NCS000546_Email RE SW011 and SW012 Sampling_20150930

From:
Randall, Mike
To:
"Hartfield, Ross Evan"
Cc:
Pickle, Ken
Subject:
RE: Allen Stormwater Outfall Issue
Date:
Wednesday, September 30, 2015 10:10:00 AM
Attachments:
imaae001.ioa
The intent is to sample FOR outfall SWO11 and SWO12 before comingling and not necessarily at the
outfall itself. I'm not sure if that is even feasible.
I suggest that the sample point be determined by Duke and if necessary approved/agreed upon by
the Regional Office. If the Regional Office determines that it is not feasible to sample for outfalls
SWO11 and SWO12 before comingling we may have to make a minor change to the permit based on
their observations.
Mike Randall
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources (DEMLR)
Land Quality Section
Stormwater Permitting
1612 Mail Service Center
Raleigh, NC 27699-1612
Office: 19 9-807-6374
Cell: 919-389-7801
Email correspondence to and from this address may be subject to public records laws
From: Hartfield, Ross Evan [ma ilto:Ross. [e-mail]]
Sent: Tuesday, September 29, 2015 5:43 PM
To: Randall, Mike <[e-mail]>
Cc: Pickle, Ken <[e-mail]>
Subject: Allen Stormwater Outfall Issue
Mike,
We have encountered an issue with two of our stormwater outfalls at the Allen Steam Station and
are looking for ways to solve the problem. I spoke with Ken Pickle about this issue earlier today, and
he suggested I email you since I have not been able to reach you by phone.
We have two stormwater outfalls (SW011 and SWO12) that are also wastewater outfalls (NPDES004
and NPDES003 respectively). Allen's stormwater permit specifies in Table 2 that samples are to be
"collected at each stormwater discharge outfall (SDO) specified above". However, we notice that in
Section D of Part 3 the permit states "All samples shall be taken before the discharge joins or is
diluted by any other waste stream, body of water, or substance. Monitoring points as specified in

this permit shall not be changed without notification to and approval of the Permit Issuing
Authority'. This language seems a bit conflicting. Is it the intention of NCDEQ for us to sample at the
two outfalls, since the permit states to do so and the condition of the two outfalls were known at
the time of permitting? Or is the intent to sample before comingling? My conversation with Ken
indicates that the latter may be the case. We would like some clarity and assistance in resolving the
issue.
We will be investigating the piping of these two outfalls to determine the possibility of alternate
sampling locations. In the meantime, we would greatly appreciate any assistance you could provide
in helping to clarify this matter. Thank you, and please let me know if I can provide you with any
further information.
Ross E. Hartfield
Environmental Specialist 2 1 EHS CCP Compliance and Permitting
526 South Church Street I EC13K I Charlotte, NC 28202
Office: 980 373 6583
Cell: 225 2813971
Fax: [phone]
Ross. Hartfield(@duke-energy.com