NCS000000_HF Lee SW Applicability Letter_20141022

DUKE
ENERGY.
PROGRESS
October 14, 2014
Mr. Bradley Bennett
NC Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1628
Subject: Duke Energy Progress, Inc. (Duke)
H. F. Lee Energy Complex
Stormwater permitting
Wayne County
Dear Mr. Bennett:
H. F. Lee Energy Complex
Duke Energy Progress
1199 Black Jack Church Road
Goldsboro, NC 27530
This letter is intended to provide clarification as to applicability of NPDES storm water permit
coverage at the subject facility. As was provided to your office in a thorough history of the site
as part of a letter dated March 25, 2014 (attached), when the site contained a coal fired steam
electric plant, all categorical storm water flows were routed such that they were regulated under
the sites NPDES wastewater permit. This is still the case for all flows on the former coal fired
site. This was in full accordance of previous guidance provided by your agency. The coal fired
generation has ceased at this site and the generation units have been demolished.
A combined cycle facility has been constructed on another part of the property. This unit
became available for commercial operation on December 31, 2012. Duke has met with staff
from your regional office onsite and confirmed through their investigation that there is no point
source of any storm water reaching any receiving stream from the facility. Additionally, current
proposed revisions to federal effluent guidelines acknowledge it is unclear, at best, if combined
cycle facilities are subject to federal categorical guidelines. Regardless of the applicability, with
no point source discharges to receiving waters, no NPDES storm water permit is necessary.
During the construction of the combined cycle, Duke (at the time Progress Energy staff) worked
with Wayne County Planning staff on local storm water issues. Wayne County staff have
confirmed for Duke that the site is exempt from Phase II storm water requirements because of
the amount of land associated with the site. Regardless, Duke has left in place retention basins
designed to meet the requirements of the Wayne County storm water ordinance as a measure of
additional stewardship.
Should there be a decision to remove ash from this site in the future, Duke will at that time apply
for coverage for associated haul roads as needed.

If you feel that another site visit would help you understand the specifics at this site, I encourage
you to contact our staff to arrange such a visit. If there are any questions regarding this request,
please contact Shannon Langley at [phone] or Ricky Miller at [phone].
Sincerely,
Rick Grant - Manager
H. F. Lee Energy Complex
cc: Ricky Miller
Tommy Hare, ORC
Shannon Langley - NC 14

NERGY.
March 25, 2014
Mr. Tracy E. Davis, PE, CPM
Director
North Carolina Department of Environment
and Natural Resources
Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
RE: Notice of Violations
Belews Creek Steam Station
Cliffside Steam Station
Dan River Steam Station
Lee Steam Electric Plant
Roxboro Steam Plant
Sutton Steam Plant
Dear Mr. Davis:
Charles M. Gates
SVP. Power Generation Operntkxis
526 South church Street
Chadotte, NC 28=
Office- 704,382.4269
Cellular 919.219.1843
This letter is in response to the six notices of violation ("NOV6") you sent to Duke Energy
Carolinas, LLC and Duke Energy Progress, Inc. (collectively "Duke Energy") regarding the
following six plants: Belews Creek, Cliffside, Dan River, H.F. Lee, Roxboro, and Sutton. Your
NOV letters allege that Duke Energy has "neither applied for nor obtained coverage under an
NPDES Stormwater Permit for stormwater discharges from the site[s]." Duke Energy
respectfully disagrees with these allegations and the company believes that the NOVs were
Issued in error.
As this letter explains, two of these plants (H.F. Lee and Sutton) have no stormwater
discharges. Duke Energy understands the term "stormwater discharges" to refer to discharges
comprised solely of stormwater, and not discharges that are a combination of industrial
wastewater and stormwater. These combined wastewater/stormwater discharges are already
addressed in the NPDES permits Issued by NCDENR to these Duke Energy plants. The
remaining four plants (Belews Creek, Cliffside, Dan River, and Roxboro) have submitted
applications for stormwater permits on multiple occasions, and In fact two of those applications
are currently before your agency waiting on action by you and your staff.
A complete response to your notices of violation requires some discussion of the history of
stormwater permitting in North Carolina. Most of this history occurred prior to the 2012 merger
of Duke Energy Corporation and Progress Energy, and much of it occurred when the companies
operated under different names, such as Duke Power or Duke Energy for the Duke Energy
Carolinas, LLC fleet and Carolina Power & Light/CP&L or Progress Energy for the Duke Energy
Progress, Inc. fleet. Even though not technically correct, this letter will use Duke Energy to refer
only to the two companies collectively following the July 2012 merger. When referring to the

