Cape Fear Steam Station (22)

AS
NCDETIR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. Randy Cox
Carolina Power and Light
d/b/a Progress Energy Carolinas, Inc.
EC13K/ P.O. Box 1006
Charlotte, North Carolina 28201-1006
Dear Mr. Cox:
Division of Water Quality
Coleen H. Sullins
Director
May 17, 2011
Subject: NPDES Stormwater Permit Application
Cape Fear Steam Electric Plant
Progress Energy Carolinas, Inc.
Chatham County
Dee Freeman
Secretary
On May 4, 2011, The Division of Water Quality received your application for renewal of the NPDES
Wastewater Permit NC0003433 for the Cape Fear Steam Electric Plant. A copy of the application was
forwarded to the Stormwater Permitting Unit (SPU) because stormwater discharges will be permitted
separately under an NPDES Stormwater Permit. A letter from Mr. Sergei Chernikov in the NPDES Unit
dated May 11, 2011 advised the company about this change.
To continue processing your application for an individual NPDES stormwater permit, the SPU needs
additional information:
NPDES Stormwater Permit Application Fee of $860.00
Resolve discrepancy between 0.18 MGD stormwater flow to Outfall 007 (Form 2C) vs. 0.056 MGD
total stormwater (flows '0' and 'P') to Outfall 007 (Attachment 2)
Site Drainage Map with additional detail. Attachment 5 that was provided did not show all
information described in Section III of EPA Form 2F, including:
o surface waterbody names
o past/present areas used for outdoor storage or disposal of significant materials
o materials loading and access areas
o areas where pesticides, etc. are applied
A larger -scale site plan that includes the above detail (in addition to all items listed in Section III) is
preferable. The 8.5" by 11" aerial map in the application is more difficult to read and does not show what
activities occur or what is stored in each of the drainage areas. Please submit a revised site drainage map
and permit application fee by June 15, 2011.
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 NorthCarolina
Internet: www,ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer Adwrallay

Mr. R. Cox
Progress Energy Carolinas, Inc.
May 17, 2011
Page 2
Along with the items above, please help us to better understand how much stormwater flow is directed
through combined wastewater Outfall 007 and under what conditions (i.e., corresponding to what depth of
rainfall). The application is not clear. Form 2C shows an average stormwater runoff flow of 0.18 MGD;
however, Attachment 2 lists a total of 0.056 MGD of stormwater runoff flow directed through Outfall 001 to
007 for "average rainfall' (not defined).
If you have any questions or comments concerning this letter, contact me at [phone] or
bethany.georgoulias@ncdenngov. or Bradley Bennett at [phone] or [e-mail].
Sincerely,
Bethany A. Georgoulias
Environmental Engineer
Stormwater Permitting Unit
cc: Raleigh Regional Office, Water Quality Section
Stormwater Permitting Unit
NPDES Wastewater Permitting / Sergei Chernikov
Robin Bryson, Progress Energy (via e-mail)
2

I
A
CCDENR
North Carolina Department of Environment and Natura
Division of Water Quality
Beverly Eaves'Perdue Coleen H. Sullins
Governor . Director
May 11, 2011
Mr. Randy Cox, Plant Manager
Carolina Power and Light
d/b/a/ Progress Energy Carolinas, Inc.
CapePearSteam Electric Plant
500 CP&L Road
Moncure, North Carolina 27559
Resources
Dee Freeman
Secretary
Subject: Draft NPDES Permit
Permit NC0003433
Cape Fear Steam Electric Plant
Chatham County
Facility Class I
Dear Mr. Cox:
Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very
carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from your current permit:
• The stormwater portion of the permit has been deleted. The Division will issue a separate
stormwater permit for this facility.
• A weekly average limit for Se has been removed from the permit based on a statistical analysis of the
effluent data. A monitoring frequency for Se has been reduced to quarterly due to the removal of the
limit.
• Monitoring frequencies for oil and grease, total suspended solids, ammonia nitrogen, and fecal
coliforms were reduced to semi-annually based on the review of the effluent data and in response to
your request (Outfall 005).
• Monitoring frequencies for oil and grease, total suspended solids, and ammonia nitrogen were
reduced to semi-annually based on the review of the effluent data and in response to your request
(Outfall 001).
• Groundwater monitoring was added to the permit. Please see Special Condition A. 9.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 NofthCarolina
Internet www.ncwaterquality.org //�
An Equal Opportunity 1 Affirmative Action Employer A,atural

