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N CG-Al£ O{p3/P -Ff-o a Progress Energy August 25, 2009 Ms. Jennifer Jones Stormwater Permitting Unit Division of Water Quality 161 7 Mail Service Center Raleigh, NC 27699-1617 AUG 2 5 2009 Subject: Carolina Power & Light Company d/b/a Progress Energy Carolinas, Inc. Weatherspoon Steam Electric Plant NPDES Permit No. NC0005363 Request for No Exposure Certification (NCGNEOOOO) Dear Ms. Jones: Progress Energy Carolinas, Inc., submits this request for No Exposure Certification which constitutes notification that the Weatherspoon Steam Electric Plant does not require a permit for storm water discharges associated with industrial activity. All storm water that falls on the plant site is comingled with wastewater and flows into the cooling pond (permitted Outfall 001). Thus all storm water at the plant site is covered under NPDES Wastewater Permit NC0005363. An industrial activity associated with the Weatherspoon Steam Electric Plant that does not flow into the cooling pond is related to the coal ash reclamation projects described in the latest NPDES permit application. The approximately 0.6 mile long access road becomes a source of industrial activity when this power plant coal combustion product is transported along this route. Our established BMPs dictate that during ash removal projects, transport trucks are filled with moistened ash (about 15-18%) within the confines of the ash pond boundary and covered with a tarp. The trucks are washed down prior to leaving the loading area and travel along a graveled on-site roadway before exiting the site via the plant access road. Hauling activities occur only on days without significant precipitation and the roadway is inspected twice a day for any spillage. The current reclamation project is scheduled to conclude fall 2011. Based on our understanding of the EPA Conditional No Exposure Exclusionfor Industrial Activity Fact Sheet 4.0, materials and activities can be sheltered with temporary covers (e.g., tarps) when a permanent structure for the activity is not possible. We therefore submit that the industrial materials associated with the coal ash reclamation projects are not exposed to storm water. Progress Energy Carolinas, Inc., requests that a No Exposure Certification be granted for the Weatherspoon Steam Electric Plant for the above mentioned activity. Progress Energy Carolinas, Inc. Weatherspoon Steam Plant 491 Power Plant Road Lumberton, NC 28358 J5y

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Page 1: Progress Energy - files.nc.gov Records 1/SELC - DEML Coal Ash... · Stormwater Permitting Unit ... industrial materials associated with the coal ash reclamation projects are ... material

N CG-Al£ O{p3/P -Ff-o

a Progress Energy

August 25, 2009

Ms. Jennifer Jones Stormwater Permitting Unit Division of Water Quality 161 7 Mail Service Center Raleigh, NC 27699-1617

AUG 2 5 2009

Subject: Carolina Power & Light Company d/b/a Progress Energy Carolinas, Inc. Weatherspoon Steam Electric Plant NPDES Permit No. NC0005363 Request for No Exposure Certification (NCGNEOOOO)

Dear Ms. Jones:

Progress Energy Carolinas, Inc., submits this request for No Exposure Certification which constitutes notification that the Weatherspoon Steam Electric Plant does not require a permit for storm water discharges associated with industrial activity.

All storm water that falls on the plant site is comingled with wastewater and flows into the cooling pond (permitted Outfall 001). Thus all storm water at the plant site is covered under NPDES Wastewater Permit NC0005363.

An industrial activity associated with the Weatherspoon Steam Electric Plant that does not flow into the cooling pond is related to the coal ash reclamation projects described in the latest NPDES permit application. The approximately 0.6 mile long access road becomes a source of industrial activity when this power plant coal combustion product is transported along this route.

Our established BMPs dictate that during ash removal projects, transport trucks are filled with moistened ash (about 15-18%) within the confines of the ash pond boundary and covered with a tarp. The trucks are washed down prior to leaving the loading area and travel along a graveled on-site roadway before exiting the site via the plant access road. Hauling activities occur only on days without significant precipitation and the roadway is inspected twice a day for any spillage. The current reclamation project is scheduled to conclude fall 2011.

Based on our understanding of the EPA Conditional No Exposure Exclusionfor Industrial Activity Fact Sheet 4.0, materials and activities can be sheltered with temporary covers (e.g., tarps) when a permanent structure for the activity is not possible. We therefore submit that the industrial materials associated with the coal ash reclamation projects are not exposed to storm water. Progress Energy Carolinas, Inc., requests that a No Exposure Certification be granted for the Weatherspoon Steam Electric Plant for the above mentioned activity.

