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HomeMy WebLinkAboutNCS000574_Cape Fear Add Info Letter_20140826A'741 NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, III Governor Secretary August 26, 2014 Mr. Harry Sideris Senior Vice President, Environmental Health & Safety Duke Energy 526 South Street Charlotte, NC 28202 Subject: NPDES Stormwater Permit Application Additional Information Request Cape Fear Steam Electric Plant Chatham County Dear Mr. Sideris: The Division of Energy, Mineral and Land Resources' Stormwater Permitting Program (SPP) received an application for an NPDES stormwater permit for this facility on August 4, 2014. We need additional information from Duke Energy Progress, Inc. ("Duke") to continue processing that application and developing a draft permit. The information submitted in August, 2014 (document signed on July 30, 2014) indicated that the "stormwater watersheds no longer drain areas with industrial activity." Pursuant to 40 CFR 122.26 (b)(14) please confirm that no significant materials remain and there is no exposed materials in areas where industrial activity took place in the past. 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. 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 stormwater 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 stormwater 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 stormwater risks from the activity. Please certify (signature required) the nonstormwater discharges on EPA Form 2F under Section V for Nonstormwater Discharges. Division of Energy, Mineral, and Land Resources Energy Section • Geological Survey Section • Land Quality Section 1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-9200 / FAX: 919-715-8801 512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: http://portal.ncdenr.org/web/Irl An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper Mr. Harry Sideris August 26, 2014 Page 2 of 2 In accordance with item V of the EPA Form 2F application, please confirm that Duke has observed all stormwater 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-stormwater flows, please amend the EPA Form 2F. If any other discharges have occurred during dry periods please indicate how those discharges are currently permitted. 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. The application included a plan view of the Cape Fear Steam Electric Plant. The map did not clearly delineate each drainage areas for the stormwater 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. Thank you for providing more recent copies of the annual certification all outfalls had been inspected for non-stormwater discharges. All of the certifications indicated that no discharges were occurring during periods of no precipitation. For future reference on other stormwater applications, for this site and other Duke facilities, if any outfalls were not observed, or they included non- stormwater flows, please amend your EPA Form 2F to report that. Also, if any discharges have occurred during dry periods, be sure to indicate in the application how those discharges are or will be permitted. We are asking that you provide this information by September 22, 2014. Otherwise we will return the application as incomplete. Also, please provide an electronic copy of all application materials, including this additional information, along with your submittal. If you have any questions about this matter, please contact me at (919) 807-6378 or bradley.bennettOncdenr.govor or Mike Randall at (919) 807-6374 or mike.randall@ncdenr.gov. Sincerely Original signed by Bradley Bennett Bradley Bennett Supervisor Stormwater Permitting Program cc: John Velte, Duke Energy Issa J. Zarzar, Director Demolition and Plant Retirement, Duke Energy Raleigh Regional Office/ Attn: John Holley DEMLR Stormwater Permitting Program Files DWR Central Files