Notes from Site Visit at Progress Energy's Ca pe Fear Steam Electric Plant on October 20,
2009

EPA conducted a site visit at Progress Energy’s Cape Fear Steam Electric Plant (Cape Fear) located in Moncure, NC on Tuesday, October 20, 2009 to learn about the operations at the plant, including the operation of the oil-fired combined cycle un its and coal-fired units and the handling of the ash generated at the plant. Tabl e 1, located at the end of this memorandum, identifies the site visit participants. An overall water balance diagram for the plant is provided as
Attachment 1.

This memorandum describes the information collected during the site visit and the pre-site visit phone call, which was held on October 14, 2009.

Plant Overview

 Cape Fear operates two coal-fired elect ric generating units. Th e coal-fired units
are summarized in the table below.

Cape Fear Coal-Fired Electric Generating Units

Unit Installation

Date Gross Capacity

(MW) Particulate
Control NOx Control SO 2 Control

5 1956 150 Electrostatic precipitator (ESP) (cold-side) Selective noncatalytic reduction (SNCR) (May 2006) None

6 1958 180 ESP (cold-side) SNCR (May 2006) None

 Cape Fear also operates two combined-cycle electric generating units (Units 1 and 2), each consisting of two oil-fired combustion turbines and one steam turbine. The exhaust gases from the combustion turbin es are used to generate steam in one of two heat recovery steam generators (HRSG). The steam from the HRSG is
used to turn one of the steam turbines. The table below summarizes information on the combined-cycle electric generating units operating at Cape Fear.Page 2

Cape Fear Combined Cycle Generating Units

Unit Installation

Date Winter Capacity (MW) Summer Capacity

(MW) Type of Unit

1 1923 15 11 HRSG

2 1924 15 11 HRSG

1A 1969 9 9 Combustion Turbine

1B 1969 9 9 Combustion Turbine

2A 1969 9 9 Combustion Turbine

2B 1969 9 9 Combustion Turbine

 Units 1 and 2 were initially construc ted as coal-fired units in 1923 and 1924, respectively. The boilers fo r Units 1 and 2 were initia lly retired in 1969. Also in 1969, Cape Fear installed the four combus tion turbines and decided to repower
the Unit 1 and 2 steam turbines to use in a combined cycle operation with the
combustion turbines.

 Units 3 and 4, which are both coal-fired units, were commissioned in the 1940s.
These two units were remove d from service in July 1977.

 Cape Fear stated that Units 5 and 6 are not considered baseload units, but instead
are considered “intermediate” units. Howe ver, Cape Fear noted that during the past three years, Units 5 and 6 have basi cally been operated as baseload units.

 Cape Fear stated that the minimum load for Units 5 and 6 is 50 MW for each unit; therefore, Cape Fear will shut down the uni ts if the requested output is less than

50 MWs.

 Cape Fear uses once-through cooling water to condense the steam associated with
the coal-fired units and the HRSGs. The plant uses the Cape Fear River as the source of the cooling water. The cooli ng water is transferred to the plant’s discharge canal via internal Outfall 003. The discharge canal flows to the Cape Fear River where the plant discharges vi a Outfall 007. Cape Fear stated that Outfall 007 is not located at the point wh ere the discharge canal enters into the Cape Fear River, but is located 29,568 feet (5.6 miles) upstream of the Cape Fear
River.

 Cape Fear also has cooling towers on site to control the temperature of the discharge to the Cape Fear River. If the temperature of the discharge canal approaches 32°C (90°F), then Cape Fear operates the cooling towers in oncethrough mode to lower the temperature of th e discharge. Cape Fear stated that the cooling towers are typically operated during the summer months (May through September).

 The Cape Fear plant has 64 employees.Page 3

Combined-Cycle Electric Generating Units

 Cape Fear stated that No. 2 fuel oil is the only fuel used in the combustion turbines. Cape Fear does not have the capab ility to burn fuels other than oil in the
combustion turbines.

 Cape Fear stores the No. 2 fuel oil in a 500,000 gallon tank. Cape Fear stated that the tank contains a 14 day supply of o il under normal operating conditions where
each of the four turbines runs for 4.5 hours per day. If longer run times are required, the oil supply days would be less.

