Response to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 2010 Page 1 of 16 (1) Identify the name, address, telephone number, an d location of the current legal owner(s) and operator(s) of Progress Energy Carolina, Inc., H.F. Lee Steam Electric Plant, as well as the name, address, telephone number, and location of its parent company.

Legal owner and operator: Carolina Power & Light Company

d/b/a Progress Energy Carolinas, Inc.

H.F. Lee Steam Electric Plant*

1677 Old Smithfield Road Goldsboro, NC 27530 (910) 580-3911

Parent Company: Progress Energy, Inc. 410 South Wilmington Street Raleigh, NC 27601 Location: West of the City of Goldsboro, Wayne County, North Carolina

Source of Responses:

Fred Holt Supervisor, Environmental Services 410 S. Wilmington Street, PEB4A Raleigh, North Carolina 27601 (919) 546-5286 – phone (919) 546-4409 – fax Fred.Holt@pgnmail.com

* Upon retirement of the Lee Steam Electric Plant's three coal-fired generating units and construction of the 3 X 1 combined cycle block, the site will be named the H.F. Lee Energy Complex (Complex) and will consist of the four currently existing Lee Plant simple cycle combustion turbine units, the five existing simple cycle turbines at the Wayne County Complex, and the newly constructed 3 X 1 combined cycle block which is scheduled to come on line in January 2013.

(2) On a Topographic map, using the most recent USGS 71⁄2 minute or 15 minute topographic quadrangle map, show the location of the facility boundaries, as well as surface water flows, including tributaries, streams, rivers, lakes, ponds, and wetlands within th e facility boundaries and that cross into or are adjacent to the facility boundaries.

See Figure 1 for the USGS topographic map showing the approximate H.F. Lee Facility boundary and local water bodies. The facility boundarie s are also shown on an aerial map in Figure 1A

.

(3) List and label each area at the facility that the company uses or has used to collect, store, treat, ordispose of fly ash, bottom ash, slag, combined fly and bottom ash, flue gas desulfurization sludge, codisposed and co-managed ash and coal refuse, solid waste, hazardous waste, as well as wastewater, including process wastewater, waste slurry or sludge, cooling water, storm water runoff, and sanitary wastewater, on an episodic or routine basis (“management areas”). For each of these areas, describe its function in managing waste or wastewater. Management areas include, but are not limited to, underground mines, underground injection wells, landfills, tanks, ponds, lagoons, basins, storm drains, pipes, and surface impoundments.

Management areas located on-site and their functions are described in Table 1

.

References:

1. 2002 NPDES permit renewal application for Lee Plant – Appendix A

2. 2007 NPDES permit renewal application for Lee Pl ant and first four adjacent oil/gas-fired CT units of the H.F. Lee Energy Complex - – Appendix B

3. Facility knowledge.

(4) For each management area, identify its location and boundaries on the map provided in response to request #2.Response to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 10, 2010 Page 2 of 16 See Figures 2, 4 and 5 for location of management ar eas of waste and wastewater. Figure 4 and 4B are provided as aerial maps for clarity.

(5) For each management area, describe the area’s approximate storage capacity, the volume of waste or wastewater currently stored, and the approximate proportion of free liquid and settled solids within the stored wastewater. Explain how the company calculated these volumes.

Approximations of the storage capacities and volumes of waste stored are provided in Table 1

. Typically, the proportions of free liquid and settled solids are not applicable for most management

areas.

Reference: See Table 1

.

(6) Provide the name of any entity with whom you have contracted for the disposal, sale, or reuse/recycling of coal combustion waste generated from your fac ility for the past five (5) years. Identify the type and amount of coal combustion waste that the company disposed of through such contracts each year for the past five (5) years.

No coal combustion products have been sold from the Lee Facility since June 2005.

Reference: Progress Energy’s Fleet-wide Ash Reuse Permit and associated A nnual Reports, which do not include data for the Lee Plant, and thus are not attached..

(7) Identify all the waste streams generated at the facility in the past five (5) years. Referring to the labels provided for each management area, provide a flow diagram showing each waste stream from the source of generation to its final disposition. In the flow diagram, include the following information: (a) descriptions of the waste streams (including but not limited to, fly ash, bottom ash and slag, combined fly and bottom ash, flue gas desulfurization sludge, co-disposed and co-managed ash and coal refuse) and their chemical characterizations; (b) the daily and annual volume of each waste stream flow; and (c) the final disposition of the waste streams, including recycled or otherwise destined for beneficial use.