Mr, Tracy E. Davis, PE, CPM
March 25, 2014
Page 2
companies prior to the merger, the terms Duke Power and CP&L will be used, even If the
companies used different names for part of that period. Duke Energy Carolinas and Duke
Energy Progress will be used when referring to the companies individually following the 2012
merger. Likewise, NCDENR has undergone several name changes and reorganizations over
this same period. For simplicity, this letter uses NCDENR to refer to the current and all
predecessor agencies.
tormwater Permlttinq ftckoround & Histo
In 1991, CP&L submitted Phase I applications to United States Environmental Protection
Agency ("USEPA") for CP&L coal plants, including H.F. Lee and Roxboro. That was followed by
Phase II applications for these facilities under "group #286" in September 1992 (March 14, 1991
letter from George Oliver, PhD (CP&L) to Director, Office of Wastewater Enforcement &
Compliance, USEPA).
In 1991, Duke Power submitted Phase I applications to USEPA for Duke Power coal plants,
including Belews Creek, Cliffside, and Dan River. That was followed up in September 1992 with
Phase II applications that included quantitative data under "group #279" (September 28, 1992
letter from Dayna Russell (Duke Power) to Director, Office of Wastewater Enforcement &
Compliance, USEPA).
The Phase 11 applications for both Duke Power and CP&L submitted to USEPA included the
Form 2F and all the information necessary for a permit writer to issue an individual stormwater
permit. Before USEPA issued a group permit for stormwater, NCDENR asserted primacy for
stormwater permitting in North Carolina.
The South Carolina Department of Health & Environmental Control (°SCDHEC") also asserted
primacy for stormwater permitting in South Carolina. SCDHEC elected to develop a sector
NPDES general permit to cover stormwater. Duke Power and CP&L filed Notices of Intent
("NOIs") to comply with the South Carolina stormwater general permit and obtained coverage
under the general permit. Coverage was effective at Robinson Site on August 31, 1992 and at
W. S. Lee Steam Station on September 28, 1993.
NCDENR opted not to develop an NPDES general permit. Instead, NCDENR adopted a
"combined permit" strategy for stormwater. In instances where stormwater and wastewater
were found to be combined in conveyances and treatment systems on a site, the combined
discharge was viewed as "wastewater" and a permittee was requested to submit only Form 1
and Form 2C with an NPDES permit renewal application (February 4,1994 letter from
Coleen Sullins (NCDENR) to George Oliver (CP&L)). Attematively, where wastewater and
stormwater streams were not combined, Form 2F was also required as part of an application for
the discharge of stormwater only.
In the early 2000s, Duke Power began developing Storm Water Pollution Prevention Plans
("SWPPPs") for its facilities. The SWPPPs identified substantially identical outfalls for each
station. The data in the SWPPPs were eventually used to complete Forms 2F as they were
included in NPDES permit renewal applications.

