NCS000571_Hearing Officers Report Final Signed_20150930

North Carolina Division of Energy Mineral and Land Resources
September 30, 2015
Memorandum
To: Tracy Davis
Director
From: Zahid Khan Original Signed By Zahid Khan
Regional Engineer, Land Quality Section, Mooresville Regional Office
Matt Gantt Original Signed By Matt Gantt
Regional Engineer, Land Quality Section, Winston-Salem Regional Office
Subject: NPDES Stormwater Permit Hearings - Duke Energy Carolinas, LLC - Dan River and Rogers Energy Complex
Hearing Officers' Report and Recommendations
Early this month we served as hearing officers for two public hearings on proposed issuance of NPDES stormwater
discharge permits for two Duke Energy Carolinas, LLC locations. As hearing officers, our main focus was to consider the
public comments received during the notice period and any comments given at the public hearing in making a
recommendation for final action on the draft permits. The two permits considered and information about the hearings is
included in the table below.
Dan River Combined Cycle Station - Permit Number NCS000572:
This facility is located at 864 South Edgewood Dr., Eden, N.C. - Rockingham County. The facility is a gas
fired power plant that discharges industrial stormwater to the Dan River in the Catawba River Basin.
Hearing was held on September 8, 2015 at the Eden Town Hall in Eden, NC.
Hearing Officer - Zahid Khan
Rogers Energy Complex (Cliffside Steam Station) - Permit Number NCS000574:
The facility is located at 573 Duke Power Road, Mooresboro, NC - Cleveland and Rutherford Counties.
The facility is a coal-fired power plant that discharges industrial stormwater to the Suck Creek and the
Broad River in the Broad River Basin. Hearing was held on September 10, 2015 at the Boiling Springs
Town Hall in Boiling Springs, NC.
Hearing Officer - Matt Gantt
Excluding Department staff, the only attendees at the public hearing were employees of Duke Energy Carolinas. There
were three Duke Energy employees at the Eden hearing and four at the hearing in Boiling Springs. There were no
speakers at either public hearing. As hearing officers, we presented the hearing officer's speech at each hearing and
gave opportunity for any public comment, but none was offered. During the public comment period we received one
written comment letter for each facility. These letters were from the permit applicant, Duke Energy Carolinas, and
included their comments on specific permit language. Division staff have reviewed these comments and made
appropriate adjustments to the final permit where warrented. Changes to the final permit were minor in nature.
Background
The fact sheets for the permits outline in more detail the basis for permit coverage and permit requirements for these
facilities. The facilities are steam electric power generating facilities. This industry sector is required to have NPDES
permit coverage for stormwater point source discharges from the industrial activities at such facilities. The permit
documents note that for a major portion of the industrial plant areas and ash handling areas of these sites, stormwater is
collected and treated in the facilities' wastewater treatment systems. Those drainage areas are covered in a separate
wastewater NPDES permit. For the areas covered by the stormwater permit, the major provisions of the permit are
requirements for a Stormwater Pollution Prevention Plan (SWPPP) for the facility, along with monitoring (visual and