A summary of the waste streams is shown in Tables 2 and 3 , including a description of their final disposition and daily and annual volumes produced, where applicable.

A flow diagram of the wastewater streams and the es timated daily flow rates of the waste streams are provided in Appendix B , as described in the 2007 NPDES permit application. These streams have

been consistent since 2005 or before. A flow di agram of waste streams ot her than wastewater is provided also provided in Appendix B.

.

Chemical characterization data for ash samples from the pond are attached in Appendix C . No data is

available for the individual wast e streams: bottom ash or slag. Data for wastewater streams are addressed in Question 9 below.

References:

1. 2002 NPDES permit renewal application for Lee Plant – Appendix A

2. 2007 NPDES permit renewal application for Lee Pl ant and first four adjacent oil/gas-fired CT units of the H.F. Lee Energy Complex – Appendix B

3. Waste Manifests – Appendix D

.
4. Facility knowledge.Response to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 10, 2010 Page 3 of 16 (8) Provide any testing and analyses relied on to determine the characterization of the waste streams, as well as any sampling results of the waste streams obtained by the facility for the past five (5) years. For any sampling results provided, include a description of the sampling procedures used.

Sampling and analysis of ash from the pond was last conducted in December 2005. Analytical results from ash sampling conducted on December 19, 2005 are reported on the “Annual Residual Sampling Summary Form” included in Appendix C

.

(9) Describe any wastewater discharges, including overflows, diversions, or other releases, that occur or have occurred within the last ten (10) years from the management areas to surface waters, including tributaries, streams, rivers, lakes, ponds, and wetland s. Identify the discharge points and runoff paths on the map provided in response to request #2. Provide any analytical data or monitoring results from the last five (5) years that demonstrate hazardous co nstituents in the wastewater discharges from the management areas to surface waters. Identify the management plans and treatment technologies that the company implements to control its wastewater discharges. Provided a copy of the National Pollutant Discharge Elimination System (NPDES) permit that authorizes these wastewater discharges. If the company has not obtained permit coverage, pr ovide an explanation for this lack of coverage. Submit any discharge monitoring re ports in which the company report ed wastewater violations from the last five (5) years.

The existing coal fired Lee Plant has two permitted outfalls to the Neuse River: Outfall 001 from the ash pond and Outfall 002 from the cooling pond. Upon closure of the Lee Plant, the H.F. Lee Energy Complex will continue to utilize the cooling pond, Ou tfall 002. A new outfall (003) is proposed to come online in 2013. Outfalls 001 and 002 are described below. No overflows, diversions, or other releases not otherwise allowed by the permit have occurred in the past 10 years. Allowed alternate flow paths are described below and in the flow diagrams provided in response to Question 7.

Outfall 001 - Discharge from Ash Pond to Neuse River Ash Transport System Wastewater Fly ash and bottom ash from all three units are hydraulically conveyed by ash sluice pipelines to the Lee Plant ash pond. Included with this sluice water is some ammonia slip from operation of the

Rotamix © system utilized for NOx air emissions control.

Precipitator and Air Preheater Wash Water Water from washing the interior of the precipitators and air heaters is typically routed to the ash pond via the ash transport system but could be routed directly or indirectly to the cooling pond.

Filter Plant Wastewater Blowdown and filter backwash wastewater generated in the filter plant is discharged into the ash sluice transport system which flows to the ash pond.

Wayne County Combustion Turbine Site Wastewaters

The containments around the accesso ry module, liquid fuel , and atomizing air modules and the wash water drain empty into collection tanks. Once there is a quantity of liquid collected in the tanks, the wastewater is removed by pumper truck and transpor ted and released into the Lee Plant ash pond. The

wash water drain tanks collect the water and de tergent used to clean the CT compressors.

Miscellaneous Wastes Equipment cooling tower basin sludge, circulating water tunnel sediment, and boiler vacuuming sediments are sent to the ash pond. Other residuals from the low volume wastes retention basin and the coal pile runoff retention basin and other miscellaneous low volume wastes from plant processes are also transported to the ash pond. Storm water from the ash line trench flows into the ash pond.Response to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 10, 2010 Page 4 of 16 Outfall 002 – Closed Cycle Cooling Pond Discharges from the cooling pond are rarely made, usually only during an extremely heavy rainfall event or hurricane. The cooling pond last discharged in April 1994. Chemical constituents contained in the cooling pond discharge are, for the most part, representative of the naturally-occurring chemical quality and quantity of the intake water. Streams routed to the cooling pond include:

Recirculated Condenser Cooling Water This flow currently provides condenser cooling water for coal-fired generating Units 1, 2, and 3. The total flow is recirculated into the pond and routed through the pond by baffle dikes to achieve maximum surface cooling efficiency be fore reaching the condenser cooling water intake structure to be used again. Cooling of the pond is achieved primar ily by evaporation from th e pond surface, which is estimated to consume approximately 3-5 MGD above natural evaporation rates during times the units are in full operation.