• The special condition A. 10. entitled "Section 316 (b) of CWA" was, added to the permit in accordance,wA
new EPA requirements.
• The special condition A. 1.1. entitled "Structural Integrity Inspeetions�of Ash Pond Dam" was added to the
permit in accordance with the, new EPA requirements.
• The special condition A. 12. entitled, Pond Closure" was added to the permit to,,prepare for the
upcorning.decommnssioning of the facility. j
• The special condition A. 13. entitled "Fish Tissue Monitoring Near Ash Pond Discharge" was added to the
permit in accordance with the Division permitting policy for coal-fired power plants.
The Division cannot grant your request to reduce monitoring, for chronic toxicity testing, total nitrogen,and
total phosphorus (Outfall 007). The moiintoring frequencies, for these parameters are estabhshed in accordance with
the 15A„NCAC 2B.0500. l
The Division cannot grant -your request to reduce monitoring for As, Cr, Hg, and Ni (Outfall 007), quarterly
monitoring is required to obtain,a statistically representative.data set for a Reasonable Potential -Analysis.
Please submit any comments to me no later than thirty days following your receipt of the draft. ,Comments
should be sent to the address listed at the bottom of this page. If no adverse commentsarereceived from the
public or fiom,you, this permit will likely be, issued in early July, with an effective date of August 1, 2011.
If you have any questions about the NPDESpermit process, please contact me at the following a -mall
address: [e-mail], or telephone number: 919-807-6393.
- Sincerely,
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex NPDES Permitting
cc: - -NPDES File's'
Raleigh Regional.Office ,/ Surface Water Protection Section (e -copy)
Aquatic Toxicology Unit (e -copy)
DEH (e -copy)
-TACU (e -copy)
EPA Region IV
1617 Mai[Service Center, Raleigh, North Carolina 27699-1617
Location 512 N Salisbury St Raleigh, North Carolina 27604` One
Phone 919-807=6300ATAX 919807=6492,ICusto`mer Service 1-877.623-6748 NorthCarolina
IntemeLwww ncwaterquality org /� /� f
An Equal Opportunity V Affirmative Action Employer, Nbbtur{i"y

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I,Oeimis'>� �Jr I - Gv �,4 0l
Belnick, Tom �,�Sb, !MV4 F9
From: Georgoulias,' Bethany
Sent: Thursday, September 02, 2010 2 20 PM
To: Bryson„ Robin R
cc: Ramey, Amber, Chernikov, Sergei, Bennett, Bradley, Belnick, Tom
Subject: RE Storm water sampling request at Cape Fear Plant
Robin,
We talked with Sergei this afternoon, and we,learned that for these next renewals, chances are that the stormwater and
wastewater requirements will be split out into two separate permits That means Stormwater Permitting Unit (SPU)
staff will be -working with NPDES WW staff, through your'renewal process to determine what info. is still needed to
develop a separate NPDES Stormwater Permit for the -Cape Fear plant
From the correspondence you sent, The'NPDES Unit advised you that none, of your'stormwater,outfalls needed to be
sampled for the renewal five years ago. However, when you apply for°your renewal later this year, you should be sure
to include current, detailed information about all the drainage areas.and,pote_ntial stormwater outfalls at the site, as
well as activities in each (in addition to the information about these previous determinations). You should also still fill
out Form 2F as completely as you can
You indicated on the phone it is still difficult to obtain any samples from the two outfalls (SW -2 and SW -8)- Ifthat
remains the case, you should clearly note on the application that no samples -from those outfalls could be obtained in
order to complete EPA's Form 2F as part ofthis year's renewal SPU staff may -request additional information as,part of
the permit development process That may include a sample from SW -4, for example, if we feel past monitoring of
NPDES WW Outfall 007 does represent all potential contaminants that.may be presenun stormwater- We will work
with NPDES WW staff to coordinate review of the application materials
You had also,asked about taking a composite sample vs a grab. Virtually all.stormwater sampling,requirements in our
permits require grab samples, so you do not need to take a composite sample for stormwater discharges. I think Form
2F may be a little confusing on that point
I hope that helps If you have any other questions, let me know
Regards,
Bethany
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NC 27604
Phone [phone]
Fax [phone]
NEW Website http //portal ncdenr orgiWeb/wq/ws/su
E-mail correspondence to and from this,address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
From: Bryson, Robin R.[mailto:robin:[e-mail]]
Sent: Thursday, September 02, 201b 11:07 AM
'To: Georgoulias,,-Bethany
Cc: Ramey, Amber
Subject: Storm water sampling request

Attached are two letters written during the last NPDES permit renewal in 2005 regarding the,request and exemption for
storm water sampling requirement associated with Form 2F required for NPDES Permit renewal for the Cape Fear Steam
Electric Plant, Chatham County, I discussed with you this morning.
Representative storm water sampling,eontinues toIbena;prob►em at a III the,outfalls,at;the plant. Please discuss with the
NPDES Unit personnel the potential for a continued exemption from sampling storm water outfalls at this plant. I can
i1
submit a request for this exemption if necessary.
1
2

