project complies with G.S. 133-3. Minority Business Forms for Local Government Projects. Minority Business Guide. Dispute Resolution with mediation for Local Governments. Contract Duration included. Projects funded through CG&L must include the Submittal Checklist, found under Plans & Specificiations at: http://www.nccql.netlEngineeringlplans.html No abandonment will be involved in Dewatering Plan All activities will be on property owned by Duke Energy at the Marshal! Steam Station None None Dewatering Plan is within the footprint of existing constructed wetland treatment system Catawba River Basin (Lake Norman) WS-IV and B CA Waters See Exhibit C Plan Sheets Not Applicable Not Applicable See Exhibit C Plan Sheets See Exhibit C Plan Sheets Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable EXHIBIT A Duke Energy Marshall FGD Wastewater Selenium Reduction Prbject Bypass Piping and Dewatering Plan Request for Authorization to Construct PROJECT DESCRIPTION CEfie g 2010 o sFarG WIS The purpose of the Marshall Flue Gas Desulfurization (FGD) Waste Water Selenium Reduction Project is to modify the existing Constructed Wetland Treatment System (CWTS) at Duke Energy's Marshall Steam Station to improve the removal of selenium. The modification will replace the first set of three (3) surface flow wetland (SFW) cells, identified as Wetland Cells 1A, 1B, and 1C, with six vertical flow wetland (VFW) cells to be located between the existing pair of equalization basins and the second set of existing SFW cells identified as Wetland Cells 2A, 2B, and 2C. The project will consist of two phases: (1) a bypass piping and dewatering plan and (2) construction plans for the VFW Treatment System. This request is for authorization to construct the bypass piping which will convey the FGD wastewaters around the construction area during construction and allow dewatering of the three SFW cells to be replaced by the VFW cells. A separate ATC request for the Phase 2 construction phase of the project will be submitted in February 2010. As shown on the attached drawings, an 18-inch HDPE bypass pipe will be installed between the equalization basins and Wetland Cells 2A, 2B, and 2C. The bypass pipe will be connected to the inlet pipes currently conveying wastewaters to Wetland Cells IB and 1C. During the bypass period, Wetland Cell 1A wilI remain off-line. The 18-inch pipe will convey the wastewaters to the downstream wetland cells, where flow will be split three ways to Wetland Cells 2A, 2B, and 2C by control valves and separate 12-inch pipes. The bypass pipe will be laid on the surface of the ground and supported by retaining pipes driven along the downslope side of the pipe. To allow sufficient time to install and connect the bypass system, the equalization basins will be drawn down to provide extra storage capacity so that flows to the connecting pipes can be temporarily closed to allow completion of the connections. After the wetland cells are bypassed, drainage trenches and sumps will be cut into their existing substrates. The sumps will be periodically pumped, with discharge of the pumped waters alternating between Wetland Cells 2B and 2C until the substrate is adequately dewatered for removal, stockpiling, and reuse as liner cover in the new VFW cells. Surface vegetation and organic matter removed from the dewatered cells will be mulched and spread in the remaining downstream wetland cells as an organic amendment. Pending approval of this ATC request, the bypass and dewatering will be initiated in February 2010. The bypass will remain in place throughout the construction of the VFW system, which is scheduled for completion in April 201 I. Because the remaining wetland cells of the existing CWTS will remain on-line, no significant change in selenium removal or reduction in compliance with current NPDES levels is expected during the bypass period. EXHIBIT B Duke Energy Marshall FGD Waste Water Selenium Reduction Project Bypass Piping and Dewatering Plan Request Authorization to Construct COPY OF NPDES PERMIT NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary June 15, 2009 Mr. David Renner, General Manager III Duke Energy Carolinas, LLC- Marshall Steam Station 8320 East NC Highway 150. Terrell, North Carolina 28682 Subject: NPDES major modification Permit No. NC0004987 Marshall Steam Station Catawba County Dear Mr. Renner: Division personnel have reviewed and approved your request for major modification. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is modified 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 October 17, 2007 (or as subsequently amended.) This permit modification addresses the request for a major modification regarding the elimination or modification of monitoring frequencies for several constituents discharged from Outfalls 002 and 004. The Division has reviewed Duke Energy's comments submitted on April 30, 2009 and has the following responses. Regarding the request that the weekly average selenium limit be changed to a monthly average limit. The Division's established procedure for compliance periods for metals shall be daily maximum and weekly average limits. North Carolina water quality standards are adopted based on chronic criteria. Based on the Division's procedure, effluent limitations for selenium . will be added at Outfall 002 and weekly monitoring for selenium will remain. at Outfall 004. The limits will be a weekly average of 29 ug/l and a daily ma tdmum of 56 ug/1. These limits are based on the results of a reasonable potential analysis that indicated the potential to exceed the North Carolina standard for selenium. Because of the complexity of selenium removal and reduction, Duke Energy has requested and will be given a three year compliance schedule to meet this limit. The compliance schedule by Duke Energy is included in Special Condition A. 23 1617 Mail Service Center, Raleigh, North Carolina 2769e-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919.807.63001 FAX: 919-807-64921 Customer Service: 1.877.623.6748 Internet: ;;ww,ncwaferquatity.org An Equal Opportunity) A'6nrative Action Employe: Novi thCarolina Naturally Letter to Mr. Renner Page 2 with specific dates corresponding to the timetables submitted. Duke Energy must come into compliance with the selenium limit by July 1, 2012., Regarding the language in the toxicity condition, staff has confirmed that the forms (TGP3B and THP3B) listed in paragraph 5 are correct. The following modifications included in the March 24th draft remain in the final permit modification: • Weekly effluent monitoring for cadmium, chromium, and silver at Outfall 002 and Outfall 004 has been deleted. Data analysis indicated that there was no reasonable potential for these parameters to exceed water quality standards in the receiving stream. There was very minimal detection of these three metals in the review of three years 'of effluent data. • Weekly effluent monitoring for total suspended solids (TSS) at Outfall 004 has been deleted. OutfalI 004 is an internal outfall discharging into the ash basin (Outfall 002). Because TSS has an effluent limit and monitoring at Outfall 002, the monitoring requirement at Outfall 004 can be removed. o The monitoring frequency for total arsenic, chloride, total mercury, and total nickel has been reduced from weekly to quarterly at Outfall 002 and Outfall 004. Analysis of the data indicated there was no reasonable potential shown to exceed the state water quality standards. Because of the effluent concentrations discharged, these constituents are still considered to be parameters of concern. Quarterly monitoring is the minimum frequency required in order for the Division to evaluate future effluent data. • The monitoring frequency for total zinc has been reduced from weekly to monthly monitoring at Outfall 002 and Outfall 004. The reasonable potential analysis indicated the potential to only exceed the acute allowable concentration for this action level parameter. Because of a record of consistently passing the toxicity tests and zinc concentrations not be problematic, it is recommended that the monitoring frequency can be reduced from weekly to monthly. • Please note that there have been minor Language changes and the addition of a new paragraph regarding data submittal in special condition A.14. Chronic Toxicity Pass/Fail permit limit. (The new paragraph is located second from the end of the condition). If any parts, measurement frequencies or sampling requirements contained in this permit modification 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, 6714 Mail Service Center, Raleigh, North Carolina 27699- 6714. Unless such a demand is made, this permit shall be final and binding. Please take notice that this permit is not transferable. The Division may require modification 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, Coastal Area Management Act, or any other Federal or Local governmental permits may be required. If you have any questions or need additional information, please contact Ms. Jacquelyn Nowell at telephone number (919) 807-6386 or email jackie.nowell®ncdenr.gov. Sfnerely, C. Teen II Sullins cc: EPA Region IV Mooresville Regional Office/Surface Water Protection Section DEH/ Public Water Supply Section/Mooresville Regional Office Aquatic Toxicology Unit NPDES File/NC0004987 Central Files 1617 Mail Service Center, Raleigh, North Cardina 27699-1617 t_ocalton: 512 N. Salisbury 51. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919.807-B4921 Customer Service:1.277-623.6748 Internet wwtw.ncwaterquetity.org Ao Equsl Oppotunityl Affirmative Action Employe. NcgthCarolina naturally PERMIT NO. NC0004987 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 provisions of North Carolina General Statute 143-215.1, other Iawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Duke Energy Carolinas, LLC is hereby authorized to discharge wastewater from a facility located at Marshall Stearn Station At the intersection of NC Highway 150 and NCSR 1842 Terrell Catawba County to receiving waters designated as the Catawba River (Lake Norman) in the Catawba River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and W hereof. This permit shall become effective July 1, 2009. This permit and authorization to discharge shall expire at midnight on April 30, 2010. Signed this day June 15, 2009. 'C--oicen H. Sullins, Director f Division of Water ty Quali By Authority of the Environmental Management Commission Page 1 of 13 PERMIT NO. NC0004987 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits . issued to this facility, whether for operation or discharge are hereby revoked, and as of this 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. Duke Energy Carolinas, LLC is hereby authorized to: 1. Continue to discharge once -through cooling water and intake screen backwash through outfall 001; treated wastewater (consisting of metal cleaning wastes, coal pile runoff, ash transport water, domestic wastewater, low volume wastes, and flue gas desulfurization (FGD) wet scrubber wastewater) from the ash settling basin through outfall 002; treated FGD wet scrubber wastewater through internal outfall 004 (upstream of the ash settling basin); yard sump overflows through outfalls 002A and 002B; and non -contact cooling water from the induced draft fan control house through outfall 003. All discharges result from activities at Duke Energy's Marshall Steam Station at the intersection of NC Highway 150 and NCSR 1841 in Terrell, Catawba County; 2. Continue to operate a FGD wet scrubber wastewater treatment system discharging to the ash settling basin through internal outfall 004; and 3. Discharge from said treatment works at the locations specified on the attached map into the Catawba River (Lake Norman) which is classified WS-IV and B CA waters in the Catawba River Basin. ?age 2of13 Outfall Information O)tfall w; RetTivha Stream; 1 kg:* t.onoitude; 001 Catawba River 35°35'42' 80°57'44" OutfarLi, 002 RecgivirSt{gam' Catawba River �aut�d 35°36'22' Lenaitude; 80°57'40- f Outfali A Receivina Stream; Latitude: 10-1 g_ifude: 002A and 0023 Catawba River 35°35'57' 80°57'47' Outtall k_ Receiving Stream+ Latitude! Longitude: 003 Catawba River 35°35'51 " 80°57'45" Duke Power Corporation NC0004987 Marshall Stearn Station PART I SECTION A: FINAL LIMITATIONS AND CONTROLS 1. Effluent Limitations and Monitoring Requirements (Outfall 001) During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Dudall 001 (once -through cooling water). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS DISCHARGE LIMITATIONS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location Flow.(MGD) Monitor & Report Daily Pump logs or similar readings Effluent Temperature (November 1- June 30) 33.3 eC Daily Grab Effluent Temperature • (July 1 - October 31) 34.4 aC Daily Grab Effluent Free Available Chlorines 0.2 rng/L 0.5 mg/L Daily Grab Effluent NOTES: 1 Once -through cooling water shall not be chlorinated. Should the facility wish to chlorinate once - through cooling water, a permit modification must be issued prior to commencement of chlorination. The monitoring requirement and effluent limitations only apply if chlorination is commenced. There shall be no discharge of floating solids or visible foam in other than trace amounts. The Regional Administrator has determined pursuant to Section 316(a) of the Act that the thermal component of the discharge assures the protection and propagation of a balanced, indigenous population of shellfish and wildlife in and on the receiving body of water. Water quality temperature standards must be maintained outside the approved 316(a) mixing zone. Page 4 of 13 PART I 2. Effluent Limitations and Monitoring Requirements (Outfall 002) During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 002 (ash settling basin discharge). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS Flow (MGD) Oil and Grease Total Suspended Solids' Total Arsenic DISCHARGE LIMITATIONS I MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Measurement Maximum Frei uezx Monitor & Report 9.0 xng/L 20.0 mg/L 05.0 mg/L Monitor & Report 12.0m1/L Monthly Quarterly Monthly Sample Type Sample Location Pump logs or similar readings Grab Grab Effluent Effluent Effluent Quarterly Grab Effluent Chloride Monitor & Report Quarterly Grab Effluent Total Copper Total Iron 1.0 mg/L 1.0 mg!.L, See note 3 Grab Effluent 1.0 mg/I, ; 1.0 mg/I., See note 3 Grab Effluent Toral Mercury Monitor & Report Quarterly Grab Effluent Total Nickel Monitor & Report Quarterly Grab Effluent Total Selenium Total Selenium' Total Zinc Total Nitrogen (NO2+NO3±TKN) Total Phosphorus Monitor & Report Weekly �29 ug/1 56 ug/1 Weekly Grab Effluent Monitor & Report Monthly Grab Grab Effluent Effluent. Monitor & Report Monthly Monitor & Report Quarterly Grab Grab Effluent Effluent Chronic Toxicity See Part I, Section A, #14 Quarterly Grab Effluent p Ii Between 6.0 and 9.0 Standard Units Monthly Grab Effluent Pollutant Analysis See part I, Section A, #20 Grab Effluent NOTES: 1 Effluent sampling shall be conducted at the discharge from the ash settling basin prior to mixing with any other waste stream(s). 2 A total suspended solids monthly average of 40 mg/L is permitted provided the Permittee can demonstrate that the difference between the monthly average of 20 mg/L and 40 mg/L is the result of the concentration of total suspended solids in the intake water. 3 Monitoring shall be per occurrence of chemical metal cleaning and samples shall be from a representative discharge. 4 There will be a three year compliance schedule for the weekly average limit of 29 ug%l and the daily maximum limit of 56 ug/I for selenium. The limits shall become effective on July 1, 2012. See Part I Section A.23 for Selenium Compliance Schedule There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 5 of 13 PART I 3. Effluent Limitations and Monitoring Requirements (Outfall OO2A) During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 002A (yard sump #1 overflows). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS DISCHARGE LIMITATIONS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location' Flow (MGD) L Episodic Estimate Effluent pH Episodic Grab Effluent Total Suspended Solids Episodic Grab Effluent Total, Iron See note 2 Grab Effluent NOTES: 1 Effluent samples shall be collected at a point upstream of the discharge to the Catawba River. 2 Sampling for Iron is required when TSS is reported as greater than 100 mg/L. There shall be no discharge of floating solids or visible foam in other than trace amounts. All flows shall be reported on monthly DMRs. Should no flow occur during a given month, the words "No Flow' shall be clearly written on the front of the OMR Episodic sampling is required per sump overflow occurrence lasting longer than one hour. All samples shall be of a representative discharge. Page 6 of 13 PART I 4. Effluent Limitations and Monitoring Requirements (Outfall 002B) During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 002B (yard sump #2 overflows). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS DISCHARGE LIMITATIONS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location= Flow (MGD) Episodic Estimate Effluent pH Episodic Grab Effluent Total Suspended Solids Episodic Grab Effluent Total Iron Seenote 2 Grab Effluent NOTES: I Effluent samples shall be collected at a point upstream of the discharge to the Catawba River. 2 Sampling for iron is required when 'TSS is reported as greater than 100 mg/L. There shall be no discharge of floating solids or visible foam in other than trace amounts. All flows shall be reported on monthly DMRs. Should no flow occur during a given month, the words No Flow" shall be clearly written on the front of the DMR. Episodic sampling 1s required per sump overflow occurrence lasting Longer than one hour. All samples shall be of a representative discharge. Pagc 7 of 11 PART I 5. Effluent Limitations and Monitoring Requirements (Outfall 003) During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfanl 003 (non -contact cooling water from the induced draft fan control house). Such discharges shall be limited and monitored by the Pei mittee as specified below: EFFLUENT CHARACTERISTICS DISCHARGE LIMITATIONS MONITORING REQUIREMENTS _ Monthly Average Daily Maximum , Measurement Frequency Sample • Type Sample Location Flow (MGD) Temperature Total Residual Chlorine:: Free Available Chlorine2 0.2 mg/L 0.5 mg/L r PH Between 6.0 and 9.0 Standard Units NOTES: 1 The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 2.80C and in no case cause the ambient water temperature to exceed 29°C. 2 Monitoring requirements apply only if chlorine is added to the cooling water. Neither free available chlorinenor total residual chlorine may be discharged from any unit for more than two hours in any one day and not more than one unit in any plant may discharge free available chlorin a or total residual chlorine at any one time. There shall be no discharge of floating solids or visible foam in other than trace amounts. Limitations shall be met at the discharge effluent. Monitoring frequencies are not specified as the discharge is to the intake canal for outran 001. Page $ of 13 PART I 6. Effluent Limitations and Monitoring Requirements (Outfall 004) During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Internal Outfall 004 (treated FGD wet scrubber wastewater to ash settling basin). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENTDISCHARGE CHARACTERISTICS LIMITATIONS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location' Flow (MGD) Monitor & Report Monthly Pump logs or similar readings E Total Arsenic Monitor & Report Quarterly Grab E Chloride Monitor & Report Quarterly Grab E Total Mercury Monitor & Report Quarterly Grab E Total Nickel Monitor & Report Quarterly Grab E Total Selenium Monitor & Report Weekly Grab I; Total Zinc Monitor & Report Monthly Grab E N0'rES: 1 Sample Location: E - Effluent from the constructed wetland prior to discharge to the ash settling basin. All flows shall be reported on monthly DMRs. Should no flow occur during a given month, the words "No Flow" shall be clearly written on the front of the DMR. All samples shall be of a representative discharge. Page 9 of 13 PART I 7. DEFINITIONS The term "low volume waste sources" means, taken collectively as if from one source, wastewater from all sources except those for which specific limitations are otherwise established in this part. Low volume wastes sources include, but are not limited to: Wastewater from wet scrubber air pollution control systems, ion exchange water treatment system, water treatment evaporator blowdown, laboratory and sampling streams, boiler blowdown, floor drains, and recirculating house service water systems. Sanitary and air conditioning wastes are not considered low volume wastes. The term "metal cleaning waste" means any wastewater resulting from cleaning (with or without chemical cleaning compounds) any metal process equipment including, but not limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning. The term, "chemical metal cleaning waste' means any wastewater resulting from the cleaning of any metal process equipment with chemical compounds, including, but not limited to. boiler tube cleaning. Chemical metal cleaning will be conducted according to approved Duke Power equivalency demonstration. The term 'TGD wet scrubber wastewater" means wastewater resulting from the use of the flue -gas desulfurizatlon wet scrubber. 8. TOXICITY RE -OPENER CONDITION This permit shall be modified, or revoked and reissued to incorporate toxicity limitations and monitoring requirements in the event toxicity testing or other studies conducted an the effluent or receiving stream indicate that detrimental effects may be expected in the receiving stream as a result of this discharge. 9. MONITORING FREQUENCIES If the Permittee. after monitoring for at Ieast six ,months, determines that effluent limits contained herein are consistently being met, it may be requested of the Director that the monitoring requirements be reduced to a lesser frequency. 10. POLYCHLORINATED BIPHENYL COMPOUNDS There shall be no discharge of polychlorinated biphenyl compounds such as those commonly used for transformer fluid. 11. BIOCIDE CONDITION The permittee shall not use any biocides except those approved in conjunction with the permit application. The permittee shall notify the Director in writing not later than ninety (90) days prior to instituting use of any additional biocide used in cooling systems which_may be toxic to aquatic life other than those previously reported to the Division of Water Quality. Such notification shall include completion of Biocide Worksheet Form 101 and a rnap locating the discharge point and receiving stream. Completion of Biocide Worksheet Form 101 is not. necessary for those outfalls containing toxicity testing. Division approval is not necessary for the introduction of new biocides into outfalls currently tested for whole effluent toxicity. 12. INTAKE SCREEN BACKWASH Continued intake screen backwash discharge and overflow from the settling basin are permitted without limitations or monitoring requirements. 13. BEST MANAGEMENT PRACTICES It has been determined from information submitted that the plans and procedures in place at Marshall Steam Station are equivalent to that of a Best Management Practice (BMP). Page 10of13 PART I 14. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)- OUTFALL 002 The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 12%. The permit holder shall perform at a minimum. ouarterto monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of February, May, August., and November. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results In a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum. in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods. exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised - February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed. If reporting pass/fail results using the parameter code TGP3B, DWQ Form AT-1 (original) is sent to the below address. If reporting Chronic Value results using the parameter code THP3B. DWQ Form AT-3 (original) is to be sent to the following address: Attention: Environmental Sciences Section North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, North Carolina 27699-I621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Sectiora no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. 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 perxnittee 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 Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement 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. If the Pcrmittee monitors any pollutant more frequently then required by this permit, the results of such monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT Forms submitted. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no Iater than the last day of the month following the month of the initial monitoring. Page I I of 13 PART I 15. ASH SETTLING BASIN Beginning on the effective date of this permit and lasting until expiration, there shall be no discharge of plant wastes to the ash pond unless the permittee provides and maintains at all times a minimum free water volume equivalent to the sum of the maximum 24-hour plant discharges plus all direct rainfall and all runoff flows to the pond resulting from a IO-year, 24-hour rainfall event, when using a runoff coefficient of 1.0. During the term of the permit, the permittee shall remove settled material from the ponds or otherwise enlarge the available storage capacities in order to maintain the required minimum volumes at all times. Annually the permittee shall determine and report to the permit issuing authority: (1) the actual free water volume of' the ash pond, (2) physical measurements of the dimensions of the free water volume in sufficient detail to allow validation of the calculated volume, and (3) a certification that the required volume is available with adequate safety factor to include all solids expected to be deposited in the ponds for the following year. Any changes to plant operations affecting such certification shall be reported to the Director within five days. NOTE: In the event that adequate volume has been certified to exist for the term of the permit, periodic certification is not needed. 