NC0003425_Comments on Draft Permit_20020924

[Fwd Draft Permit for NC0003425]
Subject: [Fwd: Draft Permit for NC0003425]
Date: Thu, 25 Jul 2002 14 41 52 -0400
From: Tom Belmck <tom.belmck@ncmail net>
To: Teresa Rodriguez <Teresa.Rodnguez@ncmail net>
I guess this one is yours.
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work- [phone] ext 543
Fax. [phone]
r- -
Subject: Draft Permit for NC0003425
Date: Wed, 10 Jul 2002 13.17 35 -0400
From: Shell Karrie-Jo@epamall epa.gov
To: dave.goodnch@ncmail net
CC: [e-mail]
Attached are the files I used to draft the NPDES permit for the Roxboro
Plant
Basically, the permit is the same as the current permit, except that I
added an internal outfall (outfall 009) to cover the infrequent
discharge of metal cleaning wastes CP&L told me that metal cleaning
wastes are burned/evaporated in the boiler The bottom ash, which
contains evaporated MCW, is then sluiced to the ash pond. The permit
requires that effluent guidelines limits for TSS, 0&G, TFe and TCu be
met at outfall 002, whenever MCW is discharged Effluent sampling
during this discharge will depend on the detention time of the ash pond
I have already discussed this new outfall with CP&L.
I also included sampling frequencies, sample types and sampling
locations for Outfall 008 - domestic wastewater.
Lastly, the fact sheet has a lot blanks where information (that I did
not have) should be inserted.
(See attached file: 3425coverpage.doc)(See attached file- 3425-supp DOC)
(See attached file- 3425-eff002 DOC)(See attached file. 3425-eff03.DOC)
(See attached file 3425-eff05 DOC)(See attached file. 3425-eff06 DOC)
(See attached file 3425-eff08 DOC)(See attached file 3425-eff0mcw.DOC)
(See attached file 3425factsheet doc)(See attached file
3425-speci.alconditions.doc)(See attached file: PARTs III&IV.doc)
Karrie-Jo Robinson -Shell, P.E. 104 - j&j _ i30
l Name: 3425coverpage doc
F13425coverpage doc Type: Microsoft Word Document (application/msword)
Encoding: base64
Download Status: Not downloaded with message
1 of 3 8/1/2002 11 51 AM

Re: CP&L' Roxboro Plant. Person County NC0003425
Subject: Re: CP&L - Roxboro Plant. Person Count NC0003425
Date: Wed, 01 Sep 1999 15:22:14 -0400
From: Tom Belnick [e-mail]>
To: "Cooke, Joanie"' <[e-mail]>
Joanie- CP&L's current permit covers this proposed add-on, since the facility
will remain below permitted flow, and there is no change in waste
characteristics. No DWQ permit mod is necessary.
"Cooke, Joanie" wrote:
> Tom,
> The Roxboro plant is in the process of relocating a guard house at the site.
> With the relocation, the facility is planning on installing a toilet within
> the guard house that will be tied into the existing domestic waste system
> which is served by an onsite package plant The previous location of the
> guard was so close to plant that a toilet within the guard house was not
> necessary. The design flow for the package plant is a monthly average flow
> of 0.015 MGD (15,000 gals per day). The current loading on the package
> plant is believed to be approximately 11,750 gals per day or 0.01175 MGD.
> Using 250 gals per day per toilet the amount of additional flow from the one
> toilet would be only 250 gallons. This addition would, under worst case
> assumptions, only raise the influent flow to the STP to approximately 12,000
> gals or .012 MGD, well below the design flow for the STP. Consequently, we
> believe the facility should be able to proceed with the installation. The
> facility needs your concurrence on this issue in order to obtain a local
> construction permit. Your response would be greatly appreciated.
> Thanks For All You Do
> Joanie P. Cooke
> Carolina Power & Light Co.
> Water & Natural Resources Unit
> [phone], HEEC
> [e-mail]
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
1 of 1 9/1/99 3:22 PM