Progress Energy Carolinas, Inc. Weatherspoon Steam Plant 491 Power Plant Road Lumberton, NC 28358

J5y

Page 2: Progress Energy - files.nc.gov Records 1/SELC - DEML Coal Ash... · Stormwater Permitting Unit ... industrial materials associated with the coal ash reclamation projects are ... material

Ms, Jennifer Jones, NCDENR 2 August 25, 2009

If there are any questions regarding the enclosed information, please contact Robin Bryson at (919) 546-3962.

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 imprisonment for knowing violations.

Sincerely,

J. Mark Frederick Plant Manager

JMF/rb Enclosures c: Mr. Larry Baxley

Ms. Robin Bryson

Page 3: Progress Energy - files.nc.gov Records 1/SELC - DEML Coal Ash... · Stormwater Permitting Unit ... industrial materials associated with the coal ash reclamation projects are ... material

AVA NCDENR

NoRTH Co.RoUNA DE_tMe:,,"" OF f}{ViRONMI':.>rr ."Jm N.uut".AI .. Rf:.<'"oiJRCF:S

Division of Water Quality / Surface Water Protection

National Pollutant Discharge Elimination System NO EXPOSURE CERTIFICATION for Exclusion

NCGNEOOOO

FOR AGENCY USE ONLY

NO EXPOSURE CERTIFICATION Please check here ifthis;sa renewal: 0 RENEWAL

National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based on NO EXPOSURE:

Submission of this No Exposure Certification constitutes notification that your facility does not require a permit for storm water discharges associated with industrial activity in the State of North Carolina because it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff.

For permitted facilities in North Carolina, DWQ must approve your application for No Exposure Certification before this exclusion is effective. Until you are issued a No Exposure Certification and your NPDES permit is rescinded, your facility must continue to abide by the terms and conditions of the current permit.

Industrial materials or activities include, but are not limited to: material handling equipment or activities, industrial machinery, raw materials, intermediate products, by-products, final products, or waste products. Material handling activities include the storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product or waste product. A storm resistant shelter is not required for the following industrial materials and activities: drums, barrels, tanks, and similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealedn means banded or otherwise secured and with locked or non-operational taps or valves; adequately maintained vehicles used in material handling; and final products, other than products that would be mobilized in stormwater discharges (e.g., rock salt).

A No Exposure Certification must be provided for each facilitv qualifying for the no exposure exclusion. In addition, the exclusion from NPDES permitting is available on a facility-wide basis only-not for individual outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you certify that a condition of no exposure exists at this facility or site and are obligated to comply with the terms and conditions of 40 CFR 122.26(g).

You are required to reapply for the No Exposure Exclusion once every five (5) years.

For questions, please contact the DWQ Regional Office for your area. (See page 6)

(Please print or type)

1} Mailing address of owner/operator (address to which all certification correspondence will be mailed):

Name Carolina Power & Light Company d/b/a Progress Energy Carolinas, Inc.

Contact Street Address City Telephone No.

SWU-NE-021309

Robin Bryson 410 S. Wilmington Street Raleigh State--=::..:;N-=C __ ZIP Code -,,2=-7-,-6~0=1 ___ _ 919 546-3962 Fax: 919 ~5~4~6~-~4~4~0~9 ________ __

Page 1 of 7

Last revised 2/13/2009

Page 4: Progress Energy - files.nc.gov Records 1/SELC - DEML Coal Ash... · Stormwater Permitting Unit ... industrial materials associated with the coal ash reclamation projects are ... material

NCGNEOOOO No Exposure Certification

2) Location of facility producing discharge:

Weatherspoon Steam Electric Plant

Larry Baxley 491 Power Plant Road

Facility Name

Facility Contact Street Address City Lumberton State NC ZI P Code --=.2-=..8 =-3 =-5-=..8 ___ _

Robeson County Telephone No. 910 671-1206 Fax: ____________________________ _

3) Physical location information:

Please provide a narrative description of how to get to the facility (use street names, state road numbers, and distance and direction from a roadway intersection). From I-40E, merge onto I-958 (exit 328A).

Take NC 211 (exit 20) aka N Roberts Ave. Turn left onto Power Plant Rd. (A copy of a map with the facility clearly located on it should be included with the certification application.)

