NC0004979_Other Correspondence_20191009

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Ms. Julie Grzyb
Division of Water Resources
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Subject: Allen Steam Station
NPDES Permit NC0004979
Permit Change Request in accordance with re -opener clause
Dear Ms. Grzyb:
With respect to the 5th Circuit recently upholding the EPA's two-year delay of the
Effluent Limitations Guideline (ELG) dates, November 1, 2020 is the earliest date for
implementation of the more stringent ELG requirements for Flue Gas Desulfurization
(FGD) treated wastewater. With this ruling, in accordance with permit re -opener clause
found in condition A.(8) it is requested that effective date of February 28, 2020 for FGD
internal Outfall 005 for Plant Allen be changed to November 1, 2020 to align with 40
CFR Part 423.
In addition to the above request, Duke Energy Carolinas, LLC has recently surveyed tha
compliance boundary for the ash basin. Attached is a figure that depicts a slight
revision to this boundary. It is requested that this figure be accepted as the official
compliance boundary of the ash basin.
Sincerely,
Terry Tuck, General Manager V
Allen Steam Station
cc: Ori Tuvia
UPS Tracking: Raleigh: 1Z X67 601 24 9828 4247
Mooresville: 1Z X67 601 24 9527 9651