16. CHEMICAL METAL CLEANING WASTES It has been demonstrated that under certain conditions it is possible to reduce the concentration of metals in boiler cleaning wastes in the range of 92 to 99+ percent by treatment in ash ponds. Because of dilution problems, and the existence of boundary interface layers at the extremities of the plume, it is difficult to prove beyond doubt that the quantity of iron and copper discharged will always be Iess than one milligram per Inter times the flow of metal cleaning when treated in this manner. The application of physical/chemical methods of treating wastes has also been demonstrated to be effective in the treatment of metal cleaning wastes. However, the effectiveness of ash pond treatment should be considered in relation to the small differences in effluent quality realized between the two methods. It has been demonstrated that the presence of ions of copper, iron, nickel, and zinc fn the ash pond waters was not measurably increased during the ash pond equivalency demonstration at the Duke Power Company's Riverbend Steam Station. Therefore, when the following conditions are implemented during metal cleaning procedures, effective treatment for metals can be obtained at this facility: (1) Large ash basin providing potential reaction volumes. (2) Well-defined shallow ash delta near the ash basin influent. (3) Ash pond pH of no less than 6.5 prior to metal cleaning waste addition. (4) Four days retention time in ash pond with effluent virtually stopped. (5) Boiler volume less than 86,000 gallons. (6) Chemicals for cleaning to include only one or more of the following: (a) Copper removal step- sodium bromate, NaBrOa: ammonium carbonate, (NH4)2CO3; and ammonium hydroxide, NH4OH. (b) Iron removal step -hydrochloric acid, HCI: and ammonium bifluoride, (NI-14)BF2 and proprietary inhibitors. (7) Maximum dilution of wastes before entering ash pond 6 to 1. (8) After treatment of metal cleaning wastes, if monitoring of basin effluents as required by the permit reveals discharges outside the limits of the permit, the permittee will re -close the basin discharge, conduct such in -basin sampling as necessary to determine the cause of nonconformance, will take appropriate corrective actions. and will file a report with EPA including all pertinent data. 17. FLOATING MATERIALS The Permittee shall report all visible discharges of floating materials, such as an oil sheen, to the Director when submitting DMRs. 18. DIKE INSPECTIONS The permittee shall check the diked areas for leaks by a visible inspection and shall report any leakage detected. Page i 2 of 13 PART I 19. CHEMICAL DISCHARGES Discharge of any product registered under the Federal Insecticide. Fungicide, and Rodenticide Act to any waste stream which may ultimately be released to lakes, rivers, streams or other waters of the United States is prohibited unless specifically authorized elsewhere in this permit. Discharge of chlorine from the use of chlorine gas, sodium hypochlorite, or other similar chlorination compounds for disinfection in plant potable and service water systems and in sewage treatment is authorized. Use of restricted use pesticides for lake management purposes by applicators licensed by the N.C. Pesticide Board is allowed. 20. PRIORITY POLLUTANT ANALYSIS The Permittee shall conduct a priority pollutant analysis (in accordance with 40 CFR Part 136) once per permit cycle at outfall 002 and submit the results with the application for permit renewal. 21. WAIVERS Nothing contained in this permit shall be construedas a waiver by permittee or any right to a hearing it may have pursuant to State or Federal laws or regulations. 22. SECTION 316 (B) OF CWA The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95. 23. COMPLIANCE SCHEDULE FOR SELENIUM LIMITATION The permittee shall have a three year schedule of compliance for the effluent limitation for total selenium. The following are interim milestones for the installation of the proposed treatment system. The date for compliance with the selenium limit shall be July 1, 2012 • Technology selection, treatment system design and obtaining an authorization to construct permit for the wastewater treatment system by August 31, 2010 • Construction of wastewater treatment system and corrunissioning by June 30, 2012 o Compliance with selenium limit - July 1, 2012 Page 13 of 13 NPDES Permit Standard Conditions Page 1 of 16 PART II STANDARD CONDITIONS FOR NPDES PERMITS Section A. Definitions 2/Month Samples are collected twice per month with at least ten calendar days between sampling events. 3/Week Samples ate collected three times per week on three separate calendar days. Act or "the Act" The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC 1251, et. seq. Annual Average The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal conform, the geometric mean of such discharges. Arithmetic Mean The summation of the individual values divided by the number of individual values. Bypass The known diversion of waste streams from any portion of a treatment facility ificluding the collection system, which is not a designed or established or operating mode for the facility. Calendar Day The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any consecutive 24-hour period that reasonably represents the calendar day may be used for sampling. Calendar Quarter One of the following distinct periods: January through March, April through June, July through September, and October through December. Composite Sample A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 ml in such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The Director may designate the most appropriate .method (specific number and size of aliquots necessary, the time interval between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Composite samples may be obtained by the following methods: (1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow. (2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period of discharge and combined proportional to the rate of flow measured at the time of individual sample collection, or (3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period with the time intervals between samples determined by a preset number of gallons passing the sampling point. Flow measurement .between sample intervals shall be determined by use of a flow recorder and totalizer:, and the preset gallon interval between sample collection feted at no greater than 1/24 of the expected total daily flow at the treatment system, or (4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a constant time interval. Use of this method requites prior approval by the Director. This method may only be used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply: > Influent and effluent grab samples shall be of equal size and of no less than 100.milliliters Version 10/1012007 NPDES Pemlit Standard Conditions Page 2of16 ➢ Influent samples shall not be collected more than once per hour. > Permittces with wastewater treatment systems whose detention time C 24 hours shall collect effluent grab samples at intervals of no greater than 20 minutes apart during any 24-hour period. • Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent grab samples at least every X hours [X = days detention time] over a 24-hour period. Effluent samples shall be collected at least every six hours; there must be a minimum of four samples•during a 24- hour sampling period. Continuous flow measurement Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be monitored continually except for the infrequent times when there may be no flow ox for infrequent maintenance activities on the flow device. Daily Discharge The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as the total mass of the pollutant discharged over the day. The "daily discharge" concentration comprises the mean concentration for a 24-hour sampling period as either a composite sample concentration or the arithmetic mean of all grab samples collected during that period. (40 CFR 122.2) Daily Maximum The highest "daily discharge" for conventional and other non -toxicant parameters. NOTE: Permittees may not submit a "daily average" calculation [for determining compliance with permit limits] for toxicants. See the relevant Federal effluent guideline's] for the appropriate calculation interval. Daily Sampling Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified iir the permit. The Division expects that sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s), that requirement will be so noted on the Effluent Limitations and Monitoring Page(s). DWQ or "the Division" The Division of Water Quality, Department of Environment and Natural Resources. I ,MC The North Carolina Environmental Management Commission. Facility Closure The cessation of wastewater treatment at a permitted facility, or the cessation of all activities that require coverage under the NPDES. Completion of facility closure will allow this permit to be rescinded. Geometric Mean The Nth root of the product of the individual values where N = the number of individual values. For purposes of calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = I. Grab Sample Individual samples of at least 100 ml collected over a period of time not exceeding 15 minutes. Grab samples can be collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream samples). Hazardous Substance Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CIean Water Act, Version 10/10/2007 NPDES Permit Standard Conditions Page 3of1G Instantaneous flow measurement A measure of flow taken at the time of sampling, when both the sample and flow will be representative of the total discharge. Monthly Average (concentration limit). The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal conform, the geometric mean of such discharges. Permit Issuingiluthority The Director of the Division of Water Quality. Quarterly Average (concentration limit). The average of all samples taken over a calendar quarter. Severe property damage Substantial physical damage to property, damage to the treatment facilities which causes therm to become inoperable, or substantial and permanent loss of natural resources which can reasonably- be expected to occur in the absence of a bypass. Severe property damage excludes economic loss caused by delays in production, Toxic Pollutant: Any pollutant listed as toxic under Section 307(a) (1) of the Clean Water Act. Upset An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation. Weekly Average (concentration limit) The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal coliform, the geometric mean of such discharges. Section B. General Conditions 1. Duty to Comply The Pernnttee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or denial of a permit renewal application [40 CFR 122.41]. a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the CIean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under section 405(d) of the Clean Water Act within the time provided in the regulations that establish these standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the requirement. b. The Clean Water Act provides that any person who violates section 301, 302, 306, 307, 308, 318 or 405 of the Act, or any pen -nit condition or limitation implementing any such sections in a permit issued under section 402, or any requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is subject to a civil penalty not to exceed $25,000 per day for each violation. [40 CFR 122.41 (a) (2)l c. The Clean Water Act provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or 405 of the Act, or any condition or limitation implementing any of such sections in a permit issued under Version 10/1012007. NPDES Permit Standard Conditions Page 4of16 g• section 402 of the Act, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or 402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a negligent violation, a person shall be subject to criminal pcxialties of not more than $50,000 per day of violation, or by imprisonment of not more than 2 years, or both. [40 CFR 122.41 (a) (2)] d. Any person who knowins# violates such sections, or.such conditions or limitations is subject to criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In the case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both. [40 CFR 122.41 (a) (2)] e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit condition or limitation implementing any of such sections in a permit issued under section 402 of the Act, and who knows at that time that he thereby places another person in imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not more than 15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to $2,000,000 for second or subsequent convictions. [40 CFR 122.41 (a) (2)] f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North Carolina General Statutes § 143-215.6A] Any person may be assessed an administrative penalty by the Administrator for violating section 301; 302, 306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections in a permit issued under section 402 of this Act. Administrative penalties for Class I violations arc not to exceed $10,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed $25,000. Penalties for Class II violations are not to exceed $10,000 per day for each day during which tJae violation continues, with the maximum amount of any Class II penalty not to exceed $125,000. [40 CFR 122.41 (a) (3)] 2. Duty to Mitigate The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in violation of this permit with a reasonable likelihood of adversely affecting human health or the environment [40 CFR 122.41 (d)]. 3. Civil and Criminal Liability. Except as provided in permit conditions on 'Bypassing" (Part II. C. 4), "Upsets" (Part ]I. C. 5) and "Power Failures" (Part II. C. 7), nothing in this permit shall be construed to relieve the Permittee from any responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the responsibility for effective compliance may be temporarily suspended. 