Mr. Tracy E. Davis, PE, CPM
March 25, 2014
Page 3
Around 2003 and following meetings between Duke Power and NCDENR representatives,
NCDENR instructed Duke Power to begin submitting the Form 2F (stormwater applications)
along with our renewal applications for NPDES permits. From this point until mid -2011, each
NPDES permit renewal application submitted included a Form 2F.
As Duke Power and CP&L completed flue gas desulfurization systems at some of our facilities
between 2006 and 2009, SWPPPs were revised and updated to reflect site changes. At this
point, NCDENR had not yet chosen to issue specific stormwater-only requirements In the
NPDES permits.
On June 20, 2011, Duke Power received a draft individual stormwater permit for Marshall Steam
Station. On duly 20, 2011, Duke Power responded to the draft permit with substantive
comments regarding the lack of environmental protective value, reasonableness, and cost
effectiveness of many of the draft permit requirements (letter from George Everett (Duke Power)
to Mr. Brian Lowther, NCDWQ Stormwater Permitting Unit, NCDENR).
NCDENR followed quickly with subsequent draft individual stormwater permits for other Duke
Power plants and some CP&L plants, all containing provisions similar to those in the Marshall
Steam Station draft permit. Both companies shared common concerns about the terms of the
draft permits. Duke Power and CP&L representatives met with NCDENR Stormwater Permitting
Unit permit writers and two levels of management on November 2, 2011. NCDENR
representatives shared their permitting rationale, and Duke Power and CP&L expressed
concerns that were generally applicable to all the draft individual stormwater permits for both
companies. The companies made a strong case for NCDENR to reconsider these draft permits
and the approach NCDENR had taken.
NCDENR subsequently revised several draft individual stormwater permits, but the changes
NCDENR made were minor and failed to address the most substantive comments the utilities
had offered, and which the companies reiterated during the open comment period. NCDENR
never finalized these draft permits.
Duke Power and CP&L representatives met with Matt Matthews (NCDENR Section Chief) on
April 24, 2012 to offer a concise but comprehensive overview of both companies' concerns
about the draft individual stormwater permits and the general approach being taken by
NCDENR. The utility representatives left that meeting with the understanding that NCDENR
would consider and clarify their approach for stormwater permitting and communicate that to the
companies (May 1, 2012 meeting summary letter from Mark Mc Gary (Duke Power) to
Matt Matthews, NCDENR). The utilities expected that NCDENR would be Issuing stormwater
permits for its plants.
Permitting Status of Plants Named in NOVs
Both the Sutton and H.F. Lee plants have no discharges consisting of stormwater only, and
have therefore not submitted Form 2F applications. At both sites, stormwater is combined with
wastewater and permitted under the current NPDES permits. The H.F. Lee Steam Plant applied
for categorical stormwater coverage in 1994 by submitting EPA Form 2F. A revised NPDES
Wastewater Permit was issued effective January 1, 1995, which required CP&L to develop a
SWPPP and to monitor at three separate stormwater outfalls. In October 1995, CP&L
requested modification of its NPDES permit to eliminate the stormwater requirements based on

Mr. Tracy E. Davis, PE, CPM
March 25, 2014
Page 4
a plan to eliminate these point source stormwater outfalls by rerouting the water to the onsite
cooling pond which has an NPDES wastewater outlet On February 12, 1996, the NCDENR's
predecessor issued a modified permit to CPBL which removed all stormwater requirements as
the stormwater outfalls had been eliminated. With no stormwater discharges since 1995,
submittal of Form 2F is unnecessary.
Both the CI'iffside and Roxboro plants have Form 2F applications currently pending before
NCDENR, having been submitted January 29, 2010 and September 27, 2011 respectively.,
Duke Power did not submit a Form 2F with the most recent NPDES permit renewal applications
for Belews Creek (submitted August 29, 2011) and for Dan River (submitted October 26, 2011),
because both had previously submitted Form 2F applications with their prior renewals,
(submitted respectively on August 29, 2006 and October 30, 2006) and Duke Power was
expecting that NCDENR would be Issuing draft stormwater permits for these two plants, as it
had done in the summer of 2011 for Marshall Steam Station. The information contained in the
2006 Form 2F applications is valid and appropriate to form the basis for issuing stormwater
permits. As a courtesy, copies of these applications are included with this letter as Exhibits B
and C. If NCDENR requires Duke Energy to submit new Form 2F applications for Belews Creek
and Dan River, Duke Energy will require additional time to complete the stormwater sampling
required as part of the application process, as data are needed from qualifying storm events.
Please find attached as Exhibit A a table that summarizes the stormwater permitting history for
these six plants.
Conclusion
Duke Energy respectfully requests that NCDENR rescind the NOW for Belews Creek, Cliffside,
Dan River, H. F. Lee, Roxboro, and Sutton. As outlined previously in this letter, H. F. Lee and
Sutton have no separate stormwater discharges, and the remaining four plants (Belews Creek,
Cliffside, Dan River, and Roxboro) previously had submitted the information necessary for
permit writers to act We look forward to working with you to quickly resolve any outstanding
Issues, and if additional information is required to complete the permitting process, please
contact John Velte at 980-373-7308.
Sincerely,
aj-�Q�
Charles M. Gates
SVP, Power Generation Operations
1 Roxboro also originally submitted Form 2F for "nevi' SW outfalls on October 2, 2008 with no action
being taken by NCDENR. The Form 2F submittal dated September 27, 2011 is for the same outfalls
submitted in 2006.

