NC0003425_Comments to Permit Application_20021007

C P & L
A Progress Energy Company
File No. 12520B
D
OCT e 9 2002
E - ! i EP, QUALITY Octobi
Ms. Teresa Rodriguez
NPDES Permit Unit
North Carolina Division of Environmental Management
512 N. Salisbury Street
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Carolina Power & Light Company (CP&L)
Roxboro Steam Electric Plant
National Pollutant Discharge Elimination System Permit No. NC0003425
Comments on Draft NPDES Permit
Dear Ms. Rodriquez:
Cecil E. Rowland
Plant Manager
7, 2002
CP&L has reviewed and prepared comments on the subject draft National Pollutant Discharge
Elimination System (NPDES) permit pursuant to the North Carolina Division of Water Quality's
(NCDWQ) letter dated September 4, 2002, which was received by the facility on Septemberl0,
2002. As stipulated, CP&L's comments (Enclosure 1) are being submitted in writing by October 11,
2002.
CP&L appreciates the continued cooperation demonstrated by the NCDWQ staff in resolving the
often complex issues involved in the renewal of its NPDES permits. If you have any questions or
require additional information, please contact Ms. Joanie Cooke at [phone].
V 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 managed 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. rr
Respectfully yours,
Cecil E. Rowland
Plant Manager
JPC/jpc
Enclosure
Roxboro Steam Plant
1700 Dunnaway Road
Semora, NC 27343

Enclosure 1
Carolina Power & Light Company
Roxboro Steam Electric Plant
Comments on Draft NPDES Permit No. NC0003425
The following comments on Carolina Power & Light (CP&L) Company's Roxboro Steam
Electric Plant's draft National Pollutant Discharge Elimination System (NPDES) permit are
submitted pursuant to the North Carolina Division of Water Quality's (NCDWQ) letter dated
September 4, 2002, which was received by the facility on September 10, 2002.
Public Notice
• The public notice identifies that no parameters are water quality limited. Temperature is
a water quality parameter and should be identified as such
Supplement to Permit Cover Sheet b/
C o/_kNcn • Under Item 1, description of the Chemical Metal Cleaning Treatment System, CP&L
�p requests the removal of the second sentence in that description. The inclusion of the
Vi �'Y J second sentence limits the operation of metal cleaning at the facility. �4A,�cn � -njo
A. (1). Outfall 002 — Ash Pond Treatment System to the Heated Water Discharge Canal
(Page 1 of 10)
/ • The pagination for Part I identities that there are 9 pages, however there are actually 10
pages included in Part I Section A. The page numbering should be corrected to reflect
the actual number. o((f
• CP&L requests that the sampling type for Total Selenium be changed to rab. con -p o5`f��
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Enclosure 1
• The notes paragraph defines the sampling location however this note is not referenced on
the limitations table in sample location column.
• The last sentence on the page identifying the location in the permit of the special
U conditions is redundant. The location and applicability of the special al conditions is
identified in a previous note on the page. CP&L requests the removal of the redundant
sentence.
A._(2). Outfall 003 — Heated Water Discharge Canal System to the Hyco Reservoir (Page 2
Of 10)
• Note 5 incorrectly references Special Condition 1, the correct Special Condition is A(7).
• CP&L requests the addition of a note for Total Residual Chlorine which identifies that
n x� sampling is only necessary if chlorine has been added to the once -through cooling water
moo'
systems.
• CP&L requests that the end of the second to last sentence be modified to read "from the
1 discharge point".
• The last sentence on the page identifying the location in the permit of the special
conditions is redundant. The location and applicability of the special conditions is
l� identified in a previous note on the page. CP&L requests the removal of the redundant
sentence.
A. (3). Outfall 005 — Cooling Tower Blowdown to the Ash Pond (Page 3 of 10)
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Enclosure 1
• CP&L requests that Item 3 below the limitations table of this page be deleted and that the
following be added as Item 3.
These limitations and monitoring requirements apply only if these materials are
added for cooling tower maintenance by the permittee There shall be no
detectable amounts of the 126 priority pollutants (40 CFR 423 Appendix A)
VG, , contained in chemicals added for cooling tower except for Total Chromium and
X� Total Zinc Compliance with the limitations for 126 pollutants may be determined
by engineering calculations which demonstrate that the regulated pollutants are
q1� not detectable in the discharge by the analytical methods in 40 CFR 136
/This new wording will more accurately reflect the EPA Steam Electric Category effluent
limitations and will be consistent with similar NPDES permits issued by the Division.
p • CP&L requests the addition of a note for Total Residual Chlorine which identifies that
14-1 �/sampling is only necessary if chlorine has been added to the cooling towers.
�JJ
�� • The notes paragraph defines the sampling location however this note is not referenced on
U / the limitations table in sample location column.
V
• The last sentence on the page identifying the location in the permit of the special
'l//conditions is redundant. The location and applicability of the special conditions is
r/ identified in a previous note on the page. CP&L requests the removal of the redundant
sentence.
A. (4). Outfall 006 — Coal Pile Runoff Treatment System to the Hyco Reservoir (Page 4 of
10)
• The sample type for pH is incorrectly identified as composite. CP&L requests the type
be correctly identified as grab. &Jq, Co' -(s:-