4. Oil and Hazardous Substance Liability Nothing in this permit shall be construed to prelude the institution of any legal action or relieve the Permittee from any responsibilities, liabilities, or penalties to which the Permittee is ox may be subject to under NCGS 143- 215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the responsibility for effective compliance may be temporarily suspended. Version 10/10/2007 NPDES Permit Standard Conditions Page 5of16 5. Property Rights The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of Federal, State or local laws or regulations [40 CFR 122.41 (g)]. 6. Onshore or Offshore Construction This permit does nor authorize or approve the construction of any onshore or offshore physical structures or facilities or the undertaking of any work in any navigable waters. 7. Severability The provisions of this permit are severable. If any provision of this permit, or the application of any provision of this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby [NCGS 150B-23]. 8. Duty to Provide Information The Pern ittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the Permit Issuing Authority niay request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the Permit Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41 (h)). 9. Duty to Reapply If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the Permittee must apply for and obtain a new permit [40 CFR 122.41 (b)]. 10. Expiration of Permit The Permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required by the agency authorized to issue permits no later than 180 days prior to the expiration date. Any Perxnittee that has not requested renewal at least 180 days prior to expiration, or any Pertnittce that does not have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will subject the Permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq. 11. Signatory Requirements All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified [40 CFR 122.41 (lc)]. a. All permit applications shall be signed as follows: (I) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision making functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating facilities, provided, the manager is authorized to make management decisions which govern the operation of the regulated facility including having the explicit or implicit duty of making major capital investment recommendations, and initiating and directing other comprehensive measures to assure long term environmental compliance with environmental laws and .regulations; the manager can ensure that the necessary systems are established or actions taken to gather complete and accurate information for permit application requirements; and where authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures . (2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or (3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or ranking elected official [40 CFR 122.22]. Version 10/10/2007 NPDES Permit Standard Conditions Page 6of16 b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be signed by a person described in paragraph a. above or by a duly authorized representative of that person. A person is a duly authorized representative only if: 1. The authorization is made in writing by a person described above; 2. The authorization specified either an individual or a position having responsibility for the overall operation of the regulated facility or activity, such as the position of plant manager, operator of a well or well field, superintendent, a position of equivalent responsibility, or an individual or position having overall responsibility for environmental matters for the company. (A duly authorized representative may thus be either a named individual or any individual occupying a named position.); and 3. The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22] c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, a new authorization satisfying the requirements of paragraph (b) of this section must be submitted to the Director prior to or together with any reports, information, or applications to be signed by an authorized representative [40 CFR 122.22] d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the following certification [40 CFR 122.22]; '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. l am aware that there am significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. ° 12. Permit Actions This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncompliance does not stay any permit condition [40 CFR 122.41 (f ]. 13. Permit Modificadon_Revocation and Reissuance, or Termination The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed by the Lrws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North Carolina General Statute 143-215.1 et. al. 14. Annual Administering and Compliance IVloniloring Fee Requirements The Perx nittee must pay the annual administering and compliance monitoring fee within thirty days after being billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 2H.0105 (b) (2) may cause this Division to initiate action to revoke the permit. Section C. Operation and Maintenance of Pollution Controls 1. Certified Operator Upon classification of the permitted facility by the Certification Commission, the Permittee shall employ a certified water pollution control treatment system operator in responsible charge (ORC) of the water pollution control treatment system. Such operator must hold a certification of the grade equivalent to or greater than the classification assigned to the water pollution control treatment system by the Certification Commission. The Pemuttee must also employ one or more certified Back-up ORCs who possess a currently valid certificate of the type of the system. Back-up ORCs must possess a grade equal to (or no more than one grade Iess than) the grade of the system [15A NCAC 8G,0201]. Version 10/10/2007 NPDES Permit Standard Conditions Page 7of16 The ORC of each Class I facility must: Visit the facility at least weekly Comply with all other conditions of 15A NCAC 8G.0204. The ORC of each Class II, III and IV facility must: ➢ Visit the facility at least five days per week, excluding holidays 9 Properly manage and document daily operation and maintenance of the facility Comply with all other conditions of I5A NCAC 8G.0204. Once the facility is classified, the Permittee shall submit a letter to the Certification Commission designating the operator in responsible charge: a. Within 60 calendar days prior to wastewater being introduced into a new system b. Within 120 calendar days of: 9 Receiving notification of a change in the classification of the system requiring the designation of a new ORC and back-up ORC 9 A vacancy in the position of ORC or back-up ORC. 2. Proper Operation and Maintenance The Permittee shall at all times provide the operation and maintenance resources necessary to operate the existing facilities at optimum efficiency, The Pern tttee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Pertnittee to achieve compliance with the conditions of this permit Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary facilities only when necessary to achieve compliance with the conditions of the permit [40 CFR 122.41 (e)]. 3. Need to Halt or Reduce not a Defense It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41 (c)]. 4. Bypassing of Treatment Facilities a. Bypass not exceeding limitations [40 CFR 122.41 (m) (2)] The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the provisions of Paragraphs b. and c. of this section. • b. Notice [40 CFR 122.41 (m) (3)] (1) Anticipated bypass_ If the Permittee notice, if possible at least ten days •anticipated quality and effect of the hyp (2) Unanticipated bypass. The Pernaittce II. E. 6. (24-hour notice). c. Prohibition of Bypass (1) Bypass from the treatment facility is prohibited and the Pezm.it Issuing Authority may take enforcement action against a Permittee for bypass, unless: (A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; (B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes or maintenance during normal periods of equipment downtime. This condition is not satisfied if adequate backup equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance; and (C) The Permittee submitted notices as required under Paragraph b. of this section. ]mows in advance of the need for a bypass, it shall submit prior before the date of the bypass; including an evaluation of the ass. shall submit notice of an unanticipated bypass as required in Part Version 10/10/2007 NPDES Permit Standard Conditions Page 8 0116 (2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement action against a Permittee for a bypass as provided in any current or future system -wide collection system permit associated with the treatment facility. (3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c. (1) of this section. 5. Upsets a. Effect of an upset [40 CFR 122.41 (n) (2)1: An upset constitutes an affirmative defense to an action brought for noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of this condition are met. No determination made during administrative review of claims that noncompliance was caused by upset, and before an action for noncompliance, is final administrative action subject to judicial review. b. Conditions necessary for a demonstration of upset: A Permittee who wishes to establish the affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant evidence that: (1) An upset occurred and that the Permirtee can identify the cause(s) of the upset; (2) The Permittee facility was at the time being properly operated; and (3) The Permittee submitted notice of the upset as required in Part II. E. 6. (b) of this permit. (4) The Permittee complied with any remedial measures required under Part II. B. 2. of this permit. c. Burden of proof [40 CFR 122,41 (n) (4)]: The Permitter: seeking to establish the occurrence of an upset has the burden of proof in any enforcement proceeding. 6. Removed Substances Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant from such materials from entering waters of the State or navigable waters of the United States. The Permitter shall comply with all existing Federal regulations governing the disposal of sewage sludge. Upon promulgation of 40 CFR Part 503, any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR 503. The Permittee shall comply with applicable 40 CFR 503 Standards for the Use and Disposal of Sewage Sludge. (when promulgated) within the time provided in the regulation, even if the permit is not modified to incorporate the requirement. The Permittee shall notify the Persnit Issuing Authority of any significant change in its sludge use or disposal practices. 7. Power Failures The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 2H.0124 — Reliability) to prevent the discharge of untreated[ or inadequately treated wastes during electrical power failures either by means of alternate power sources, standby generators or retention of inadequately treated effluent. Section D. Monitoring and Records 1. Representative Sampling Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of the permitted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is characteristic of the discharge over the entire period the sample represents. All samples shall be taken at the monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream, body of water, or substance. Monitoring points shall not be changed without notification to and the approval of the Permit Issuing Authority [40 CFR 122.41 (j)]. Version 10/1012007 NPDES Permit Standard Conditions Page 9ofl6 2. Reporting Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a monthly Discharge Monitoring Report (DMR) Form (MR 1, 1.1, 2, 3) or alternative forms approved by the Director, postmarked no later than the last calendar day of themonth following the completed reporting period. The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of these, and all other reports required herein, shall be submitted to the following address: NC DENR / Division of Water Quality / Water Quality Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 3. Flow Measurements Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a maximum deviation of less than 10%0 from the true discharge rates throughout the range of expected discharge volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device. The Director shall approve the flow measurement device and monitoring location prior to installation. Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part 1 of this permit and based on the manufacturer's pump curves shall not be subject to this requirement 4. Test Procedures Test procedures for the analysis of pollutants shall conform to the EMC regulations (published. pursuant to NCGS 143-215.63 et seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act (as Amended), and 40 CFR 136; or in the case of sludge use or disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been specified in this permit [40 CFR 122.41]. To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection and reporting levels that are below the permit disrharge requirements and all data generated must be reported down to the minimum detection or lower reporting level of the procedure. If no approved methods are determined capable of achieving minimum detection and reporting Levels below permit discharge requirements, then the most sensitive (method with the lowest possible detection and reporting level) approved method trust be used. 5. Penalties for Tampering The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring de -vice or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If a conviction of a person is for a violation committed after a first conviction of such person under this paragraph, punishment is a fine of not more than $20,000 per day of violation, or by imprisorunent of not more than 4 years, or both [40 CFR 122.41]. 