NCS000571_Rogers Energy Complex (Cliffside) Add Info Response Letter_20140918

(' DUKE
ENERGY
September 18, 2014
Mr. Bradley Bennett
State of North Carolina
Department of Environment and Natural Resources
Division of Energy, Mineral & Land Resources
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: Rogers Energy Complex
NPDES Stormwater Permit Application
Duke Energy Response to Additional Information Request
Dear Mr. Bennett;
Environmental Services
Duke Energy
526 South Church Street
Charlotte, NC 28202
Mailing Address.
Mail Code EC13K/ P.O. Box 1006
Charlotte. NC 28201-1006
Duke Energy Carolinas, LLC (Duke Energy) presents the following information to the North
Carolina Department of Environment and Natural Resources (NCDENR),- Division of Energy,
Mineral, and Land Minerals in response to NCDENR's request for additional information dated
August 26, 2014. The request was submitted following Duke Energy's July 31, 2014 submittal of
a National Pollutant Discharge Elimination System (NPDES) stormwater permit application for
the Rogers Energy Complex (formerly Cliffside Steam Station), located in Cleveland and
Rutherford Counties, North Carolina.
For ease of reference, NCDENR's excerpted queries appear in italics below, followed by Duke
Energy's (DE) associated response.
NCDENR Request 1: Please resubmit EPA Form 1 General, indicating in Section IX whether
or not the facility is located on Indian Lands.
DE Response: Revised EPA Form I attached.
NCDENR Request 2. Please explain what is meant by "In developed areas" submitted as
"Supplemental Information under "GENERAL SITE INFORMATION" in
the third paragraph of the first page
DE Response: "In developed areas" refers to industrial use areas of the site generally
containing buildings, structures, roads, parking areas, etc. where stormwater
runoff is collected by yard drains and routed via a subsurface piping network.
NCDENR Request 3: Please explain what "DOT Regulations are followed" submitted as
"Supplemental Information in Section "YARD DRAINAGE BASIN,"
subsection "Significant Materials/Controls - Oil" in the first paragraph.
DOT regulates hazardous materials in transportation. I'm not aware of

any Federal or State DOT regulations for fuel oil storage tanks, a
dispenser, and dikes.
DE Response: "DOT Regulations are followed' refers only to transportation of oil via tanker
trucks on-site prior to unloading. Stormwater in this area of the site is routed to
the ash basin and discharges through NPDES Outfall 002.
NCDENR Request 4 Please clarify the third paragraph in Section "YARD DRAINAGE
BASIN, " subsection "Significant Materials/Controls — Oir that discusses
"USED OIL" and WASTE OIL"' The first sentence refers to a 4,000
gallon used oil storage tank. The fourth paragraph (sentence) refers to
a waste oil tank. It is unclear as to whether or not you are describing
one tank or two separate tanks — one for used oil and another for waste
oil.
DE Response: The 4,000 gallon used oil tank and the referenced waste oil tank are the same
tank. Stormwater in this area of the site is routed to the ash basin and
discharges through NPDES Outfall 002.
NCDENR Request 5. 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
additional 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.
DE Response: All stormwater outfalls have been observed during dry periods with no
discharges noted as indicated on the submitted Form 2F.
NCDENR Request 6: Our understanding was that Duke would follow the same format as the
Riverbend application in subsequent application submittals, including
sample results from all stormwater discharge outfalls. Please provide
sampling results for all stormwater outfalls at this site, or provide a
schedule for sampling the remaining outfalls and following up with the
results.
DE Response: Stormwater samples were collected from 18 outfalls and the analytical results
were submitted to NCDENR via cover letter dated August 25, 2014. The
following outfalls were sampled:
Sampling Date: July 19, 2014
Outfalls Sampled: SW004, SW005, Drainage Area 15 (one representative 8"
HDPE)
Sampling Date: July 21, 2014
Outfalls Sampled: SW001, SW002, Unit 6 Switchyard East Culvert (30 RCP),
Unit 6 Switchyard West Culvert (24" RCP),
2

Drainage Area 16 (36" CMP), Drainage Area 16 (42"
CMP), Drainage Area 16 (54" CMP), Landfill Drainage
Area (21" CMP)
Sampling Date: August 1, 2014
Outfalls Sampled: SW009, SW011, SW012, Drainage Area 16 (30" CMP),
Drainage Area 16 (24" CMP), Landfill Drainage Area (42"
CMP), Landfill Drainage Area (36" CMP)
Samples were not collected from the remaining outfalls per the following
rationale:
Outfall SW003: This outfall formerly conveyed stormwater runoff from
industrial use areas surrounding the Unit 5 Powerhouse. The
outfall was abandoned by plugging at an up -gradient manhole in
approximately the 2010 timeframe and all runoff from this area is
now routed to the ash basin. Some minimal discharge is
observed from this outfall during rainfall events. The plug has
been inspected and appears to be functioning well. The station
is continuing to investigate the source of this discharge. No
discharge occurs during dry periods.
Outfall SW008: This outfall conveys non -contact stormwater from an isolated
area on the opposite side of the Broad River that was formerly
used as a sand mining operation. The mining operation ceased
in 2012. The area is vegetated and not used for any purpose
associated with the Rogers Energy Complex. Outfall SW008
should be removed from any permitting requirements.
Outfall SW010: This outfall conveys non -contact stormwater runoff from an
undeveloped, non -industrial use wooded area (Drainage Area
10) located north of the Unit 5 Switchyard. This outfall also
conveys water from a perennial stream that starts on adjoining
property. This conveyance culvert runs beneath the switchyard
and discharges in a low area south of the switchyard. Outfall
SW010 should be removed from any permitting requirements.
Drainage Area 15: As described in the "Supplemental Information",
stormwater runoff from this area discharges through ten 8"
diameter HDPE pipes located along the railroad tracks. There is
no single SW015. A stormwater sample was successfully
collected from one of these pipes, and this sample can be
considered representative of all discharges from this area.
Collecting samples from all ten of these conveyances is not
feasible due to limited access and negligible stormwater
discharge flow.
Landfill Drainage Area 18" CMP- As described in the "Supplemental
Information", stormwater runoff from this area discharges
through four CMP culverts beneath the railroad tracks.
Stormwater samples were successfully collected from three of
3