 Cape Fear stated that the four combustion turbines are “Frame 5” General Electric
combustion turbines.

 The combustion turbines are considered “fast start” electric generating units because they can be operational in 7 mi nutes and operating at full load in 10
minutes.

 The combustion turbines are operated onl y during times of peak electricity demand. The combustion turbines typi cally only run for approximately 30 minutes at a time, which the plant refers to as “peaker runs.”

 In 2008, each of the combustion turbines ope rated for a total of approximately 50 hours during the year.

 Although the combustion turbines are set up to operate in combination with the HRSGs as combined-cycle electric genera ting units, the combustion turbines can be operated in simple-cycle mode. When the combustion turbines operate in simple-cycle mode, the plant closes a da mper to allow the exhaust gases to bypass the HRSG and flow directly to the stack.

 When the unit operates in combined-cyc le mode, the exhaust gas flows through
the HRSG and transfers its heat to the wa ter system and generates steam. Cape
Fear stated that it take s approximately two hours to pre-heat the HRSG and get the unit online. Because of this long start-up time, the plant uses the HRSGs during only rare occasions when the units are expected to be operating for extended periods of time, which are during the extreme high (peak summer) and/or low (peak wint er) temperatures.

 The HRSG units are each capable of generating 177,000 pounds per hour of

steam.

 Cape Fear stated that both the A and B (e.g., 1A and 1B) combustion turbines must be operating for the plant to be able to operate the HRSG for the unit.

 Cape Fear stated that there are no wastew aters generated from the combined cycle units other than periodic metal cleaning wastes on the combustion turbines.

 Cape Fear stated that the combustion tu rbines do not generate ash or residue.Page 4

Coal-Fired Generating Units

 Cape Fear receives its coal via rail. The plant burns bituminous coal in Units 5
and 6. The sulfur content of the coal is 1.1 to 1.7 lb/MBTU. The ash content of the coal is approximately 10 percent. The chlorine content in coal is not a parameter Progress Energy Carolinas rou tinely measures. The standard EPRI PISCES database (2005), median chlori ne content of bituminous coal is 894 mg/kg dry wt. (average 952 mg/kg).

 Cape Fear keeps approximately 40 days wo rth of coal on site. Coal pile runoff generated from stormwater that contacts the coal pile is collected in an area near the pile and transferred to the plant’s West ash pond (described later in these notes).

 Cape Fear operates a SNCR system on Units 5 and 6. For the SNCR system, the plant injects urea directly into the boile r. The SNCRs operate frequently during the ozone season (May through September). The plants may operate the SNCRs occasionally outside of ozone season if it is needed to meet the plant’s NOx
limits.

 In 2006 when the SCNRs were first opera ted, Cape Fear used ammonia for the SNCR injection; however, the plant deci ded to switch from ammonia to urea because urea is safer. Cape Fear note d that they had detected ammonia in the West ash pond effluent after the SNCRs began operating.

 Cape Fear stated that there is a boiler blowdown stream from the two coal-fired electric generating units. The boiler blow down is transferred to the plant’s east ash pond. Cape Fear stated that the blow down has high concentrations of silver.

Ash Handling System

 Cape Fear operates wet ash handling systems for both fly ash and bottom ash
from Units 5 and 6.

 Cape Fear collects fly ash from Units 5 and 6 with a cold-side ESP. Ash collected by the ESPs falls into one of the four hoppers for the unit. The plant has two hopper “trains”, one for Unit 5 and one for Unit 6. Each “train” has four hoppers.
The economizer ash and ESP ash are collect ed in separate hoppers. The ash in each hopper, one at a time, is released into the ash sluice line which flows to the ash pond.

 Dry ash from the hoppers is combined into one dry fly ash header pipe. A hydroveyor pulls vacuum on the dry ash and mi xes it with water. Cape Fear stated that the hydroveyor uses plant water to ge nerate a vacuum as a result of the Venturi effect. The vacuum pulls fly ash from the hoppers into the flowing water.Page 5

 After the hydroveyor, the sluiced ash flows in to an air separator. The air separator is a cylindrical tank that rotates the slui ced ash like a centrifuge, separating the air
from the mixture.

