NC008699_Comments_20170816

Rodriguez, Teresa
From: Shell, Karrie-Jo <Shell Karrie-Jo@epa gov>
Sent: Wednesday, August 16, 2017 11.25 AM
To: Rodriguez, Teresa
Cc: Davis, Molly, Staples, Bridget
Subject: RE Reidsville Energy Center Permit NCO089699
Here are some initial comments ---
Is this facility planning to comply under Track I or Track 2? For enforcement purposes, the permit should specifically
state which one
Page 5 — Part I.A.6. For new facilities that must comply with the CWIS, the appropriate reg cite is 40 CFR 125.84, not
125.95.
Assuming the facility will comply with Track I:
Part I.A.(7): The language should mirror that in the regs. I suggest:
Velocity monitoring — add the following language per the regs.
"The maximum head loss across the intake screen for each cooling water intake structure must be used to determine
compliance with the maximum through -screen design intake velocity of velocity requirement of 0.5 feet per second.'
Recordkeeping — add the following per 125.88, which specifically refers to the requirements in the CWIS rule::
"The permttee must keep records of all the data used to complete the permit application and show compliance with the
requirements, any supplemental information developed under 40 CFR Section 125.86, and any compliance monitoring
data submitted under 40 CFR Section 125.87, for a period of at least three years from the date of permit issuance.
For enforceability purposes, I would include the definitions in the rule under 125.83 for Design intake flow,
Design intake velocity, and Entrainment
Hope this helps!
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•Teresa [e-mail]]
Sent: Wednesday, August 16, 2017 9:16 AM
To: Shell, Karrie-Jo <[e-mail]>
Subject: Reidsville Energy Center Permit NCO089699

Hi Karrie-Jo, this is the new permit I'm writing for a new combined cycle plant. I drafted monitoring conditions for the
cooling water intake but would like you to review them since we have no other permit with similar conditions. The
condition is in Part A.(7).
Thanks,
Teresa
Teresa Rodriguez
Environmental Engineer
NC Division of Water Resources
NC Department of Environmental Quality
919 807 6387 office
Teresa rodnguez(a)ncdenr qov
1617 Mad Service Center
Raleigh, NC 27699-1617
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