Hearing Officers' Report
September 2015 Public Hearings
Dan River Combined Cycle Station
Rogers Energy Complex (Cliffside Steam Station)
quantitative) and inspection requirements. These provisions provide comprehensive coverage through the
implementation, regular evaluation and adjustment of management measures on each site to minimize the discharge of
pollutants during rainfall events.
SUMMARY OF PUBLIC COMMENTS AND RECOMMENDATIONS
As indicated above, the only comments received on the draft NPDES stormwater permits were from the permit applicant,
Duke Energy Carolinas, LLC. Duke Energy staff requested that general comments from the Rogers Energy letter also be
considered for the Dan River permit. Staff in the Stormwater Permitting Program have reviewed the comments received
from Duke Energy and have developed responses to their concerns. We concur with the recommended changes in the
final permits for these facilities. The changes included are minor in nature, and the final permits maintain essentially the
same requirements as those taken to public notice. In the process of finalizing the permits, staff have developed
transmittal letters for each permit that address the permittee's comments and the Division's responses to these
comments. The major issues raised in the comments are summarized below.
• Duke Energy requested that the permits allow them to track employee training electronically. Division staff have
worked to address this allowance in the final permits.
• In a number of situations, Duke Energy requested that representative outfall status be allowed for a number of
outfalls. This is a process that is allowed in all stormwater permits and can be coordinated with regional office
staff. Consistent with this approach, these permits will maintain monitoring for the outfalls and direct the facilities
to work with the regional office staff on potential representative outfall determinations after the permits are issued.
• In a number of situations, Duke Energy requested adjustments to the monitoring period based on the final
effective date of the permit. These requests were intended to allow any work needed to provide proper access to
outfall points before the requirements began. The final permits reflect an appropriate timeline for these activities.
• Duke Energy questioned the levels established for benchmarks for copper and silver and asked if these levels
could be re-evaluated. The stormwater discharge benchmark values are designed to protect the aquatic biota
from pollutants generated at industrial sites. More information is included in the response to comments from
permitting staff. The final permits remain unchanged on the benchmark requirements.
Based on our review of the information associated with these permits, public comments received and discussions with
stormwater permitting staff, I recommend that the Director move forward to issue the final permits with the minor
modifications that have been included. Final permits are attached to this package for your signature.
If you have any questions, please contact me to discuss.
Page 2

ATTACHMENTS
A. Announcement of Public Hearings
B. Comments Received on Stormwater Permits
Page 3
Hearing Officers' Report
September 2015 Public Hearings
Dan River Combined Cycle Station
Rogers Energy Complex (Cliffside Steam Station)

Attachment A: Announcement of Public Hearing

Aug. 2, 2015
PUBLIC NOTICE
N.C. DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES INTENT TO ISSUE
NPDES STORMWATER DISCHARGE PERMIT #NCS000572
Public comment on the draft permit is invited. All comments received by Sept. 8, 2015 will be
considered in the final determination regarding permit issuance and permit provisions.
PERMIT APPLICATION
Duke Energy Carolinas, LLC, 422 South Church St., Charlotte, N.C., has applied for an NPDES
stormwater permit for the Dan River Combined Cycle Station, 864 South Edgewood Dr., Eden, N.C.,
Rockingham County. The facility is a gas-fired power plant, which discharges industrial stormwater to
the Dan River.
The draft stormwater permit and related documents are available online at:
htlp://portal.ncdenr.or /g web/guest/duke-npdes-permits. Printed copies of the draft permit and related
documents may be reviewed at the department's Winston-Salem Regional Office, 450 West Hanes Mill
Road, Suite 300, Winston-Salem, N.C. To make an appointment to review the documents, please call
336-776-9797.
Public comment on the draft permit should be mailed to: Stormwater Permitting, 1612 Mail Service
Center, Raleigh, N.C., 27699-1612.
Public comments may also be submitted by email to: publiccommentsgncdenr.gov. Please be sure to
include "Dan River" in the email's subject line.
PUBLIC HEARING
The N.C. Department of Environment and Natural Resources will hold a public hearing to accept
comments on the draft permit on Tuesday, Sept. 8 at 6 p.m. at Eden Town Hall, 308 East Stadium Dr.,
Eden, N.C. Registration for speakers begins at 5 p.m.

