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HomeMy WebLinkAboutNC0000396_Draft Permit Comments 2001_20010620r � • Asheville Steam Electric Plant Draft NPDES Permit Comments 1998 January <10 ppb February <10 ppb March <10 ppb April <10 ppb May <10 ppb June <10 ppb July 10 ppb ** August <10 ppb September <10 ppb October <10 ppb November <10 ppb December <10 ppb 1999 January <10 ppb February <10 ppb March <10 ppb April <10 ppb May <10 ppb June <10 ppb July <10 ppb August <10 ppb September <10 ppb October <10 ppb November <10 ppb December <10 ppb 2000 January <10 ppb February <10 ppb March <10 ppb April <10 ppb May <10 ppb June <10 ppb July <10 ppb August <10 ppb September <10 ppb October <10 ppb November 23 ppb December <10 ppb 2001 January <10 ppb February <10 ppb March <10 ppb April <10 ppb May <10 ppb ** Per the 1998 Environmental Monitoring Report,the French Broad River, upstream of the Asheville Plant intake, had a concentration of 22 ppb in July when sampled. This intake of copper is the probable cause for the higher than normal discharge from Outfall 002. Copper condenser tubes were replaced with stainless steel tubes in 1994. 5 cind-Ladinwoh tb,„6 , _ gigNivis _ [-- i. . Asheville Steam Electric Plant 6 1/ ^ nro 016, I • Draft NPDES Permit Comments /� �e h' , I , Section A(7) Section 316(a) Thermal Variance Reapplication tPtl� �� °'� k -J C �,/ PSL co/yowl h i av ci°L.0 • The citation referenced in the fourth line cannot be found. The correct citation is Clio 0 /WO() i le-t' probably Section 122.21(m) (6). &'kiwi%�- Section A(8)—Stormwater Pollution Prevention Plan (a &tell ) s().°41 • This section of the permit appears to be the standard language for storm water program `� M. development at industrial sites. However, the scope of the regulated storm water discharges at the Asheville plant is certainly less significant than what was intended to be addressed by the DWQ standard language. Any storm water program development activities at the Asheville plant would address only the new and old access roads. All other areas associated with industrial activity for the Asheville Plant drain to the ash pond which is already permitted. CP&L believes that the storm water discharge monitoring should suffice for addressing the storm water discharges from the roads. CP&L, therefore, requests that this section of the permit be deleted or significantly reduced in scope. We would be glad to meet with the DWQ staff to discuss this issue. Section A(9)—Stormwater Minimum Monitoring and Reporting Requirements ( '/ki (,4 a) • Part a. of this section allows a facility to petition for representative outfall status. The six stormwater outfalls for the Asheville Plant are substantially identical. CP&L, hereby requests that SW-3 be used for representative stormwater monitoring. • Part d. requires that monitoring results be submitted no later than January 31 for the previous year in which sampling was required to be performed. Using the example in Section A(4) above, CP&L understands that the monitoring results could be submitted no later than January 31, 2003. • Part f. (2) should contain the word "flushing" after"waterline and fire hydrant." Additionally, it is believed that"habits"should be"habitats." Part II Page 1 of 18 • DEM in item 2 needs to be replaced with DWQ. Part II Page 10 of 18 • Item 11 - Signatory Requirements, paragraph a. (1) has been modified in the Federal Regulations. This provision in the DWQ boilerplate should also be updated accordingly. 2 ri 6).1) 0, 11 ,N"b - -4 tzjaztilaitP- A-; /444)4 ;r1-taelig d'Al Division of Water Quality /5101 MEMO From: Date: To: Subject: �,t� 6nd1„e) lnhcf, S '�'�kr''l / 1,c,� f r Pa'1- -}o I 64G f L4 C( 4)W/Sw wal Gam+ I � irt, livesieille N[ ,f 4 11 l t 1 uaft&NS °re hAttt `� PIM�S Jr, P S+ CYN pro cc v1� +Iv ccefi s3 rood) el om w -Nq SwP3 ' Gv,,.. a J- S LU Audi" 144 g'o'd Cb,. ,34 WI 6t4. , Altai NCDENR North Carolina Department of Environment and Natural Resources PO Box 29535, Raleigh, North Carolina 27626-0535/Phone: 733-5083