6. Records Retention Except fox records of monitoring information required by this permit related to the Pettnittee's sewage sludge use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR 503), the Pertnittee shall retain records of all monitoring information, including. ➢. all calibration and maintenance records. Y all original strip chart recordings for continuous monitoring instrumentation Version 10/10/2007 NPDES Permit Standard Conditions Page 10 of 16 Y copies of all reports required by this permit D copies of all data used to complete the application for this permit These records or copies shall be maintained for a period of at least 3 years from the date of the sample, measurement, report or application. This period may be extended by request of the Director at any time [40 CFR 122.41]. 7. Recording Results For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record the following information [40 CFR 122.411: a. The date, exact place, and time of sampling or measurements; b. The individual(s) who performed the sampling or measurements; c. The date(s) analyses were performed; d. The individual(s) who performed the analyses; e. The analytical techniques or methods used; and f. The results of such analyses. 8. Inspection and Entry The Petrnittee shall allow the Director, or an authorized representative (including an authorized contractor acting as a representative of the Director), upon the presentation of credentials and other documents as may be required by law, to; a. Enter upon the Permittee`s premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of this permit; b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this pit; c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this permit; and d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise authorized by the Clean Water Act, any substances or parameters at any location [40 CFR 122.41 (i)]. Section E Reporting Requirements 1. Change in Discharge All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute a violation of the permit. 2. Planned Changes The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions to the permitted facility [40 CFR 122.41 (1)]. Notice is required only when: a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR 122.29 (b); or b. The alteration or addition could significantly change the nature or increase the quantity of pollutants discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to notification requirements under 40 CFR 122.42 (a) (1). c. The alteration or addition results in a significant change in the Permirtec's sludge use or disposal practices, and such alteration, addition or change may justify the application of permit conditions that are different from or absent in the existing permit, including notification of additional use or disposal sites not reported during the permit application process ornot reported pursuant to an approved land application plan. 3. Anticipated Noncompliance The Pemuttee shall give advance notice to the Director of any planned changes to the permitted facility or'other activities that might result in noncompliance with the permit [40 CFR 122.41 (1) (2)]. Version 10/10/2007 NPDES Permit Standard Conditions Page llof16 4. Transfers This permit is not transferable to any person except after notice to the Director. The Director may require modification or revocation and reissuance of the permit to document the change of ownership. Any such action may incorporate other requirements as may be necessary under the Clean Water Act [40 CFR 122.41 (1) (3)]. 5. Monitoring Reports Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41 (I) (4)]. a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II. D. 2) or forms provided by the Director for reporting results of monitoring of sludge use oz disposal practices. b. If the Per nittee monitors any pollutant more frequently than required by this permit; the results of such monitoring shall be included in the calculation and reporting of the data submitted on the DMR. 6. Twenty-four Hour Reporting a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment. Any information shall be provided orally within 24 hours from the time the Permittee became aware of the circumstances. A written submission shall also be provided within 5 days of the time the Permittee becomes aware of the circumstances. The written submission. shall contain a description of the noncompliance, and its cause; the period of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40 CFR 122.41 ® (6)]. b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral report has been received within 24 hours. c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response personnel at (800) 662-7956, (800) 858-0368 or (919) 733-3300. 7. Other Noncompliance The Permittee shall report all instances of noncompliance not reported under Part H. E. 5 and 6. of this permit at the time monitoring reports are submitted. The reports shall contain the information listed in Part II. E. G. of this permit [40 CFR 122.41 (I) (7)]. 8. Other Information Where the Permittee becomes aware that it failed to submit any relevant facts in a permmit application, or submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or information [40 CFR 122.41 (1) (8)]. 9. Noncompliance Notification The Perminee shall report by telephone to either the central office or the appropriate regional office of the Division as soon as possible, bur in no case more than 24 hours or on the next worldng day following the occurrence or first knowledge of the occurrence of any of the following: a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge digester; the known passage of a slug of hazardous substance through the facility; or any other unusual circumstances. b. .Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc. c. Any failure of a pumping station, sewer line, or. treatment facility resulting in a by-pass directly to receiving waters without treatment of all or any portion of the influent to such station or facility. . Version 10/10/2007 NPDES Permit Standard Conditions Page 12 of 16 Persons reporting such occurrences by telephone shall also file a written report within 5 days following first knowledge of the occurrence. 10. Availability of Reports Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices of the Division. As required by the Act, effluent data shall not be considered confidential. Knowingly making any false statement on any such report may result in the imposition of r riminal penalties as provided for in NCGS 143-215.1 (b)(2) or in Section 309 of the Federal Act. 11. Penalties for Falsification of Reports The Clean eater Act provides that any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than 525,000 per violation, or by imprisonment for not more than two years per violation,or by both 140 CFR 122.41]. 12. Annual Performance Reports Perrnittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.1C). The report shall summarize the performance of the collection or treatment system, as well as the extent to which the facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality. The report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon which annual period is used for evaluation. PART III OTHER REQUIREMENTS Section A. Construction The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment capacity, nor change the treatment process(es) utilized at the treatment plant unless the Division has issued an Authorization to Construct (AtC) permit. Issuance of an AtC will not occur until Final Plans and Specifications for the proposed construction have been submitted by the Permittee and approved by the Division. Section B. Groundwater Monitoring The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to determine the compliance of this NPDES permitted facility with the current groundwater standards. Section C. Changes in Discharges of Toxic Substances The Permitter shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42): a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following "notification Ievels"; (1) One hundred micrograms per liter (100 t.tg/L); (2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitnile; five hundred micrograms per liter (500 pg/L) for 2.4-dinitrophenol and for 2-methyl-4.6-dinitrophenol; and one milligram per liter (l mg/L) for antimony; (3) Five times the ma:dinutn concentration value reported for that pollutant in the permit application. b. That any activity has occurred or will occur which would result in any discharge, on a non routine or infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following "notification levels"; Version 10/10/2007 NPDES Permit Standard Conditions Page 13of16 (1) Five hundred micrograms per liter (500 pg/L); (2) One milligram per liter (I mg/L) for antimony; (3) Ten times the maximum concentration value reported for that pollutant in the permit application. Section D. Evaluation of Wastewater Discharge Alternatives The Permittee shall evaluate all wastewater disposal alternatives and pursue the most environmentally sound alternative of the reasonably cost effective alternatives. If the facility is in substantial non-compliance with the terms and conditions of the NPDES permit or governing rules, regulations or laws, the Pertnittee shall submit a report in such form and detail as required by the Division evaluating these alternatives and a plan of action within 60 days of notification by the Division. Section E. Facility Closure Requirements The Permittee .must notify the Division at Ieast 90 days prior to the closure of any wastewater treatment system covered by this permit. The Division may require specific measures during deactivation of the system to prevent adverse impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the permitted facility. PART IV SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES Section A. Publicly Owned Treatment Works (POTWs) All POTWs must provide adequate notice to the Director of the following: 1. Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants; and 2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as influent to that POTW at the time of issuance of the permit. 3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of effluent introduced into the POTW, and (2) any anticipated impact of the change on the quantity or quality of effluent to be discharged from the POTW. Section B. Municipal Control of Pollutants from Industrial Users. 1. Effluent limitations axe listed in Part I of this permit. Other pollutants attributable to inputs from industries using the municipal system may be present in the Pennittee's discharge. At such time as sufficient information becomes available to establish limitatons for such pollutants, this permit may be revised to specify effluent limitations for any or all of such other pollutants in accordance with best practicable technology or water quality standards. 2. Under no circumstances shall the Permittee allow introduction of the following wastes in the waste treatment system: a, Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to, wastestrcams with a closed cup flashpoint of less than 140 degrees Fahrenheit of 60 degrees Centigrade using the test methods specified in 40 CFR 261.21; b. Pollutants which will cause corrosive structural damage to the POTW, but in no case Discharges with pH lower than 5.0, unless the works is specifically designed to accommodate such Discharges; c. Solid or viscous pollutants in amounts which will cause obstruction to the "flow in the POTW resulting in Interference; d. Any pollutant, including oxygen demanding pollutants (BOD, etc) released in a Discharge at a flow rate and/or pollutant concentration which will cause Interference with the POTW; e. Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no case heat in such quantities that the temperature at the POTW Treatment•Plant'exceeds 40°C: (104°F) unless the Division, upon request of the POTW, approves alternate temperature limits; Version .10/1012007 NPDES Permit Standard Conditions Page 14of16 f. Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will cause interference or pass through; g. Pollutants which result in the presence of toxic gases, vapors, or fumes within the POT\V in a quantity that may cause acute worker health and safety problems; h. Any trucked or hauled pollutants, except at discharge points designated by the POTW. 3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance by the Perrtuttee with all applicable effluent limitations. Such actions by the Permittee may be necessary regarding some or all of the industries discharging to the municipal system. 4. The Permittee shall require any industrial discharges sending influent to the permitted system to meet Federal Pretreatment Standards promulgated in response to Section 307(b) of the Act Prior to accepting wastewater from any significant industrial user, the Permittee shall eitherdevelop and submit to the Division a Pretreatment Program for approval per 15A NCAC 2H .0907(a) or modify an existing Pretreatment Program per 15A NCAC 2H .0907(b). 