 Cape Fear then combines the sluiced fl y ash with the bottom ash and pumps the ash mixture to the East ash pond.

 Progress Energy stated that they have a committee that has/is investigating whether to install a dry fly ash handli ng system at Cape Fear and the other Progress Energy plants. The following factors affect the decision to install the dry fly handling system at Cape Fear:

 Lack of available space for dry ash silos and piping;

 Issues associated with transportation of dry fly ash to solid waste disposal (Cape Fear does not have a landfill);

 Cape Fear’s ponds are not lined and therefore do not have a leachate collection system; and

 Capital cost of the ash handling system.

 Cape Fear stated that the bottom and fl y ash are sluiced to the ash ponds once per shift. The plant has two shifts per day.

Ash Ponds

 Cape Fear has three inactive ash ponds on site. The inactive ash ponds started receiving wastes in 1956, 1960, and 1963. All three inactive ash ponds are now covered by thick vegetation and forest. Cape Fear stated that th ey did not receive guidance from regulatory officials on how to close these ponds and, therefore, the plant did not cap the ponds. The vegeta tion and forest just occurred naturally over the pond wastes. Cape Fear’s record s are unclear when each of these ponds stop receiving wastewater, but standard practi ce at that time was to direct the ash sluice to the “new” pond upon completion. Therefore, the best supposition would be the 1956 pond stopped receiving as h sluice in 1960, the 1960 pond stopped receiving ash sluice in 1963, and th e 1963 pond stopped receiving ash sluice in
1978.

 Cape Fear has two active ash ponds, the east and west ash ponds.

 The west ash pond began operation in 1978 and receives stormwater, low-volume wastes, and coal-pile runoff. Low volume wastes from the plant are sent to a retention basin with an oil-water separato r prior to being transferred to the west ash pond.

 The east ash pond began operation in 1985 and receives fly and bottom ash. The east ash pond has an estimated footprint of approximately 58 acres.

 The east ash pond has a dike that runs across the middle of the pond that essentially breaks the pond in to two separate cells for the pond. All water enters
in the first cell and overflows into the s econd cell. The plant has an alum addition system at the point of overflow from the first cell of the east ash pond to thePage 6

second cell. Cape Fear noted that the system would be used to increase the settling in the pond, but they haven’t started using th e system yet. Progress Energy stated that there is a simila r alum system at the Sutton plant.

 The east ash pond outer dike was construc ted with clay. The inner dike is constructed with dredged ash. Cape Fear dr edges and restacks the ash in the east ash pond approximately once every week.

 Cape Fear stated that they are consider ing increasing the height of the east ash pond embankment/dike to increase the pond’s capacity. Additionally, the plant is considering dredging the east ash pond a nd putting the ash in the west ash pond.

 Cape Fear stated that th e retention time through both active ponds (east and west) is approximately 5-7 days.

 The west ash pond overflows into the di scharge canal via internal Outfall 001. The east ash pond overflows into the disc harge canal via inte rnal Outfall 005.

 Both the east and west ash ponds overflow continuously to the discharge canal.

 Cape Fear stated that they do not recycle the effluent of the ash ponds for reuse in the plant because of plant design, low quantit y of effluent, and the availability of other better quality water.

 None of the ponds at Cape Fear (incl uding the inactive ponds) were constructed with synthetic lining materials or leachate collection systems.

 Cape Fear is currently conducting struct ural integrity studi es on the west ash pond. Cape Fear recently hired a contract or to perform dike slope stability inspections. The contractor is drilling bore holes into the dike to determine the composition throughout the depth of the dike.

 Cape Fear stated that both the east and west ash ponds ar e also inspected routinely by plant personnel. These inspections c onsist of looking for animal patches, excessive vegetation, and other parameters of pond integrity around the perimeter of the pond. Cape Fear stated that they are not performing any routine inspections on the interior (bottom) of the ponds. The routine inspections are typically performed on a monthly basis.