Mr. Tracy E. Davis, PE, CPM
March 25, 2014
Page 5
cc: Carl P. Boyce
Erin B. Culbert
Mitchell C. Griggs
John Elnitshy
Michael R. Olive
Paige H. Sheehan
John S. Velte
James R. Wells

EXHIBIT A
Summary of Stormwater Permitting
Facility"
Date EPA
Data EPA
Dates Farm 2F
Date Facility
Comments
Prase I
Phase II
Submitted (YIN)
Eliminated SW
Permit
Permit
with NPDES
Point Source
Application
Application
Permit
Outfalls
Submitted
Submitted
Applications
Belews Creek
3/14/1991
9/28/1992
8/29/2006 — YES
NA
Form 2F was not provided with the most recent
8/2912011— NO
NPDES Permit application based on expectation
that DENR would soon be issuing an individual
SW Permit (as per permitting process underway
2011 to present).
Cliffside
3/14/1991
9/28/1992
1/27/2003 — NO
NA
Form 2F was provided with the last NPDES
1/29/2010 — YES
Permit Milcation.
Dan River
3/14/1991
9/28/1992
10/30/2006 — YES
NA
Foran 2F was not provided with the most recent
10/26/2011 — NO
NPDES Permit application based on expectation
that DENR would soon be issuing an individual
SW Permit (as per permitting process underway
2011 to present).
H.F. Lee
3/14/1991
9/2811992
1/1/1995 (effective
2/12/1996
NPDES Permit Mod. Issued by DENR in 1996 to
date of NPDES
reflect completion of pre -approved modifications
WW permit to
routing all SW to cooling pond (€.e., permitted
CPBL requiring
WW outfall).
SWPPPs
Roxboro
3/14/1991
9/28/1992
10/2/2006 - YES
NA
All SW was routed through permitted wastewater
9/27/2011 - YES
(WW) outfalls up to 2005. Changes on site led to
potential for point source SW discharge so Form
2F was provided from 2006 on.
Sutton
3/14/1991
9/28/1992
NA
Sutton never
Coal plant sent SW to retention basin and then
had SW point
ash pond.
source
discharges
SW = Stormwater, WW = Wastewater, SWPPP = Stormwater Pollution Prevention Plan
a These facilities are (or were originally) coat fired steam electric generating facilities. Presently, Dan River, H.F. Lee, and Sutton cosi units are retired
and those three sites have recently constructed combined cycle combustion turbine facilities.