Aug. 2, 2015
PUBLIC NOTICE
N.C. DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES INTENT TO ISSUE
NPDES STORMWATER DISCHARGE PERMIT #NCS000574
Public comment on the draft permit is invited. All comments received by Sept. 10, 2015 will be
considered in the final determination regarding permit issuance and permit provisions.
PERMIT APPLICATION
Duke Energy Carolinas, LLC, 526 South Church St., Charlotte, N.C., has applied for an NPDES
stormwater permit for the Rogers Energy Complex (formerly known as the Cliffside Steam Station), 573
Duke Power Rd., Mooresboro, N.C., Cleveland and Rutherford counties. The facility is a coal-fired
power plant, which discharges industrial stormwater to Suck Creek and the Broad River.
The draft stormwater permit and related documents are available online at:
http://portal.ncdenr.org/web/guest/duke-ppdes-permits. Printed copies of the draft permit and related
documents may be reviewed at the department's Mooresville Regional Office, 610 East Center Ave.
Suite 301, Mooresville, N.C. To make an appointment to review the documents, please call 704-663-
1699.
Public comment on the draft permit should be mailed to: Stormwater Permitting, 1612 Mail Service
Center, Raleigh, N.C., 27699-1612.
Public comments may also be submitted by email to: publiccommentskncdenr.gov. Please be sure to
include "Cliffside" in the email's subject line.
PUBLIC HEARING
The N.C. Department of Environment and Natural Resources will hold a public hearing to accept
comments on the draft permit on Thursday, Sept. 10 at 6 p.m. at Boiling Springs City Hall, 114 East
College Ave., Boiling Springs, N.C. Registration for speakers begins at 5 p.m.

Attachment B: Comments Received on Stormwater Permits

DUKE
ENERGY
September 8, 2015
Mr. Bradley Bennett
State of Noah Carolina
Department of Environment & Natural Rcsvur,,es
Division of Energy, Mineral & Land Resutin es
Sturmwater Permitting Program
1612 Mail Se, vice Center
Kaleigh, NU 2/699-1612
Subject: Comme iv, on the draft NrDBS Sto,mwater rermit
Dan Kiver Cun,bined Cycle Station - rermit No. NCSUUUS'/2
Attention- Stormwater Permitting
Dear Mr. Bennett:
Herryy K. StaBns
Senior Vice President
t=nwronmenta,, Realm 3 Safety
52b Sentra Unman Stmvi
Mad COZ6 tX3XN
Chdilotte. IVC 28202
(70-4)302-4303
Duke Energy Carolinas, LLC (Duke) requests modifitatiuns to the draft industrial stur,nwater
permit for the Dan River Combined Cy,,le Station. Specifically, we request that the permit oc
amended to address the decommissioning activities ut tuimer van Kiver Stean, Station. Duke
requests that the issued hermit piuvide coverage of a stormwater outtall at the northern discharge
pipe at the fu,n,ei Swuw outtaah. This discharge pipe receives stormwater from the drainage
ditch along t)asin side of Edgewood Road, oil trap tank from area around Combustion Turbine,
c1 6, and coal yard. However, the discharge frim this pipes immediately cvrranglus with flew
from the discharge pipe from the south which conveys stormwatei trop, the switchyard oil trap
tank and groundwater frun, CT area. chis comingling occurs prior to any discharge to a
receiving water as the discharges converge into one concrete conveyance and are discharged to
the Dan Kiver.
Duke has requested coverage of this combined flow as part of the pending amendment to
NPDES permit NC0003486_
after decommissiuning of the Powerhouse, the stormwater from the drainage ditch along the
t)asin side of Edgewood Road will continue to flow through this lvcatiun.

Pag,- 2
Should you have any questions regarding this submittal or require additional informatiun, htease
cuntact Joyce Dishmon at 336-623-0238 ur Finail Juyc,[e-mail]
Sincerely,
Harry K. Slderis
Duke Energy
Senior Vice President, Gnvi►unmental, health K Satety
cc: Jim Wells
Richard Baker
Jeremy Pruett
Joyce vishuiuu
Uaua Newwmb

