NC0003425_Comments_20160916

Strickland, Bev
From: Shell, Karrie-Jo <[e-mail]>
Sent: Friday, September 16, 2016 7:49 AM
To: Rodriguez, Teresa
Cc: Diaz, Denisse; Davis, Molly; Zimmer, Andrea; Staples, Bridget
Subject: RE: Roxboro Intake map
Thanks for sending the updated map and flow schematic. I still have a few comments and recommendations for the
permit.
The permit should clearly state the sampling locations for all internal and external outfall. For instance, there is no
sampling location mentioned for outfall 001. Also, for outfall 003, the permit refers to a map, but you cannot tell from
the map the exact sample location.
I recommend the permit list all the wastewaters that contribute to the outfall 006. Because one of the waste streams is
truck wheel wash, I recommend an oil and grease limit or monitoring requirements for this outfall.
Please clarify where the emergency overflow for the FGD treatment system goes; the fact sheet lists FGD emergency
overflow as a waste stream. Is the emergency flow all collected and eventually treated in the bioreactor, or does some
of it end up in the ash pond? If any FGD wastewater bypasses treatment and is sent directly to the ash pond, the outfall
for the ash pond should include the EG for FGD wastewaters.
The permit allows Duke until November 1, 2018, to meet the new effluent guidelines for fly ash and bottom ash sluice
wastewaters (i.e., no discharge). Can you clarify if they are already doing dry ash handling for fly ash? The fact sheet
suggests that they are. If so, then why is the extension to 2018?
The permit is not specific regarding identification of new seeps. Other Duke permits referenced a Seep Identification
Plan, which EPA has commented should be attached to the permit.
Internal outfall 008 only requires annual reporting for both the existing flowrate and the expansion to 0.025 MGD. I
recommend at least monitoring quarterly for one year after the expansion then reducing the monitoring to annually.
The is a typo in the table for outfall 010. For arsenic, the sample type is misspelled.
Karrie-Jo Robinson -Shell, P.E.
Environmental Engineer
US EPA Region 4
Water Protection Division
61 Forsyth Street
Atlanta, GA 30303
[phone]
From: Rodriguez, Teresa[mailto:[e-mail]]
Sent: Wednesday, September 14, 2016 4:06 PM
To: Shell, Karrie-Jo <[e-mail]>
Subject: Roxboro Intake map

Teresa Rodriguez
Environmental Engineer
NC Division of Water Resources
NC Department of Environmental Quality
919 807 6387 office
Teresa. rod riauez(a-)ncdenr.aov
1617 Mail Service Center
Raleigh, NC 27669-1617
Nothing Compares.-,-.,.
s..v
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