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HomeMy WebLinkAboutNCS000548_Email RE Response to Comments on Draft Permit_20210212Gamble, Aana C From: Gamble, Aana C Sent: Friday, February 12, 2021 2:54 PM To: Wylie, Robert R Cc: Lucas, Annette; Farkas, Jim J Subject: RE: [External] Draft Permit for Your Review Attachments: NCS000548_Draft Perm it_20210212.pdf Good afternoon Robert, I hope you're doing well! I have included your original comments below, with the Division's responses in blue. I have also attached an updated copy of the draft permit. We hope to have this permit out to public notice by the end of next week. Marshall Steam Station has implemented several measures during the current Industrial Storm Water permit to minimize the discharge of pollutants associated with industrial activities. Approximately 7 outfalls have been eliminated and many BMP have been installed. In the draft permit it changes the monitoring frequency to quarterly from semi-annual. My understanding is that this change was incorporated to capture all calendar seasons. However, for a S year period to increase the frequency by 100% Duke Energy does not see much value gained in comparison to time and cost with this increase. It is requested that the permit include a provision for the quarterly monitoring to only be implemented for one year and then begin semi-annual monitoring in the second year. If an outfall does go into Tier status, if issue is not corrected, then that outfall will be on a monthly sampling frequency if Tier Two status is reached. All of the NPDES General and Individual Industrial Stormwater Permits across the state are moving from semi-annual sampling to quarterly sampling, both to capture all calendar seasons, and also to make North Carolina's requirements consistent with the stringency of stormwater permits in other states in EPA Region 4. This is not specific to Marshall Steam Station or other Duke facilities. Please note that the language in Part D-3 has also been updated to clarify permit requirements regarding sampling and recording "no discharge" during sampling periods. These are not new requirements, but a clarification of NPDES industrial stormwater permit requirements. This language will be updated in all individual and general industrial stormwater permits going forward. Part D-1 (b) is requested to be deleted or clarified. Marshall Steam Station has many oil containing components. However, these components are within the station and if a spill occur it is captured and cleaned up on - site. The clean-up typically occurs within the stations plant drain system or if it leaves the station it would be captured and cleaned up in the wastewater treatment system. There is so much of an effort involved in tracking all on -site oil usage with no value from a discharge monitoring gained. Is the intent of this requirement to capture oil usage for only areas that drain to a Storm Water outfall? This item can be deleted, since oil and grease sampling is captured in the specific monitoring requirements in the permit. Part D-3 e — states that sampling is not required to be performed outside the facility's normal business operating hours. This is interpreted that sampling is only required to be conducted Monday through Friday during day light hours and not required on weekends and/or holidays. Duke's interpretation of D-3(e) is consistent with the requirements of the permit. When this permit goes into effect it is Duke Energy's understanding that all monitoring resets to the renewed permit schedule. If an outfall is in Tier status prior to the effective date Duke Energy will continue with implementation of BMPs but the monitoring frequency is reset to quarterly monitoring and the outfall is no longer in a Tier status. The above statement is not consistent with the requirements of the permit. While the count of exceedances towards Tier 2 or Tier 3 does reset with the new permit cycle, the issuance of a renewed permit does not end the monthly monitoring/other tier requirements. These must be ended through the provisions of the permit or through consultation with the Regional Office. Language has been added to D-1(d): "If the facility was in Tier Two or Tier Three status under the previous permit, the facility shall continue monthly monitoring and reporting requirements until relieved by the provisions of this permit or the Division." Language has been added to D-5, D-6, and D-7 to specify how Tier status ends (other than consultation with the Regional Office): "The facility will remain in Tier One/Two/Three status until three consecutive samples are under the benchmark or are inside the benchmark range for all parameters." The above language that was added to this permit will be added to the individual permit template, so that these items can be captured in other individual stormwater permits going forward. Please let me know if you should have any additional questions. Have a great weekend! Aana Gamble Environmental Specialist II, Dam Safety Division of Energy, Mineral and Land Resources North Carolina Department of Environmental Quality Phone: (919) 707-9151 Email: aana.gamble@ncdenr.gov Physical Address: 512 North Salisbury Street Mailing Address: 1612 Mail Service Center Raleigh, NC 27699-1612 EiZZA. � u.v.�n.nsa nisi au�u�r Email correspondence to and from this address is subjected to the North Carolina Public Records Law and may be disclosed to third parties. From: Wylie, Robert R [mailto:Robert.Wylie@duke-energy.com] Sent: Thursday, February 4, 2021 1:48 PM To: Gamble, Aana C <Aana.Gamble@ncdenr.gov> Subject: [External] Draft Permit for Your Review CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Aana, Duke Energy has reviewed the attached draft Industrial Storm Water Permit for Marshall Steam Station and offers the following comments: Marshall Steam Station has implemented several measures during the current Industrial Storm Water permit to minimize the discharge of pollutants associated with industrial activities. Approximately 7 outfalls have been eliminated and many BMP have been installed. In the draft permit it changes the monitoring frequency to quarterly from semi- annual. My understanding is that this change was incorporated to capture all calendar seasons. However, for a 5 year period to increase the frequency by 100% Duke Energy does not see much value gained in comparison to time and cost with this increase. It is requested that the permit include a provision for the quarterly monitoring to only be implemented for one year and then begin semi-annual monitoring in the second year. If an outfall does go into Tier status, if issue is not corrected, then that outfall will be on a monthly sampling frequency if Tier Two status is reached. Part D-1 (b) is requested to be deleted or clarified. Marshall Steam Station has many oil containing components. However, these components are within the station and if a spill occur it is captured and cleaned up on - site. The clean-up typically occurs within the stations plant drain system or if it leaves the station it would be captured and cleaned up in the wastewater treatment system. There is so much of an effort involved in tracking all on -site oil usage with no value from a discharge monitoring gained. Is the intent of this requirement to capture oil usage for only areas that drain to a Storm Water outfall? Part D-3 e — states that sampling is not required to be performed outside the facility's normal business operating hours. This is interpreted that sampling is only required to be conducted Monday through Friday during day light hours and not required on weekends and/or holidays. When this permit goes into effect it is Duke Energy's understanding that all monitoring resets to the renewed permit schedule. If an outfall is in Tier status prior to the effective date Duke Energy will continue with implementation of BMPs but the monitoring frequency is reset to quarterly monitoring and the outfall is no longer in a Tier status. Thanks for allowing the review of this permit. If you have any questions please let me know. Thanks, Robert Wylie Duke Energy Corporation Permitting and Compliance, Carolinas 704 562-8258 (cell) Robert.Wvlie@duke-energy.com From: Gamble, Aana C <Aana.Gamble@ncdenr.gov> Sent: Tuesday, January 12, 2021 12:11 PM To: Wylie, Robert R <Robert.Wvlie@duke-energy.com> Cc: Lucas, Annette <annette.lucas@ncdenr.gov>; Moore, James <james.moore@ncdenr.gov> Subject: [EXTERNAL] Draft Permit for Your Review Good afternoon Robert, I have attached a copy of the draft NPDES Individual Industrial Stormwater Permit for the Duke Energy Carolinas LLC - Marshall Steam Station facility (NCS000548), as well as a cover letter for that permit. Please let us know if you have any questions. Thank youl Aana Gamble Environmental Specialist II Division of Energy, Mineral and Land Resources North Carolina Department of Environmental Quality Phone: (919) 707-3648 Email: aana.gamble@ncdenr.gov Physical Address: 512 North Salisbury Street Mailing Address: 1612 Mail Service Center Raleigh, NC 27699-1612 D7 E ,T t-src:t.wx c ui Q�:, Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.