EXHIBIT B

A. Ara yaU nOW MCIU 0 CY any r'Wmm* MCM Cr Oarn MMMMY W mea[ er r MF� V� earYW 1PFAM%�,, vme For orOperation.
Operation. d weetawater trsatrwd e"W"M or pr chin or any O w errrtron[nerrtai ProOrirest Whldr may died do dWdhuM dsaalbod
fn this eppli�lOr1? ihia , but Is not 0ndtad b. PenM mrdttoas, K nbrisht" Or erdwcIff A ceders, N*wcKnwA COfa lCe
eei�ad� suo-, tae carrel Grdws. and Grant Or loan owdOmm.
IdadNkadon of Gondilksrs.
B. YOU nmy arm aOC OWW sreieu Deerrm Q =q4EJWCKffWWWW e1�I pv, vers w,n� ■,.eP.a }■'�+p■• •- w,..n+.. ,..y -••,�• I� •�
you now have under way or which You On. Iadhrxls whether wade propeaer is now under way or plommd, and Idleala YmF ealwf Or
iopopraphm map is raravadabi-) the fiiw- Indudina eadr of b Make end diedwoe structreer #* drdnpa .sa C4 sad- -mare
weir Otdalk paved rw and rruil*ps within the athwe ane d each norm w9w outJM, each lowm past or praant areas mad for
outdoor aw" ar diepoew d do 'k- -1 materbb, each e6atkMry strueben asrhot measure b rsduea! poor In amen water -anal?,
mdsdetr lw&V and aco alae% areas where peadcIdes, herbicides, ed Monera and F1 01111 am oppoK each d its haardaus
womb i eabraK storepe or dlepsaM units (trrdesdtrrp eachme not requf<.d to have a RCRA permit which Is used for sommaAafinp harardew
waste under AO CFR 26LU$ each wd where lulds km the farifty aro hued widergromd; spfips, and deer surba, wabr bodes which
receive slam water ducosrp+s �+ e+s Thr• — _ - --
EPA Form 35%.2F (Rev. 1.02) Pape 3 of 3 Cantinaed on Page 2
EPA ID Number fcWfian ftm IOfForm r)
Fam Appeared. OMR No. 2DID W
print or [ype In the Unamwad areas
NCO022406
AW" esplms 531.02
_
L%Aed States W Apency
� to
2F
Application for Permit Discharge Storm Water
DES
CEPANDische es Associated with Industrial Activ
Pspwrwork ft*m lean #A NUUM
IpLj&raparbrp budeer fa hb appEesI k adrrraI b s amps 28.6 horse per oppicelicn tndrft flee for nRbft 4+shaions. eseafiq erd^fp dam
sauces. pet?tedrN and rr riap me dam needed and mnpla0np and rado I Dee morin d3rbinahn Sold ami rawis Irp ft bedm ee!~rr 11
seal dlrr aspecid � oofadiolr did7mesfrn Cr su ----,ores r N frh tm 6rrirdr -, whichmoo, aeaee r eadros t h bsden m:OdK
Pudolanch, pat�'i,11,8. I b Apngl.,Oi M 9, S N WW* m DC 2Drt crIX drry [� d lydo n ab and fthi o y
1 Br
ANA 011an d � 20011
I. outfall Location
For eachlist the lafltude and e d Its kmm b Cm neral 15 ascan'- and Vw d qrw_
A. Outfa3 Humber
B. Latitude
C. t.nn;OAIe
D. Raoelvlrrp Water
Mae
36 16
3 47
1
-36 1 a 7d
It 3 a
Is: For mea ftrinp
purposes the above
ouftb represeM the
rommining otttfslls.
R. Monts
A. Ara yaU nOW MCIU 0 CY any r'Wmm* MCM Cr Oarn MMMMY W mea[ er r MF� V� earYW 1PFAM%�,, vme For orOperation.
Operation. d weetawater trsatrwd e"W"M or pr chin or any O w errrtron[nerrtai ProOrirest Whldr may died do dWdhuM dsaalbod
fn this eppli�lOr1? ihia , but Is not 0ndtad b. PenM mrdttoas, K nbrisht" Or erdwcIff A ceders, N*wcKnwA COfa lCe
eei�ad� suo-, tae carrel Grdws. and Grant Or loan owdOmm.
IdadNkadon of Gondilksrs.
B. YOU nmy arm aOC OWW sreieu Deerrm Q =q4EJWCKffWWWW e1�I pv, vers w,n� ■,.eP.a }■'�+p■• •- w,..n+.. ,..y -••,�• I� •�
you now have under way or which You On. Iadhrxls whether wade propeaer is now under way or plommd, and Idleala YmF ealwf Or
iopopraphm map is raravadabi-) the fiiw- Indudina eadr of b Make end diedwoe structreer #* drdnpa .sa C4 sad- -mare
weir Otdalk paved rw and rruil*ps within the athwe ane d each norm w9w outJM, each lowm past or praant areas mad for
outdoor aw" ar diepoew d do 'k- -1 materbb, each e6atkMry strueben asrhot measure b rsduea! poor In amen water -anal?,
mdsdetr lw&V and aco alae% areas where peadcIdes, herbicides, ed Monera and F1 01111 am oppoK each d its haardaus
womb i eabraK storepe or dlepsaM units (trrdesdtrrp eachme not requf<.d to have a RCRA permit which Is used for sommaAafinp harardew
waste under AO CFR 26LU$ each wd where lulds km the farifty aro hued widergromd; spfips, and deer surba, wabr bodes which
receive slam water ducosrp+s �+ e+s Thr• — _ - --
EPA Form 35%.2F (Rev. 1.02) Pape 3 of 3 Cantinaed on Page 2