Equipment Cooling Water (Non-contact Cooling Water) Circulating water for Unit 3 is withdrawn from cooling water makeup and/or the cooling pond and passed through two heat exchangers to provide non-contact cooling for the plant’s closed-cooling water system. After passing through the heat exchange rs, the circulating water is routed to the cooling pond. Units 1 and 2 use a cooling tower for heat removal for their equipment closed-cooling water system. Cooling tower blowdown is routed to the low volume waste retention basin. This wastewater has been referred to as “service water” in the past.

Coal Pile Runoff The coal pile area is surrounded by a drainage ditch that is routed to a clay-bottomed, asphalt and concrete-sided settling pond. The basin is sized so as to adequately store runoff and allow the suspended solids to settle before the supernatant is discharged by overflow to the cooling pond. During routine maintenance of the pond, any solids re moved will be disposed of in the active ash pond.

Sewage Treatment System Domestic waste is treated in a septic tank and sand filter bed system. Flow from the system is dependent upon fluctuating demand due to variations in the number of personnel on site. Residuals are disposed of off-site by a licensed contract disposal firm. The sand in the system is periodically changed to ensure system effectiveness is maintained. The spent sand is disinfected and then sent to an off-site

landfill.

Low Volume Wastewaters

A low volume waste retention basin receives wastew aters from three sumps lo cated throughout the Lee Plant. The sumps collect waste fr om floor and equipment drains, th e fuel oil unloading area, boiler blowdown, cooling tower overflow, sampling stream s, and rainfall from the immediate plant area. Water treatment wastes, including filter backwash and settling basin drains, are also directed to a plant sump. In addition, the low volume basin receives discharges from equipment washings, boiler and condenser drains, and closed-cooling system blowdown and drains, grey water from contractor washing stations, and Units 1 and 2 cooling tower blowdown. Oily waste collectors remove oil and grease and a holding chamber allows the solids to settle out before the effluent is discharged into the cooling pond. To maintain the efficiency of the basin and allow adequate freeboard, the settled sludge from the basin and from the three sumps will periodically be removed and disposed of in the ash pond.

Precipitator and Air Preheater Wash Water Under normal operations, water from washing the interior of the precipitators and air heaters are routed to the ash pond via the ash transport system. Howeve r, these wastewaters could be routed directly or indirectly to the cooling pond in unusual situations.

Wayne County Combustion Turbine Site Wastewater The wastewater collection system sump receives wa stewaters from the filter plant, Reverse OsmosisResponse to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 10, 2010 Page 5 of 16 (RO) water treatment system (reject water), exce ss evaporative cooling water, process drains, and stormwater from the oil water separator. Two pum ps (rated at 580 gpm each ), one for operation and one for a back up, transfer the wa stewater to the Lee Plant cooling pond. The filter plant discharge

was initiated around 2002.

The oil water separator treats water from the containm ent areas around the two fuel oil storage tanks, the fuel forwarding pumps, and the fuel oil unload ing area. Storm water coll ection containment areas

around transformers and substations are examined fo r the presence of any oily substance; if oily substances are present in the containment, nothin g will be drained from the containments until that substance is properly removed.

Backwash water

Backwash from intake screening devices located on the Neuse River is discharged into the Neuse River bypass canal associated pursuant to North Carolina regulations at NCAC 15A .0106 (f)(2), if

necessary.

Available analytical data for hazardous constituents (as defined at 40 CFR 26 1, Appendix VIII) for the wastewater discharges are provided in the 2007 NPDES renewal applications ( Appendix B ) and the Discharge Monitoring Reports ( Appendix E ). No exceedances of the NPDES permit limitations have occurred in the previous five years. The NPDES permit no. NC0000396 is attached in Appendix F

.

References:

1 2002 NPDES permit renewal application for Lee Plant – Appendix A

.

2 2007 NPDES permit renewal application for Lee Pl ant and first four adjacent oil/gas-fired CT units of the H.F. Lee Energy Complex – Appendix B

.

