Draft Notes from Site Visit at Progress Energy's Cape Fear Steam Electric Plant on October 2 0 , 200 9

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 abo ut the operations at the plant

, including the operation of the oil

- fired combined cycle units and coal

- fired units and the handling of the ash generated at the plant

. Table 1, located at the end of this memorandum

, identifies the site visit participants. A n 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 1 4 , 2009.

Plant Overview

**•** Cape Fear opera tes two coal

- fired electric generating units

. The 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

5 Control

1956 1 50 Electr ostatic precipitator ( ESP ) ( cold

- side ) Selective non

catalytic reduction ( SNCR ) (2006) None

6 1958 1 80 ESP ( cold

- side ) SNCR (2006) None [QUESTION FOR CAPE FEAR: Does the plant operate hot

- side or cold

- side ESPs?] [QUESTION FOR CAPE FEAR: Please confirm t he start date for the SNCRs

. ]

ANSWER FROM CAPE FEAR: Units 5 and 6 operate cold

- side ESPs.

ANSWER FROM CAPE FEAR: The start date for the SNCRs for Units 5 and 6 was May 2006.

**•** Cape Fear also operates two combined

- cycle electric generating units (Units 1 a nd 2)

, each consisting of two oil

- fired combustion turbines and one steam turbine

. The exhaust gases from the combustion turbine s are used to generate steam in one

of two heat recovery steam generator s (H RS G) . The steam from the HRSG is

used to turn one of the steam turbines. The table below summarize s 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 Uni t

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 constructed as coal

- fired units in 1923 and 1924,

respect ively, but the units were retired in XXXX

. [QUESTION FOR CAPE FEAR: What year were Units 1 and 2 initially retired ( prior to the repowering ) ?]

ANSWER FROM CAPE FEAR: The boilers for Units 1 and 2 were initially retired in 1969, prior to repowering.

In 1969, Cape Fear installed the four combustion turbine s and also decided to repower the Unit 1 and 2 steam turbines to use in a combined cycle operation with

the combustion turbine s.

**•** Units 3 and 4 were decommissioned in the 1940s. [QUESTION FOR CAPE

FEAR: Were Units 3 and 4 coal

- fired units prior to being decommissioned?]

ANSWER FROM CAPE FEAR: Units 3 and 4 , both coal

- fired units, were commissioned in the 1940s. These two units were removed from service July

1977.

**•** Cape Fear stated that Units 5 and 6 are not considered baseload units, but instead

are considered “intermediate” units. However, Cape Fear noted that during the past three years, Units 5 and 6 have basically been operated as baseload units.

**•** Cape Fear stated that the minimum load for Units 5 a nd 6 is 50 MW for each unit ; therefore, Cape Fear will shut down the units if the requested output is less than

50 MWs.

**•** Cape Fear use s once

- through cooling water to condense the steam associated with

the coal

- fired units and the HRSGs. The plant uses t he Cape Fear River as the source of the cooling water. The cooling 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 via Outfall 007. Cape Fear state d that Outfall 007 is not located at the point where the discharge canal enters into the Cape Fear River, but is located XX feet prior to the Cape Fear River. [QUESTION FOR CAPE FEAR: How far upstream of the Cape Fear River is Outfall 007 located?]Page 3

ANS WER FROM CAPE FEAR: The plant discharges via Outfall 007 to the canal at a point approximately 29,568 feet (5.6 miles) upstrea m 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 once

through mode to lower the temperature of the discharge. Cape Fear stated that the cooling towers are typically operat ed during the summer months (May through September)

.

**•** The Cape Fear plant has 64 employees.

Combined

- Cycle Electric Generating Units

**•** Cape Fear stated that No. 2 f uel o il is the only fuel used in the combustion

turbines. Cape Fear does not have the capability to burn f uels 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 oil when all four combustion turbines are operating at full load. [QUESTION FOR CAPE FEAR: During the site visit, Leon stated that when all four units operate at full load, they use 8,000 gallons/hour. If these are the correct numbers, then the tank only has a 2.6 day supply of oil. Please confirm the information in this bullet.]