5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved POTW Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program as required under Section 402(b)(8) of the Clean Water Act and implementing regulations or by the requirements of the approved State pretreatment program, as appropriate. Section C. Pretreatment Programs Under authority of sections 307(b) and (c) and 402(b)(8) of the Clean Water Act and implementing regulations 40 CFR Part 403, North Carolina General Statute 143-215.3 (14) and implementing regulations 15A NCAC 2H .0900, and in accordance with the approved pretreatment program, all provisions and regulations contained and referenced in the Pretreatment Program Submittal arc an enforceable part of this permit. The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the Clean Water Act, the Federal Pretreatment Regulations 40 CFR Part 403, the State Pretreatment Regulations 15A NCAC 2H .0900, and the legal authorities, policies, procedures, and financial provisions contained in its pretreatment program submission and Division approved modifications there of. Such operation shall include but is not limited to the implementation of the following conditions and requirements: 1. Sewer Use Ordinance (SUO) The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. 2. Industrial Waste Survey (IWS) The Permittee shall update its Industrial Waste Survey (IWS) to include all users of the sewer collection system at least once every five years. 3. Monitoring Plan The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data to be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific pretreatment local limits. Effluent data from the Plan shall be reported on the DMRs (as required by Part II, Section D, and Section E.5). 4. Headworks Analysis (HWA) and Local Limits The Permittee shall obtain Division approval of a Headworks Analysis (HWA) at Ieast once every five years, and as required by the Division. Within 180 days of the effective date of this permit (or any subsequent permit modificadon) the Permittee shall submit to the Division a written technical evaluation of the need to revise local limits (i.e., an updated HW_A or documentation of Why one is not needed) [40 CFR 122.41]_ The Permittee shall develop, in accordance with 40 CFR 403.5(c) and 15A NCAC 2H .0909, specific Local Limits to implement the prohibitions listed in 40 CFR 403.5(a) and'(b) and 15A NCAC 2H .0909. Version 10110/2007 NPDES Permit Standard Conditions Page 15of16 5. Industrial User Pretreatment Permits (IUP) & Allocation Tables In accordance with NCGS 143-215.1, the Perrnittee shall issue to all significant industrial users, permits for operation of pretreatment equipment and discharge to the Permittee's treatment works. 'These permits shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special conditions, and compliance schedules as necessary for the installation of treatment and control technologies to assure that their wastewater discharge will meet all applicable pretreatment standards and requirements. The Permitter shall maintain a current Allocation Table (AT) which summarizes the results of the Headworks Analysis (HWA) and the limits from all Industrial User Pretreatment Permits (1UP). Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as determined by the HWA. 6. Authorization to Construct (AtC) The Perrnittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable industrial users for the construction or modification of any pretreatment. facility. Prior to the issuance of an AtC, the proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all Industrial User Pretreatment Permit (IUP) limitations. 7. POTW Inspection & Monitoring of their STUB The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division approved pretreatment program in order to determine, independent of information supplied by industrial users, compliance with applicable pretreatment standards. The Permittee must a. Inspect al! Significant Industrial Users (SIUs) at least once per calendar year, and b. Sample all Significant Industrial Users (SIUs) at least twice per calendar year for all permit - limited pollutants, once during the period from January 1 through June 30 and once during the period front July 1 through December 31, except for organic compounds which shall be sampled once per calendar year, 8. SIU Self Monitoring.and Reporting The Perrnittee shall require all industrial users to .comply with the applicable monitoring and reporting requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit, or in 15A NCAC 2H .0908. 9. nforcemcnt Response Plan (ERP) The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards promulgated pursuant to section 307(b) and (c) of the Clean Water Act (40 CFR 405 et. seq.), prohibitive discharge standards as set forth in 40 CFR 403.5 and 15A NCAC 2H .0909, and specific local limitations. All enforcement actions shall be consistent with the Enforcement Response Plan (ERP) approved by the Division. 10. Pretreatment Annual Reports (PAR) The Pen -nit -tee shall report to the Division in accordance with 15A NCAC 2H .0908. In lieu of submitting annual reports, Modified Pretreatment Programs developed under 15A NCAC 2H .0904 (b) may be required to meet with Division personnel periodically to discuss enforcement of pretreatment requirements and other pretreatment implementation issues. For all other active pretreatment programs, the Perrnittee shall submit two copies of a Pretreatmexit Annual Report (PAR) describing its pretreatment activities over the previous twelve months to the Division at the following address: NC DENR / DWQ / Pretreatment Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Version 10/10/2007 NPDES Permit Standard Conditions Page 16 of 16 These reports shall be submitted according to a schedule established by the Director and shall contain the following: a.) Narrative A brief discussion of reasons for, status of, and actions taken for all Significant Industrial Users (SIUs) in Significant Non -Compliance (SNC); b.) Pretreatment Program Summary (PPS) A pretreatment program summary (PPS) on specific forms approved by the Division; c.) Significant Non -Compliance Report (SNCR), The nature of the violations and the actions taken or proposed to correct the violations on specific forms approved by the Division; d.) Industrial Data Summary Forms (1DSF) Monitoring data from samples collected by both the POTW and the Significant Industrial User (SIU). These analytical results must be reported on Industrial Data Summary Forms (IDSF) or other specific format approved by the Division; e.) Other Information Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of SIUs in SNC, and any other information, upon request, which in the opinion of the Director is needed to determine compliance with the pretreatment implementation requirements of this permit; 11. Public Notice The Permittee shall publish annually a list of Significant Industrial Users (SIUs) that were in Significant Non -Compliance (SNC) as defined in the Permittce's Division -approved Sewer Use Ordinance with applicable pretreatmcxnt requirements and standards during the previous twelve month period. This list shall be published within four months of the applicable twelve-month period. 12. Record Keeping The Permittee shall retain for a minimum of three years records of monitoring activities and results, along with support information including general records, water quality records, and records of industrial impact on the POTW. 13. Funding and Financial Report The Permittee shall maintain adequate funding and staffing levels to accomplish the objectives of its approved pretreatment program. 14. Modification to Pretreatment Programs Modifications to the approved pretreatment program including but not limited to Iocal limits modifications, POTW monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan modifications, shall be considered a permit modification and shall be governed by 15 NCAC 2H .0114 and 15A NCAC 2H .0907. Version 10/10/2007 EXHIBIT C Duke Energy Marshall FGD Waste Water Selenium Reduction Project Bypass Piping and Dewatering Plan Request Authorization to Construct TWO (2) SETS OF SIGNED, SEALED AND DATED PLANS "FINAL DRAWING — NOT RELEASED FOR CONSTRUCTION" 4 EXHIBIT D Duke Energy Marshall Steam Station Marshall FGD Wastewater Selenium Reduction System BYPASS PIPING AND DEWATERING TECHNICAL SPECIFICATIONS January.6, 2010 Prepared by: Water's Edge Hydrology, Inc. & Gannett FIeming, Inc. Clearfield, Pennsylvania & Charlotte, North Carolina r . Professional Engineers Certification vod' (.-0 -1 CAP °0. +114.". °' GS B/O '°'1,ef, ", 2 0 SE�r o 2 �± �$EAL ' 17326 e • ° u n ° V S'4 Ij.1 i97954 ea Signature Date Jesse G. Hite, Jr., P.E North Carolina Professional Engineer No. 017126 Marshall FGD Wastewater Selenium Reduction System BYPASS PIPING AND DEWATERlNG TECHNICAL SPECIFICATIONS January 6, 2010 CONTENTS Page 1.0 GENERAL .. TS 1-1 1.1 PROJECT DESCRIPTION TS1-1 1.2 CONFIRMATION TS1-1 1.3 COMPLIANCE WITH PERMITS . TS1-2 2.0 PRODUCTS TSI-2 2.1 EROSION AND SEDIMENTATION CONTROL PRODUCTS TS1-2 2.1.1 Straw Bales TS 1-2 . 2.2 FLOW CONTROL PRODUCTS . TSI-2 2.2.1 Bypass Pipes and Fittings . TS1-2 2.2.2 Flexible Couplings TS1-2 2.2.3 Flow Control Valves ..TS1-2 3.0 EXECUTION . TS1-2 3.1 CONSTRUCTION SEQUENCE TS 1-2 3.2 EROSION AND SEDIMENTATION CONTROL TS1-4 3.2.1 Straw Bale Installation TS1-4 3.2.2 Maintenance TS1-4 3.2.3 Other Measures TS1-4 3.3 FLOW CONTROL ASSEMBLIES TS1-4 3.3.1 General TS1-4 3.3.2 Bypass Pipe Layout TS1-4 3.3.3 Pipe Support TS1-4 3.3.4 Flow Control Valves TSI-5 3.3.5 Connections to Existing Pipes TS1-5 3.3.6 Access Road Crossing TS1-5 3.4 DEWATERING PLAN TS1-5 3.4.1 Gravity Drainage TS1-5 3.4.2 Drainage Ditches and Sumps TS1-5 3.4.3 Pumping TS1-6 3.5 SURFACE MATERIAL .TS1-6 3.5.1 Surface Material Removal . TS 1-6 3.5.2 Mulching and Spreading TS 1-6 Water's Edge Hydrology, Inc. / Gannett Fleming, Inc. TS1-ii Marshall FGD Wastewater Selenium Reduction System BYPASS PIPING AND DEWATERING TECHNICAL SPECIFICATIONS January 6, 2010 1.0 GENERAL 1.1 PROJECT DESCRIPTION The purpose of the Marshall FGD Waste Water Selenium Reduction Project is to modify the Constructed Wetland Treatment System (CWTS) at Duke Energy's Marshall Steam Station to improve the removal of selenium. The modification will replace the first set of three (3) surface flow wetland (SFW) cells, identified as Wetland Cells 1A, 1B, and 1C, with six vertical flow wetland (VFW) cells to be located between the existing pair of equalization basins and the second set of existing SFW cells identified as Wetland Cells 2A, 2B, and 2C. The project will consist of two phases: (1) a bypass piping and dewatering plan and (2) construction plans for the VFW Treatment System. This request is for authorization to construct the bypass piping which will convey the FGD wastewaters around the construction area during construction and allow dewatering of the three SFW cells to be replaced with the VFW cells. A separate ATC request for the construction phase of the project will be submitted in February 2010. As shown on the attached drawings, an 18-inch HDPE bypass pipe will be installed between the equalization basins and Wetland Cells 2A, 2B, and 2C. The bypass pipe will be connected to the inlet pipes currently conveying wastewaters to Wetland Cells 1B and 1C. During the installation of the bypass piping, all flow will run through Wetland Cell 1A. Once the bypass piping is constructed, flow to Wetland 1A will be shut off. During the bypass phase, the 18-inch pipe will convey the wastewaters to Wetland Cells 2A, 2B, and 2C by control valves and separate pipes. The bypass pipe will be laid on the surface of the ground supported by retaining pipes driven into the ground along the downslope side of the pipe. To allow sufficient time to install and connect the bypass system, the equalization basins will be drawn down to provide extra storage capacity so that flows to the connecting pipes can be temporarily closed to allow completion of the connections. After the wetland cells are bypassed, drainage trenches and sumps will be cut into their existing substrates. The sumps will be periodically pumped with discharge of the pumped waters alternating between Wetland Cells 2B and 2C until the substrate is adequately dewatered for removal, stockpiling and reuse in the new VFW cells. Surface vegetation and organic matter removed from the dewatered cells will be mulched and spread in the remaining downstream wetland cells as an organic amendment. 1..2 CONFIRMATION All Plan Drawing features representing existing site conditions are based on ground surveying, and all elevations have been established relative to the elevation controls shown on the Plan Drawings and are not tied to USGS topographic elevations. The Contractor is responsible for confirming the accuracy of all existing site.conditions as they pertain to successful completion of this project, and for bringing to - the attention of the Buyer's Agent any discrepancies that may hinder this completion or result in a construction configuration significantly different from that intended by the Plan Drawings. Water's Edge Hydrology, Inc. / Gannett Fleming, Inc. TS1-1 Marshall FGD Wastewater Selenium Reduction System BYPASS PIPING AND DEWATERING TECHNICAL SPECIFICATIONS January 6, 2010 1.3 COMPLIANCE WITH PERMITS The Contractor assumes responsibility for meeting applicable water quality discharge standards for erosion and sediment control during construction. Under this provision, the Contractor shall be responsible for any fines levied as a result of discharge waters not meeting these standards. The Contractor may elect to employ erosion and sedimentation control practices in addition to those specified as needed to meet this obligation. The Contractor shall also comply with the conditions of all other permits applicable to the project, and shall be familiar with these permits as provided by the Buyer's Agent. 