Rel
O. F'SR1lPf
M1 a ffmw to der swoon Ms 1"M wow. nOMW of k7*nwrt abaapa, is dbpawt past and ptnard Rntalafa IIIaBaaaA7alt.
wg4%*d to ni *rko wow bythese matwbkt wM boon u*w Rwat maftftb Weft sad eases areae; attd d» Muaiw
For ONFMORW pMON d+a l wim and a doaa"M of hold told nee&ea U M centra maeawsa tO tda,. poataares fr
eb m "w him&. and a d-NOURn d h daehnntt t.M "M taster recdvK kwkx lop do edtedtee std type at ritaYtlanaaea ibr
thrru
SvM8
and tial Y
ThoMns d. th §Ws, tlnnerel M@Ma9w,
Belews cook Steam $Won
'Vi URI WIMPenNAM wan wormed du
wars occurring or that they have boon
or
bm MW w WNUM tt for tree
=M- M- 4 h ONW M Faan
It 2cw of UN-CUUM to vorlry met sartu
on tiss NIMES sppilosson aeconftly.
or
end
1?/Zg /a b
One reportable spill of oil occurred In the last three yan. It occurred on Occerobw 10, 20M A light sheen
of appnood u" 10 het by 10 feet was formed on BdwM Lake at the Bohwn Creek Steam Station Intake ens
when appy 0.01 gallons of oil was released from an air compressor.
No otter reporhbM spills or sync leant Melte of toxic or hazardous pollutants have occurred at thb fedltfy In
the Int one yens.
EPA Form 9510.2F Mw. 1-92) Pape 2 cf 3 cadhow oa Pale 3

EPA ID Number (oap hM Ilam f df m 1)
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ere any d to awym repow in by a oor>far3 Wy dr
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Prism Laboratory
449 Springbrook Road
BOD, 0 ,
P.O. Box 240843
I1stlrnos>le, Metals,
Charlotte, NC 28224-0543
Nillfite+Nitratea
Flouride, Selenium,
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hewed under my torr or
supeniJalon in accordance with a system designed to assure the! qualfited peraonmel property gather and evsWe
the lnformaflam submbed. Based on my inquiry of the person orpermw who manage the system cr tbow persmmua
dk&W responalbb for gatharhfg the lnfmmatlon, the kdh murtton submllted Is. to the beat of my hxmdedge and
belief, true, aaurafe, and complete. l am aware that there ars slgnlficart penallles liar sig No lrtfial ndbn,
In"no, the mmmaltliv of fine and ftr*mmenf for ioxm&c vioklons. -
homes J. ouUwla. Gerwal Marapar, Beiews Creek steam Sbftn 14334 44543400
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one
vw�riuno r.r+w menage vdMM Nr►4aer
PdkdM luft I f*Wkpdg (N
kw Grab awrpb '7. Qab BwrqW SUM
CAS Number Taken During Ro*waiphled T Owing RowAfthlad Event
(ifavab*) lD Composite Composite Sampled
Minutes Sources or Polkdants
0 46, U9JL 9.74WC NIA NIA 1 See Supplllmortal
MAXIMUn 1 OU"
Average VOW
NUMbw
Polkdard
urs
Copper. Total01 2
hon, Tout01a00
or
1 0.03 mg&
7.097
And
ambsornOw
1
1
"
SelenlLM low 01147
Storm
11.72
CAS Nuff4w
TW= Dudnp
Ra*welghted
Taken Dwft
t gftlsd
Events
Ar evallow)
Find 30
composite
RAW
coalvalle
Seffow
1.S -WL
NIA i
NIA
1
8OUrars Of Paiulanla
ON a Gnaw
C5 mgn
NIA
WA
WA
1
Sea Supplemental
NIA
WA
1
"
EMormallon attach
di�w
16 mgA.
0.7
WA
NIA
26.62 mcill
53.28 nigil
Owren d
190 mglL
2200 mgL
NSA
NIA
w
d
1522.
I wo mgIL
NIA
NIA
1
0.21 MgA
&Ws 088)
WA
1
3.85 malL
2.56 nyll.
NSA
NIA
1
TOW
1294 mg-
0.353 mg-
WA
WA
1
N
Pt=PNM
PIL
PIE.
pH
I GAO
NIA
A
WA
1
M
Part - teen ! la en t jj
panty for No proem wastewater (W the faft Is operafbnp under an *Aft NPDES psmfdt}. Cw0sta ons M4ie for each a M&L
On the � for adkillional data@a and Mukements.
vw�riuno r.r+w menage vdMM Nr►4aer
PdkdM luft I f*Wkpdg (N
kw Grab awrpb '7. Qab BwrqW SUM
CAS Number Taken During Ro*waiphled T Owing RowAfthlad Event
(ifavab*) lD Composite Composite Sampled
Minutes Sources or Polkdants
0 46, U9JL 9.74WC NIA NIA 1 See Supplllmortal
SPA Form 3510.2E MW 1.92) Pepe Vit -1 Continue as Reverse
rrrwrrrriuvn a[m�a�
Copper. Total01 2
hon, Tout01a00
0.11 OxwlL
66.40Il.
1 0.03 mg&
7.097
NIA
WA
FSA
NIA
1
1
"
SelenlLM low 01147
37.74 y 01.
11.72
N/A
NA
1
00625
3.6 MU4UL
1.S -WL
NIA i
NIA
1
NIMH +Nerals
0.38 mg-
NIL
0.76 nag -Nn.
NIA
WA
1
"
Sulfate
26.62 mcill
53.28 nigil
WA
WA
1
"
Flwdde
X0.10 Mon
0.21 MgA
IVA
WA
1
SPA Form 3510.2E MW 1.92) Pepe Vit -1 Continue as Reverse

