Allen Steam Facility (7)

Georgoulias, Bethany
From: Mc Gary, Mark E [Mark McGary@duke-energy com]
Sent: Friday, November 18, 2011 9 30 AM
To: Georgoulias, Bethany
Cc: Velte, John S, Everett, George T, Stowe, Allen
Subject: Draft stormwater permits for Marshall, Allen, and Riverbend
Bethany
Duke Energy reiterates the positions stated in our comment letters to NCDENR-DWQ in response to the draft stormwater
permits for the Marshall, Riverbend and Allen Steam Stations We do not believe the requirements for inclusion of
analytical sampling of any benchmarks to be valid Stormwater runoff has been occurring at these facilities for decades
with no indications of adverse impacts to the receiving water bodies DWQ has provided no evidence of actual or
potential adverse impacts that would warrant the inclusion of sampling for these many benchmarks There should be a
substantial water quality issue, such as a 303(d) listing, to justify the requirements for monitoring of any benchmark values
in these permits Duke Energy maintains that many of the requirements mandated by these draft permits are of little or
marginal value in terms of environmental protection, and that these requirements place an unjustified burden on our
facilities
As an alternative, Duke Energy proposes a stormwater permitting approach more in line with the requirements of other
states general permits such as the South Carolina Industrial Stormwater General NPDES Permit SCR000000, Part 8 —
Sector -Specific Requirements for Industrial Activity, Subpart O, Sector O — Steam Electric Generating Facilities In
particular, we propose the following alternative requirements
a Semi-annual quantitative sampling for those outfalls discharging stormwater runoff from areas that store coal
This would be limited to any stormwater runoff from the coal storage pile that discharges directly to the receiving
water body Samples would be analyzed for TSS and pH only, with effluent limits of 50 mg/I for TSS, and 6 0 to
90su forpH
b Semi-annual quantitative sampling for any parameters for which a 303(d) listing exists for the subject section of
the receiving water body Sampling would be performed for the listed constituent at all defined representative
outfalls Sampling for the listed constituent would be discontinued following two consecutive non -detect results
c Semi-annual qualitative sampling at all defined representative outfalls Samples would be characterized by color,
odor, clarity, presence of floating solids, settled solids, suspended solids, foam, oil sheen, or other indications of
stormwater pollution
d Qualitative and quantitative monitoring will be limited to defined representative outfalls only Presently, those
outfalls are identified as
I Marshall Steam Station SW003 and SW007
ii Riverbend Steam Station SW002, SW003, SW007 and SW008
III Allen_, am Station _ SW005, SW008, SW011-and-SW015-
IV Buck Steam Station SW002, SW005 and SW073 ;
e Development of stormwater pollution prevention plans as stated in the draft permits
We would welcome another opportunity to meet with you and others in the Stormwater Permitting Unit to further explain
our concerns and work toward resolution
Thanks
Mark McGary, P E
Duke Energy EHS
From: Georgoulias, Bethany [mailto:[e-mail]]
Sent: Monday, November 14, 2011 1:45 PM
To: Mc Gary, Mark E

Cc: Bennett, Bradley
Subject: RE: Meeting on draft stormwater permits for Marshall, Allen, and Riverbend
Hi Mark,
I was dust following up with you to see if the end of November was a good timeframe for you all?
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NC 27604
Phone [phone]
Fax [phone]
NEW Website http Hportal ncdenr org/web/wq/ws/su
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: Monday, November 07, 2011 2:18 PM
To: 'Mc Gary, Mark E'; 'Vette, John S'
Cc: Bennett, Bradley; Patterson, Robert; Lowther, Brian; Parker, Michael; 'Stowe, Allen'; 'Everett, George T
Subject: RE: Meeting on draft stormwater permits for Marshall, Allen, and Riverbend
Gentlemen,
Thanks so much for meeting with us last week about the NPDES stormwater permits for these three Duke Energy plants
We appreciate your taking the time to come to Raleigh and discuss several of the issues that have come up during the
draft permit phase We hope we explained some aspects about our stormwater permits and program that were
confusing or not so clear before We realize we may not have answered all of your questions or concerns, but we hope
we conveyed how important we value the dialogue as we move forward to finalize these permits
We look forward to coming back together with ideas from both sides about alternatives and clarifications we can
consider integrating into the permits Some of these ideas include
(1) alternative monitoring schemes that serve both purposes of characterizing stormwater discharges based on
potential pollutants from the activities here, and serving as a tool for the permittee's Stormwater Pollution Prevention
Plan/BMP assessment,
(2) proposals for a period of time after which monitoring for some parameters can be discontinued and why (for
example, to identify the most likely constituents present),
(3) proposals for alternative qualitative monitoring requirements to accommodate the large number of outfalls and
accessibility concerns,
(4) proposals for alternative storm events that should be measured (e g , "measureable storm event" based on discharge
potential instead of "representative," based on the 0 1" rainfall criterion)
Our goal is to progress towards finalizing something by the end of the year I know we're moving into the holiday season
soon, and so we'd like to propose having these ideas ready by November 30`h Please let us know if that timeframe
works for you all
Thanks again,
Bethany Georgoulias

Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NC 27604
Phone [phone]
Fax [phone]
NEW Website http //portal ncdenr orq/web/wq/ws/su
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: Monday, October 24, 20113:42 PM
To: 'Mc Gary, Mark E'; Velte, John S; Everett, George T; Stowe, Allen
Cc: Bennett, Bradley; Patterson, Robert; Lowther, Brian; Parker, Michael
Subject: RE: Meeting on draft stormwater permits for Marshall, Allen, and Riverbend
Mark,
We are all set for a meeting on Wednesday, November 2nd at 10:30 AM I have reserved the large conference room
(#3) on the 14`h Floor of the Archdale Building at the NC DENR offices here in Raleigh If you need to find us earlier that
morning, our Unit is located on the 91h floor
You have been down here several times and are probably aware of the parking options (and challenged), but please let
me know if you need more information Several of the DENR Divisions will be moving over to the new Green Square
building that week, so I'm not sure what to expect up there that day, but it's a great meeting space
Since we are discussing three plants and the permits in general, I think it would help for me to put an agenda together
I'll draft up something and get it out in the next week I think it would help to talk about items common to all of the
permits first and then get into site-specific details We'll use the comments you all submitted as a guide If you would
like me to include anything else, let me know
We look forward to speaking with you If you have any questions in the meantime, please don't hesitate to contact me
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N Salisbury St, Raleigh, NC 27604
Phone [phone]
Fax [phone]
NEW Website http //portal ncdenr orq/web/wq/ws/su
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: Mc Gary, Mark E [mai Ito: Mark. [e-mail]
Sent: Monday, October 24, 20112:04 PM
To: Georgoulias, Bethany
Cc: Velte, John S; Everett, George T; Stowe, Allen
Subject: RE: Meeting on draft stormwater permits for Marshall, Allen, and Riverbend

Bethany
Looks like Wed, Nov 2 is best for us
Please send a meeting notice to those copied on this email
See you then
Mark
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