HomeMy WebLinkAboutNCS000574_RAI Response_20140922�•� DUKE
ENERGY,
PROGRESS
September 22, 2014
Mr. Bradley Bennett
Supervisor Stormwater Permitting Program
Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: Response to Additional Information Request
NPDES Stormwater Permit Application
Cape Fear Plant
Chatham County
Dear Mr. Bennett:
Cape Fear Steam Electric Plant
500 C P & L Road
Moncure, NC 27559
Duke Energy Carolinas, Inc. (Duke Energy) received and reviewed the subject letter dated August 26,
2014. The purpose of this letter is to provide the requested additional information. For ease of review, I
have listed each of your questions/requested items and provided a response directly beneath.
1. The information submitted in August 1014 indicated that the "storm water watersheds no
longer drain areas with industrial activity." Pursuant to 40 CFR 112.26 (b)(14) please confirm
that no significant materials remain and there and there is no exposed materials in areas
where industrial activity took place in the past
As described in Duke Energy's supplemental permit materials (stamped "received" by your
office on July 31, 2014), all fuels formerly used for power generation have been removed from
the site; rail lines no longer receive coal; the access road is not currently used for the transport
of raw materials, waste material or by-products historically used or created by the facility for
power generation; and all material handling sites, refuse sites, shipping and receiving areas, and
fuel storage areas (including the coal pile) relating to power generation have been removed.
Only de minimis amounts of material may remain.
The only remaining waste material on site generated during the operation of the steam electric
plant is the coal ash that was sluiced to the ash basins. Any release of effluent from the ash
basins is authorized under an NPDES Wastewater Permit. Therefore, except for the presence of
ash within the on-site ash basins, there are no significant materials remaining onsite and no
exposed materials in areas where industrial activity took place in the past.
There are wastes currently being generated due to the demolition of the facility which are
temporarily stored in laydown areas and removed from the site through the access -road. There
may also be other materials including small amounts of fuels which are necessary to operate
demolition. Stormwater outfalls for drainage areas potentially affected by these construction
activities are currently protected by measures described in the approved Erosion and
Sedimentation Control (E&SC) Plan along with the conditions of the NPDES Construction
Stormwater General Permit NCGO10000, received on March 23, 2012.
11. We understand that the site is undergoing demolition of the coal-fired plant. Please provide a
schedule and narrative description of the demolition activities that could impact stormwater
discharges. Our concern is that the conditions of the stormwater permit should anticipate
changing site conditions during the demolition period. We want to check whether conditional
provisions addressing the demolition should be written into the permit, and whether the
provisions might be structured so as to lapse when the demolition is accomplished.
As you stated, the Cape Fear Plant is currently being demolished. On August 22nd, the site
underwent the first of three implosions scheduled for 2014. Weather permitting, all of the
structures on site (with the exception of the intake structure, transmission lines, and
switchyards) will be demolished by the end of the year. Duke Energy plans to remove the
construction/demolition materials, then fill, grade, and seed the site by mid -2015.
During plant operation, stormwater that drained power plant areas having the potential for
spills or leakage was routed to plant drains and pumped to either an oil/water separator or
directly to an ash basin. During demolition, plant drains and sumps are being cleaned with any
residue removed and transported off site for disposal. Site stormwater may continue to be
routed to the plant drains, stored in the sumps, or released for sheet flow within the demolition
project limits of disturbance until the site grading is complete. Any discrete storm water outfalls
within the identified demolition project limits of disturbance boundary are currently protected
by measures described in an approved E&SC Plan along with the conditions of the NPDES
Construction Stormwater General Permit.
111. Similarly, we anticipate that the closure of the site's ash ponds may soon be underway, and
that the activity may be begun and completed within the term of the stormwater permit We
would expect that some aspects of the ash pond closure activity may present the potential for
storm water pollution (for example, activities such as transport of ash along on-site haul
roads.) in so far as is possible at this point in time, please provide Information on the ash pond
closure that could inform our drafting of the storm water permit Aspects such as the location
of haul roads, time schedules, and site modifications necessary to accomplish the undertaking
would help us assess how the permit should address the storm water risks fram the activity.
The ash pond closure plan for Cape Fear Plant has not been developed. The schedule and
requirements for closure will be developed in accordance with the Coal Ash Management Act of
2014. If the decision is made to remove the ash and transport it off site, the haul road path
would be selected and potential storm water outfalls identified. The historically -identified
storm water outfall along the access road (Outfall SW 003) would be a potential permitted
outfall but Duke Energy may elect to modify this very small watershed to eliminate this outfall.
Duke Energy understands that if site conditions change such that there is a point source
discharge of industrial stormwater, we will be required to obtain permit coverage in accordance
with 40 CFR 122.26(a)(1)(ii).
!V. Please certify (signature required) the nonstormwater discharges on EPA Form 2F under
Section V for Nonstormwater Discharges.
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The signed certification is enclosed with this correspondence.
V. In accordance with item V of the EPA Form 2F application, please confirm that Duke has
observed all storm water outfall conveyances on the site and that Duke has reason to conclude
that the observed flow is groundwater only. If any other outfalls were not observed, or they
included non -storm water flows, please amend the EPA Form 2F. If any other discharges have
occurred during dry periods please indicate how those discharges are currently permitted
All former stormwater outfalls have been observed during dry periods with no discharges noted.
VI. Please provide details (dates, location on site, drainage area Impacted, etc.) about the
presence or any past storage and/or releases of polychlorinated biphenyl compounds (PCBs)
on site. If there were any known releases, please discuss actions taken to remediate any areas
affected. Include information about what drainage areas might have been Impacted by PCBs.
There has been historical storage/use of PCBs at this facility. This was primarily use and storage
in oil -filled PCB transformers but could include other minor sources (e.g. lighting ballasts,
etc.). This use dates back to original start of operations at the site in 1923. This also included
storage for disposal/destruction of PCB transformer used oil. All PCB oil -filled equipment has
been removed or reclassified. The PCB transformer used oil tank has been removed. When PCB
oil filled equipment was onsite, those drainage areas were routed to the effluent channel and
out the NPDES-permitted wastewater Outfall 007. We have no records of any releases of PCBs
at the facility being discharged.
Vll. The application included a plan view of the Cape Fear Steam Electric Plant. The map did not
clearly delineate each drainage areas for the storm water outfalls listed in the application.
Please provide a plan size (nominally 24"x 36") site drainage map clearly showing all drainage
areas and other Items listed In Section III of EPA Form 2F.
A plan size site drainage map for the storm water outfalls is enclosed with this correspondence.
Duke Energy appreciates the opportunity to respond to NCDENR's request for additional information.
Should you have any questions regarding this submittal or require additional information, please contact
LeToya Ogallo at (919) 546-6647 or email Letoya.Ogallo@duke-energy.com.
Sincerely,
Issa I. Zarzar
Director Demolition and Plant Retirement
Enclosures
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