NCS000580_Hearing Officers Report_20170127

North Carolina Department of Environmental Quality
January 27, 2017
Memorandum
To: Tracy Davis
Director, Division of Energy, Mineral and Land Resources
From: John Hennessy Original Signed by John Hennessy
Supervisor, Compliance and Expedited Permitting Unit, Division of Water Resources
Subject: NPDES Stormwater Permit Hearing - Duke Energy Progress, LLC. Power Facilities
Hearing Officer's Report and Recommendations
On October 4, 2016 1 served as Hearing Officer for a public hearing on the proposed issuance of NPDES discharge
permits for two Duke Energy Progress, LLC power plant facilities. The public hearing considered two draft permits at
each of the facilities. At each facility a draft permit was considered for wastewater discharges and for stormwater
discharges. My main focus in this report is considerations for the finalization of the NPDES stormwater discharge permits
at the two facilities. The permits considered are outlined in the table below.
Mayo Steam Electric Plant - NCS000580: This facility is located at 10660 Boston Road in Roxboro, NC -
Person County. The facility discharges stormwater to Mayo Lake in the Roanoke River Basin.
Roxboro Steam Electric Plant - NCS000581: The facility is located at 1700 Dunnaway Road, in
Roxboro, NC - Person County. The facility discharges stormwater to Hyco Lake in the Roanoke River
Basin.
The hearing was held in Roxboro, NC at the Person County Government Building on October 4, 2016. Around 93 people
attended the hearing, not counting Department staff. Twenty-three people spoke at the hearing and provided comments
on the two permits being considered. These comments were mainly focused on the requirements of the wastewater
permits or on the general issues for coal ash closure. The public comment period on the proposed permits was open until
November 4, 2016. During the comment time period the Division received three comment documents related specifically
to the two stormwater permits. Two of these were from the permittee - Duke Energy Progress, LLC. and covered their
comments on specific permit language for each of the facilities.
Background
The permit fact sheets for the permits outline in more detail the basis for permit coverage and permit requirements for
these facilities. These facilities are coal fired steam electric power generating facilities. This industry sector is required to
have NPDES permit coverage for stormwater point sources discharges from the industrial activities at their facilities. The
permit documents and the information presented at the hearing noted 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 system.
Those drainage areas are covered in separate wastewater NPDES permits. For the areas covered by these stormwater
permits, the major provisions of the permit are requirements for a Stormwater Pollution Prevention Plan (SWPPP) for the
facilities along with monitoring (visual and quantitative) and inspection requirements. These provisions provide
comprehensive coverage through the implementation and 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

Hearing Officer's Report
October 4 Public Hearing
Mayo and Roxboro Electric Plants
As indicated above, there was only one specific public comment received that addressed the two Stormwater NPDES
Permits. This comment document was for the Mayo facility. There were other general comments that requested that
none of the stormwater or wastewater permits be issued, but these comments did not contain any specific references
related to changes to the proposed stormwater permits or specific reasons for not issuing stormwater permit coverage.
During the comment period we also received comment letters on each facility's stormwater permit from the permitee -
Duke Energy Carolinas, LLC.
Staff in the Stormwater Permitting Program have reviewed the comments received and I have met with staff to review the
comments and the Division's responses to these concerns. Based on these discussions I 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 response to these
comments. The discussion below summarizes the major issues specifically related to the stormwater permits.
General Comment — a number of comments received included general comments to request that the stormwater
and wastewater permits not be issued. However, these comments did not include any specific references to
concerns related to the stormwater permits. The specific references in these comments were targeted toward
concerns with the wastewater components of the facilities — seeps, ash basins, wastewater discharges, etc.
These issues are all addressed in the wastewater permits. The stormwater permits only cover relatively small
drainage areas at the two facilities and these drainage areas are outside of the area of the plant yard, coal
storage areas, ash ponds and the industrial intensive activities on the sites.
• One commenter at the public hearing questioned why stormwater was routed to the ash basins and commented
that the stormwater should be rerouted away from the basins. We understand the concerns about the volume of
runoff that may be added due to stormwater runoff. However, these drainage areas are routed to the basins
because these areas contain locations where coal or coal ash may be stored and utilized on the site. Runoff from
these areas is captured and routed to the basins to allow for treatment of these waste streams in keeping with
effluent guidelines established in state and federal wastewater treatment requirements prior to discharge.
• The one public comment letter was related to the draft Mayo stormwater permit and noted the following issues:
o Pointed out an inaccurate reference in the draft permit to the Catawba River Basin and questioned the
review since the wrong basin was sited. This one reference was in a footnote in the draft permit and
points to a requirement in the facility's wastewater NPDES permit for a fish tissue report and requests that
this report also be forwarded to the Stormwater program. This requirement is one that is found in all the
stormwater permits where similar reports are required by the wastewater permit. It is unfortunate that this
reference was inaccurate in the draft, but is understandable that this occurred since this component is
carried over in all of the stormwater permits. We appreciate this reference being pointed out and have
made the corrections in the final permit.
o Requested that lake and sediment samples be taken near the stormwater outfalls as a benchmark for
deposits into the lake. The Mayo facility has only one stormwater outfall regulated in the final permit.
That outfall drains an area around the facility's entry roadway. The permit requires analytical monitoring
of a number of parameters that will provide information on potential pollutants that may be discharged. In
addition, there are qualitative monitoring requirements that will evaluate the outfall location and determine
if any sediment issues may be of concern at the outfall location. Given these requirements and the
pollution prevention components of the permit, no additional monitoring has been added to the final
permit.
o Requested that stormwater be captured, contained and tested prior to discharge. As indicated previously,
the stormwater permit is only for one outfall location draining an access road and surrounding areas. The
major industrial areas of the facility are captured and treated as part of the wastewater treatment system
and discharged under set discharge limits in the wastewater NPDES permit.
o Requested that the coal ash basin and storage areas and similar areas be enclosed to not allow
stormwater to enter these areas. As noted above, these industrial areas are routed to the wastewater
treatment system (ash pond) and considered when effluent limits are set. This is consistent with federal
requirements for handling these areas as wastewater components with effluent guidelines.
Page 2

Hearing Officer's Report
October 4 Public Hearing
Mayo and Roxboro Electric Plants
o Other comments seemed to center on the impacts of unlined, uncapped and unenclosed lagoons. These
comments noted the impacts from previous failures and the need to handle waste streams in a different
manner. We understand that these areas are concerns to those in the area of these facilities and note
that the Department has various programs that will be looking at these issues. The permit under
consideration here regulates stormwater discharges only and does not authorize or control any
wastewater or groundwater issues. Reviews of those issues continue to be ongoing within the
Department.
• The permitte, Duke Energy Progress, LLC, submitted comment letters for each of the proposed stormwater
permits. Issues related in these letters are summarized here:
o Requested that permit reference Duke Energy Progress, LLC rather than Duke Energy Progress, Inc.
This change has been made in the final permits.
o Requested that the monitoring dates in the permit tables be updated to reflect the effective date of the
permit. Since the permits are issued for a five year cycle, the dates have been modified to be in line with
the final effective date of the permits.
o Noted incorrect reference to the Catawba River Basin. As noted above, these changes have been made
in the final permits.
o In the Roxboro letter requested that certain monitoring parameters be removed for the two outfalls
because the drainage areas do not contain electrical equipment or oil storage. Based on information
contained in the permit application describing potential pollutants in the drainage basins, results of
submitted monitoring data and consistency with previously issued permits and potential parameters of
concern we have maintained most of the parameters in the final permits. The final version has removed
PCB monitoring since there does not appear to be past exposure to equipment or storage that would lead
to this parameter being included.
o In the Mayo letter, noted that outfalls 004, 005, 006c, 006d and 006e have been included in the
wastewater NPDES permit due to potential non-stormwater flows. Because these outfalls will be covered
as wastewater discharges they have been removed from the final stormwater permit.
o In the Mayo letter, noted that outfall 006b does not have a point source discharge. Without a point
source, the area is not covered by the federal NPDES stormwater requirements. This outfall has been
removed from the final permit.
o In the Mayo letter, requested that copper monitoring be modified or removed because copper is a
commonly occurring ore mineral in the area. DEQ acknowledges that background soil containing metals
may influence discharge values enough to exceed established benchmark values for metals like copper,
zinc, and possibly others that are equally ubiquitous. The Tier Responses in the permit allow DEQ
flexibility to relieve monthly monitoring if the permittee demonstrates circumstances are appropriate
(discharge levels reflect natural background or background influences beyond the permittee's control, for
example) and/or all reasonable stormwater pollution prevention measures have been attempted but
cannot bring levels down. In these instances, DEQ must also consider whether there are water quality
problems in the receiving waters resulting from these metals before making a decision on whether to
grant the permittee's request for reduced monitoring or to require additional efforts to reduce
concentrations. The permit already provides flexibility for the permitee to work with our staff on
monitoring adjustments as additional information is gathered during permit implementation.
Based on my review of the information associated with these permits, public comments received and my discussions with
Stormwater staff I recommend that the Director move forward to issue the final permits with the minor modification that
have been included. Final permits are attached to this package for your signature.
If you have any questions, please contact me to discuss.
In addition to the information contained above I would also like to provide some recommendations based on the
comments received during this process as well as comments and discussions from the public process for previous Duke
facility stormwater permits. A number of comments seemed to be concerned with ensuring oversight of the permit
Page 3

Hearing Officer's Report
October 4 Public Hearing
Mayo and Roxboro Electric Plants
conditions at the facility. Staff in the DEMLR regional office focus on the proper implementation of permits on a daily
basis. To assist in ensuring that these efforts are handled effectively I recommend:
1. With the issuance of this permit the Raleigh Regional Office should contact the facility to ensure that the facility
contacts are aware of the DEMLR stormwater contacts in the regional office so both parties can readily
communicate if they have questions. They should also assure that the facility makes the regional office aware in
advance of planned movement of any ash material on the site in the future or on any changes at the facility. This
contact should be designed to allow the regional office to schedule an onsite visit early on in this process to
review the procedures utilized and evaluate any potential stormwater issues in the process.
2. DEMLR has multiple programs that may be involved with activities on the facility site — Stormwater, Erosion and
Sedimentation Control and Dam Safety. The Division should ensure that as regional staff are on site for site visits
or inspections associated with any of these program areas they should also be aware of the conditions related to
other programs and be ready to assess potential issues and make appropriate programs aware of any concerns.
DEMLR staff should also be sure to provide similar information in coordination with other Divisions as well.
Page 4

Hearing Officer's Report
October 4 Public Hearing
Mayo and Roxboro Electric Plants
ATTACHMENTS
A. Announcement of Public Hearing
B. Hearing Information — Stormwater Presentation
C. Comments Received on Stormwater Permits
Page 5

Attachment A: Announcement of Public Hearing

PUBLIC NOTICE
N.C. DEPARTMENT OF ENVIRONMENTAL QUALITY INTENT TO ISSUE NPDES
STORMWATER DISCHARGE PERMITS #NCS000580 AND #NCS000581
Public comment or objection to the draft permits is invited. All comments received by Nov. 4, 2016 will
be considered in the final determination regarding permit issuance and permit provisions.
PERMIT APPLICATIONS
Duke Energy Carolinas, LLC has applied for NPDES permits to discharge stormwater from each of the
following power plants:
• Mayo Steam Electric Generating Plant, 10660 Boston Rd., Roxboro, N.C., Person County. The
facility discharges to Mayo Reservoir in the Roanoke River basin.
• Roxboro Steam Electric Generating Station, 1700 Dunnaway Rd., Semora, N.C., Person County.
The facility discharges to Hyco Reservoir in the Roanoke River basin.
The draft stormwater permits and related documents are available online at: http://deq.ncov/news/hot-
topics/coal-ash-nc/npdes-permits. Printed copies of the draft permits and related documents may be
reviewed at the department's Raleigh Regional Office. To make an appointment to review the
documents, please call 919-791-4200.
Public comment on the draft permits should be mailed to: Stormwater Permitting, Attn: Mike Randall,
1612 Mail Service Center, Raleigh, N.C., 27699-1612. Public comments may also be submitted by email
to: mike.randallgricderingov. Please be sure to include "Mayo" or "Roxboro" in the email's subject
line.
PUBLIC HEARING
The N.C. Department of Environmental Quality will hold a public hearing to accept comments on the
aforementioned draft permits, as well as the two facilities' draft NPDES wastewater permits, at 6 p.m.
Tuesday, Oct. 4 at the Person County Government Building. The Government Building is located at 304
S. Morgan St., Roxboro, N.C. Speaker registration begins at 5 p.m.

