NC0003433_Comments_20180724 (2)

aN DUKE
Cape Fear Steam Electric Plant
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ENERGY®
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NC 27559
July 24, 2018 FZECEIVEDIDENRIDWR
Mr.Jeff Poupart A�� ® 2 218
Division of Water Resources Water Resources
1617 Mail Service Center Permitting Section
Raleigh, NC 27699-1617
Subject: Comments on the DRAFT NPDES Permit for Cape Fear Steam Electric Plant
Permit No. NC0003433
Chatham County
Dear Mr. Poupart:
Duke Energy Progress, LLC (Duke Energy) submits the following comments on the draft National
Pollutant Discharge Elimination System Permit for the Cape Fear Steam Electric Plant, issued for public
comment by the North Carolina Department of Environmental Quality ("NCDEQ") on June 27, 2018.
Duke Energy appreciates NCDEQ's efforts to develop the Draft Permit. Duke Energy continues to work
toward closing Cape Fear's surface impoundments, and finalizing this wastewater permit is a critical step
to advance that process by authorizing dewatering from the ash basins. Duke Energy requests a
conference call to discuss these items before the permit is finalized. Duke Energy offers the following
comments and requests for modification and/or clarification on specific provisions of,the Draft Permit:
1) Cover Letter—Duke Energy requests the facility be denoted as Class I facility. The cover
letter denotes the facility as Class II. Duke Energy has not received a classification change
made by the Water Pollution Control Operators Certification Commission or the Division of
Water Resources reclassifying the facility to a Class II facility.
2) Page 5 of 23 A(3) a.—Duke Energy requests clarification in the description for Outfall 007
that decanting is removing the free water 3 feet above the settled ash layer.
3) Page 6 of 23 A(3) d.—Duke Energy requests clarification in the definition of decanting that
the facility is allowed to drawdown the wastewater in the ash basin to no less than 3 feet
above the settled ash layer.
4) Page 6 of 23, Page 8 of 23, Page 10 of 23 and page 12 of 23—Notes(notes are numbered
differently on the outfall). The note states that if one of the pollutants (As,Se, Hg, Ni, and
Pb) reaches 85%of the allowable level during the decanting/dewatering,the facility shall
immediately discontinue discharge of the wastewater and report it to the Regional Office

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and the Complex NPDES Permitting Branch via telephone and email. Duke Energy is
preparing a procedure for implementation of this requirement and will be sharing it with
Division staff soon for consideration to assure a consistent interpretation and
implementation across the state.
5) Page 6 of 23, Page 8 of 23, Page 10 of 23, page 12 of 23 and Page 13 of 23—Duke Energy
requests the effluent limits table be modified by removing 50 NTU from the table and
adding a statement that refers to the applicable footnote for turbidity(the footnotes are
numbered differently depending upon the outfall). As written the table and note are
' confusing,the table limits the discharge to 50 NTU, however the note implies that the
discharge can be above 50 NTU if there is no increase of turbidity in the receiving stream.
6) Page 7, 9, 11, 13 and 16 of 23 Notes (the Notes are numbered differently depending on the
outfall)—Duke Energy requests concurrence from the Division that flow sensor devices are
allowed to be used to record flow at these Outfalls for the purposes of reporting flow on the
eDMR.
7) Page 13 of 23 A. (7)—Duke Energy requests the flow limit for Outfall 008 on Page 13 of 23
be listed as a daily maximum to be consistent with other flow limitations for Outfall 008 on
pages 7, 9, and 11 of 23.
8) Page 16 of 23 A. (9)—Duke Energy requests the flow limit for Outfall 009 be listed as a
monthly average rather than a daily maximum. The ash beneficiation plant is designed as a
closed loop system to allow for the reuse of stormwater that falls on the facility. However,
there may be times during large rain events, when there is stormwater in excess of the
amount the system is designed to handle,this stormwater will overwhelm the system and
be discharged from Outfall 009.
9) Page 19 of 23 A. (13)—Duke Energy requests a change in the upstream sampling point for
instream monitoring to require sampling 0.4 miles upstream from Outfall 008. Duke Energy
provided comments earlier in this letter that the location of Outfall 008 will change. The
new location will be approximately 0.4 miles from the confluence of the Deep and the Haw
Rivers,which constitutes the beginning of the Cape Fear River.
10) Page 27 USGS Quad Map—Duke Energy requests Outfall 008 be relocated on the drawing to
the following location 35°37'27.89"N 79°03'04.62"W. The outfall will be located just north
of the 5-16 treatment system.
11) Page 27 USGS Quad Map—Duke Energy requests Outfall 009 be relocated on the drawing,
near Outfall 008,to the following location 35°35'28.72"N 79°03'04.65"W. The outfall will
be located just to the north of the 5-16 treatment system.
12) Page 4 of the fact sheet.—Duke Energy request the fact sheet be amended to state the
treatment system will be added as necessary to meet permit limits.

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Duke Energy welcomes any further discussion on our comments or the draft permit. If you have any
questions, please contact Steve Cahoon at 919.546.7457 or at [e-mail].
Sincerely,
Issa Zarzar
Duke Energy
GM -CCP Regional Ops and Maintenance
Bc: Issa Zarzar-CCP—NC10
James Wells,VP—Duke EHS CCP
Richard E. Baker Jr.—Director, Env. Programs- EC13
John Stamas—Environmental Specialist, Cape Fear Plant
Shannon Langley- NCRH 15
Steve Cahoon—NCRH 15