Re: Rc;:`,.go Plant - Addition of Toilets in Contractor Trailersw /�QC t e
Subject: Re: Roxboro Plant - Addition of Toilets in Contractor Trailers
Date: Tue, 20 Jul 1999 15:49:51 -0400
From: Tom Belmek <[e-mail]>
To: "Cooke, Joanie" <[e-mail]>
Joanie- It sounds like CP&L will still be under design flow for the package
WWTP, so NPDES doesn't have a problem with the installation. I'll keep a copy
of this letter on file (CP&L, Roxboro, NC003425) and foward a copy to Raleigh
Regional Office.
"Cooke, Joanie" wrote:
> Tom,
> As we discussed earlier today, the Roxboro plant is planning to add toilets
> to four contractor trailers at the site. Two toilets in three of the
> trailers and one toilet in the last trailer for a total of seven. The
> facilities will be tied into the existing domestic waste system which is
> served by an onsite package plant. The design flow for the package plant is
> a monthly average flow of 0.015 MGD (15,000 gals per day). Using 250 gals
> per day per toilet the amount of additional flow from the seven toilets will
> be 1,750 gallons. Currently, there are no monitoring requirements for the
> sewage treatment plant (STP) since it discharges into the ash pond. The
> effluent from the STP was routed to the ash pond in early 1994, prior to
> this the STP's effluent went to the reservoir where monitoring was required.
> Using past operating values for flow (data from 1993), the maximum monthly
> average value was 0.010 MGD (10,000 gals per day). Therefore, looking at
> the worst case monthly average of 10,000 gals and increasing that flow by
> 1750 gals per day to a total of 11,750 gals per day or 0.01175 MGD, the
> design flow for the STP will not be exceeded. Based on the above
> information and on our conversation, the plant will proceed with the
> installations.
> Thanks For All You Do
> Joanie P. Cooke
> Carolina Power & Light Co.
> Water & Natural Resources Unit
> [phone], HEEC
> [e-mail]
Mailto:tom [e-mail]
N.0 DENR-DWQ/NPDES Unit
P.O.Box 29535, Raleigh NC 27626-0535
Work: [phone] ext. 543
Fax: [phone]
1 of 1 7/20/99 3:50 PM

Re: CP&L Roxboro Plant, Person County, NPDES # NC0003425
Subject: Re: CP&L Roxboro Plant, Person County, NPDES # NC0003425
Date: Mon, 07 Aug 2000 11:48:39 -0400
From: Tom Belnick <[e-mail]>
To: "Cooke, Joanie" <[e-mail]>
CC: Susan A Wilson <[e-mail]>
Joanie- Sue Wilson talked this over with Kim Colson of Non -Discharge. Kim's
view was that industrial facilities with collection systems located onsite do
not need to apply for a non -discharge collection system permit. From an NPDES
permit perspective, we do not need to permit this additional piping/lift station
by ATC, but just caution that any additional hydraulic loading be within the
WWTP capabilities. Since that is the case here, we concur that you can proceed
to construction.
PS- We'll plan on arriving about 10am for the site visit tomorrow. There will
be a total of 4 NPDES folks.
"Cooke, Joanie" wrote:
> Tom,
> As we discussed last week, the Roxboro plant is planning on building a new
> fuel handling building on the plant site. Included in the project is the
> addition of a lift station to service the new building. The existing fuel
> handling will not be removed but it also will not be occupied at this time.
> All personnel will move to the new building. Since no additional lad will
> occur due to no net increase in plant personnel, the existing sewage
> treatment system will have any additional hydraulic loading added. Based on
> this and our previous discussion, it is my understanding that the Roxboro
> plant can proceed with the construction (including the addition of the lift
> station). You concurrence on this would be greatly appreciated.
> Thanks for all you do.
> Joanie P. Cooke
> Water & Natural Resources Unit - ESS
> HEEC
> Bell 919-362-3553 (Caronet 772-3553)
> Pager 919-565-6832
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
1 of 1 8/7/00 11:49 AM