2.0 PRODUCTS 2.1 EROSION AND SEDIMENTATION CONTROL PRODUCTS 2.1.1 Straw Bales The Contractor shall maintain sufficient straw bales on site for placement if necessary for local erosion or sedimentation control. Straw bales shall be fifty (50) pounds weight minimum. Hay bales are not acceptable. 2.2 FLOW CONTROL PRODUCTS 2.2.1 Bypass Pipes and Fittings The Bypass Pipes and Fittings shall consist of twelve (12) inch and eighteen (18) inch SDR 32.5 high density polyethylene (HDPE) pipe as indicated on the Plan Drawings. HDPE pipes and fittings shall be heat fused according to manufacturers requirements. 2.2.2 Flexible Couplings Flexible Couplings shall be stock twelve (12) inch and eighteen (18) inch flexible couplings, as manufactured by Femco, Inc, suitable for coupling polyvinyl chloride (PVC) pipe to equal nominal diameter HDPE pipe. 2.2.3 Flow Control Valves Flow Control Valves shall be an Agri Drain Model VV 18, 18-inch in -line slide gate manufactured by Agri Drain Corporation. 3.0 EXECUTION 3.1 CONSTRUCTION SEQUENCE The following provides the suggested sequence of activities for implementation of this project. Some of these activities may be conducted concurrently depending on the stage of project completion as Water's Edge Hydrology, Inc. / Gannett Fleming, Inc. TS1-2 Marshall FGD Wastewater Selenium Reduction System BYPASS PIPING AND DEWATERING TECHNICAL SPECIFICATIONS January 6, 2010 approved by the Buyer's Agent. The Buyer's Agent must approve any alternative sequencing preferred by the Contractor. 1. Conduct a site meeting between the Contractor and the Buyer's Agent to review the project plans and designate access routes and staging areas. 2. InstalI Bypass Pipe and valves from near the connection points to the inlet pipes to Wetland Cells 1B and 1C down through the temporary pipes to Wetland Cells 2A, 2B, and 2C. 3. Manage flows to the equalization basins to allow at least 2 days of excess storage capacity. 4. Shut off flow from the equalization basins to the existing outlet box. 5. Open the stop gate to Wetland Cell 1A. 6. Install stop gates to 'shut off flow to Wetland Cells 1B and 1C. 7. Complete connections between the inlet pipes to Wetland Cells 1B and 1C and the Bypass Pipe. 8. Open stop gates on the equalization basin outlet pipes for Wetland Cells 1B and 1C (which are now bypassed). 9. Close the stop gate to Wetland Cell 1A. 10. Resume discharge from the equalization basins. 11. Remove all stop logs in the Wetland Cells 1A, 1B, and 1C outlets to begin dewatering of the surface waters. 12. When surface drainage via the existing outlets is complete, excavate sumps and drainage channels in Wetland Cells 1A, IB, and 1C to their Iiner elevations. 13. Pump collected sump waters alternately to Wetland Cells 2B and 2C until Wetland Cells 1A, 1B, and 1C are dewatered to the liner level. 14. When the upper six (6) inches or more of substrate has been dewatered in the drained wetland cells, remove surface material from the cells. 15. MuIch removed surface material and spread as an organic supplement to the remaining wetland cells. Water's Edge Hydrology, Inc. / Gannett Fleming, Inc. TS1-3 Marshall FGD Wastewater Selenium Reduction System BYPASS PIPING AND DEWATERING TECHNICAL SPECIFICATIONS January 6, 2010 3.2 EROSION AND SEDIMENTATION CONTROL 3.2.1 Straw Bale Installation The Contractor shall install local Straw Bales for temporary sediment control if necessary to comply with Item 1.3. Straw Bales shall be staked at a minimum using two (2) wood stakes having a one (1) foot minimum ground penetration when flush with the top of the bales. 3.2.2 Maintenance The Contractor shall routinely inspect any erosion and sedimentation control structures to assure their continued function, at the minimum after each precipitation event. Straw Bales shall be replaced if clogged or damaged. 3.2.3 Other Measures The Contractor shall implement the project plan in such a manner as to prevent the presence of standing water in any working areas. Activities shall be suspended during periods of excessive rainfall. 3.3 FLOW CONTROL ASSEMBLIES 3.3.1 General All pipe joints in this plan shall have water -tight seals; the Contractor is responsible for providing appropriate fittings and methods to achieve this. The Bypass Pipe shall be constructed in its entirety prior to connection to the existing wetland cell inlets. The Contractor shall inspect the bypass system for approval by the Buyer's Agent before proceeding with any connection activities. 3.3.2 Bypass Pipe Layout The Bypass Pipe shall be laid on the existing ground surface in the alignment shown on the Plan Drawings, such that positive drainage is maintained for its entire length. The Contractor may modify this alignment with approval from the Buyer's Agent to achieve satisfactory positive drainage. The Bypass Pipe shall be eighteen (18) inch diameter between the junction with the existing inlet pipe to Wetland Cell 1C and the tee to Wetland Cell 2B. All other segments shall be twelve (12) inch diameter. 3.3.3 Pipe Support The Bypass Pipe shall be supported from Iateral movement by three (3) inch diameter by five (5) foot steel pipe posts driven to a depth of at least three (3) feet on the downhill side of the pipe. The post spacing shall be a maximum of ten (10) feet in slope areas, and twenty five (25) feet elsewhere. Blocking may be required to support the pipe if it is vertically unsupported for a distance of ten (10) feet or more. Water's Edge Hydrology, Inc. / Gannett Fleming, Inc. TS1-4 MarshallFGD Wastewater Selenium Reduction System ' BYPASS PIPING AND DEWATERING TECHNICAL SPECIFICATIONS January 6, 2010 3.3.4 Flow Control Valves Flow Control Valves shall be installed: (I) on the inlet to Wetland Ce11 2C, (2) on the inlet to Wetland Cell 2B, and (3) on the pipe to Wetland CeI1 2A inunediately after the tee junction to Wetland Ce11 2B. Following initiation of bypass flows, the Flow Control Valves shall be adjusted to balance the flows between the three cells to the extent practicable. 3.3.5 Connections to Existing Pipes The Bypass Pipe shall be connected to the existing wetland cell inlet pipes using the specified flexible couplings. The existing inlet pipes shall be exposed sufficiently prior to connection that the connection can be accomplished immediately after cessation of flow from the equalization basins. The Contractor is responsible for providing pipe fittings to create a functional joint between the Bypass Pipe and the existing inlet pipes at the angles achievable by the design Iayout. 3.3.6 Access Road Crossing The Bypass Pipe shall be protected by a twenty-four (24) inch steel casing pipe where it crosses the existing access road. The Contractor shall provide cover fill at the direction of the Buyer's Agent to construct pipe cover and approach grades appropriate for site access by standard two -wheel -drive automobiles. 3.4 DEWATERING PLAN 3.4.1 Gravity Drainage After cessation of flow from the equalization basins, the stop logs in the existing wetland cell outlet controls shall be removed, and the cells will be allowed to drain by gravity for a period of at least twenty-four (24) hours before the excavation of drainage ditches begins. 3.4.2 Drainage Ditches and Sumps A system of Drainage Ditches shall be excavated into the existing wetland cell substrate in the general configuration indicated on the Plan Drawings. The Drainage Ditches shall terminate in Dewatering Sumps to be used for pumping. Ditches and Sumps shall be excavated to the top of the existing GCL Iiners. It is acceptable to remove the upper eighteen (18) inches of substrate using standard bucket equipment, provided that this depth will not intercept the existing liners. The remaining material shall be removed to the liner surface using a smooth -rim, rubber -sheathed bucket excavator or backhoe. Excavated substrate shall be cast into the cell onto surrounding substrate; no material may be placed outside of the cell. Water's Edge Hydrology, Inc. / Gannett Fleming, Inc. TSI-5 Marshall FGD Wastewater Selenium Reduction System BYPASS PIPING AND DEWATERING TECHNICAL SPECIFICATIONS January 6, 2010 3.4.3 Pumping The Dewatering Sumps shall be pumped down to the extent practicable on a regular basis starting immediately after gravity drainage is completed and continuing until no extractable drainage has occurred for three (3) consecutive weeks. A trash. pump or similar pump device shall be used capable of extracting less than two (2) inches of standing water. Pumped waters shall be discharged to the inlets of Wetland Cells 2B and 2C, alternating between the two cells every other week. All pumped waters shall be discharged through a filter sock appropriate for the pump apparatus employed. 3.5 SURFACE MATERIAL 3.5.1 Surface Material Removal The existing surface material within the wetland cells shall be removed to expose the inorganic subsurface substrate materials, such that these materials can be used for liner cover in later VFW system construction. Surface materials shall include all standing plants, plant roots, and organic sediment accumulations. Surface materials shall be removed and temporarily stockpiled in the area indicated on the Plan Drawings for later redistribution. Removal of surface materials shall not proceed until the upper six (6) inches of substrate have been dewatered to the satisfaction of the Buyer's Agent. 3.5.2 Mulching and Spreading The surface materials removed from the existing wetland cells shall be mulched (mechanically ground) in a process that either spreads or allows them to be broadcast spread for a linear distance of at least thirty (30) feet. An aerial spreading method such as a mulcher or spreader is appropriate. The recovered surface materials from Wetland Cells 1A, 1B, and 1C shaIl be uniformly mulched and spread in this manner along the perimeters of downstream Wetland Cells 2A, 2B, 2C, 4A, 4B, and 4C as a beneficial organic amendment. The Contractor shall determine from the volume of recovered surface material an appropriate spreading rate between these cells, for approval by the Buyer's Agent. Water's Edge Hydrology, Inc. / Gannett Fleming, Inc. TS1-6 EXHIBIT E Duke Energy Marshall FGD Waste Water Selenium Reduction Project Bypass Piping and Dewatering Plan Request Authorization to Construct BYPASS PIPE HYDRAULIC CALCULATIONS The following section illustrates the hydraulic calculations associated with the Bypass Piping System which will be used during construction of the Vertical Flow Wetland cells that will replace Surface Flow Wetlands 1A, 1B, and 1C. Hydraulic calculations were performed using the computer program Bentley Flowmaster, service pak 3, and program output is included in the appendix. The maximum total design flow rate through the system is 1580 gallons per minute (GPM). The pipe is 18-inch diameter HDPE, SDR 32.5 with an inside diameter of 16.89 inches. Pipe slope varies, but is generally not less than .5%. At the design flow, the depth of water in the pipe is 7.76 inches, or approximately 46% full Professional Engineers Certification .