these culverts. The 18" CMP culvert had no discharge at the
time samples were collected suggesting this culvert discharges
from a limited contributing drainage area. Future sampling
efforts from this culvert may not be feasible.
Unit 6 Switchyard 18" RCP: As described in the "Supplemental Information",
stormwater runoff from this area discharges through three RCP
culverts located on the west side of the switchyard. Stormwater
samples were successfully collected from two of these culverts
(the 24" diameter northernmost culvert, and 30" diameter
southernmost culvert). These two culverts were sampled due to
the presence of mineral oil -filled equipment within their
contributing drainage areas. The middle 18" diameter RCP
culvert was not sampled as there are no significant materials or
activities within the contributing drainage area.
NCDENR Request 7• Please clarify the Site Plan.
1. The plan shows a SW003, but does not show a drainage are 3, nor
does the supplement(al) information discuss either SW003 or
Drainage Area 3.
2. The supplement(al) information discusses "Outfall SW015
(Drainage Are 15), but the plan does not indicate a location for
SW015.
3. The supplement(al) information discusses "Outfall SW016
(Drainage Area 16), but the plan does not indicate a location for
SW016.
4. Neither the site plan nor the supplement(al) information make
mention of an SW013 or Drainage Area 13. Are we to understand
there is not a SW013 or Drainage Area 13?
DE Response to Item 1: As previously stated in the response to NCDENR Request 6, this
outfall formerly conveyed stormwater runoff from industrial use areas
surrounding the Unit 5 Powerhouse. The outfall was abandoned by
plugging at an up -gradient manhole in approximately the 2010
timeframe and all runoff from this area is now routed to the ash basin.
Some minimal discharge is observed from this outfall during rainfall
events. The plug has been inspected and appears to be functioning
well. The station is continuing to investigate the source of this
discharge. No discharge occurs during dry periods.
DE Response to Item 2: As previously stated in the response to NCDENR Request 6 and
described in the "Supplemental Information", stormwater runoff from
Drainage Area 15 discharges through ten 8" diameter HDPE pipes
located along the railroad tracks. There is no single SW015.
DE Response to Item 3: As described in the "Supplemental Information", stormwater runoff
from Drainage Area 16 discharges through five CMP culverts beneath
0

the railroad tracks. The Site Plan indicates the locations of these five
CMP culverts. There is no single SW016.
DE Response to Item 4: Drainage Area 13 was combined with Drainage Area 16. There is
now no Drainage Area 13.
NCDENR Request 8: Please provide analytical sampling results for stormwater discharges
(SW001, SW002, SW004, SW005, SW009, SW011, SW012, SW015,
and SW016).
DE Response: Reference previous responses to NCDENR Request 6.
NCDENR Request 9: 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.
DE Response: PCB oil -filled equipment was present at the facility in the past, however, all oils
containing PCBs have been removed. A detailed timeframe of removal actions
is not available. Most areas of the site where PCB oil -filled equipment was
formerly located drains to the ash basin and discharges through NPDES Outfall
002. Some PCB oil -filled electrical equipment was also located in the Units 1-4
Switchyard which discharges through Outfall SW004. Outfall SW004 was a
NPDES permitted wastewater outfall at the time when this PCB oil -filled
electrical equipment was present. One past incident involving the failure of a
possible PCB -containing transformer bushing occurred in the Unit 5 Switchyard
(Drainage Areas 1 and 2). The affected area was remediated. There have
been no known PCB impacts to stormwater at the facility.
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 Mark McGary at 980-373-7898 or email Mark.McGary@duke-
energy.com.

I certify, under penalty of law, that this document and all attachments were prepared under ink direction
or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information submitted. Based on my inquire of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is.
to the best of my knoll ledge and belief, true, accurate, and complete. 1 art aware that thrre are
significant penalties for submitting false information, including; the possibility of fines and imprisonment
for knowing violations.
Attachment
A
Sincerely,
..
Rick Roper — General Manager II
Rogers Energy Complex

bc: Steve Hodges — Rogers Energy Complex
Rick Roper - Rogers Energy Complex
Penny Stafford
Mark McGary
Steve Cahoon
Harry Sideris
Linda Hickok
Mike Shrader
Document Number: 8-6
Record Type Codes ENC -50-02
UPS: