NCS000580_Public Comments for Mayo and Hyco_20161104

From:
Earl Hamil
To:
Randall. Mike
Subject:
Mayo and Hyco
Date:
Thursday, November 3, 2016 1:19:39 PM
From: Earl Hamil [mailto:[e-mail]]
Sent: Wednesday, November 2, 2016 8:22 PM
To: '[e-mail]'
Subject: Mayo and Hyco
I am extremely disappointed with the obvious disregard for any sense of proper
regulation/requirements in these permits. They need to be completely redrafted and
republished for another round of public comments.
Among the obvious observations/comments to be offered are:
■ The draft permits would allow the continued operation of unlined, leaking coal ash
ponds, despite documented contamination of streams and groundwater. DEQ should
require Duke Energy to remove its coal ash from these leaking, unlined pits. Duke
Energy has built a state of the art, fully lined coal ash landfill right across Highway 501
from the leaking coal ash basin where the ash could be moved.
■ The draft permits would allow Duke Energy to use streams as coal ash pollution ditches
by designating them as "effluent channels" as part of its private wastewater system, with
no water quality limits. This is completely irresponsible and in no way supports the
mission and purpose of DEQ.
■ At Roxboro, the new permit would allow Duke Energy to pump out all the wastewater
from its leaking, unlined coal ash lagoons into Hyco Lake, with insufficient monitoring
and no limits on toxic pollutants including arsenic, mercury, lead, thallium, and many
others.
■ The current Mayo permit prohibits pollution of Crutchfield Branch stream, which flows
to the Dan River — but the new proposed permit would allow Duke Energy to dump
unlimited amounts of arsenic, mercury, and many other pollutants into this important
tributary. In this day and age, why would DEQ consider RELAXING a requirement
already in place, creating pollution where none exists currently?
■ At Mayo, DEQ also proposes to allow Duke Energy to pump out most of the wastewater
from the coal ash pit into Mayo Lake, a popular fishing destination, with no limits on
toxic pollutants. This polluted wastewater could be emptied long before new federal
limits take effect in 2018. DEQ also would allow Duke Energy to pump out arsenic
from the most polluted wastewater at the bottom of the Mayo coal ash pit at 34 times the
current federal standard. Again, NOTHING from this plant is environmentally friendly
to the point it can be pumped untreated into the lake.
■ When a permit is issued, the emissions limits contained therein should be effective at
the onset of the permit. Why give Duke three - seven years to achieve limits? DEQ
proposes to give Duke Energy more than five additional years to comply with the new

federal limits on the discharge of arsenic, mercury, selenium, and nitrates from the
Roxboro plant and fails to establish any interim limits on the discharge of those
pollutants from either Roxboro or Mayo between now and when the federal limits are
put into effect. DEQ proposes to give Duke Energy two and a half years of additional
time before the company must stop discharging polluted coal ash transport water from
the Roxboro plant into Hyco Lake.
• Why permit a storm water drainage scheme that puts all the storm water thru the ash pit,
thus contaminating it, then release it? Proper storm water design should require
segregated storm water collection, with flow thru an oily water separator and into an
impoundment where it can be tested and then either released or treated and released.
The current proposed design invites the potential for high amounts of contaminated
water to be released into the lake.
■ Mayo and Hyco need to be held to the same stringent standards as others in the state
where ash is being removed. The ash from these plants is no less toxic and Duke is
certainly no more diligent at these plants than elsewhere.
■ The Clean Power Plan, in whatever shape it ultimately takes, will likely close both these
faculties. The fact that they use coal, are >35 years old, have very poor efficiency
compared to combined cycle gas are not in good state of repair meaning they are
uncompetitive in the power delivery market. The Commissions need to look long range
at what they want located here in 5-10 years. The Commission also needs to dismiss
any consideration in these permits related to preservation of jobs or tax base by trying
to "help" Duke - both are already lost. Timing is the only remaining question.
• The Duke assertion that these costs are costs of doing business is correct. What Duke
fails to mention is they have already been paid to take the necessary steps to keep their
wastes secure and out of the environment. They chose not to do so and squandered the
money they received from rate payers on other things. The cash to pay for this
remediation should be an after tax cost to Duke and its shareholders. They risked this
originally not the rate payers. By the way, Duke currently has $6billion in cash on
hand so it's not like they are struggling to afford this.
Looking forward to seeing the new drafts after the editing is complete.