Enclosure 1
• , ote 2 incorrectly references Special Condition 2, the correct Special Condition is A(8).
• The last sentence on the page identifying the location in the permit of the special
conditions is redundant. The location and applicability of the special conditions is
Offidentified in a previous note on the page. CP&L requests the removal of the redundant
sentence.
A. (5). Outfall 008 — Domestic Wastewater Treatment System to the Ash Pond (Page 5 of
10)
•
The monitoring requirements portion of this page has measurement frequencies
�p
identified. These measurement frequencies were not in the previous permit nor is there 5� LF
any explanation for their inclusion in this draft in the accompanying fact sheet. Previous
�� 1v
correspondence from NCDWQ indicates that the inclusion of this effluent page without
measurement frequencies was necessary to ensure the understanding of what constitutes
"proper operation and maintenance". CP&L believes the inclusion of measurement
ll -�
frequencies in this draft is in error and requests their removal If NCDENR determines
poli
that this comment is not acceptable, CP&L requests a consultation with NCDENR to
discuss measurement frequencies.
•
The limitation
effluent concentrations of 45 mg/l for biochemical oxygen demand (BOD)
and 30.0 mg/L for total suspended solids (TSS) are expressed as a Daily Maximum. This
h u `
is inconsistent with secondary treatment requirements and 15A NCAC 213.0406 (�v� c l S
4,1
which express these concentration limitations as a Weekly Average as well as the
Ej%
numeric value for TSS as 45 0 mg/L. CP&L requests that the effluent limitations be
changed to a Weekly Average and that the limitation for TSS be changed to 45.0 mg/L.
rd

Enclosure 1
• /The last sentence on the page identifying the location in the permit of the special
conditions is not needed for this page. CP&L requests the removal of the sentence.
A. (6). Internal Outfall 009 — Metal Cleaning Wastes to the Ash Pond (Page 6 of 10)
Since this metal cleaning process wastewater is routed through the ash pond (Outfall 002)
and TSS and Oil & Grease (O&G) are limited at Outfall 002, there is no need to require
) TSS and O&G limits at this Outfall 009. CP&L requests that these limits be deleted.
0 ,�s C�Y'
� CP&L requests the removal of the word "evaporated" from the second paragraph at the
/ Q° bottom of the page. The inclusion of the word "evaporated" limits the operation of metal
cleaning at the facility.
L
• The last sentence on the page identifying the location in the permit of the special
/conditions is not needed for this page. CP&L requests the removal of the sentence.
• The description for this outfall has the wording "internal' included. Other outfalls at this
1Z facility, which are also internal, did not have the descriptive word. CP&L requests either
the removal of the word "internal' for this outfall or the inclusion of the word at the other
internal outfalls.
A. (8). Acute Toxicity Monitoring (ANNUAL) — (Page 8 of 10)
• The third paragraph from the bottom of the page identifies that should there be no
discharge of flow from the facility during any month that the facility will submit a test
f form indicating "No Flow". This paragraph is applicable to a monthly monitoring
requirement not an annual monitoring requirement. CP&L requests that this paragraph
.l
be either deleted or modified to reflect the annual requirement.
�C

Enclosure 1
The last two paragraphs on this page are redundant.
be deleted.
CP&L request that these paragraphs
Part II Standard Conditions For NPDES Permits Section B. General Conditions Item 11
(Page 5 of 11�
r�� / • The Signatory Requirements have been modified in the Federal Regulations. This
provision in the DWQ boilerplate language should also be updated accordingly.
J \ V
b Part II Standard Conditions For NPDES Permits Section C Operation and Maintenance of
Pollution Controls Item 1 (Page 6 of 11)
• The certified operator regulations have been modified in the North Carolina
Administrative Code. This provision in the DWQ boilerplate language should also be
5 updated accordingly.
Part H Standard Conditions For NPDES Permits Section C Operation and Maintenance of
Pollution Controls Item 4 (Page 6 of 11)
• DWQ defines a bypass as "the known diversion of waste streams from any portion of a
treatment facility including the collection system, which is not a designed or established
or operating mode for the facility." Since neither the NC Statutes nor the DENR
regulations contain a definition of bypass, (other than a bypass in reference to
pretreatment) the definition of bypass should default to the federal definition. The EPA
defines bypass as ".. the intentional diversion of waste streams from any portion of a
treatment facility." Although the difference between these definitions may appear to be
subtle, the meaning of the definition in the proposed permit in regard to the reporting
requirements and liabilities associated with the NPDES permit are, in CP&L's belief,
_! 6

Enclosure 1
significant and excessive beyond that authorized by law and regulation. CP&L requests
that the proposed defmition in the proposed permit be replaced by the EPA definition or
that the DWQ inform CP&L that the proposed definition is to be interpreted as the EPA
definition.
Part III Other Requirements — Item D
• This requirement is inappropriate for this facility and is essentially impossible to comply
with since a permittee cannot continually evaluate all wastewater disposal alternatives.
(� CP&L requests that this requirement be deleted from this permit as it has from other
CP&L permits.
Fact Sheet (Page 1)
• The permitted flow referenced for the facility is for Outfall 008. Outfall 008 is not the
permitted flow for the facility. The fact sheet should be changed to reflect that Outfall
008 is not the permitted flow."����
• The facility class is identified as non -applicable, however, the facility has been classified
as both a Grade II biological and a Grade I Physical/Chemical by the Training and
Certification Unit of NCDWQ. The fact sheet should be corrected to reflect the actual
classifications.
7