ANS WER FROM CAPE FEAR: The 14

- day supply reflects the normal operation of 4.5 hours per day run time for the four turbines

. 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 turbine s are considered “fast start” electric generating units because they can be operati onal in 7 minutes and operating at full load in 10

minutes

.

**•** T he combustion turbines are operate d only duri ng times of peak electricity

demand. The combustion turbines typically only run for approximately 30 minutes at a time, which the plant refer s to as “peaker runs

. ”

**•** In 2008, each of t he combustion turbines operated for a total of approximately 50

hours d uring the year

.

**•** Although the combustion turbines are set up to operate in combination with the

HRSGs as combined

- cycle electric generating units, the combustion turbines can be operated in simple

- cycle mode. When the combustion turbines operate in simple

- cycle mode, the plant closes a damper to allow the exhaust gases to bypass the HRSG and flow directly to the stack.Page 4

**•** When the unit operates in combined

- cycle mode, the exhaust gas flows through the HRSG and transfers its heat to the water system and gener ates steam. Cape Fear stated that it takes 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

exten ded periods of time, which are during the extreme high (peak summer) and/or low (peak winter) 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) combus tion turbines must be operating for the plant to be able to operate the HRSG for the unit.

**•** Cape Fear stated that there are no wastewaters generated from the combined cycle units other than periodic metal cleaning wastes on the combustion turbines.

**•** Ca pe Fear stated that the combustion turbines do not generate ash or residue.

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. [QUES TION FOR CAPE FEAR: What is the chlorine content of the coal?] The ash content of the

coa l is approximately 10 percent.

ANSWER FROM CAPE FEAR: Chlorine content in coal is not a parameter Progress Energy Carolinas routinely measures. The standard EPRI P ISCES database (2005), median chlorine content of bitumi n ous coal is 894 mg/kg dry wt. (average 952 mg/kg)

.

**•** Cape Fear keeps approximately 40 days worth of coal on site

. Coal pile runoff generated from stormwater that contacts the coal pile is collect ed 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 boiler. The SNCRs operate frequen tly 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 operated, Cape Fear used ammonia for the SNCR inj ection; however, the plant decided to switch from ammonia to urea because urea is safer. Cape Fear noted that they had detected ammonia in the West ash pond effluent after the SNCRs began operating.Page 5

**•** Cape Fear stated that there is a boiler blowdown strea m f rom the two coal

- fired electric generating units. The boiler blowdown is transferred to the plant’s east ash pond. Cape Fear stated that the blowdown has high concentrations of silver.

Ash Handling System

**•** Cape Fear operates wet ash handling systems fo r 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 fo r Unit 6. Each “train” has four hoppers. [QUESTION FOR CAPE FEAR: Are the economizer ash and ESP ash collected

in separate hoppers ? If so, where are the economizer ash and ESP ash combined?]

ANSWER FROM CAPE FEAR: Yes, separate hoppers. The ash in each h opper, 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 hydrov e y o r pulls vacuum on the dry ash and mixes it with water. Cape Fear stated that the hyd rov e y o r uses plant water to generate a vacuum as a result of the

Venturi effect . The vacuum pulls fly ash from the hoppers into the flowing water.

**•** After the hydrov e y o r, the sluiced ash flows into an air separator. The air separator is a cylindrical tank t hat rotates the sluiced ash like a centrifuge, separating the air

from the mixture

.

**•** Cape Fear then combines the sluiced fly ash with the bottom ash an d pumps the

ash mixture to the E ast ash pond.

**•** Progress Energy stated that they have a committee that has /is investigating

whether to install a dry fly ash handling system at Cape Fear and the other Progress Energy plants

. The following f actors affect the decision to install the dry fly handling system at Cape Fear :

**•** Lack of available space for dry ash silos a nd 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 syste m.

**•** Cape Fear stated that the bottom and fly ash are sluiced to the ash ponds once per

shift. [QUESTION FOR CAPE FEAR: How many shifts per day?]

ANSWER FROM CAPE FEAR: The plant has two shifts per day.

Ash PondsPage 6

**•** Cape Fear has three inactive ash ponds on site . The inactive ash ponds started receiving wastes in 195 6

, 1960, and 1963. All three inactive ash ponds are now covered by thick vegetation and forest. Cape Fear stated that they did not receive guidance from regulatory officials on how to close the se ponds and

, therefore, the plant did not cap the ponds. The vegetation and forest just occurred naturally over the pond wastes. [QUESTION FOR CAPE FEAR: When did each of these ponds stop receiving wastewater ?]

ANSWER FROM CAPE FEAR: The records are un clear but standard practice 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 ash sluice in 1960, the 1960 pond stopped receiving ash sluice in 1963, and t he 1963 pond stopped receiving ash sluice in 1978

.

**•** Cape Fear has two active ash ponds, the e ast and w est 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 pla nt are sent to a
retention basin with an oil

- water separator 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 into two separate cells for the pond. All water enters

in the first cell and overflows into the second cell. The plant has an alum addition

system at the point of overflow from the first cell of the east ash pond to the second cell. Cape Fear noted that the system would be used to increase the settling in the pond, but they haven’t started using the system yet. Progress Energy stated that there is a similar alum system at the Sutton plant.

**•** The e ast ash pond outer dike was constructed with clay. The inner dike is constructed with dredged ash. Cape Fear dredges and restacks the ash in the e ast ash pond approximately once every week.

**•** Cape Fear stated that they are considering 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 and putting the ash in the west ash pond.

**•** Cape Fear stated that the r etention time through both active ponds (east and west) is approximately 5

- 7 days.

**•** The west ash pond overflows into the discharge canal via internal Outfall 001. The east ash pond overflows into the discharge canal via internal Outfall 005.

**•** Both the eas t and west ash ponds overflow continuously to the discharge canal.Page 7

**•** Cape Fear stated that they do not recycle the effluent of the a sh ponds for reuse in the plant. [QUESTION FOR CAPE FEAR: Why does the plant not recycle the ash pond effluent?]

ANSWER FR OM CAPE FEAR: Plant design, low quantity of effluent

, and other better quality water is available.

**•** None of the ponds at Cape Fear (including the inactive ponds) were constructed with synthetic lining materials or leachate collection systems.

**•** Cape Fear i s currently conducting structural integrity studies on the w est ash pond

. Cape Fear recently hired a contractor to perform dike slope stability inspections. The contractor is drilling bore holes into the dike to determine the composition throughout the dep th of the dike.

**•** Cape Fear stated that both the e ast and w est ash ponds are also inspected routinely by plant personnel. These inspections consist of looking for animal patches, excessive vegetation, and other parameters of pond integrity around the perim eter of the pond . Cape Fear stated that the y 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 monitoring wells around the pe rimeter of the ash ponds. Cape Fear analyzes the groundwater for metals semi

- annually from all six wells. The groundwater monitoring report from June 2009 is included as

Attachment 2 of this memorandum. [QUESTION FOR CAPE FEAR: Please provide the ground water monitoring reports from the previous four sampling
events.]

ANSWER FROM CAPE FEAR: Groundwater monitoring reports for March 2007, December 2007, April 2008, and December 2008 are attached.

Metal Cleaning Wastes

**•** Cape Fear performs metal cleaning operations on the combustion turbine units when the system performance starts to degrade. Cape Fear stated that the last two metal cleaning operations were performed in 2003 and 2008.

**•** Cape Fear stated that metal cleaning consists of washing the compresso r blades

with water and a non

- corrosive 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. A pproximately 150 gallons of wastewater are generated each time the plant performs a metal cleaning operation on all four combustion turbines.