(10) For all stormwater discharges associated with industrial activity from the facility, as defined at 40 C.F.R. 122.26(a)(14), identify the industrial activity (including the appropriate NAICS and SIC codes) that requires coverage under an NPDES permit. In addition to the information provided about these discharges in response to request #9, provide a copy of the facility’s current Stormwater Pollution Prevention Plan (“SWPPP”), as well as copies of its comprehensive site evaluations, inspection records, and monitoring results fo r the last five (5) years. If the company has not developed a SWPPP, provide an explanation for this decision.

The industrial activity that conditionally requires co verage under a NPDES permit is Electric Power Generation, Fossil Fuel, NAICS code 221112; and Electric Power Generation by Fossil Fuels, SIC

code 4911.

The Lee Plant are not required under its NPDES perm it to maintain a SWPPP. Stormwater discharges associated with industrial activities from the coal plant yards and power block is either routed to the cooling pond or to the ash pond. Discharges from both of these management areas are discharges authorized by the NPDES permit. The raw material, coal, is brought in by rail along a land corridor not owned by Progress Energy until the rail is on the plant site where storm water is handled as stated above. The access road is not used on a routine basis to ship waste products or by products off-site nor

to receive raw materials.

References:

1 Facility Knowledge.

2 NPDES permit No NC0000396 ( Appendix F ).Response to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 10, 2010 Page 6 of 16 (11) Describe any groundwater monitoring system in place at the facility. Provide any groundwater sampling and analysis plans, groundwater monitoring results that detected releases of hazardous constituents, and corrective actions taken in response to groundwater contamination. Identify the location of groundwater monitoring wells, both active and inactive, on the map provided in response to request #2.

Groundwater monitoring has been conducted around the active ash pond since 2007. Monitoring wells MW-1 through MW-4 were installed in May of 2007 and have been sampled on a semi-annual basis since installation. Groundwater sampling is conduct ed by a subcontractor and results are sent to

NC D E NR on a regular basis, however no sampling and analysis plans exist. Well locations are shown

on Figure 3 a nd in Appendix G . Well construction records and a su mmary of analytical results are provided in Appendix G . Whereas the groundwater sampling results have been collected from inside the compliance boundary, no corrective actions have been initiated to date. Lee Plant is in the process of placing wells at the compliance boundary.

Reference:

1 Facility knowledge.

2 Facility maps and monitoring results ( Appendix G ).

(12) Describe any known spills or releases to groundwater from each management area within the last ten (10) years.

No spills or releases to groundwat er are known to have occurred in the last ten years from the management areas. Groundwater quality results from the monitoring system around the active ash pond (provided in question 11) show slightly elevated concentrations of some inorganic constituents. However, note that these results are from inside the compliance boundary as defined by the North Carolina 2L Groundwater Standards. Progress Energy is in the process of siting background wells and wells located at the compliance bou ndary so that an analysis can be completed to determine if a statistically significant release has occurred.

Reference:

1. Facility knowledge.

(13) For each management area, identify any seepage flows as well as their origins, flow paths, and destinations. Indicate the location of these flows on the map provided in response to request #2. Provide any reports or documentation with sampling results and/or information about the volumes of these seepage flows from the last five (5) years.

Inactive Ash Ponds No documented seepage areas.

Active Ash Pond A seepage condition exists along the south end of the east containment dike for the secondarysettling/stilling basin. The seepage is occurring through the dike and exiting along the lower quarterportion of the (exterior) slope. Flow volume of the seepage has not measured. Specific flow path of the seepage is not documented, but expected to flow down gradient toward the Neuse River. Piezometers are in-place at the seep age area for monitoring water levels within the slope. The location of this seepage condition is shown on Figure 2

.

Cooling Pond A seepage condition exists along the east end of the north containment dike. The seepage is occurringResponse to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 10, 2010 Page 7 of 16 under the dike and also includes ground boil conditions. The seepage area has been mitigated with a geotextile and aggregate blanket. In 2004, seepag e flow volume was estimated at 0.25-0.5 gpm from the geotextile and blanket area and 5 to 10 gpm from a boil area. Specific flow path of the seepage isnot documented, but expected to flow down gradient toward the Neuse River. Piezometers are inplace at the seepage area for monitoring water levels within the sl ope. The location of this seepage

condition is shown on Figure 2

.

Documentation within the last five years of the seepage flows were included in the Office of Solid Wastes and Emergency Response (OSWER) response letter previously provided to EPA. This

document is entitled, 

### “ Report of 2008 Limited (Annual) Field Inspection Cooling Lake Dike and Ash Pond Dikes Lee Plant, Wayne County, North Caro lina” (December 29, 2008), and is incorporated herein by reference.