1102,08085110 1:06 L 209756,:20799004 L5,067110

Ll
Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Thursday, September 02, 2010 2:20 PM
To: 'Bryson, Robin R.'
Cc: Ramey, Amber; Chernikov, Sergei; Bennett, Bradley; Belnick, Tom
Subject: RE: Storm water sampling request at Cape Fear Plant
Robin,
We talked with Sergei this afternoon, and we learned that for these next renewals, chances ar- [hat the stormwater and
wastewater requirements will be split out into two separate permits. That means Stormwater ot rmitting Unit (SPU)
staff will be working with NPDES WW staff through your renewal process to determine what info. is still needed to
develop a separate NPDES Stormwater Permit for the Cape Fear plant.
From the correspondence you sent, The NPDES Unit advised you that none of your stormwater outfalls needed to be
sampled for the renewal five years ago. However, when you apply for your renewal later this year, you should be sure
to include current, detailed information about all the drainage areas and potential stormwater outfalls at the site, as
well as activities in each (in addition to the information about these previous determinations). You should also still fill
out Form 2F as completely as you can.
You indicated on the phone it is still difficult to obtain any samples from the two outfalls (SW -2 and SW -3). If that
remains the case, you should clearly note on the application that no samples from those outfalls could be obtained in
order to complete EPA's Form 2F as part of this year's renewal. SPU staff may request additio :al information as part of
the permit development process. That may include a sample from SW -4, for example, if we feel past monitoring of
NPDES WW Outfall 007 does represent all potential contaminants that may be present in stormwater. We will work
with NPDES WW staff to coordinate review of the application materials.
You had also asked about taking a composite sample vs. a grab. Virtually all stormwater samplin— requirements in our
permits require grab samples, so you do not need to take a composite sample for stormwater dis:.:iarges. I think Form
2F may be a little confusing on that point.
I hope that helps. If you have any other questions, let me know.
Regards,
Bethany
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: http://Portal.ncdenr.org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
From: Bryson, Robin R. [mailto: robin. [e-mail]]
Sent: Thursday, September 02, 2010 11:07 AM
To: Georgoulias, Bethany
Cc: Ramey, Amber
Subject: Storm water sampling request

Attached are two letters.written during°the last NPDES permit renewal an 2005 regarding.the request and exemption for
storm water sampling requirement associated with Form 2'F required for NPDES Permit renewal for the Cape Fear Steam
Electric Plant, Chatham County,, I discussed with you this morning.
Representative storm watersam,pling continues to be a problem at all the outfalls�at the,plant. Please discussswith the
'NPDES Unit personnel the' potential for a continued exemption from sampling storm water outfalls at this plant. I can
submit a request for this exemption if necessary.
►N

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Ms. Victoria K. Will
Cape Fear Steam Plant
500 CP & L Road
Moncure, North Carolina 27559
Ci4kY :
Dear Mo. mill:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
October 12, 2005 RECEIVED
OCT 17 2005
CAPE FEAR PLANT
Subject: NPDES Permit NC0003433
Cape Fear Steam Plant
Wake County
The Division evaluated your request to waive sampling requirements for the stormwater outfalls for the Cape
Fear Steam Plant's renewal application. Five stormwater outfalls are covered under the NPDES permit, SW -1,
SW -2, SW -3, SW -4, and 008. Outfalls SW -1 and 008 drain the area were the old ash ponds were located. The
ponds have not been used for more than 30 years and are covered with vegetation. In this case the application
requirements are not applicable because there is no exposed materials or industrial activity. Outfall SW -4 drains
an area near the railroad tracks and is tributary to outfall 007. Outfall 007 is the outfall at the discharge canal and
is monitored and sampled under the permit. Outfall SW4 is represented by outfall 007, therefore no sampling is
necessary for the application. Outfalls SW -2 and SW -3 drain small areas from the road and railroad line and are
combined with parking and grassy areas. As informed by Progress Energy, these outfalls do not collect enough
flow to obtain a representative sample. The sampling and testing requirements for outfalls SW -2 and SW -3 are
also waived for the permit renewal application. At this time the Division is not granting any modifications to the
conditions pertaining to stormwater outfalls in the permit. Due to the proximity of the renewal date,
modifications to the permit pertaining the elimination of outfalls shall be requested with the permit renewal
application. If you have any questions please contact Teresa Rodriguez of the NPDES Unit at [phone],
extension 553.
Sincerely,
Gil Vinzani
EAST NPDES Unit Supervisor
cc: Raleigh Regional Office, Water Quality Section
EAST NPDES Unit Files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer VISIT us ON THE INTERNET @ http:lm2o.enr.state.nc.us/NPDES

