Cape Fear Steam Station (12)

NCDENR / DWQ
FACT SHEET FOR NPDES STORMWATER PERMIT DEVELOPMENT
Progress Energy Carolinas, Inc
NPDES No. NCS000550
t- � : LF acility Informah'on - t ;
(1.) Facility Name:
Cape Fear Steam Electric Plant
(2.) Permitted Flow, MGD:
N/A
(6.) County:
Chatham
(3.) Facility Class:
N/A
(7.) Regional Office:
Raleigh
(4.) Facility Status:
Existing
(8.) USGS Topo Quad:
(5.) Permit Status:
New Stormwater Only
Permit
a.� Stream�Characteriscs �; p
(1.) Receiving Stream(s):
Shaddox Creek, UT to Shaddox Creek, Cape Fear River
(2.) Sub -basin:
03-06-07
(6.) Drainage Area
(mi2):
N/A
(3.) SIC Code:
4911
(7.) Summer 7Q10 (cfs)
I
(4.) Stream Class:
WS -Iv
(8.) Average Flow (cfs):
,
(5.) 303(d) Listed:
No, but Cape Fear
segment downstream is
(9.) IWC (%):
N/A
SUMMARY
This is a new NPDES stormwater permit for Progress Energy Carolinas' 400 megawatt (MWe)
steam electric power plant on the Cape Fear River in Moncure, North Carolina The facility
operates two coal fired units with a total net generating capacity of 316 Mwe, two waste heat
recovery units with a total net capacity of 28 MWe, and four internal combustion turbines with a
total net capacity of 56 MWe
This facility site has four stormwater outfalls that discharge to Shaddox Creek, an unnamed
tributary to Shaddox Creek, and to the Cape Fear River lust upstream of Buckhorn Dam in Chatham
County Two of the outfalls ("SW -1" or 001, and "SW -8" or 008) are from inactive ash ponds that
rarely ever discharge. The other two outfalls ("SW -2" or 002, and "SW -3" or 003) discharge
stormwater associated with industrial activities See below for a summary of flows to each outfall.
Historically, the Cape Fear Steam Electric Plant had only a wastewater permit (NC0003433) and
sampled some stormwater outfalls for the NPDES renewal application During this past permit
renewal, the company was advised to apply fer a separate NPDES stormwater permit, and
stormwatei requirements were removed from NC0003433 The Division initiated an effort this
past year to segregate stormwater management requirements) nto a separate stormwater permit,
rather than combine wastewater and stormwater under one NPDES permit, for power plants This
direction is based on the accumulating complexities in power plant wastewater permits, and the
Division's need to better manage stormwater data records for these sites. The proposed draft
NPDES stormwater permit for this facility reflects the permitting strategy for all coal-fired power
plant establishes by Cie Stormwa;er P,,rmittmg Un t (SFU) in 2009

NPDES PERMIT FACT SHEET CP&L/Progress Energy Carolinas—Cape Fear Steam Electric
Page 2 NPDES No. NCS00550
This plant site was included in the Environmental Integrity Project and Earthlustice report called
"Out of Control Mounting Damages from Coal Ash Waste Sites" (February 2010) The report noted
groundwater monitoring at the Cape Fear Steam Plant found concentrations of lead, chromium,
boron, iron, manganese, and sulfate above NC groundwater standards, at wells within 125' of ash
pond impoundments. The plant site operates four unlined ash impoundments, one active and three
inactive. The draft stormwater permit proposes monitoring for all of these constituents except iron
and manganese.
This power plant facility is scheduled to be decommissioned in 2017
Outfall SW -1 (001)
This outfall discharges from the abandoned ash pond on the north-northwest side of the property
to the Cape Fear River No industrial activities are performed in this pond Stormwater discharges
are rare
Outfall SW -2 (002)
This outfall receives stormwater runoff from the area along the railroad between the entrance road
and plant site, as well as open field, and discharges to Shaddox Creek The outfall was sampled in
September 2010 as part of the NPDES wastewater permit renewal application (May 2011)
COD levels were under the 120 mg/1 benchmark (48 6 mg/1), and BOD levels were low (3 6 mg/1),
suggesting a larger amount of non-biodegradeable organic material. Total Suspended Solids (TSS),
Oil and Grease (0&G), pH and nutrients were all well below or within range of current stormwater
benchmarks The copper concentration (0 007 mg/1) was the same as the current benchmark.
Arsenic, mercury, selenium, chromium, and nickel concentrations levels were all below
benchmarks. No results were reported for aluminum, antimony, beryllium, boron, bromide,
cadmium, lead, magnesium, manganese, molybdenum, silver, thallium, tin and zinc, but all
were reported as pollutants "that may be present in coal along the rail." Total residual chlorine
(TRC), ammonia, nitrate -nitrite, TKN, and fecal coliform were also reported ("natural
environmental processes" were cited as a potential source), but these would not likely be
associated with industrial activities at this plant site Although fecal values were noted over the
1000 CPU/100 ml benchmark, fecal coliform monitoring is not proposed because there are no
likely sources associated with industrial activities
Outfall SW -3 (003)
This outfall includes drainage from a swale beside the plant entrance road Above -ground ash
sluice pipelines traverse this area. This outfall was also sampled in September 2010 as part of the
NPDES wastewater permit renewal application (May 2011)
COD (67 mg/1) and BOD (9.3 mg/1) were slightly higher than the other outfall but still below
benchmarks (120 mg/1, 30 mg/1, respectively). TSS (35 2 mg/1) was higher but also below the 100
mg/l benchmark. TN and TP were similar to SW -002 levels. All metals measured (see above) were
below benchmarks. Again, no results were reported for aluminum, antimony, beryllium,
boron, bromide, cadmium, lead, magnesium, manganese, molybdenum, silver, thallium, tin
and zinc, but all were reported as pollutants "that may be present in coal along the rail " Likewise
TRC, ammonia, nitrate -nitrite, TKN, and fecal coliform were reported but not likely attributable to
industrial activities Although fecal values were noted over the 1000 CPU/100 ml benchmark,
me mtormg is not pi oposed because ' here are no like],, sources associa' ed with mdustri,,l activities