References:

1. Facility knowledge.

2. “Report of 2008 Limited (Annual) Field Inspection Cooling Lake Dike and Ash Pond Dikes Lee Plant, Wayne County, North Carolina”, December 29, 2008. (Included in OSWER response and incorporated by reference).

(14) Provide any hydrological studies conducted at the facility within the last five (5) years

No hydrological studies have been conducted at the Lee Plant with the last five years.

(15) Identify any known drinking water wells within a five (5) mile radius of the facility’s outer boundaries. Provide any monitoring or sampling results that demonstrate hazardous constituents present within

these wells.

The Fork Township Sanitary District supplies drinking water to the area in the vicinity of the Lee Plant. The district obtains water from numerous groundwater sources and some district wells are within 5 miles of the Lee Plant. Progress Energy does not review or obtain monitoring or sampling results for any of these wells. Well locations are shown on Figure 6.

Reference: Source Water Assessment Program Repor t for Fork Township Sanitary District, NC Division of Environmental Health, Public Water Supply Section, March 15, 2010 ( Appendix H).

(16) Describe the cooling system at the facility. If applicable, submit the source of the water withdrawn and the amount of water withdrawn in gallons per day. If applicable, describe the cooling water intake screen backwash system and identify the individual backwash flows, the volume, and the discharge points for each flow. Submit any sampling results of the backwash.

Approximately 372 MGD of cooling water is used from the cooling pond. Water is collected from the pond through the plant intake structure and routed to the condensers then back to the pond, or to the water treatment system for use in plant processes.

Make-up water from the Neuse River is routed to th e cooling pond and the closed cycle cooling system for Unit 3, if needed (approximately 12.7 MGD). The intake from the Neuse River passes through a bar screen which does not typically require backwash ing. However, backwash from intake screening devices is allowed to be discharged into the Neus e River bypass canal associated with the Neuse River pursuant to North Carolina regulations at NCAC 15A 02H.0106 (f)(2), should backwashing be necessary. No data is available on the quantity of backwash flows or on its chemical characteristics.Response to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 10, 2010 Page 8 of 16 For maintenance of the bar screen, floating solids such as logs and sticks are removed from the screen approximately every two weeks. Sand accumulated near the screen is dredged approximately once

every ten years.

References:

1. 2002 NPDES permit renewal application for Lee Plant – Appendix A

. 2. 2007 NPDES permit renewal application for Lee Plant and first four adjacent oil/gas-fired CT units of the H.F. Lee Energy Complex – Appendix B

. 3. Facility Knowledge

(17) Provide analyses performed on slope stability, inflow design floods, or dam breaks for any of the management areas within the last five (5) years.

The “Lee Plant Ash Pond Secondary Settling Dike Stability Information” package prepared by MACTEC Engineering and Consulting, Inc. is included in Appendix I