Frpgressfnergy
July i 1•; 2005
Mr: 1 aI rk McIntire
North ,Ca:rolina-Division of Water- Quality
,NPDES,Perrnitting Vhit
1617 Mail' Service Center
-RaleighNCj,,„2,7590-1617
RE Storm Water_Mbndoring,Requirt-nients
Cape Fear `Steam Electric 'P>I int
NPDES Permit NC0003433
Cape Eear File ''Point: ,;l�,2S20B- i
Dear `Mr: McIfntire:
On •June 30, 2005, Jenny Atkins and Judy Garrett of iheb Division of Water”
Quality's ,(DW(jRaleigh..Regionah Office and.Aisha Lau_ of DWQ,,'s Storm,'Water
'Permitting,Unit.visited the Cape Fear Steam °Eleetric,,Plant. They, met Danny,
`Hed'gepg,,0 ,, James, Reed 'and Steve, CaH on of Progress Energy .Carolinas
,r _T
(Progress Energy) to review. the, plant's storm water outfalls 'and discuss the,
,storm water sampling protocols for the NPDES; permit renewal application.
The group, from''both Progress'Endfg•,J aiid'NCDENR, visited eaclYof the, -storm'
water outfalls identified in the NPDES permit '(SW 1, aSW=2, FSW-3, SW=4; -and
Outfall 008) aAcf, §cussed their status asL related to industrial's storm wi ter;from
the, site as well as,th6ir, ability to'be-sampled,for NPDES-permit°renewal using
the sampling protocol' as,,descri'bed in 4,0 'CFR,Part 122.26.
After,,Teviewing each of ,the,,above referenced'storm watenoutfalls,on the plant
site, ,the group, from NCDENR agreed that $W=1' and, outfall 008 were-,with'in.`ihe
'confines,d -the old 'abandoned ash'ponds.-This•is located away fr6jm any,of'the
plant's ,industrial activities, and wou1'd not, receive, any storm water containing
ndustrial',process `polfiutarits�. In addition, the 'NCDENR group, agreed that it
would' take greater, than a 25=year' storm event for a discharge event to take
.place at.either, of these ,outfalls', ,(last,discharge from outfall 008 Was April 2,
`1998). Ms. Lau _indiedted that alone would exempt these two oiitfalls;'fronl fhe�
stotm,water program:
The ,group, Ifrofn both 7Progr„ess Energy and NCDENR, also - reviewed storm water
outfalls SW -2, SW -3, and .`SW_ 4. These outfall'§, dr=cin„the' onsite railroad cracks,
,(used t6,dehver coal to the plant) and the plant access road'from Cbrii th Road.
Alli ofthese outfalls have a very small drainage -area, (<,4.S: acres) and very,small
area,ofi'mpervious surface (the largest being Q.5 acres),. The above -referenced
Progress Eoergy Wahrias, Iric.
Cape fedStem Plant
1500 CPWRoad
Mo6cure,,,k'?7559

.outfalls are -riot located near any, of the industrial processes at the plant site, nor
are they located near any portion of the site where coal or,any other,chemicals
'brought onto the site would be unloaded. Storm water from the- industrial
process areas and unloading areas of the Cape Fear Plant are discharged, into
NPDES; permitted outfalls, either the east, ash pond (NPDES outfall 005) or the
discharge canal' (NPDES outfall 007). Therefore, any storm water samples taken
,for analytical monito,,'Iig from, -SW: -2, SW-3,,or SW -4, would not, -be indicative of
our industrial process. The, group from `NCDENR felt that these outfalls do not
fall under ,the, intent, of the storm water permit program, and should not have
any analytical rrionitoring ;-equire`inents,associated with`thern.,
Based on the site visit and concurrence from the NCDENR group, the Cape Fear
Plant is requesting that the NPDES Permitting'Unit remove -the, requirement for
analytical storm water monitoring for then NPDES permit renewal application, and
not require the plantto, submit EPA Form 3510-2F with its:NPDES permit
ren&w Lpackage. The plant also requests that<outfall 008 and storm- water
outfall SW -1 be.removed .from the visual monitoring, requireinents.ofth'e current
;NPI!
ES permit. The plant does not have any,issues with the current permit
requirement to visually monitor storm water,fromroutfalls SW -2, 8W=3, and SW=
4, but as stated, abow;, does not-b;,lieve these 'outfalls should have any analytical
monitoring requirement-, associated with them in the permit or permit renewal
process.
As always thank you for your prompt,attentiori to our permitting needs, .if you
have,any questions abcuL these issues please contact Mr., Steve Cahoonv_'ia
phone at (P 19) 546-74"v-,, or via e-mail at [e-mail].
I certify, under penalty of law, that this document and all'.atta6hinents, were.
prepared 'under my direction or -supervision in accordance with d system,designect
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.
Very truly yours,
Victoria K. Will
Plant Manager