**•** A waste disposal company, Shamrock Environmental, tests the metal cleaning wastewater for heavy metals. Cape Fear stated that the metal cleaning wastewater has always been classified by Shamrock as non

- hazardous. Shamrock then ships

the wastewater off site for treatment.Page 8

**•** Cape Fear has a control room which monitors the temperature and other operational parameters of the combustion turbines. If the oil lube temperature for the combustion turbines reaches 170°C, then the system will automatically shut down. To prevent the unit from shutting down, the combustion turbine operator can mitigate the temperature by spraying water on the turbines’ radiators. The spray water is then collected by sumps , processed through an oil/water separator,

and transferred to the e ast ash pond. [QUESTION FOR CAPE FEAR: Please confirm the handling of the radiator cooling water.]

ANSWER FROM CAPE FEAR: Radiator cooling water is in a closed system. What is discussed above is water that may be sprayed on the exterior of the radiators to aid in the cooling. This water does not come into direct contact with radiator cooling water.

**•** Air preheate r washes are performed once a year on the coal

- fired units . The wash

water is collected and transferred to the e ast ash pond. [QUESTION FOR CAPE FEAR: What volume of wastewater is generated from the air preheater washes?]

ANSWER FROM CAPE FEAR: Approxi mately 4,000,000 gallons of wastewater are generated from each air preheater wash. This process typically takes 30 hours to complete.

**•** Cape Fear cleans both the water side and fireside of the boiler tubes for the coal

fired units. For the fire

- side clean ings, Cape Fear uses high pressure water to remove residue from the tubes. Cape Fear stated that the fire

- side cleanings occur approximately every 18 months. [QUESTION FOR CAPE FEAR: What volume of wastewater is generated and how does the plant handle th e waste water from

the fire

- side cleanings?]

ANSWER FROM CAPE FEAR: Approximately 700,000 gallons of wastewater are generated from each fire

- side boiler cleaning. This process typically takes 5 hours to complete.

**•** For the water

- side cleanings, Cape Fe ar uses 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 cleaning is evaporate d in the boiler. [QUESTION FOR CAPE FEAR: What volume of wastewater is generate d from the water

- side boiler tube cleanings ?]

ANSWER FROM CAPE FEAR: 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 9

Table 1. Site Visit Attendees

Name Organization (Representing) Telephone E

- mail

Leigh Barr Cape Fear (919) 774

- 5208 leigh.barr@pgnmail.com

Leon Johnson Cape Fear (919 ) 812

- 8218 leon.johnson@pgnmail.com

Hershell McCarty Cape Fear (919) 744

- 5200 hershell.mccarty@ pgnmail.com

Dave Phipps Cape Fear (919) 774

- 5260 david.phipps2@pgnmail.com

Danny Wimberly Cape Fear (919) 774

- 5238 danny.wimberly@pgnmail.com

Robin Bryson Progress Energy (919) 546

- 3962 robin.bryson@pgnmail.com

Fred Holt Progress Energy (919) 546

- 5286 fred.holt@pgnmail.com

Donna Hill UWAG (205) 257

- 5234 dbhill@southernco.com

Jezebele Alicea

Virella EPA/Office of Water (202) 566

- 1755 alicea.jezebel e @epa.gov

Josh Hall EPA/Office of Water (202) 566

- 1003 hall.josh@epa.gov

Kurt Blohm ERG (Contractor to E PA) (703) 633

- 1675 kurtis.blohm@erg.com

TJ Finseth ERG (Contractor to EPA) (703) 633

- 1698 thomas.finseth@erg.com

[QUESTION FOR CAPE FEAR: Please add the missing phone numbers to the table.]

ANSWER FROM CAPE FEAR: See completed table above.

Note: On e name was misspelled. Leigh Barr and Hershell McCarty are no longer at the Cape Fear Plant.