.Response to EPA CWA 308 and RCRA 3007 Information RequestProgress Energy Carolinas, Inc.Lee Steam Electric PlantAugust 10, 2010Page 9 of 16Table 1. Waste and Wastewater “Management Areas” at the Lee Steam Electric Plant.Response to Questions 3 and 5No.onMapWaste and WastewaterManagement AreaManagement Area Description/ FunctionStorageCapacityVolume ofWasteCurrentlyStoredAdditional Information/Comments11Inactive Ash Pond #1Encompasses approximately 9 acres. Does notcurrently receive waste or wastewater from the plant.Materials currently stored in the inactive pondinclude fly ash, bottom ash and boiler slag.Unknown37,500 cubicyards (CY)Negligible free liquid. SeeNote 2.2, 3Inactive Ash Ponds #2and #3Ponds are adjacent to each other and separated by asmall embankment, essentially serving as one pondencompassing approximately 79 acres. Does notcurrently receive waste or wastewater from the plant.Materials currently storedin the inactive pondsinclude fly ash, bottom ash and boiler slag.Unknown 666,300 CYNegligible free liquid. SeeNote 2.4 Inactive Ash Pond #4Encompasses approximately 85 acres. Does notcurrently receive waste or wastewater from the plant.Materials currently stored in the inactive pondinclude fly ash, bottom ash and boiler slag.Unknown 641,000 CYNegligible free liquid. SeeNote 2.5Active Ash PondEncompasses approximately143 acres. Receives ashsluice water, fly ash, bottom ash and boiler slagalong with other categoricallow volume wastewaterand stormwater, including residuals from stormwaterbasins. The ash pond allows solids to settle prior towater discharge to the Neuse river (Outfall 001).4.7 million CY 3.4 million CYApproximately 72% solids and28% free liquid estimated fromratio of capacity to volume ofwaste stored.6 Small Retention PondEncompasses 2.3 acres. Originally constructed in theearly 1980’s to serve as ametal cleaning waste pond.It saw limited use since metal cleaning wastes suchas boiler cleaning wastes are evaporated through theboilers. It has not been used for waste treatment forapproximately twenty five years.27,000 CY 4,700 CYApproximately 17% solids and83% free liquid estimated fromratio of capacity to volume ofwaste stored.Response to EPA CWA 308 and RCRA 3007 Information RequestProgress Energy Carolinas, Inc.Lee Steam Electric PlantAugust 10, 2010Page 10 of 16No.onMapWaste and WastewaterManagement AreaManagement Area Description/ FunctionStorageCapacityVolume ofWasteCurrentlyStoredAdditional Information/Comments17 Ash Sluice PipeTransfers ash from the facility to the Active AshPond.No permanentstorage capacityTransfer pipe;not used forstorageNo additional comments.8Coal Pile StormwaterBasinEncompasses 0.8 acres.Collects runoff from theCoal Yard area. Outlets into Cooling Pond.~9,700 CY 2,400 CYSee Note 2. Availablefreeboard for the Coal YardStormwater Basin isapproximately 7,300 CY andwas calculated based onestimated dike elevations.Approximately 33% solids and67% free liquid estimated fromratio of dike elevations volumeto volume of waste stored.9 Cooling PondEncompasses 545 acres. Collects runoff fromvarious areas of the Lee Plant via the oil waterseparator (also known as the Low Volume WasteRetention Basin) and from the Wayne CountyEnergy Complex via an oil water separator. TheSewage Treatment System and Coal Pile StormwaterBasin are conveyed intothe Cooling Pond. Alsoreceives cooling water from the Condensers and Unit3 equipment cooling water. The Cooling Pond isauthorized to discharge to the Neuse River (Outfall002) but has not discharged since 1994.3,808 acre-feet n/aVolume obtained fromFiveYear Independent ConsultantInspection(December 29,2004)submitted with theOSWER response. Volumeestimated from designelevation of the dikes andsurface area. No significantsolids are expected to bepresent within the CoolingPond.10 Ash Trench LineTrenching to accommodate ash sluice lines.Stormwater from the ash trench lines is conveyedinto the Active Ash Pond.NoneAsh trench lineis not forstorage;contains ashsluice line.No significant solids.Response to EPA CWA 308 and RCRA 3007 Information RequestProgress Energy Carolinas, Inc.Lee Steam Electric PlantAugust 10, 2010Page 11 of 16No.onMapWaste and WastewaterManagement AreaManagement Area Description/ FunctionStorageCapacityVolume ofWasteCurrentlyStoredAdditional Information/Comments111Stormwater DrainageSystem and Oil WaterSeparator for the LeePlantCollects stormwaterrunoff and low volume wastesfrom plant and collection sumps. Separates any oilfrom waste fluids (oil contained and sent off-site).Outlets to the Cooling Pond.~425,000 gals ~425,000 galsVolume estimated from oldfacility drawings (circa 1950).12Sanitary Sewer Pipelines/ Sewage TreatmentSystem at Lee PlantCollects and treats domestic waste and waste frompotable water drains at the plant. Sewage TreatmentSystem consists of a septic tank, dosing tank andsand filter with a discharge to the Cooling Pond.Septictank/dosing tank-3515 gallonsUnknownVolumes estimated from oldfacility drawings (circa 1950).13Turbine Room SumpSewerBuilding drainage sumps from Unit 1 and Unit 2sides collect water and discharge through a commonline.No permanentstorage capacityVariable; notused forstorageNo significant solids.14Car Shaker Pit SumpSewerCar Shaker Pit area sump collects water (usuallyrainwater).No permanentstorage capacityVariable; notused forstorageNo significant solids.15Wastewater TransferPipe6” waste water line that transports water from H.F.Lee Energy Complex area to current coal