from
add
as touts for each
Poerrtart
And Gab "MW
CAS Number Taken DwMrgFlo*weighbd Taken Curl
(IMMA") A
Aft Of
Slann
FW*%st ad Evsrrls
Sanplad
BONN d Pdkdwas
NA
0
- data kr tha dam
s wtdrh r rrf W d+e ms>dmum vakres tar the Arrw tad
e.
1.2.b.
Dated
Storm
Event
Draatloa
d Stam Evart
{M fift es)
Tata! rainfall
during storm avant
(in hwhee)
N O N6 of trouts betwoo
6epMWnp of dorm meaa-
Md artd and of pr4lota
mMUMble rain awnt
Total &W k m
rain avant
Mabas crepe* Unw
6-2408
36 min
0.3
i 72
93193.1 gallons
T. PMWIO
aon
rnsasuranent or estimate.
TMorsticai flow calculations were used to estimate total flow from rain event
EPA Form 3510.21F (Rev_ 1-92) Pap VII -2

EXHIBIT C

Please pdni ar type h tie whstaded areas EPA IO f q mber (wff atom Rom l of Farm 1) Form Approved. OMB Na 2040 M
NCOI ODU I Awwm a on 831-2
Form Uftw Paoecdm Agency
2F Vd'hEPA Application for Pen it to Discharge Storm Water
NPDES
Discharges Associated with Industrial Activity
sp
F1btc noMp budera kr fie apobft Is all b esit+h P5p 2Bfi ReductionwIP Ad Noticearsrrq 2tte booze par spplrefa4 trdtadYtD bte for mA"e f+a4a+daw6 seerdlnp eolakq dela
sauces, 9 II and nholrblainp fm dam needed, end annpef gl end mvlerafhp fm a* don d Irianmft Send car5nsrls raQardinp fm burden estirarls,
any afar mpod d fi aftlim d 1ske. o m or supp dbm I rinpa ft f+[s khm>,indudi�q Yahldh nary hnche®e a reduce ft ft to: Chiu
Yafdhnsq PdWRrardtiP1101=11alankr-10 Phrl daeApenq,4mMSt.tlsYll.{Ithehihpb%-DXN4crDncbr,000dlydonasfrs►adRegalsbny
A. Outfall Number
Am you now
In Mi tlar d rr
d
B. Le"O I C. L.orskuds
D. Rec"M water
Po DY MY Fsxr 1w, til#rf15, or bw MAMMNY b meet any for go�
ser h eno mrd aquyarar5nI or prackes or any cam eahvtronm5ntal progrs which may afhei the dfse#asrp� daeraibed
This Mduda% but is red toiled to, parmit cordlfone, adr*M mva oraoncv,w ordure. erft=,N, oompRence
ulnwm court ordn5 and gram or Ivan rte.
1. Idenificatlon of Condltlana,
of
mcu may - arty vraror poQIM (or agm snvlrahanmta! pr*i-w may yaw dsd }
sham tMdar way s for or which You plan. bdicale wheom sea propam b now under xray or plbnned, and Wkxb your eal ial or planned
M. Site DrWrigge MW
Attach a 5110 nap btowdnq tOPOOmphy (or 1 60ft to DAM of divinago anus served by No ouM te) omwW ;h bu appkakn d a
bpographic map h unnevabbe) depicting the Mcifiy krd xft each of Ms bat M and disdwps stnacbuas; in drdnegn area d each stony
water aulfaf; paved areas and bufd W YAW the drains area of each atone water outtalk, each known past or present areas used for