Attachment B: Hearing Information — Stormwater Presentation

12/5/2016
■
■
NPDES Stormwater Permitting Public Hearing
Duke Energy Progress, Inc. —Mayo and Roxboro Steam Electric Plant
Pusan County Government Building
W,ber 4, 2016
Department of Environmental Quality
NORTH CAROLINA
NPDES Stormwater PermM���
• 40 CFR 122.26 — Permits for Industrial Activities
-Ten Categories of Industrial Activities are regulated
— includes Steam Electric Power Generation Facilities
• Some Areas are Excluded from Coverage
— areas without exposed materials or industrial activity
— areas with no point source discharge
— areas draining to wastewater treatment
• Plant Areas — most drain to wastewater treatment
Department of Environmental Quality
Stormwater Permitting Requireme
• Stormwater Pollution Prevention Plan
• Monitoring of Outfalls
— Quantitative
— Qualitative
• Site, BMP and Outfall Inspections
• Adjustment of Management Plans
ILM
Department of Environmental Quality nif

12/5/2016
Pollution Prevention Plan
• Written Management Plan for Each Site
• Site Plan drawing
• Pollution Prevention / Good Housekeeping
• Implementation of Management Practices
• Certification of non-stormwater discharge
• Employee Training
• Regular Review and Update
ILM
Department of Environmental Quality 1140
r-s—tormwater Monitoring
• Visual and Analytical Monitoring
• Conventional Pollutants, Metals, etc.
• Monitoring to Guide Management Efforts
•Tiered Response to Benchmark Values
• Benchmark Values are not Limits — but do lead
to required responses
ILM
Department of Environmental Quality
Inspections and Plan
• Outfall, Facility and Management Measure Inspections
•Semi-annual and Response to Monitoring Results
• Document Findings and Actions
• Review Plan Annually and with Site Changes
ILM
Department of Environmental Quality nif
2

Attachment C: Comments Received on Stormwater Permits

Bennett, Bradley
From: Randall, Mike
Sent: Wednesday, November 02, 2016 7:43 AM
To: Bennett, Bradley; Munger, Bridget
Subject: FW: Comments on Duke Energy Storm Water Discharge at the Mayo Lake Plant Permit
From: Ken Bailey [mailto:[e-mail]]
Sent: Tuesday, November 01, 2016 3:45 PM
To: Randall, Mike <[e-mail]>
Cc: Ken Bailey <[e-mail]>
Subject: Comments on Duke Energy Storm Water Discharge at the Mayo Lake Plant Permit
Dear Mr. Randall,
My Name is Kenneth W. Bailey. I live on Mayo Lake at 179 Snug Harbor, in Roxboro and my phone
number is [phone].
I have the following comments regarding the subject permit.
1. The draft permit references the Catawba River Basin. Lake Mayo is in the Roanoke River Basin,
not the Catawba. The fact that you didn't cite the correct river basin indicts the credibility of the entire
draft permit. If you can't get the geographic location right, how can you be trusted to get the science
right? The Roanoke River Basin which also provides drinking water for the City of Virginia
Beach. How would those citizens feel knowing Duke is being allowed to discharge pollutants into
they're drinking water? The Roanoke River basin begins in the Blue Ridge Mountains of Virginia and
ends in the Albemarle Sound of North Carolina. The basin covers nearly 10,000 square miles with
3,500 falling within North Carolina, making it the sixth -largest of the state's 17 river basins. The basin
encompasses 126 HUs that range in size from less than one to 113 square miles. There are five CUs
(eight -digit watershed delineations) in the basin with the major rivers including the Dan,
Smith, Mayo and Roanoke. Large reservoirs in the basin include Hyco, Mayo, Kerr Lake and Lake
Gaston. Cities and towns inside or bordered by the basin include Eden, Reidsville, Walnut Cove,
Mayodan, Wentworth, Yanceyville, Roxboro, Henderson, Roanoke Rapids, Williamston, Windsor and
Plymouth. The mistake citing the Catawba rather than the Roanoke River Basin would indicate you
merely cut and pasted this draft from a permit for the Catawba. It's nothing less than astounding
that you would use a Catawba permit as your template for this draft when one source cites the
Catawba as a national poster child for the problems with unlined coal ash impoundments. Unlined coal ash
impoundments threaten the Catawba River through three primary routes of exposure: 1) catastrophic release,
such as the recent event in Tennessee, 2) daily untreated discharges from the coal ash ponds, and 3) seepage of
contaminants from coal ash into the groundwater. This proposed permit would allow the same degradation on
Lake Mayo that has been inflicted on the more than 800,000 people who rely on the Catawba for their drinking
water as well as other uses, such as recreation. All of the residents on Mayo Lake and the surrounding area get
their drinking water from wells.
2. Like all who attended the public meeting in Roxboro on October 4th, I am greatly concerned by the
pollution that Duke Energy is adding to Mayo Lake and to the ground water. I don't trust Duke to do