 Cape Fear has six groundwater monitori ng wells around the perimeter of the ash ponds. Cape Fear analyzes the groundwater for metals semi-annually from all six wells. The groundwater monitoring re port from March 2007, December 2007, April 2008, December 2008, and June 2009 are included as Attachment 2 of this
memorandum.Page 7

Metal Cleaning Wastes

 Cape Fear performs metal cleaning oper ations on the combustion turbine units when the system performance starts to degr ade. Cape Fear stated that the last two metal cleaning operations were performed in 2003 and 2008.

 Cape Fear stated that metal cleaning c onsists of washing the compressor blades
with water and a non-corrosiv e detergent (Zok-27). The detergent is mixed and pumped into the inlet of the compressor. After the detergent is given sufficient time to contact the compressor blades, the wastewater is pumped to drums for storage. Approximately 150 gallons of wa stewater are generated each time the plant performs a metal cl eaning operation on all four combustion turbines.

 A waste disposal company, Shamrock E nvironmental, tests the metal cleaning wastewater for heavy metals. Cape Fear st ated that the metal cleaning wastewater has always been classified by Shamrock as non-hazardous. Shamrock then ships
the wastewater off site for treatment.

 Cape Fear has a control room which monitors the temperature and other operational parameters of the combustion tu rbines. If the oil lube temperature for the combustion turbines reaches 170°C, th en the system will automatically shut down. To prevent the unit from shutti ng down, the combustion turbine operator can mitigate the temperature by spraying water on the exterior of the turbines’ radiators to aid in the cooling. This wate r does not come into direct contact with radiator cooling water. The spray water is then collected by sumps, processed through an oil/water separator, and tr ansferred to the east ash pond. Unlike the spray water, the radiator cooling water is in a closed system.

 Air preheater washes are performed once a year on the coal-fired units. The wash
water is collected and transferred to the east ash pond. Approximately 4,000,000 gallons of wastewater are generated from each air preh eater wash. This process typically takes 30 hours to complete.

 Cape Fear cleans both the waterside and fi reside of the boiler tubes for the coalfired units. For the fire-side cleanings, Ca pe Fear uses high pressure water to remove residue from the tubes. Cape Fear stated that the fire-side cleanings occur approximately every 18 months. Appr oximately 700,000 gallons of wastewater are generated from each fire-side boiler cl eaning. This process typically takes 5 hours to complete.

 For the water-side cleanings, Cape Fear us es an EDTA solution to clean the boiler tubes. Cape Fear stated that this cleaning occurs approximately every 10 to 12 years. The wastewater from the clea ning is evaporated in the boiler. Approximately 122,796 gallons of wastewater are generated from each water-side boiler cleaning. The wastewater is collected in frac tanks and then evaporated in
the boiler.Page 8Table 1. Site Visit AttendeesNameOrganization (Representing)TelephoneE-mailLeigh BarrCape Fear(919) 774-5208 leigh.barr@pgnmail.comLeon JohnsonCape Fear(919) 812-8218 leon.johnson@pgnmail.comHershell McCartyCape Fear(919) 744-5200 hershell.mccarty@pgnmail.comDave PhippsCape Fear(919) 774-5260 david.phipps2@pgnmail.comDanny WimberlyCape Fear(919) 774-5238 danny.wimberly@pgnmail.comRobin Bryson Progress Energy (919)546-3962 robin.bryson@pgnmail.comFred HoltProgress Energy(919) 546-5286 fred.holt@pgnmail.comDonna HillUWAG(205) 257-5234 dbhill@southernco.comJezebele AliceaVirellaEPA/Office of Water(202) 566-1755 alicea.jezebele@epa.govJosh Hall EPA/Office of Water (202) 566-1003 hall.josh@epa.govKurt Blohm ERG (Contractor to EPA)(703) 633-1675 kurtis.blohm@erg.comTJ Finseth ERG (Contractorto EPA) (703) 633-1698 thomas.finseth@erg.comNote: Although Leigh Barr and Hershell McCartywere at Cape Fear Plant at the time ofthe site visit, they are no longer therenow.