plantlocation and treatment.280 gpmTransfer pipe;not used forstorageNo significant solids.16Sanitary System for CTSiteCollects and treats domestic waste and waste frompotable water drains at the plant. The SewageTreatment System is routed to a septic field.1500 gals SepticTank and 1000gals Pump Tank.n/aVolume derived from theWayne County EnvironmentalHealth Department.17Stormwater DrainageSystem and Oil WaterSeparator at CT SiteCollects stormwaterrunoff from plant and collectionsumps. Separates any oil from waste fluids (oilcontained and sent off-site). Outlets to the CoolingPond.Oil Waterseparator is sizedfor 200 gpm.n/aOil water separator was sizedbased on design calculations.Assumed to be 90% free liquid.1. Per request #5, the additional information includes the approximate proportion of free liquid and settled solids in storedwastewater and an explanation of howthese volumes were determined.2. Existing ash volumes were estimated in preparation for facility demolition. To estimate the volume, the area of each inactive ash pond was estimated usingaerial photography combined with topographic mapping data. Theash thickness in each inactiveash pond was estimated by conducting a series of handResponse to EPA CWA 308 and RCRA 3007 Information RequestProgress Energy Carolinas, Inc.Lee Steam Electric PlantAugust 10, 2010Page 12 of 16auger borings at representative locations within each pond. The depth andcorresponding elevation atwhich virgin soils were encountered in each boringwas recorded as the ash depth/pond bottomat that location. Using information collected from the hand auger borings, aerial photography and contour data,ash depths or pond bottom elevations between each boring location were interpolated to arrive at estimated average ash depths/bottom elevations across theentire footprint of eachpond. The average estimated ash depths/bottom elevations were used to estimate the volumes of ash currently retained within eachpond.Response to EPA CWA 308 and RCRA 3007 Information RequestProgress Energy Carolinas, Inc.Lee Steam Electric PlantAugust 10, 2010Page 13 of 16Table 2. Waste Streams Generated at the LeeSteam Electric Plant in the Past Five YearsResponse to Question 7(1)By definition in the Information Request, wastewater includes“process wastewater, waste slurryor sludge, cooling water, storm water runoff, and sanitarywastewater.”(2)Flows are for current facility with Lee Plant coal-fired units and fourcombustion turbines place and do not include future flow estimates.(3)By definition in the Information Request,waste streams other than wastewater include “by-products, residues, solid waste, and hazardous waste”.Waste Stream DescriptionFinal Disposition of Waste Stream Daily flow(2)Annual flow(2)Wastewater(1)Ash Transport System Wastewater Outfall 001 – Neuse River 2.5 MGD 821 MGDPrecipitator and Air Preheater Wash Water Outfall 001 – Neuse River 0.5 MG per event Approx. 0.5 MGFilter Plant Wastewater Outfall 001 – Neuse River 0.14 MGD 46 MGDH.F. Lee CT Site Wastewaters – stormwater and CTcompressor wash watersOutfall 001 – Neuse River (will discharge to the proposedOutfall 003 in the future)0.002 MG per wash;variable for stormwaterVariableMiscellaneous wastes Outfall 001 – Neuse River Variable VariableRecirculating condenser cooling water and Unit 3Equipment Cooling WaterCooling Water Pond (Outfall 002 – Neuse River if discharged) 369 MDG – no dischargesince April 1994.n/aCoal Pile Runoff Cooling Water Pond (Outfall 002 – Neuse River if discharged)0.02 MGD – no dischargesince April 1994n/aSewage Treatment System Water Cooling Water Pond (Outfall 002 – Neuse River if discharged)0.004 MGD – nodischarge since April1994n/aLow Volume Wastewater Cooling Water Pond (Outfall 002 – Neuse River if discharged)0.07 MGD – no dischargesince April 1994n/aH.F. Lee CT Site Wastewaters – filter plant, ROwater treatment system, excess evaporative coolingwater, process drains, and oil water separator.Cooling Water Pond (Outfall 002 – Neuse River if discharged) 580 gpm – no dischargesince April 1994n/aResponse to EPA CWA 308 and RCRA 3007 Information RequestProgress Energy Carolinas, Inc.Lee Steam Electric PlantAugust 10, 2010Page 14 of 16Table 2. Waste Streams Generated at the Lee SteamElectric Plant in the PastFive Years, continuedResponse to Question 7(1)By definition in the Information Request, wastewater includes“process wastewater, waste slurryor sludge, cooling water, storm water runoff, and sanitarywastewater.”(2)Flows are for current facility with Lee Plant coal-fired units and fourcombustion turbines place and do not include future flow estimates.(3)By definition in the Information Request,waste streams other than wastewater include “by-products, residues, solid waste, and hazardous waste”.Waste Stream DescriptionFinal Disposition of Waste StreamDaily flow(2)Annual flow(2)Waste Streams(3)Bottom Ash Sluiced to Ash Pond ~ 48 tpd ~16,270 tpyFly Ash Sluiced to Ash Pond ~ 90 tpd ~65,090 tpyMiscellaneous hazardous wasteShipped to off-site hazardous waste facility See Table 3 VariesMiscellaneous non-hazardous waste, universalwastes, etc.Shipped to off-site waste facility See Table 3 VariesSpent sand from sweater treatment system Shipped to off-site landfill after sterilization 1 to 2 cubic yards/ event 2 to 4 cubicyards/ yearResponse to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 10, 2010 Page 15 of 16 Table 3 Hazardous and Non Hazardous Waste Streams Generated at Lee Steam Electric Plant in the

