Allen Steam Facility (15)

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent:, Wednesday, March 21`, 2012 2 48 PM
To: 'Mc Gary, Mark E'
Cc: 'Velte,John'S', 'Everett George,T', 'Stowe; Allen' Bennett, ,Bradl'ey, Parker, Michael,
Patterson', Robert,lowther, Brian, Matthews, Matt, Karoly, Cyhd,, Chernikov_, Sergei
Subject: Revised' Draft,NPDES Stormwater Permits for Marshall, Allen, and Riverbend
Attachments: NCS000546-548-549-draftcover-rev2012 pdf, NCS000546=draftpermit-rev2012 pdf,
NCS006548-draftpermit-rev2012 pdf, NCS000549-draftpermh-rev2012 pdf
Mark,
We have revised the draft sto,rmwater 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 Stormwate� Permitting'Urnt
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: 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,
c
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 tither way, it will be next month before we get to the public notice stage at the
earliest J dust 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 Permitting Unit
1617 Mad`Service Center,,Raleigh, NC,27699=161'7
5x12 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: MoGary, Mark E'[madto:Mark. McGary@duke-energyxcim]
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 Stearn Stations We do not,believe the,requirements for inclusion of
analytical sampling of any benchmarks to be valid Stormwater runoff has been occurnng,at,these facilitiesford'ecades
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 of sampling forthese 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 unjustified 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, and 6 0 to
90su 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'forthe listed constituent at all defined representative
outfalls Sampling for the listed constituent would be discontinued following two,consecutive, non -detect results
c_ Semi-annual qualitative sampling at all defined representative outfalls Samples would be characterized by color,
odor, clarity, presence of floating 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
Marshall Steam'Station SWO03 and SWO07

u Riverbend Steam Station SWO02, SW003, SWO07 and SW008-
iii Allen Steam Station SW005, SW008, SW011 and SW015
IV Buck Steam Station SW002, 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 Storm -water Permitting Unit to further explain
our,concerns and work toward resolution
Thanks
Mark McGary, P -E
'Duke Energy EHS
From: Georgoulias, Bethany[madto:[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 dust 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 Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NC 27604
Phone [phone]
Fax (919) 807=6494
NEW Website http //portal ncdenr org/web/wq/ws/su
E -mad correspondence to and from this address may be -subject to the North Carolina Public
Records, Law and may be disclosed to third parties
From: Georgo0has, 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
Subjects' RE: Meeting on, draft-stormwater permits for Marshall, Allen,, and Riverbend
Gentlemen,
Thanks,so much for meeting with us last week about the NPDES stormwater perm itsfor these,three Duke Energy plants
We appreciate your taking the time to come to Raleigh and discuss several of'th&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 coming back together with ideas 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 tooLfor the permrttee's Stormwater Pollution Prevention
Plan/BMP assessment,
(2)
pro posalsfor a period of, time after which monitoring for some parameters can be discontinued and why (for
example, to identify the most likely constituents present),
(3j proposals;for alternative qua Iitative;momtoring requirements to accommodate,the large number of outfalls and
access! NI!ty-,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 towards4inalizing 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 30th Please let us know if that timeframe
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- (91,9) 807-6494
NEW Website http //portal ncdenr orq/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, 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,
Weare all set fora 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 9th floor
You have been down here several times and are probably aware of the parking options (and' challenges '),'but please 'let
me know if you need more information Several of the DEN 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 itwould 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
We look forward to speaking with you If you have any questions in the meantime, please don't hesitate to,contact me
Thanks,
Bethany

Bethany Georgouiias
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 nttp //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 [mailto:Mark. [e-mail]
Sent: Monday, October 24, 2011 2:04 PM
To: Georgoulias, Bethanv
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