the right thing when it comes to protecting the environment by making "business" decisions over
pollution prevention.
3. 1 strongly suggest that test samples be taken of the lake water and sediment near the existing
storm water outfalls and held as a bench mark for any storm water or other deposits into the lake.
4. The permit identifies different tiers of testing stormwater at the outfalls but by time the test results
are completed the polluted storm water has entered the lake. I don't agree with this method. Storm
water from the site should be captured, contained and tested "PRIOR" to allowing it to drain into the
lake. Why are large commercial activities allowed to dump pollutants into the lake when private
residents are not and should not be? Their pollution quantities are thousands of times what private
residents would generate.
5. A better solution would be to fully enclose the coal ash pit and coal storage area and other similar
areas to contain hazardous waste and prevent storm water from entering these areas in the first
place. Yes that would be very expensive but how can you put a price on our fresh water
resources? Additionally, this would also serve to protect the ground water by not allowing polluted
storm water from being absorbed into the soil and the generated dust from entering the atmosphere.
6. An example of what coal ash can do is what happened in Kingston, Tenessee. On Dec. 22, 2008,
when a dike failed at TVA's Kingston Fossil Plant, 5.4 million cubic yards of coal ash cascaded into
the Emory and Clinch rivers and smothered about 300 acres of land. The breach released a slow -
moving wave of toxic sludge and polluted water into the river in what remains the nation's largest
coal -ash spill in history. It snapped trees as if they were twigs and knocked homes off
their foundations. It destroyed houses and damaged dozens of others. To clean up the spill and
restore the area, TVA has spent $1 billion and is on pace to spend $200 million more by the time the
project finishes in 2015. There are hundreds of coal -ash impoundments across the nation, and the
EPA has found dozens that it believes are leaking. In the wake of the 2008 spill, some utilities,
including TVA, vowed to convert to dry ash storage, a far safer way to handle the material. The point
here is that to clean up a toxic mess is much more expensive than do it right the in the first place.
Two utilities in South Carolina, for instance, are voluntarily removing coal ash from storage sites near
waterways. North Carolina has sued a major power provider over pollutants leaking from coal -
ash storage ponds.
7. What really concerns me, is what have they been doing up until this point? They should be given
a cease and desist order on allowing storm water to enter the lake until the pollution problem is
addressed and a plan for prevention implemented.
8. Finally, coal ash is a well documented problem. If Duke is not held accountable, then citizens will
be left footing the bill. For generations to come, the coal ash from these unlined, uncapped and
unenclosed lagoons will continue to leach toxic metals into the drinking water and the lake. Citizens
will be responsible for paying for drinking water treatment, healthcare bills and lost recreation and tax
bills should a cleanup be necessary while Duke gets a slap on the wrist fine, which no where near
pays for the damage caused. Most disturbing is the lack of integrity, honesty and forthcoming-ness
exhibited by Duke on numerous other sites throughout the state and the country regarding the
seepage and unpermitted discharges. In a 2009 NPDES permit application, Duke failed to disclose
multiple point discharges where millions of gallons per day of water was being illegally
discharged. Reference the issue with Riverbend on the Catawba River Basin. Millions of dollars in
fines are coming out of some of those but it's trying to close the door after the damage is done. How
many such incidents will happen before power companies are held accountable by regulators who
are supposed to be protecting resources?
4

fnDUKE
ENERGY,
October 31, 2016
Mike Randall
Stormwater Permitting Program
Division of Energy, Minerals and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: Comments on the DRAFT NPDES Permit for Mayo Steam Electric Plant
Permit No.: NCS000580
Person County
Dear Mr. Randall:
Harry K. Slderis
Senior We Presideni
Environmental, Health & Safety
526 S. Church Steel
Mail Code: EC3XF
Charlotte, hfC2a202
(AW) 3a24M
Duke Energy Progress, LLC (Duke Energy) submits the following comments on the subject draft National
Pollutant Discharge Elimination System Permit for stormwater discharges at the Mayo Steam Electric
Plant. Duke Energy offers the following comments and requests for modification and/or clarification on
specific provisions of the Draft Permit:
1. On the cover page, the permit indicates the permit is issued to "Duke Energy Progress, Inc."
Please change this to "Duke Energy Progress, LLC."
2. As discussed on your visit to the site on September 8, 2016, please remove outfalls 004, 005,
006c, 006d and 006e. These outfalls are being included in the NPDES wastewater permit
because of potential for flows not associated with stormwater.
3. As discussed and confirmed during your visit on September 8, 2016, please remove coverage for
outfall 006b. The discharge from the Outfall 006b feeds a heavily vegetated area without a
defined point source and is approximately 750 feet from Mayo Reservoir.
4. Duke Energy requests that the dates in Table 2 be updated to be reflective of the effective date
of the permit and that the permit be issued for a period of five years.
5. Duke Energy requests the benchmark value for copper be modified or removed in this permit.
Duke request that copper monitoring only be required with no associated benchmark due to the
fact that Copper is a commonly occurring ore mineral in the bedrock of northeastern Person
County in the area around Mayo Lake. The association of copper production with gold mining
activity in the central northern Piedmont of North Carolina (known as the Virgilina Gold District),
near the state line, is well documented with published documentation as early as 1917. In
addition, several small mines were opened in the area in the late &h and early 20`h centuries
for the sole purpose of mining copper, including at least two copper mines only a mile or two
east of Mayo Lake in Person County. In the rocks of the area, copper -bearing minerals (including

