NC0005088_Modification Request_20200115

DUKE
ENERGY
January 15, 2020
Ms. Julie Grzyb
North Carolina Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Rogers Energy Complex
NPDES Permit NC0005088
Permit Modification Request
Dear Ms. Grzyb:
Rogers Energy Complex
573 Duke Power Roao
Mooresboro, NC 28114
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By this letter, Duke Energy Carolinas, LLC requests a modification of NPDES Permit
NC0005088 to extend the deadline by which Rogers Energy Complex must comply with
new effluent limits for flue gas desulfurization (FGD) wastewater. This request was
previously discussed with Mr. Jeff Poupart in a meeting on December 18, 2019.
EPA's existing rule regarding Steam Electric Power Generating ELGs allows the
Department to set a compliance date within a range of acceptable dates. Previously,
Duke Energy requested a compliance date of December 31, 2023 for FGD wastewaters
at the subject facility in order to allow an appropriate planning, construction, and
implementation window. Based on the information available at the time, the Department
instead gave the facility until December 31, 2021 to comply. Since then, EPA has
proposed significant changes to the ELG's. Among the changes is a condition that coal
fired units that are retired by a certain date will be exempt from meeting the stringent
Technology Based Effluent Limits (TBEL's) for FGD wastewaters. These rules are
expected to be finalized this summer.
It now appears the ELGs will provide several alternatives for facilities that are retired by
a certain date. Given this new information in the record, Duke requests modification of
the compliance date for FGD ELG's to the December 31, 2023 as allowed by the
currently codified rules. This will allow the company to evaluate the retirement dates
and treatment needs for the facility in light of the alternatives presented in the new
version of the rule. In accordance with its RPA evaluation, the Department has
determined there are no water quality -based effluent limits required at the site for
constituents associated with FGD wastewater in order to assure the receiving water
meets applicable criteria.
A check in the amount of $1,030 is attached for evaluation of this request.

Ms. Julie Grzyb
North Carolina Department of Environmental Quality
Division of Water Resources
January 15, 2020
If you have questions, please contact Robert Wylie at [phone] or
[e-mail].
Sincerely,
� f.I
Dave Barnhardt, General Manager II
Rogers Energy Complex
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cc: Landon Davidson Nsps 7u�-7 's 3 0 or o %/
Asheville DWR regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778-8211
Robert Wylie — EC13
Steve Hodges
Shannon Langley — NC15
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