CP&L RoxSoro Steam; NC0003425; SynFuels
M
Subject: CP&L Roxboro Steam; NC0003425; SynFuels
Date: Tue, 06 Jun 2000 09:29:50 -0400
From: Tom Belnick <[e-mail]>
To: Fred holt <[e-mail]>, joanie cooke <[e-mail]>
Fred/Joanie- After reviewing the leachate data for the Synfuel binder
material, the Division agrees that a permit modification is not
necessary for CP&L to utilize SynFuels at the Roxboro facility. The
leachate data shows that the binder material yielded no leachable
compounds of concern above the limit of detection. Thanks for providing
the supporting material.
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
1 of 1 6/6/00 9:30 AM

[Fwd: [Fwd: Modeling/ Progress Energy] --GEMSS]
Subject: [Fwd: [Fwd: Modeling/ Progress Energy] --GEMSS]
Date: Fri, 30 May 2003 11:14:18 -0400
From: Michelle Woolfolk <[e-mail]>
Organization: NCDENR-Division of Water Quality
To: [e-mail], [e-mail]
Subject: Re: [Fwd: Modeling/ Progress Energy] --GEMSS
Date: Fri, 30 May 2003 10:33:31 -0400
From: Adugna Kebede <[e-mail]>
Organization: NCDENR
To: Michelle Woolfolk <[e-mail]>
Michelle,
My opinion (based on insufficient info) on GEMSS:
The model is used for three dimensional time varying simulations of rivers, lakes,
estuaries, and coastal water bodies. It has wide range of applications. The model is
designed in a modular fashion to allow coupling of existing modules with user
defined modules. The existing modules includes hydrodynamics, water quality, etc. As
long as they have the data to support their modeling effort using GEMSS and they
compare GEMSS results with CORMIX (they have suggested to present CORMIX results
along with GEMSS results), it should be okay to use the model. Based on my limited
reading about the model and the limited information provided, I do not see any
reason why we shouldn't allow the use of such a model. (The model description
provided at the J.E. Edinger web site is not detailed enough to have a good
understanding of the model. )
Thanks.
Adugna
Michelle Woolfolk wrote:
> Adugna,
> There is a description of the model at the J.E. Edinger web site. Look it over
> and let me know if you think it is suitable for the task. No memo needed - just
> an opinion.
> Michelle
> MICHELLE WOOLFOLK
> NCDWQ PLANNING BRANCH
> 1617 MAIL SERVICE CENTER
> RALEIGH NC 27699-1617
> PH:919/733-5083 x505 FX:919/715-2941
> [e-mail]
> ------------------------------------------------------------------------
> Subject: Modeling/ Progress Energy
> Date: Thu, 15 May 2003 12:18:06 -0400
> From: Susan A Wilson <[e-mail]>
> Organization: NC DENR DWQ
> To: "England, Louise" <[e-mail]>
> CC: Michelle Woolfolk <[e-mail]>,
> Mark Mcintire <[e-mail]>
I of 2 6/5/03 1:09 PM

[Fwd: [Fwd: Modeling/ Progress Energy] --GEMSS]
> Louise - I passed your message regarding the GEMSS model along to
> Michelle. They are looking into it. I would just correspond with
> Michelle (and/or Mark -since Mark is the contact for Duke and knows what
> you plan to do).
> I'm about to be on vacation for a couple of weeks and wanted to let you
> know.
> Susan
> (and your other issues re. biocides - I passed along to Joe Corporon -
> he wrote the letter and got the materials together).
2 of 2 6/5/03 1:09 PM