Last Five Years

Response to Question 7

Waste Stream Year Shipped Amount Shipped*

Non hazardous non regulated material (oily soil) 2010 4500 Non hazardous (oily pads) 2010 200 Hazardous regulated materials NA1993, diesel, 3, PGIII 2 010 2248 gallons Asbestos 2010 16 bags Asbestos 2010 1.5 cubic yard

Hazardous Waste- Waste Ae rosols 2009 29 pounds

Universal Waste batteries, wet, filled with acid, 8, UN2794,

PGIII 2009 Illegible on manifest

Universal waste batteries, dry, containing potassium hydroxide solid, 8, UN3028, PGIII 2009 Illegible on manifest

Universal waste lamps 2009 Illegible on manifest Non hazardous non regulated material (oily water) 2009 6068 gallons Non hazardous non regulated material (non PCB capacitors) 2009 85 pounds Non hazardous non regulated material (TPH impacted oil and gravel) 2009 1500 pounds

Non hazardous non regulated material (used oil and water) 2009 569 pounds Non hazardous non regulated oily spill debris/absorbents/PPE 2009 1200 pounds Non hazardous non regulated material oily sludge 2009 1600 pounds Non hazardous non regulated material used oil 2009 4200 pounds Non hazardous non regulated material (fuel oil) 2009 1600 pounds Asbestos 2009 182 cubic yards Asbestos 2009 958 bags Non hazardous non regulated material (oily water) 2008 1950 gallons Universal Waste Batteries, dry, containing potassium hydroxide solid, 8, UN3028, PGIII 2008 43 pounds

Universal Waste Lamps 2008 422 pounds

Universal Waste batteries, wet, filled with acid, 8, UN2794,

PGIII 2008 1500 pounds

Asbestos 2008 64.59 cubic yards Asbestos 2008 492 bags Asbestos 2008 80 pounds Non hazardous non regulated material (oily water) 2007 963 Petroleum oil, combustible liquid, NA1270, PGIII, oil used bulk 2007 7746 gallons Non hazardous non regulated material (oily water) 2007 1818 gallons Non hazardous non regulated material (TPH impacted soils/gravel) 2007 900 pounds

Non hazardous liquid n.o.s. contact water 2007 109 gallons Asbestos 2007 13.69 cubic yards Asbestos 2007 25 bags Non hazardous non regulated material (oil) 2006 1506 gallons Non hazardous non regulated material (oily water) 2006 11,728 gallons Hazardous waste solid, n.o.s. (barium, l ead), 9, NA3077, PG III 2006 30 pounds Non hazardous non regulated material (empty) 2006 150 pounds Non hazardous non regulated material (oil/water/glycol) 2006 Unknown Non hazardous non regulated material (oily rags) 2006 Unknown Non hazardous non regulated material (oily soil/rock) 2006 500 poundsResponse to EPA CWA 308 and RCRA 3007 Information Request Progress Energy Carolinas, Inc.

Lee Steam Electric Plant

August 10, 2010 Page 16 of 16 Waste Stream Year Shipped Amount Shipped*

Asbestos 2006 6 bandols Asbestos 2006 958 bags Asbestos 2006 46 cubic yards Asbestos 2006 4 dump trucks

Asbestos 2006 3 sand filter trucks Non regulated non hazardous (u sed oil/water) 2005 857 pounds Non hazardous non regulated (used oil) 2005 1678 pounds

Asbestos 2005 49 containers Asbestos 2005 173.5 cubic yards

Asbestos 2005 224 containers Asbestos 2005 53 bags *Daily and annual volume production of these wastes vary in response to maintenance and operation activities at the site, and are not available.