P u f' 12
chalcopyrite, chalcocite, cuprite, and malachite] commonly occur throughout the shear zones
and fracture zones of the bedrock. In particular, copper mineralization in the area occurs both
along quartz/quartzite stringers or veins and, more dominantly, within the bedding planes and
texture of the parent bedrock itself (schist is the dominant rock type in this area).
6. On page 11 of 15, references to the "Catawba River" and "Mountain Island Lake" should be
changed to Mayo Reservoir.
7. Duke Energy requests that the sampling dates in Table 5 be changed to align with the permits
issuance date.
Duke Energy welcomes any further discussion on our comments or the Draft Permit. If you have any
questions, please contact Shannon Langley at 919.546.2439 or at [e-mail]_
Sincerely,
t�
Harry K. Sideris
Senior Vice President Environment, Health & Safety
Duke Energy
cc: Mr. John Hennessey —Mayo Public Hearing officer
1617 Mail Service Center
Raleigh, NC 27699-1617

page 13
Bc: Tom Copolo- Mayo Station Manager
Jim Wells, VP — Duke EHS CCP (via email)
Richard E. Baker Jr., P.E., P.M.P — Director, Env. Programs - EC13 (via email)
Bert Lea — Environmental Coordinator, Mayo Plant
Shannon Langley - NCRH 15

DUKE
ENERGY.
October 31, 2016
Mike Randall
Stormwater Permitting Program
Division of Energy, Minerals and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: Comments on the DRAFT NPDES Permit for Roxboro Steam Electric Plant
Permit No.: NCS000581
Person County
Dear Mr. Randall:
Harry K. Sideris
Senior Vice Preslden!
Environmental, Health & Safety
526 S. Church Street
Mall Code: EC3XF
Charlotte, NC 28202
[phone]
Duke Energy Progress, LLC (Duke Energy) submits the following comments on the subject draft National
Pollutant Discharge Elimination System Permit for stormwater discharges at the Roxboro Steam Electric
Plant. Duke Energy offers the following comments and requests for modification and/or clarification on
specific provisions of the Draft Permit:
1. On the cover page, the permit indicates the permit is issued to "Duke Energy Progress, Inc."
Please change this to "Duke Energy Progress, LLC."
Z. As discussed on your visit to the site on September 8, 2016, because of the drainage areas
associated with these two outfalls, Duke Energy requests removal of sampling requirements for
PCBs, Copper, Selenium, Mercury and Zinc. The drainage areas areas do not contain electrical
equipment or oil storage.
3. Duke Energy requests that the dates in Table 2 and Table 5 be updated to be reflective of the
effective date of the permit and that the permit be issued for a period of five years.
4, On Part II page 11 of 15, references to the "Catawba River" and "Mountain Island Lake" should
be changed to Hyco Reservoir.
Duke Energy welcomes any further discussion on our comments or the Draft Permit. If you have any
questions, please contact Shannon Langley at 919.546.2439 or at [e-mail].
Sinc ly
�F
Warty K. As
Duke Energy
Senior Vice President Environment, Health & Safety

Page 12
cc: Mr. John Hennessey —Roxboro Public Hearing officer
1617 Mail Service Center
Raleigh, NC 27699-1617

Page - 13
Bc: William I Thacker- Roxboro Station Manager
Jim Wells, VP — puke EHS CCP (via email)
Richard E. Baker Jr., P.E., P.M.P — Director, Env. Programs - EC13 (via email)
Robert Howard — Environmental Coordinator, Roxboro Plant
Shannon Langley - NCRH 15