Re: comment$ on NC0003425 - CPL Roxboro Steam Electric
Subject: Re: comments on NC0003425 - CPL Roxboro Steam Electric
Date: Wed, 23 Oct 2002 16:18:36 -0400
From: Teresa Rodriguez <[e-mail]>
Organization: NC DENR DWQ
To: [e-mail]
CC: shell. karrie [e-mail], Dave Goodrich <[e-mail]>
Marshall,
The following is in response to your comments:
1. The mixing zone was based on monitoring and modeling done by the USGS,
UNC and CP&L during the late seventies. The data gathered during the study
were used to establish the mixing zone. Since the characteristics of the
effluent or the conditions under which the mixing zone was developed have
not changed, we believe the conditions should remain as previously approved.
2. A. The sampling location column does not reflect the requirement but it
is referenced in the footnote for temperature. For clarity I can add the
locations in the sampling location column for temperature.
B. I agree, they do have instream monitoring. I will make a note in the
amended fact sheet.
C. As per CP&L this provision was included to allow for downtime in
equipment maintenance or failure. I will try to reword this so that the
intention is stated clearly.
3. They sample within the mixing zone and the results show that they are
meeting the temperature standard within the mixing zone. They have a
biological monitoring program (Special Condition A.(12)) for monitoring the
lake which covers many parameters including temperature at various locations
in the lake outside of the mixing zone. Since they are meeting the standard
in the mixing zone no sampling outside of the mixing zone was included in
addition to the biological monitoring plan.
4. A. The list is final, I had an old version that said draft, but this.
section didn't change.
B. I did the reasonable potential for selenium based on the existing limit
as the allowable concentration. The limit was developed some years ago
based on a model for fate and transport of selenium in the lake, but I don't
have the details of the calculations. Data from the monitoring program have
shown decreased concentrations of selenium in the lake. The limit is not
necessary now that the fish advisory was lifted and they showed no
reasonable potential.
CP&L submitted a letter with comments on the draft permit. I'm still
working with some corrections to the permit and CP&L requests. I will write
an amended fact sheet to explain all the changes. I will send you the
permit and the amended fact sheet for your review.
If you have any questions regarding this information please let me know.
Teresa
[e-mail] wrote:
> the following (mostly) temperature mixing zone questions are based on my
> never having seen this permit. Will you be able to respond to us by Oct
> 10 so we have time to determine if we need to send a comment or an
> objection letter? thanks! Marshall
> 1) Section A(11)a spells out the spatial extent of the temp mixing zone.
> This seems to include whole arms of the lake and at least part of its
> main body. 15A NCAC 02B.0204(a)(1) requires that the discharge will not
> prevent free passage of aquatic organisms around the mixing zone.
> Because the depth of the mixing zone isn't provided, what documentation
> do you have to assure that there is a zone of free passage and that this
1 of 2 10/29/2002 9:04 AM

Re: comments on NC0003425 - CPL Roxboro Steam Electric
> mixing zone conforms with NC requirements? The fact sheet doesn't
> address this. If this is based on previous modeling, have recent data
> been used in the model to re -verify?
> 2) A. Footnote 3 in Section A(2) says that continuous monitoring for
> temp shall occur between 4C and 4D in the attached map. However, the
> sample location in the table above doesn't reflect this ambient
> monitoring requirement; it only indicates that there is effluent
> monitoring for temp. Why doesn't it reflect this ambient monitoring
> requirement?
> B. The last bullet in the "DMR Data" portion of the fact sheet
> says that there is no instream monitoring requirements in this permit.
> In light of footnote 3 cited above, this statement doesn't seem correct.
> C. If Footnote 3 requires continuous monitoring, is that
> consistent with the last sentence in Section A(11)(d)? I can interpret
> the latter to require discrete samples, not continuous sampling. Pls
> explain.
> 3. Section A(11)(b) says that all water discharged from the afterbay
> (mixing zone) shall comply with NC temp standards. However, as far as I
> can tell, the permit does not require ambient measurement outside the
> mixing zone to assess and confirm compliance. Pls explain the lack of
> ambient measurements outside the mixing zone to show that NC temp stds
> are being met.
> 4. re selenium,
> A. In the last sentence in the 4th bullet under the "Summary" section
> of the fact sheet, why is NC's 2000 303(d) list referred to as "draft"?
> Isn't it final and hasn't EPA approved it?
> B. 1. it isn't clear to me how the RPA for selenium was conducted. Pts
> explain.
> 2. I am also very curious about what background conc was assumed.
> I am concerned that zero was used. If it was, pls explain or document
> why that is a valid assumption.
2 of 2 10/29/2002 9:04 AM

Roxboro NC0003425 Responses to EPA Comments on Draft Permit
Subject: Roxboro NC0003425 Responses to EPA Comments on Draft Permit
Date: Mon, 21 Oct 2002 14:34:32 -0400
From: "Cooke, Joanie" <[e-mail]>
To: "Teresa Rodriguez (E-mail)" <[e-mail]>
Teresa,
I have included my responses to several of the EPA comments in italics. Let me know
if I need to clarify more.
Thanks
1) Section A(11)a spells out the spatial extent of the temp mixing zone.
This seems to include whole arms of the lake and at least part of its
main body. 15A NCAC 02B.0204(a)(1) requires that the discharge will not
prevent free passage of aquatic organisms around the mixing zone.
Because the depth of the mixing zone isn't provided, what documentation
do you have to assure that there is a zone of free passage and that this
mixing zone conforms with NC requirements? The fact sheet doesn't
address this. If this is based on previous modeling, have recent data
been used in the model to re -verify?
The mixing zone is based on monitoring and modeling that was conduct by the US
Geological Study, UNC Department of Environmental Sciences and CP&L during the
seventies. The studies/reports were submitted in the late seventies to the state
(circa 1978). No additional thermal loading (any which were not addressed in those
reports) have been added to the site since then. Hence the modeling and data
presented then is still pertinent and applicable today including the acknowledgement
that the current mixing zone along with the current monitoring meets the regulatory
requirements.
2) A. Footnote 3 in Section A(2) says that continuous monitoring for
temp shall occur between 4C and 4D in the attached map. However, the
sample location in the table above doesn't reflect this ambient
monitoring requirement; it only indicates that there is effluent
monitoring for temp. Why doesn't it reflect this ambient monitoring
requirement?
The facility samples and reports temperature at Cane Creek our background
temperature.
B. The last bullet in the "DMR Data" portion of the fact sheet
says that there is no instream monitoring requirements in this permit.
In light of footnote 3 cited above, this statement doesn't seem correct.
C. If Footnote 3 requires continuous monitoring, is that
consistent with the last sentence in Section A(11)(d)? I can interpret
the latter to require discrete samples, not continuous sampling. Pls
explain.
This provision allows facility compliance during periods of equipment downtime due to
failure or maintenance (similar to the one included in the definition for continuous
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1 of 2 f) ' 10/21/2002 2:36 PM

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Roxboro NC,0003425 Responses to EPA Comments on Draft Permit
flow monitoring). Due to the nature and location of the monitoring equipment this
provision is necessary.
3. Section A(11)(b) says that all water discharged from the afterbay
(mixing zone) shall comply with NC temp standards. However, as far as I
can tell, the permit does not require ambient measurement outside the
mixing zone to assess and confirm compliance. Pls explain the lack of
ambient measurements outside the mixing zone to show that NC temp stds
are being met.
The facility samples temperature at 4C4D (within the mixing zone). To date the
facility is meeting the temp stds within the zone hence no designation of outside the
mixing zone has been included in the permit.
4. re selenium,
A. In the last sentence in the 4th bullet under the "Summary" section
of the fact sheet, why is NC's 2000 303(d) list referred to as "draft"?
Isn't it final and hasn't EPA approved it?
B. 1. it isn't clear to me how the RPA for selenium was conducted. Pls
explain.
2. I am also very curious about what background conc was assumed.
I am concerned that zero was used. If it was, pls explain or document
why that is a valid assumption.
Joanie P. Cooke
CP&L, A Progress Energy Company
[phone], [e-mail]
Pager [phone]
Fax [phone] .
3 of 2 10/31/2002 2:36 PM

Re: comments on NC0003425 - CPL Roxboro Steam Electric
> mixing zone conforms with NC requirements? The fact sheet doesn't
> address this. if this is based on previous modeling, have recent data
> been used in the model to re -verify?
> 2) A. Footnote 3 in Section A(2) says that continuous monitoring for
> temp shall occur between 4C and 4D in the attached map. However, the
> sample location in the table above doesn't reflect this ambient
> monitoring requirement; it only indicates that there is effluent
> monitoring for temp. Why doesn't it reflect this ambient monitoring
> requirement?
> B. The last bullet in the "DMR Data" portion of the fact sheet
> says that there is no instream monitoring requirements in this permit.
> in light of footnote 3 cited above, this statement doesn't seem correct.
> C. If Footnote 3 requires continuous monitoring, is that
> consistent with the last sentence in Section A(11)(d)? I can interpret
> the latter to require discrete samples, not continuous sampling. Pls
> explain.
> 3. Section A(11)(b) says that all water discharged from the afterbay
> (mixing zone) shall comply with NC temp standards. However, as far as I
> can tell, the permit does not require ambient measurement outside the
> mixing zone to assess and confirm compliance. Pls explain the lack of
> ambient measurements outside the mixing zone to show that NC temp stds
> are being met.
> 4. re selenium,
> A. In the last sentence in the 4th bullet under the "Summary" section
> of the fact sheet, why is NC's 2000 303(d) list referred to as "draft"?
> Isn't it final and hasn't EPA approved it?
> B. 1. it isn't clear to me how the RPA for selenium was conducted. Pls
> explain.
> 2. I am also very curious about what background conc was assumed.
> I am concerned that zero was used. if it was, pts explain or document
> why that is a valid assumption.
2 of 2 10/25/2002 9:25 AM

comments or NC0003425 - CPL Roxboro Steam Electric
IofI
Subject: comments on NC0003425 - CPL Roxboro Steam Electric
Date: Tue, 24 Sep 2002 10:06:14 -0400
From: [e-mail]
To: [e-mail]
CC: [e-mail], [e-mail],
[e-mail], [e-mail]
the following (mostly) temperature mixing zone questions are based on my
never having seen this permit. Will you be able to respond to us by Oct
10 so we have time to determine if we need to send a comment or an
objection letter? thanks! Marshall
1) Section A(11)a spells out the spatial extent of the temp mixing zone.
This seems to include whole arms of the lake and at least part of its
main body. 15A NCAC 02B.0204(a)(1) requires that the discharge will not
prevent free passage of aquatic organisms around the mixing zone.
Because the depth of the mixing zone isn't provided, what documentation
do you have to assure that there is a zone of free passage and that this
mixing zone conforms with NC requirements? The fact sheet doesn't
address this. If this is based on previous modeling, have recent data
been used in the model to re -verify?
��d? a, . YV
,(A)�X;t� 7-1-0
2) A. Footnote 3 in Section A(2) says that continuous monitoring for
temp shall occur between 4C and 4D in the attached map. However, the 'yw Ill
sample location in the table above doesn't reflect this ambient C �L
monitoring requirement; it only indicates that there is effluent
monitoring for temp. Why doesn't it reflect this ambient monitoring j
requirement?
B. The last bullet in the "DMR Data" portion of the fact sheet
says that there is no instream monitoring requirements in this permit.
In light of footnote 3 cited above, this statement doesn't seem correct.
C. If Footnote 3 requires continuous monitoring, is that
consistent with the last sentence in Section A(11)(d)? I can interpret
the latter to require discrete samples, not continuous sampling. Pls
explain.
3. Section A(11)(b) says that all water discharged from the afterbay
(mixing zone) shall comply with NC temp standards. However, as far as I
can tell, the permit does not require ambient measurement outside the
mixing zone to assess and confirm compliance. Pls explain the lack of
ambient measurements outside the mixing zone to show that NC temp stds
are being met.
4. re selenium,
i
A. In the last sentence in the 4th bullet under the "Summary" section
of the fact sheet, why is NC's 2000 303(d) list referred to as "draft"?
Isn't it final and hasn't EPA approved it?
B. 1. it isn't clear to me how the RPA for selenium was conducted. Pls
explain.
2. I am also very curious about what background conc was assumed
I am concerned that zero was used. If it was, pls explain or document
why that is a valid assumption.
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