NCS000573_Email RE Minor Mod Rationale_20180314

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Wednesday, March 14, 2018 5:03 PM
To: Lucas, Annette; Riddle, Rick L
Subject: Fw: [External] Belews Creek - Stormwater Outfall Request
Attachments: BCSS Request for Addition of Stormwater Outfalls.pdf
Friends,
I finally found it: the last time we discussed whether adding stormwater outfalls to these permits was a major
or minor modification was for this request for Belews Creek. See the rationale below.
The Riverbend outfall that was added to that permit was in a modification finalized in June 2016 (by
me). That's almost two years ago, so I definitely didn't have it in the front of my memory bank. The record is
in Laserfiche.
Let's discuss if the future request for Marshall will follow a similar path.
0
Bethany Georgoulias, Environmental Engineer
NCDEQ / DEMLR / Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh, NC 27604
919 / 807-6372 (phone); 919 / 807-6494 (fax)
Website: http://deg.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be disclosed to third parties.
From: Georgoulias, Bethany
Sent: Thursday, February 8, 2018 1:03 PM
To: Lucas, Annette
Cc: Alexander, Laura
Subject: FW: [External] Belews Creek - Stormwater Outfall Request
Annette,
This request came in directly to me because Rick and I met with Joyce about it and other outfall questions that
Duke staff had last year. It is a request to add outfalls to the Belews Creek Permit. We need some guidance to
process it.

1. Adding outfalls would not normally be a minor modification (no fee) as described in 40 CFR 122.63, but
I don't think it qualifies as a major modification —I think our stormwater situation is
different. Why? All our other stormwater permits don't specify outfalls (Duke permits are the
exception), and that means all our other permittees can add outfalls without any modification request
or fee; they simply revise their SPPP and sample accordingly. Also, this request involves two outfalls
from the same landfill area that already has an outfall in the permit (SW027 at Belews Creek). This
mod might be as simple as designating SW027 as representative and making minor text changes to
Part ll, p 10 in the permit, if the RO agrees. Do you agree that we should treat this as a minor
modification? Otherwise we have to advise the company to pay a fee and go through public notice.
2. Laura will need to enter this request into BIMS as a modification (even if it's a minor one) to Permit No.
NCS000573. Rick is assigned to Belews Creek Steam Station. Should she assign it to him, or should it
stay with me? Either way is fine with me; just let Laura know your decision.
Thanks,
Bg
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany.geor og uliaskncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
Email correspondence to and from this address is subject to the North Carolina Public Records
Law and may be disclosed to third parties.
From: Dishmon, Joyce Martin [mailto:[e-mail]]
Sent: Thursday, February 01, 2018 11:36 AM
To: Georgoulias, Bethany <[e-mail]>
Cc: Ogallo, LeToya Fields <[e-mail]>; White, Glen <[e-mail]>
Subject: [External] Belews Creek - Stormwater Outfall Request
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].
Bethany,
During our meeting in September we discussed sedimentation basins from a closed E&SC plan that collects
stormwater from the ditch line along Craig Road Landfill at Belews Creek Steam Station — permit
#NCS000573. The E&SC was permitted and installed during Phase 1 of Construction of Craig Road Landfill but
the plan was closed in 8/15. At the time of our meeting, the basins had not been maintained and we

discussed whether the US Corp of Engineers would identify them as jurisdictional. The US Corps of Engineers
have conducted a site evaluation and along with information provided concerning the E&SC design data the
USCOE decided that these structures would not be jurisdictional waters of the US.
The hard copy letter requesting that these basins be added to the current stormwater permit (NCS000573)
was sent to your attention on 1/31/18. 1 have attached an electronic copy of the letter for your file.
Thank you for your consideration. Please let me now if you have questions/comments.
oqo#ce Diihmon.
Sr. Environmental Specialist
ESH CCP Permitting & Compliance
Duke Energy
Office: [phone]
Cell: [phone]
[e-mail]
DUKE
' ENERGY,-