NCS000580_Discussion on Outfalls Email_20201020

Gamble, Aana C
From: Tollie, Lori White <[e-mail]>
Sent: Tuesday, October 20, 2020 3:37 PM
To: Lucas, Annette; Gamble, Aana C; Georgoulias, Bethany; Langley, Shannon; Winston,
Cynthia C
Subject: [External] Duke Energy SW Discussion Revised Meeting Notes from 10/8/2020
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Annette, Aana, and Bethany,
Duke Energy is undertaking a tremendous amount of complex work activities to safety close the ash basins across NC.
Your input in how we manage stormwater is appreciated and will help guide our decisions going forward. I have
summarized the meeting notes from October Bch for your concurrence. Please let me know if you have any questions or
concerns. Thank you.
Flow source description
Type ISW permit action
DEQ's Position
needed
Non -industrial activity
None
Agreed
drainage re-route.
Industrial activity
None
Agreed
drainage routed to
existing permitted
outfall.
Industrial activity
Minor mod to add
Agreed
drainage routed to new
outfall if similar outfalls
permitted outfall
exist.
Industrial activity
NO ISW permit actions
Agreed
drainage routed to
needed. NPDES
existing NPDES
wastewater permit
wastewater outfall
mods may be necessary
if not covered.
We also discussed 4 assumptions that we wanted concurrence on:
1. Drainage from closed and capped landfill is not considered industrial activity as no waste is exposed and site is
vegetated. Haul roads carrying waste products or raw materials is considered industrial activity. DEQ agreed
provided that the landfill had a liner system. Annette agreed to do some more research on this to confirm that
having a liner was a determining factor in the classification of ISW vs. Non ISW
2. Modifications can only be made to unexpired permits. If permits are expired, full renewal with addition is
necessary. Agreed
3. Lining of SW basins in former upland ash basin fingers is not required if the area is clean closed in accordance
with DWM criteria. Lining decisions will be determined by the company and based on groundwater models.
1

DEQ also requested that we, by email, keep Annette and her staff, along with the regional DEMLR engineer
aware of these SW routing decisions. She recommended open and frequent communications to expedite any
permitting needs we may have and to make sure DEQ understands what we're doing.
4. Dry ponds will follow the same guidance as wet ponds concerning whether they are lined or not. Agreed.
Duke Energy
Permitting & Compliance
2500 Fairfax Road
Greensboro, NC 27407
Cell: [phone]
Office: [phone]