Allen Steam Facility (11)

Georgoulias, Bethan
From: Georgoulias, Bethany
Sent: Thursday, March 22, 2012 1041 AM
To: 'Mc Gary, Mark E'
Cc: 'Velte, John S', 'Everett, George T', 'Stowe, Allen%, Bennett, Bradley; Parker, Michael,
Patterson, Robert; Lowther, Brian, Matthews, Matt; Karoly, Cyndi, Chernikov, Sergei
Subject: RE- Revised Draft NPDES Stormwater Permits for Marshall, Allen, and Riverbend - Public
Notice Update
Hi Mark,
We've been asked to hold off the, public inotice of these permits until(we have had a chance to meet`with you all. My e-
mail yesterday indicated that these would begoing,out to notice in the next week, but those notices will be held for
now. However, we Will have to re -notice the permit at some point soon because of the significant changes. I apologize
for the confusion We look forward to an opportunity to,discuss these permits. Please let�us know some dates that
would be,good for you to meet.
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mad, Service,Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NC 27604
Phone [phone]
Fax [phone]
NEW'Website http //portal ncdenr org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
From: Georgoulias, Bethany
'Sent: Wednesday, March 21, 2012 2:48 PM
To: 'Mc Gary, Mark E'
Cc: 'Vette, John S'; 'Everett, George T; 'Stowe, Allen'; Bennett; Bradley; Parker, Michael; Patterson, Robert; Lowther,
Brian; Matthews, Matt; Karoly, Cyndi; Chernikov, Sergei
Subject: Revised Draft NPDES Stormwater Permits for Marshall, Allen, and Riverbend
Mark,
We have revised the draft stormwater permits for these three plants (attached). Hard copies, along with the attached
cover letter explaining the changes, are being mailed out to you. Because of the significant changes, we are re -running,
the public notice for these draft permits That.notice,should be available on our website in the next few days ,(please
check http.//Portal.ncdenr org/web/wq/ws)su/current-notices) and will' be published in the newspapers in the next
week or so This will allow another 30 -day comment period and move the scheduled issuance date into May.
If,you would like to,meet and discuss; please let us know. We would be happy to sit down with you all again and,go over
any questions that you might have
Regards,
Bethany Georgoulias

Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center,, Raleigh, NC,27699-1617
512 N Salisbury St, Raleigh, NO 27604
Phone [phone]
Fax [phone]
NEW -Website http //portal ncdenr org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
From: Georgoulias, Bethany
Sent: Friday, December 16, 2011 11:41 AM
To: 'Mc Gary; Mark E'
Cc: Velte, John S; Everett, George T; Stowe, Allen; Bennett, Bradley; Parker, Michael; Patterson, Robert; Lowther, Brian
Subject: RE: Draft stormwater,permits for Marshall, Allen, and Riverbend
Hi Mark,
December schedules and logistics with the Green Square Building moves have delayed us more than I'd hoped for
responding to you all on this I wanted to update you.
We are scheduled to meet with our Section managers the middle of next week, and I hope to have something out to you
all shortly after This means we probably won't be able to convene until,after the holidays in January, but I imagine
several people there will be taking vacation over the next few weeks as well -
Also, I've begun working on the, Buck CCTC review and permit development The staff report request needs to be
completed and sent to the region for review I hope to:get through that step before the Christmas holidays, but I'll keep
you posted on where I am with that Either way, it will be next month before we get to the public notice stage at the
earliest. I .Just wanted to let you know°that was in,the development process.
Please let me know if you have any questions or updates on the Buck CCTC facility completion schedule since the last
time we discussed.
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater,Permittmg Unit
'1617 Mail Service Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NC 27604
Phone [phone]
Fax [phone]
NEW'Website http //portal ncdenr org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
From: Mc Gary, Mark E [madto:[e-mail]]
Sent: Friday, November 18, 20119:30 AM
To: Georgoulias, Bethany
Cc: Velte, John S; Everett, George T; Stowe, Allen
Subject: Draft stormwater permits for Marshall, Allen, and Riverbend

Bethany
Duke Energy reiterates the positions stated' in our comment letters to NCDENR-DWQ in, response to the draft stormwater
permits for the Marshall, Riverbend and Allen Steam Stations We do not believe the requirements for inclusion of
analytical sampling of,any benchmarks to be valid Stormwater runoff has been occurring at these facilities for decades
with no indications of adverse impacts to the receiving water bodies DWQ has provided no.evidence of actual or
potential adverse impacts that would warrant the inclusion sof sampling for these many benchmarks There should be a
substantial water quality issue, such as a 303(d) listing, to justify the requirements for monitoring of any benchmark values
in these permits Duke Energy maintains that many of,the requirements mandated by these draft permits are of little or
marginal value'in terms, of environmental protection, and that these requirements place an unjustlfied'burden on our
facilities
As an alternative, Duke Energy proposes a stormwater permitting approach more in line with the requirements of other
states general permits such as the South Carolina Industrial, Stormwater General'NPDES Permit SCR000000, Part,8 —
Sector -Specific Requirements for Industrial Activity, Subpart O, Sector O —Steam ,Electric -Generating Facilities- In
particular, we propose the following alternative requirements
a Semi-annual quantitative sampling for,those outfalls discharging stormwater runoff,from areas that store
coal This would' be limited to any stormwater runoff from the coal storage pile that discharges directly to'the
receiving water body Samples would be analyzed for TSS and pH only, with effluent limits of 50 mg/I, for TSS,
and60to9Osu forpH
b Semi-annual quantitative sampling for any parameters for,which a 303(d) listing exists for the subject section of
the receiving water body Sampling would be performed for the listed constituent,at all defined representative
outfalls Sampling for the listed constituent -would be discontinued following two consecutive non -detect results
c Semrannual qualitative sampling at'all defined representative outfalls Samplias,would be characterized by color,
odor, clarity, presence offloating solids, settled solids, suspended solids, foam, oil sheen, or other indications of
stormwater pollution
d Qualitative�and quantitative monitoring will be limited to defined representative outfalls only, Presently, those
outfalls are'identified as
I Marshall Steam Station SWO03 and SWO07
u' Riverbend Steam Station SW002, SW003, SWO07 and,SW008
III Allen Steam Station SW005, SW008, SW011 and SW015
IV, Buck Steam Station SW,002, SWO05 and SW073
e- Development of stormwater pollution prevention plans as stated in the draft permits
We would welcome another opportunity to meet with you and others in the Stormwater Permitting Unit to further explain
our concerns and work toward resolution
Thanks
Mark McGary, P E
Duke, Energy EHS
From: Georgoulias, Bethany[mailto:[e-mail]]
Sent: Monday, November 14, 2011 1:45 PM
To: Mc Gary, Mark E
Cc: Bennett, Bradley
Subject: RE: Meeting on draft stormwater permits -for Marshall, Allen, and Riverbend
Hi Mark,
I was just following up with you to see if the end of November was a good timeframe for you all?
Thanks,
Bethany

Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permittmg'Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NO 27604
Phone [phone]
Fax [phone]
NEW Website http //portal ncdenr org/web/wq/ws/su
E-mail correspondence to -and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
From: Georgoulias, Bethany
Sent: Monday, November 07, 20112:18 PM
To: 'Mc Gary, Mark E'; 'Velte,'John S'
Cc: Bennett, Bradley; Patterson, Robert; Lowther, Brian; Parker, Michael; 'Stowe, Allen'; 'Everett, George T
Subject: RE: Meeting on ,draft stormwater permits for'Marshall, Allen, and Riverbend
Gentlemen,
Thanks so much for meeting,with us last,week about the INPDES stormwater permits for these'three Duke Energy
plants We appreciate your taking the time to come to Raleigh and discuss several of the issues that have come up
during the draft permit phase We hope we explained,some,aspects about,our stormwater permits and program that
were confusing or not so,clear before We realize'we may not have answered all of your questions or concerns, but we
hope we conveyed how important we value the dialogue as we move forward to`finalize these permits
We look forward to corning back together with idea`s from both sides about alternatives and clarifications we can
consider integrating into the permits. Some of these ideas include.
(1) alternative monitoring schemes that serve both purposes of: characterizing stormwater discharges based on
potential pollutants from the activities here, and serving as a tool for the permittee's Stormwater Pollution Prevention
Plan/BMP assessment;
(2) proposals for a period of time after -which monitoring for some parameters can be discontinued and why (for
example, to identify the most likely constituents present);
(3) proposals for,alternative qua_ Irtative monitoring requirements to accommodate the, large number of outfalls and
accessibility concerns,
(4) proposals for alternative storm events that should be measured (e g., "measureable storm event" based on discharge
potential"instead of "representative,"' based on the,0.1" rainfall criterion).
Our goal is to progress towards,finalizing something by the end of the year. I know we're moving,into the holiday'season
soon, and so we'd like to propose having these ideas ready by November 30`h Please let us know'if thattimeframe,
works for you all
Thanks again,
Bethany Georgoulias
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NC 27604
Phone [phone]
'Fax [phone]
NEW Website http //portal ncdenr org/web/wo/ws/su

`E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
From: Georgoulias, Bethany
Sent: Monday, October 24, 20113-42 PM
To: 'Mc Gary, Mark E'; Velte, John S; Everett, George T; Stowe, Allen
Cc: Bennett, Bradley; Patterson, Robert; Lowther, Brian; Parker, Michael
Subject: RE: Meeting on draft stormwater permits for Marshall, Allen, and Riverbend
Mark,
We are all set for a meeting on Wednesday, November 2nd at 10:30 AM I have reserved the large conference room
(#3) on,the 14th Floor of,the Archdale Building at the NC DENR offices here in Raleigh. If you,need to find us earlier that
morning, our Unit is located on the 91h floor.
You have been down here severa'I times and are probably aware of the parkin&options (and challenges!,), but please let
me know if you need more information. Several of the DENR Divisions will be moving over to the new Green Square
building that week, so I'm not sure what to expect up there that day, but it's a great meeting space
Since we are discussing three plants and the permits in,general, I think it would help for me to put•an agenda
together I'll draft up something and get it out in the next week. I think it would help to talk about items common to all
of the permits first=and then get into site-specific details We'll use the comments you all submitted as a guide. If you
would like me to include anything else, let me know
Welook forward to speaking with you. If you have,any questions in the meantime, please don't hesitate to contact me
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NC 27604
Phone [phone]
Fax -'(91'9) 807-6494
NEW Website http //portal ncdenr oro/web/wq/ws/su
E-mail correspondence'to and from this °address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
From:, Mc Gary, Mark E Imailto:Mark. McGa[y(Muke-energy.com1
Sent: Monday, October 24, 20112:04 PM
To: Georgoulias, Bethany
Cc: Velte, John S; Everett, George T; Stowe, Allen
Subject: RE: Meeting on draft stormwater permits for Marshall, Allen, and Riverbend
Bethany.
Looks like Wed, Nov 2 is best for,us.
Please send a meeting notice to those,copied on this email.
See you then
Mark