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HomeMy WebLinkAboutNCS000554_Buck CTCC Duke Response to Draft_20120320r •, • PDuke Energye March 13, 2012 Ms Bethany A Georgoulias Division of Water Quality Stormwater Permitting Unit North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 27699 -1617 Subject Duke Energy Carolinas, LLC Draft NPDES Stormwater Permit Comments Buck Combined Cycle Station Permit No NCS000554 Dear Ms Georgoulias 526 South Church St Charlotte, NC 28202 Mailing Address PO Box 1006 Mail Code EC13K Charlotte, NC 28201 -1006 704 382 8768 704 382 6240 fax RCS [R OWIN MIAR202012 DENR - WA,,-,R QUALITy WETLANDS AND STpRMWATER BRANCH We have reviewed the subject draft stormwater permit for the Buck Combined Cycle (CC) Station and submit the following comments Part 11, Section B of the draft permit mandates analytical and qualitative monitoring for TSS, non -polar oil and grease and pH Duke Energy does not believe there is any justification for inclusion of these parameters associated with stormwater runoff from such a benign facility as the Buck CC Station In particular. a All petroleum sources at the facility that could potentially contribute to oil and grease impacts to stormwater are located within secondary containments b All stormwater runoff is processed through a stormwater detention pond installed as part of the erosion and sedimentation control plan for construction of the facility The industrial use areas surrounding the facility cover approximately 14 acres, and are comprised primarily of building roofs with asphalt pavement or gravel surfaced areas surrounding the buildings. Included within this drainage area are some minor vegetated areas located east of the cooling tower and in the vicinity of the water treatment facility Considering that the primary purpose of this pond was for sedimentation control during construction, there should now be little concern over TSS in the pond discharge. c There are no existing or foreseeable influences that would affect stormwater pH at the facility Consequently, Duke Energy requests that all analytical sampling requirements in Part 11, Section B be removed from the draft permit www duke - energy com Part II, Section B of the draft permit includes the requirement to compare analytical results to benchmark values listed in Table 3 Duke Energy reiterates the positions stated in our comment letters in response to the draft stormwater permits for the Marshall, Riverbend and Allen Steam Stations We maintain the position that the inclusion of benchmarks is invalid There should be a substantial water quality issue, such as a 303(d) listing, to Justify the inclusion of any benchmark values in the permit DWQ has provided no evidence of actual or potential adverse impacts that would warrant the inclusion of these benchmarks Consequently, Duke Energy requests that all references to benchmarks in Part II, Section B be removed from the draft permit Duke energy agrees with the requirements for semi- annual qualitative monitoring in Part II, Section C We request that all references to "SDO" in the draft permit be defined as "stormwater outfall SW001" to more accurately reflect that the facility has only one stormwater outfall Please contact Mark McGary @duke- energy com or at 704 - 634 -7098 if you have any questions or need any additional information Sincerely, Mark McGary, RE Environmental, Health & Safety