NC0001422_Draft Comments_20200616

DUKE
ENERGY®
PROGRESS
May 6, 2020
Via LISPS Certified Mail #7018 1130 0001 4419 9511 (2 copies)
Dr. Sergei Chernikov, Ph.D.
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Duke Energy Progress, LLC.
L. V. Sutton Energy Complex NPDES Permit NC0001422
NPDES Permit Modification Comments
Dear Dr. Chernikov:
L. V. Sutton Energy Complex
801 Sutton Steam Plant Rd
Wilmington, NC 28401
o 910.341.4750
f 910.341.4790
Duke Energy Progress, LLC (hereinafter Duke Energy) staff have reviewed the draft National
Pollutant Discharge Elimination System Permit for L.V. Sutton Energy Complex, issued for
public comment by the North Carolina Department of Environmental Quality on April 10, 2020.
We appreciate the efforts undertaken to modify this permit. Duke Energy respectfully submits
the following comments for consideration.
Comments:
Duke Energy requests the heading of Table A.(L) remove the language "removing the
free water above the settled ash layer that does not involve mechanical disturbance of the
ash" as ash excavation is compete in both the 1971 and 1984 ash basins. Duke also
requests the removal of language associated with former outfalls 002 and 004 since these
outfalls no longer exist and are removed from the permit.
2. The toxicity monitoring frequency in Table A.(1.) should be changed from "Monthly" to
"Quarterly" to align with condition A. (15.) CHRONIC TOXICITY LIMIT
(QUARTERLY) — OUTFALL 001 and our requests as part of the amendment application
dated January 21, 2020.
3. Duke Energy did not request modification to the toxicity testing scheduled months as part
of this amendment. Duke Energy requests that toxicity testing for Outfall 008 in Section
A.(5.) continue to be the months of February, May, August, and November as in the
current permit.
4. Since the frequency for toxicity testing has changed from "Monthly" to "Quarterly" for
outfall 001, Duke Energy request clarification in condition A.(15.) that toxicity testing for
Outfall 001 will be conducted during the months of February, May, August, and
November to align with our other toxicity testing requirements.

L. V. Sutton Electric Plant NPDES Permit NC0001422
NPDES Modification Comments
Thank you for your consideration of the above -requested items. If there are any questions, please
contact either:
• Ms. Lori Tollie, Environmental Specialist, at [phone] or email Lori. Tollie @ duke-
energy.com, or
• Mr. Kent Tyndall, Environmental Professional for the L. V. Sutton Energy Complex;
phone [phone] or e-mail Kent.Tyndall@duke-energy com.
Sincerely,
4t%j-
i n Talbott
Station Manager
to