��;lasiii6i8a, te�a°°�-(�1 C/�I�Q�''is 4.4v....Ce+.eeee sio ``l� ° p SEAL e SEAL° m 17126 b e e aN��•. ,1G/NS �° G. Hi"��&o+°� Signature Date Jesse G. Hite, Jr., P.E North Carolina Professional Engineer No. 017126 Worksheet for Bypass Piping - Gravity Section Project Description Friction Method Solve For Input Data Manning Formula Normal Depth Roughness Coefficient 0.010 Channel Slope 0.00500 ft/ft Diameter 16,89 in Discharge 1580.00 gal/min Results Normal Depth 7.76 in Flow Area 0.70 ft2 Wetted Perimeter 2.10 ft Top Width 1.40 ft Critical Depth 0,73 ft Percent Full 45.9 Critical Slope 0.00329 ft/ft Velocity 5.05 ft/s Velocity Head 0.40 ft Specific Energy 1.04 ft Fronde Number 1.26 Maximum Discharge 8.77 ft'/s Discharge Fuji 3657.14 gal/min Slope Full 0.00093 ftlft Flow Type SuperCritical GVF Input Data Downstream Depth 0.00 in Length 0.00 ft Number Of Steps 0 GVF Output Data Upstream Depth 0.00 in Profile Description Profile Headioss 0.00 ft Average End Depth Over Rise 0.00 Normal Depth Over Rise 45.93 Downstream Velocity Infinity ft/s Upstream Velocity infinity ft/s 11812010 10:02:06 AM Bentley Systems, Inc. Haestad Methods Solution Center Bentley FtowMaster [08.01.071.00] 27 Siemons Company Drive Suite 200 W Watertown, CT 06795 USA +1.203-755.1665 Page 1 of 2 Worksheet for Bypass Piping - Gravity Section GVF Output Data Normal Depth 7,76 in Critical Depth 0.73 ft Channel Slope 0,00500 ft/ft Critical Slope 0.00329 ftfft Bentley Systems, Inc. Haestad Methods Solution Center Bentley FlowMaster [08.01.071.00] 1/8/2010 10:02:06 AM 27 Slemons Company Drive Suite 200 W Watertown, CT 06795 USA +1.203.755-1666 Page 2 of 2 EXHIBIT F Duke Energy Marshall FGD Waste Water Selenium Reduction Project Bypass Piping and Dewatering Plan Request Authorization to Construct 8% x 11 FLOW SCHEMATIC DIAGRAM / HDPE `\X,12° RE UC HOPE 18'90° ELBOW \\ %HDPE 18' TEE HDPE 18'X12' REDUCER / \ / \ / ,HDP 12' 9D\BOW7---. \ 12' HDPE TEMPORARY \\ BYPASS PIPE \ \ SCALE: NONE DATE: 1/08/10 OF PROJECT NO.: DRAWING: DEWATERING_8X11 PLOT FILE: DEWATERING_BX11 CTB FILE: MARSHALL.CTB HDPE 18'X12' REDUCER HDPE 18' 45° WYE 18' HDPE TEMPORARY BYPASS PIPE HDPE 18' 18' HDPE TEMPORARY BYPASS PIPE AGRIDRAIN 18° SLIDE GATE VALVE WETLAND CELL 2C fiannettFlening 800 Leonard Street Clearfield, PA 16830 (814) 765-4320 90° ELBOW WETLAND CELL 4C WETLAND CELL24 w N W E S EXHIBIT F Duke Energy Marshall FGD Waste Water Selenium Reduction Project Bypass Piping and Dewatering Plan Request Authorization to Construct Beverly Eaves Perdue Governor Mr. Ron Lewis Duke Energy Mail Code EC13K 526 S. Church Street Charlotte, North Carolina 28202 Dear Mr. Lewis: Al# NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Dee Freeman Director Secretary February 18, 2010 SUBJECT: Authorization to Construct A to C No. 004987A03 Duke Energy. Marshall Steam Station Flue Gas Desulfurization WWTP Improvements Phase 1: Bypass Piping and Dewateri„ng Plan Catawba County A letter of request for an Authorization to Construct was received January IA, 2010, by the Division of Water Quality (Division), and final plans and specifications for the subject project have been reviewed and found to he satisfactory. Authorization is hereby granted for the construction of modifications to the existing Flue Gas Desulfurization (FGD) Wastewater Treatment Plant, with discharge of treated wastewater into the Ash Settling Basin (via Internal Outfall 004), which discharges into the Catawba River (Lake Norman, Outfall 002) in the Catawba River Basin. This authorization results in no increase in design or permitted capacity and is awarded for the construction of the following specific modifications: Installation of an 18-inch HDPE gravity bypass pipe between the equalization basins and wetland cells 2A, 2B, and 2C, to allow removal of material in wetland cells 1 A, 1B and 1C for wetland conversion in a future authorization to construct, in conformity with the project plans, specifications, and other supporting data subsequently filed and approved by the Departrnent of Environment and Natural Resources.. This Authorization to Construct is issued in accordance with Part 111, Paragraph A of NPDES Permit No. NC0004987 issued June 15, 2009, and shall be subject to revocation unless the wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in Permit No. NC0004987. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Locatron: 512 N Salisbury St Raleigh, North Carolina 27604 Phone: 919-607-6300 `i FAX: 919-'807-6492 'r Customer Service: 1-677-623-6748 Internet: wymtncvaterguality:org An Equal Opparlunily Atturiattve Actmn Employer One North Car atura Mr. Ron Lewis February 18, 2010 Page 2 The sludge generated from these treatment facilities must be disposed of in accordance with G.S.143-215.-1 and in a manner approved by the Division. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take immediate corrective action, including those as may be required by the Division, such as the construction of additional or replacement wastewater treatment or disposal facilities. The Mooresville Regional Office, telephone number (704) 663-1699, shall be notified at least forty-eight (48) hours in advance of operation of the installed facilities so that an on site inspection can be made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. Upon completion of construction and prior to operation of this permitted facility, a certification must be received from a professional engineer certifying that the permitted facility has been installed in accordance with the NPDES Permit, this Authorization to Construct and the approved plans and specifications. Mail the Certification to: Construction Grants & Loans, DWQIDENR, 1633 Mail Service Center, Raleigh, NC 27699-1633. Upon classification of the facility by the Certification Commission, the Permittee shall employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of the wastewater treatment facilities. The operator must hold a certificate of the type and grade at least equivalent to or greater than the classification assigned to the wastewater treatment facilities by the Certification Commission. The Permittee must also employ a certified back-up operator of the appropriate type and grade to comply with the conditions of T15A:8G.0202. The ORC of the facility must visit each Class I facility at least weekly and each Class II, III and IV facility at least daily, excluding weekends and holidays, must properly manage the facility, must document daily operation and maintenance of the facility, and must comply with all other conditions of T15A:8G.0202. A copy of the approved plans and specifications shall be maintained on file by the Permittee for the life of the facility. During the construction of the proposed additions/modifications, the perrnittee shall continue to properly maintain and operate the existing wastewater treatment facilities at all times, and in such a manner, as necessary to comply with the effluent limits specified in the NPDES Permit. Mr. Ron Lewis February 18, 2010 Page 3 You are reminded that it is mandatory for the project to be constructed in accordance with the North Carolina Sedimentation Pollution Control Act, and when applicable, the North Carolina Dam Safety Act. In addition, the specifications must clearly state what the contractor's responsibilities shall be in complying with these Acts. Prior to entering into any contract(s) for construction, the recipient must have obtained all applicable permits from the State. Failure to abide by the requirements contained in this Authorization to Construct may subject the Permittee to an enforcement action by the Division in accordance with North Carolina General Statute 143-215.6A to 143-215.6C. The issuance of this Authorization to Construct does not preclude the Permittee from complying with any and all statutes, rules, regulations, or ordinances which may be imposed by other government agencies (local, state, and federal) which have jurisdiction. One (1) set of approved plans and specifications is being forwarded to you. If you have any questions or need additional information, please contact Seth Robertson, P.E. at telephone number (919) 715-6206. Sincerely, Coleen H. Sullins kp:sr Avf cc: Jesse G. Hite, Jr., P.E. — Gannet Fleming, Inc., Suite 1008, 301 S. McDowell St., Charlotte, NC 28204-2622 Catawba County Health Department DWQ Mooresville Regional Office, Surface Water Protection DWQ, Technical Assistance and Certification Unit DWQ, Point Source Branch, NPDES Program Ken Pohlig, P.E. ATC File No. 004987A03 Duke Power Marshall Steam Station Flue Gas Desulfurization WWTP Improvements Phase 1: Bypass Piping and Dewatering Plan A To C No. 004987A03 Issued February 18, 2010 Engineer's Certification , as a duly registered Professional Engineer in the State of North Carolina, having been authorized to observe (periodically/weekly/full time) the construction of the modifications and improvements to the Marshall. Steam Station Flue Gas Desulfurization WWTP, located at the intersection of NC Highway 150 and NCSR 1.841 in Catawba County, hereby state that, to the best of my abilities, due care and diligence was used in the observation of the following construction: Installation of an 18-inch HDPE gravity bypass pipe between the equalization basins and wetland cells 2A, 2B, and 2C, to allow removal of material. in wetland. cells IA, IB and IC for wetland conversion in a future authorization to construct, in conformity with the project plans, specifications, and other supporting data subsequently filed and approved by the Department of Environment and Natural Resources. I certify that the construction of the above referenced project was observed to be built within. substantial compliance and intent of the approved plans and specifications. Signature Registration No. Date Send to: Construction Grants & Loans DENR/DWQ 1633 Mail Service Center Raleigh, NC 27699-1633 Laborat r Ce Laboratory Name: Inspection Type: Inspector Name's): Inspection Date: INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only, 5155 Duke Power Co, Marshall Stea Held Maintenance Chet Whtn November 30, 2009 Station Date Report Completed: January 13, 2010 Date Forwarded to Reviewer: January 22, 2010 Reviewed by: Jason Smith. Date Review Completed: January 25, 2010 Cover Letter to use: Insp. Initial Insp. Reg. X lnsp, No Finding Insp, CP Unit Supervisor: Gary Francies Date Re c ived 1/25/2009 Date Forwarded to Alberta: 1/25/2010 Date Mailed: y. • NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen Ft Sullins Governor Director Dee Freeman Secretary January 26, 2010 5155 Mr. Rodney Wike Duke Power Co. Marshall Steam Station 13339 Hager's Ferry Road Huntersville, NC 28078-7929 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Wike: Enclosed is a report for the inspection performed on November 30, 2009 by Mr. Chet Whiting* No findings are cited in this report, a response is not required. We appreciate the fine job you and your staff are doing. As a certification requirement, your laboratory must continue to carry out the requirements set forth in 15A NCAC 2H 0800. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. If you wish to obtain an electronic copy of this report by email, or if you have questions or need additional information please contact me at 828-296-4677. Sincerely, Gary Francies Unit Supervisor Laboratory Section cc: Moofesville Regional Office Chet Whiting DENR DWO Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Rateigh, North Carolina 27699-1623 Location; 4405 Reedy Creek Road. Rafekih, North CaroItna 27'6.0?-6445 Phone: 919-73.3-3908 FAX: 919-733-624.1 Internet: www.dwgiatlorg An Fp up1Opportunity AffirmaPve Action. F.rnp yer Customer Service: 1-877-034570 ywiw,pcw-awrqualdy,org One NorthCarolina Naturally LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: On -Site Inspection Report Duke Power Co. Marshall Steam Station NC0004987 Duke Power Company LLC 13339 Hager's Ferry Road Huntersville, NC 28078-7929 5155 November 30, 2009 Field Maintenance Chet Whiting Rodney Wike This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. !!. GENERAL COMMENTS: The laboratory has been proactive in its approach to certification; the analysis of recommended post calibration pH checks is one example. The laboratory has also implemented a system for consumable traceability well before it was required by North Carolina Wastewater/Groundwater Laboratory Certification policy. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: General Laboratory Comment: The name of the .vendor/manufacturer was not included as part of consumable tracking. North Carolina Wastewater/Groundwater Laboratory Certification document, Quality Assurance Policies for Field Laboratories states: "All chemicals, reagents, standards and consumables used by the laboratory must have the following information documented: Date received, Date Opened (in use), Vendor, Lot Number, and Expiration Date. A system (e.g., traceable identifiers) must be in place that links standard/reagent preparation information to analytical batches in which the solutions are used. Documentation of solution preparation must include the analyst's initials, date of preparation, the volume or weight of standard(s) used, the solvent and final volume of the solution. This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement". This item was corrected on -site during the inspection. No further response is necessary for thisfinding. lir- Page 2 Lab #5155 Duke Power Co. Marshall Steam Station !V. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for Marshall Steam Station (NPDES permit # NC0004987) for August and September, 2009. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: All findings noted during the inspection were adequately addressed prior to the completion of this report. The inspector would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Chet Whiting Date: January 13, 2010 Report reviewed by: Jason Smith Date: January 25, 2010 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary January 25, 2010 Mr. Ron Lewis Duke Energy Mail Code EC 13K 526 S. Church Street Charlotte, North Carolina SUBJECT: Acknowledgement of Request for an Authorization to Construct Duke Energy Marshall Flue Gas Desulfurization WWTP WWTP Improvements NPL)ES Permit No. NC0004987 Dear Mr. Ron Lewis: The Construction Grants and Loans Section received your request for an Authorization to Construct and the supporting documentation on January 14, 2010. We will notify you and your engineer upon completion of our review. Your project has been assigned to Ken Pohlig, P.E. He can be reached at (919') 715-6221. If you have any questions concerning this matter, please contact me at (919) 71S-6.206. Sincerely, n/ eth Robertson, P.E., Srvitor Construction Grants and Loans Section Design Management Unit swc/dr cc: Jesse G. Hite, Jr., P.E. — Gannet Flea ring, Inc., Suite 1008, 301 S. McDowell St., Charlotte, NC 28204-2622 Mooresville Regional Office WQ Central. Files Ken Pohlig, P.E. Steve Coffey, P.E. ATC File 004987A03 1633 Mail Service Center, Raleigh, North Carolina 27699-163t3 Location: 2728 Capital Blvd. Raleigh, North Carolina 27604 Phone; 919-733-69001 FAX: 919-715-62291 Customer Service. 1-877-623.6748 Internet: www.rtncwaterqualitp.©rg An Equa Opportunity t Athrmarive Action. Lmpuyer One NarthCaro1 a attire!!