NPDES PERMIT FACT SHEET CP&L/Progress Energy Carolinas—Cape Fear Steam Electric
Page 3 _ NPDES No. NCS00550
Outfall SW -8 (008)
This outfall discharges from an abandoned ash pond south of the plant to Shaddox Creek. Ash
disposal to this pond was terminated in the late 1970s A majority of this area is covered with
grass and trees, with a small pool of approximately 3 acres of standing water No industrial
activities are performed in this pond, and stormwater discharges are rare
COMPLIANCE SUMMARY- BASED ON THE PREVIOUS 5 YEARS
There are no outstanding and/or chronic compliance problems related to the stormwater
requirements that had been contained in the NPDES permit.
TOXICITY TESTING'
No toxicity testing for stormwater discharges is proposed in this permit.
INSTREAM MONITORING s
Progress Energy is not required to perform any instream monitoring for stormwater discharges
REASONABLE POTENTIAL ANALYSIS
Reasonable potential analysis is not used to determine stormwater discharge monitoring
parameters.
PROPOSED CONDITIONS
Stormwater must be controlled by the development and implementation of a
Stormwater Pollution Prevention Plan (SPPP or Plan) SPPP requirements that are
consistent with other industrial facilities are proposed.
Analytical monitoring follows the NPDES stormwater template for power plants according
to the permitting strategy developed by the Stormwater Permitting Unit in 2009
o Semi-annual monitoring for 13 priority metals (Ag, As, Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb,
Se, Tl, Zn) + Al & B, with benchmarks where available.
o Semi-annual mercury (Hg) monitoring with more sensitive method 1631E but no
benchmark (or obligation to monitor monthly in Tier 2)
o Semi-annual monitoring for COD, TSS, pH, sulfates, and 0&G
o Requirement to submit annual data summary to DWQ regional office
• Nutrient monitoring for this permit term is proposed because of the chlorophyll a
standard violations downstream in the Cape Fear River
• Benchmark concentrations trigger stormwater management actions and are not
effluent limits. Benchmarks provide a tool with which to assess the effectiveness
of best management practices (BMPs)
• A tiered -response to stormwater benchmark exceedances applies that includes
flexibility for both DWQ and the permittee to determine the most appropriate
actions
• Footnote 3 under Part II, Section B. Table 2 specifies that monitoring is not
required for SW -1 and SW -8 (inactive ash ponds) unless there are discharges from
storm events smaller than the 25 -year, 24-hour storm
BASIS FOR PROPOSED CONDITIONS
The permit conditions reflect the Environmental Protection Agency's (EPA) and North Carolina's
pollution I revention approach to stormwate- permitting The quality of the sti rmwater dischai ;e
associated with an industrial activity will depend on the availability of pollutant sou.-ces. The