fn DUKE
ENERGY.
September iu, 2015
Mr. Bradly Bennett
State or MortM uarulina
Department of Environment and
Stormwater Permittiny
1612 Flail Service [;enter
RalaiuM, I9i.; 27bv9-1e72
Eleutronic Sa6mittal
Natural Resourca3
narry Pv. 30eris
Sv, nv. W. Y,-0—"
cnvironmenra,, rreamp 3 5arery
526 U17a—n 4S'bact
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t.nor1 itv, NG zzmm'2
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Sabjeut: Royerb Eneryy Complex (Cliffside)
Lomments of i Draft Indast,ial 5tormwater Permit (No. NCS000571)
Dear Mi. Bennett:
Witn ru-terence to Vie Aa—yast 2. 2015 pa6lic notice. DURE Eneryy offers the following
comments on the sul sect dran perm;t.
Part I Paye 2 of 2
i nu lucatiun map 6 Ia6Glled "uma Eneryy Pryres3". Thib shoals be labelled as "Dake
Energy Carolinas,
Part II Page 4 of 14
under item W-Empluyua i raining" DaRe tneNy atilie-es cumpater basea t,aininy for
SPPP. In this process no signatures arm 7,e5tainea Out tPia recoras at emplayee
attendance are kept electronically. It is requested that tRe option to maintain mcuraa ut
amployee training electronically be allowed instead of keeping signed records of
training.
Part 11 Page 7 of j 4
unser I a5le 2 there are 10 drains in the drainage area for SWu15, 5 drains for the
drainage area to, 5w016 anci 4 uuttalls tar the lei idtill. All of the drains per drainage
area are rrom similar scenes. It is r.laestea that repass, ,tativa outtall states (RU5)
be granted for the SWu 15, Svvu1 o ana tRe landfill drai, iaye arca3.

Page 2 of 3
Supturnftr 10, 2U15
Fetter to Mr. Bradley Bennett
PaR II Page 9 of 14
Under i able 3 it is requested that the dates of the monitoring pariud be adjosted to
reTlect Me eTT-=Ctiye date W Me permit (e. -y. Year 1 - Period 1 bcyin January 1. 2016).
This will allow for any improvement needed to eataoiiun acceaa arOaa Tar analytical
monitoring.
Under Table 4 some of the l5encRmarR values are vel y I7jwY. Fur L;upper Me bumcnmaM
value is listed as 0.01 mg/l. The Silver value is listed at u.uuu3 mg/l. Pius Tor Silver the
practical quantitication ievel listed in the Fact Sheet is 0.001 mgll; which as noted in the
Fact Sftut is MuMer than the bencFimarR level. Lould these two values be re-
evaluate-or
e-
evaluatear pe potential e.iat5 that tMeae pa,ametera could 6c meaauied in Sturm
water ran -off from the influence of 13acRgrouna soil containing metals, inateaa UT an
indabbial activity.
Part II Paye 13 UT 14
Under Table 6 it is requested tRat tMe nates OT the monitoring puriva tae adjuated to
retlect the effective date of the permit (e.g. Year 1 - Period 1 begin January j, 2016).
i Flia will alluvv tur any improvement needed to establish access areas for visual
monitoring.
FACT SHEET
Page i:
The Unit 6 switchyard does not have oil trap tanks since tyle transrormers are air cooled.
i he last Sentence should be deleted.
Page 2:
Under Oatfall SW002 delete the last sentence since this area does not Mave an oil trap
tang. 0, oder Outtali SW005 Units 1-4 taf5ine building has been demolished so no roof
drains diauMarye in tHia area. As part of the decommissioniny the Rench drains tram
tMe units 1-4 screen murm tc tPie current intaRe Rave been removed and rplaced With a
drop inlet box.
Paye 3:
Under Ourtail Svvuub McOt5 L. miaapelled.

Paye 3 of 3
Septcm6er 10, 2015
Cutter to Mr. Bradley ben, Batt
Payu 4:
Atter the paragraph for Unit 6 switch yard area, a laydown area #z drainage area Pias
ften 5uilt. It includes a yravel laydown area and drains to a sediment basin which
dizL;Maryea W a, unnamea tri5ata�yy to the Bruaa Hiver.
Page 8:
under "Other Proposed Hegairemant5" in the second 60118L for clarification this site does
Mavu uparatiny a, pita. However, sampliny daring normal opuratiny hours is preferred
rrom a sarety standpoint.
It you have tiny questions associated with these comments please contact noVert vvylie
at 704 352-4669.
Sincerely,
Harry K. Sideris
SVP, Environmental, Health and Sarety
cc: [e-mail]