4) Is the facility located on Native American Lands? 0 Yes Rl No

5) Is this a Federal facility? 0 Yes IZl No

6) Latitude 34 34' 58" Longitude 78 58' 25" (deg., min., seconds)

7) This NPDES No Exposure Exclusion application applies to which of the following:

o New or Proposed Facility

~ Existing

Date operation is to begin _______ _

Date operation began June, 14, 2008

o Renewal of existing No Exposure Certification Certification No.: NCGNE __________ _

8) Was this facility or site ever covered under an NPDES Stormwater Permit? I8l Yes 0 No

If yes, what is the NPDES Permit Number? NC0005363

9) Standard Industrial Classification:

Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial activity at this facility

SIC Code:.-L L L l

10) Provide a brief description of the types of industrial activities and products produced at this facility: Weatherspoon is a coal-fired electric plant. The coal combustion product (ash) is being trucked off site along the access road.

11) Does this facility have any Non-Discharge permits (ex: recycle permits)?

IZI No

DYes

If yes, list the permit numbers for all current Non-Discharge permits for this facility:

Page 2 of 7 SWU-NE-021309 Last revised 2/13/2009

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· . NCGNEOOOO No Exposure Certification

Exposure Checklists (12. - 14.)

12} Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not eligible for the no exposure exclusion.

a. Using, storing, or cleaning industrial machinery or equipment, and areas where 0 Yes 0 No ~ N/A residuals from using, storing or cleaning industrial machinery or equipment remain and are exposed to storm water

b. Materials or residuals on the ground or in stormwater inlets from spills/leaks 0 Yes ~ No 0 N/A

c. Materials or products from past industrial activity 0 Yes 0 No IX N/A

d. Material handling equipment (except adequately maintained vehicles) 0 Yes IX! No 0 N/A

e. Materials or products during loading/unloading or transporting activities 0 Yes ~ No 0 N/A

f. Materials or products stored outdoors (except final products intended for outside 0 Yes 0 No ~ N/A use [e.g., new cars] where exposure to stormwater does not result in the discharge of pollutants)

g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, 0 Yes 0 No [gI N/A and similar containers

h. Materials or products handled/stored on roads or railways owned or maintained by 0 Yes ~ No 0 N/A the discharger

L Waste material (except waste in covered, non-leaking containers [e.g., dumpsters]) 0 Yes ~ No 0 N/A

j. Application or disposal of process wastewater (unless otherwise permitted) 0 Yes 0 No ~ N/A

k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not 0 Yes 0 No ~ N/A otherwise regulated (Le., under an air quality control permit) and evident in the stormwater outflow

I. Empty containers that previously contained materials that are not properly stored 0 Yes 0 No IX N/A (Le., not closed and stored upside down to prevent precipitation accumulation)

m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers 0 Yes 0 No IZl N/A stored outside, has the facility had any releases in the past three (3) years?

13} Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not eligible for the no exposure exclusion.

a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or 0 Yes 0 No [gI N/A deterioration, or evidence of leaks?

b. Is secondary containment provided for all exterior ASTs? If so, is it free of any 0 Yes 0 No ~ N/A cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?

Page 3 of 7 SWU-NE-021309 Last revised 2/13/2009

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NCGNEOOOO No Exposure Certification

14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the no exposure exclusion.

a. Is secondary containment provided for single above ground storage containers (including drums, barrels, etc.) with a capacity of more than 660-gallons?

b. Is secondary containment provided for above ground storage containers stored in close proximity to each other with a combined capacity of more than 1,320-gallons?

c. Is secondary containment provided for Title III Section 313 Superfund Amendments and Reauthorization Act (SARA) water priority chemicals*?

d. Is secondary containment provided for hazardous substances** designated in 40 CFR §116?

e. Are release valves on all secondary containment structures locked?

15) Hazardous Waste:

a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?

b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of hazardous waste?

c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of hazardous waste?

If you answered yes to questions b. or c., please provide the following information:

DYes 0 No IZI N/A

DYes 0 No 1&1 N/A

DYes 0 No IZI N/A

DYes 0 No ~ N/A

DYes 0 No ~ N/A

DYes 0 No 1&1 N/A

DYes 0 No ~ N/ A

DYes 0 No I» N/A

Type(s) of waste: _________________________ _

How is material stored: _________________________ _ Where is m~erial stored: ________________________ _

How many disposal shipments per year: ___________________ _ Name of transport / disposal vendor: ____________________ _ Vendoraddress: ___________________________ _

Footnotes to Questions 14) c. & d.

*Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for de minimis amounts of certain substances, and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR §372.38.

**Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities of the hazardous substances listed in 40 CFR §117.3.

Page 4 of 7 SWU-NE-021309 Last revised 2/13/2009

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NCGNEOOOO No Exposure Certification

16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.

a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? 0 Yes 0 No I» N/A

b. Does your facility have coal piles on site? 0 Yes 0 No I» N/A

c. Does your facility store other fuel sources outside in piles, such as wood chips, 0 Yes 0 No IX N/A sawdust, etc.?

d. Does your facility have air emissions associated with its industrial activity (e.g., 0 Yes 0 No ~ N/A degreasing operations, plating, painting and metal finishing)? If so, describe the industrial activity:

e. If you answered yes to d., are those emissions permitted by an Air Quality Permit? 0 Yes 0 No 0 N/A Please specify:

f. Please list any other environmental program permits (federal, state, etc.) not specified earlier in this application (such as Hazardous Waste Permits, etc.):

Permit: , Program:

Permit: , Program:

Permit: , Program:

Permit: , Program:

Permit: , Program:

Permit: , Program:

Permit: , Program:

Page 5 of 7 SWU-NE-021309 Last revised 2/13/2009

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NCGNEOOOO No Exposure Certification

17) Certification:

I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no

exposure" and obtaining an exclusion from NPDES stormwater permitting.

I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities

or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).

I understand that I am obligated to submit a no exposure certification form once every five (5) years to the North Carolina

Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into

which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water

Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no

exposure and to make such inspection reports publicly available upon request.

In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under

an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, 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 gathered and evaluated 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 fine and imprisonment for

knowing violations.

I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief

such information is true, complete, and accurate.

Printed Name of Person Signing: J Mark Frederi ck Title: Plant Manager

L/4J,· ,r,u4d ! /2:5' /07' (SigKature of Applicant) (Date Signed)

Please note: This application for the No Exposure Exclusion is subject to approval by the NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for compliance with no exposure conditions prior to that approval. The Regional Office may also inspect your facility at any time in the future for compliance with the No Exposure Exclusion.

North Carolina General Statute 143-215.6 8(i) provides that:

Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other

document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false

statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly

renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the

[Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine

not to exceed ten thousand dollars ($10,000).

There is currently no fee for a No Exposure Exclusion.

Page 6 of 7 SWU-NE-021309 Last revised 2/13/2009

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NCGNEOOOO No Exposure Certification

Final Checklist

This application should include the following items:

~ This completed application and all supporting documentation. I» A map with the location of the facility clearly marked. o If this is a renewal, indicated current NCGNE number in Question 7. IZJ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.

Mail the entire package to:

Stormwater Permitting Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617

The submission of this document does not guarantee the issuance of a No Exposure Exclusion.

For questions, please contact the DWQ Regional Office for your area.

DWQ Regional Office Contact Information:

Asheville Office ...... (828) 296-4500 Fayetteville Office ... (910) 433-3300 Mooresville Office ... (704) 663-1699 Raleigh Office ........ (919) 791-4200 Washington Office ... (252) 946-6481 Wilmington Office ... (910) 796-7215 Winston-Salem ...... (336) 771-5000 Central Office ......... (919) 807-6300

Page 7 of 7 SWU-NE-021309 Last revised 2/13/2009

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• I

Progress Energy Carolinas, Inc. Weatherspoon Steam Electric Plant

I o

I 0.1

I 0.2

I I 0.3 0.4

Map-1

No Exposure Certification Request Site Maps

I 0.5 miles

Page 11: Progress Energy - files.nc.gov Records 1/SELC - DEML Coal Ash... · Stormwater Permitting Unit ... industrial materials associated with the coal ash reclamation projects are ... material

Progress Energy Carolinas, Inc. Weatherspoon Steam Electric Plant

-765 ft to top of grade

Open drain pipe • • • • • • \\

Drainage from abandoned rail line ditches and fields . • • • • • • • • · · · ·

• • · · · • · · · 4---Drain junction box

N

i Approximated

Scale (approximated)

1" = 80'

Map-2

No Exposure Certification Request Site Maps

Page 12: Progress Energy - files.nc.gov Records 1/SELC - DEML Coal Ash... · Stormwater Permitting Unit ... industrial materials associated with the coal ash reclamation projects are ... material

Progress Energy Carolinas, Inc. Weatherspoon Steam Electric Plant

N

1 Scale (approximated)

1" = 270'

NC72

No Exposure Certification Request Site Maps

Power Plant Road

Unnamed tributary to the Lumber River

Map-3

SW-1 t

1 1

Used auto parts business

Small pond offsite

Top of grade