NPDES PERMIT FACT SHEET CP&L/Progress Energy Carolinas—Cape Fear Steam Electric
Page 4 NPDES No. NCS00550
Division believes that implementation of Best Management Practices (BMPs) and traditional
stormwater management practices which control the source of pollutants meets the technology-
based standards of the Clean Water Act, i e, Best Available Technology (BAT) and Best
Conventional Pollutant Control Technology (BCT). The permit conditions are not numeric effluent
limitations, but rather are designed to be flexible requirements for implementing site specific plans
that minimize and control pollutants in the stormwater discharges associated with the industrial
activity.
Title 40 Code of Federal Regulations (CFR) Part §122 44(k)(2) authorizes the use of BMPs in lieu of
numeric effluent limitations in NPDES permits when the agency finds numeric effluent limitations
to be infeasible. The agency may also impose BMP requirements which are "reasonably necessary"
to carry out the purposes of the Act under the authority of 40 CFR §122 44(k)(3) The pollution
prevention requirements (BMP requirements) proposed in this permit operate as limitations on
effluent discharges that reflect the application of BAT/BCT The basis is that the BMPs identified
require the use of source control technologies which, in the context of this industrial permit, are
the best available of the technologies economically achievable (or the equivalent BCT finding)
Benchmarks for metals monitoring are based on concentrations that protect against acute impacts
to aquatic life (Y2 Final Acute Value, or FAV, where available) because of the duration and nature of
storm events Benchmarks for conventional pollutants are based on water quality standards (pH);
secondary treatment standards in 40 CFR §133 (pH of 6-9, 0&G of 30 mg/1, and the assumption
that COD will not exceed four times a BOD level achieved by secondary treatment, or 4 x 30 mg/1=
120 mg/1), and the 1983 National Urban Runoff Program study (TSS of 100 mg/1).
Because the inactive ash ponds (SW -1 and SW -8) here would only discharge stormwater in
response to very large events that might flood the river into the bermed area, the draft permit does
not require sampling from either of these outfalls as long as there are no discharges from events
less than the 25 -year, 24-hour storm.
UNIFORM STORMWATER PERMITTING STRATEGY FOR POWER PLANTS
In recent years, the Stormwater Permitting Unit has recognized the complex issues associated with
coal -burning power plants and the increased attention on coal ash storage, use, and disposal at
these sites Data on stormwater discharges from these plant sites is limited because traditionally
the focus has been on wastewater Regions have also voiced concern about potential
contamination from metals in stormwater discharges associated with the activities at these sites.
After researching constituents these activities or materials may introduce to the power plant
property (and with them potential for stormwater pollution), the Unit formulated a uniform
approach to power plant permits in 2009 in support of gathering information and treating power
plants consistently in our program
The template permit for these facilities includes semi-annual analytical monitoring for 13 priority
metals (Ag, As, Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb, Se, Tl, Zn), as well as aluminum (Al) and boron (B), with
benchmarks where available BASIS This list was established with information from a research
study report ['Human and Ecological Risk Assessment of Coal Combustion Wastes, RTI International,
August 2007 Draft] and discussions with Robert Schreusdale of RTI International that suggested
these metals could signal contamination problems The Stormwater Permitting Unit also discussed
potential contaminants with Duke University faculty member Dr Avner Vengosh, who researched
the TVA ash pond spill in December 2008 in Kingston, TN In addition, DWQ regional offices
sampled discharges from cogeneration plants in the Fayetteville region and flagged metals of
concern There are limit( d data with which to characterize stormwater disc!iarges from this

NPDES PERMIT FACT SHEET CP&L/Progress Energy Carolinas—Cape Fear Steam Electric
Page 5 NPDES No NCS00SSO
industry, but the Division has identified a concern and need for better understanding about
stormwater discharges from these plant sites
Mercury monitoring must be done with the more sensitive method 1631E, but no benchmark
applies (or obligation to monitor monthly in Tier 2) BASIS. Power plants are a potential source of
mercury, and although some mercury may be regional, there is a'risk that significant quantities
come from the activities at the plant. While wastewater permit limits are calculated based on low
stream flow and high wastewater effluent flow conditions—and sometimes do not warrant the
lower -detection method—stormwater contributions vary broadly and do not change the bio -
accumulative nature of methyl -mercury The Division recognizes the complexity of regional air
transport and deposition, as well as the cost and resources involved in the clean mercury sampling
protocol, therefore, the draft permit exempts mercury from monthly monitoring in the tiers.
Monitoring parameters also include conventional pollutants associated with the types of activities
and possible contaminants at a power plant Chemical Oxygen Demand (COD), Total Suspended
Solids (TSS), pH, sulfates, and Oil and Grease (0&G) A provision allows pH values to be below the
benchmark if the facility can document rainfall pH is as low or lower at the time of sampling.
In the analytical monitoring section of the permit, "Tier 3" outlines response actions prompted by
any four benchmark exceedances at an outfall. Tier 3 includes the language that the Division can
"work with the permittee to develop alternative response strategies." BASIS The Division
recognizes the ubiquitousness of elements like copper and zinc, and the low benchmark
concentrations for many of these metals; however, it also recognizes that activities at power plants
can contribute these pollutants The Division's Stormwater Permitting Unit feels alternatives to
more monitoring can facilitate solutions, and that the permit tier structure is flexible enough to
relieve the permittee of monitoring when appropriate, without need for permit modification.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE.
Draft Permit to Public Notice. Publish no later than October 18, 2011
Permit Scheduled to Issue December 2, 2011 (est.)
STATE CONTACT.
Ifyou have any questions on any of the above information or on the draft permit, please contact
Bethany Georgoulios at [phone]