outdoor sbrage or dspoaal of sbMcwd ma10riab, each @Aft stud= control messure to ro*= poM*mb in stoma weer nundf.
nhaterela lea ft and access arm. areas where peefddes, h@d*Idas, Sof oondtionua and I s are appled; each of b hazardous
waste treairnsni, atorapo or disposal wills (kwkx p each ars not naqui ned to have a RCRA pe mit which b used for aao wMalkp hazardous
waste under 40 CFR 282.34X each weO where Nadds bcm the fa ft are h faded underground; springs and ober surfew water bodies which
receive storm water cls _ fhhm the
L
FPA Form 3810-21F {Rev. 1-02) Page ! of 3 Owtimud an Page 2

C
r -W � =jUM% Prue M =WrMM aW am aloe MMM Lem) Or tn7 WvbW
10 th0 OAK and an al INN Of the told eine a ane drained by tw mdfa l
Ckow Area of ape
TOW Am* OrzhW
oudal
Area d hrorwimm $urf80a
TC421 AM Dmkwd
ru,I low vide Imlia
uxllts
Number
ur�ks
wdfs
SINW1 See attached
7hru supplemental
S*v21 IMonnatlon.
B. Provide a rawnd" t r u*d is that are ar In tie pass tom years ham boa heated, *trod or
In a memo* b slow errp aelae to @tam water, alaulad of beatmeM, @forage. or dlsposd; pest and tit matarWe marmpement
P grid to rtdl+4,jW oaldat W these nlatrrlate Am slant weber runw. materlale W ft and low" sloes: and"locatbn,
Mame* and tSMM in It" sol oondllalera. and fifflzers are wpledL
See attached supplemental Information.
math a sumuii a w IMSWudural oanhol rnsaemaea t0 redlrc�
etonn Water turn .and a deteErtOM Co the ftft nt Me ebaml Water Mai . klduft "sdredmde and of maiiMlna" far
coro+ol and troablant and the ullrtrale d aald or mks Welles otherthan
oumA
-Uri !nm
Number
Trea!lnent TWO 2F-1
Sw001 See attached supplementaN Information.
thru
wo18
SN*
Non Storfnwatar D1sc es
Weft &lat are acrtlal(s) Meted by Oft apapllnlon have tlm belled or ertrrelad the p]lelerme
norutomm�a6�rdbcharaee, end fh! ap disdlarpaa tlom ftnsa outfati(s) aro Iddr11111ed b either an acaorrlpallylrlp Conn 2C
or Form 2E for to @**tial.
Wane (*w arprklq
Gary , Gwwral Manager of
Mated Fossil Stations
of W1a abet
Visual Inspection@ wen performed 200
perfored during October 6 of the GuMis to vwlfy that either nonostannwater
discharges were not occurring or that they were appropriately identified In the NPDES penak application.
Vi. S1 niftai nt Leaks or 1119
RaMeexp repanenq the tact Y of ftft or epos Of +arch a has arda:a d the b=y to ft Mod three
tlIs date and location of isle W1 or, and Onlype arb ernowl of rrnd*rfel nomad
d.
1. On September S, 2006 approximately 0.1 gallons of was released to the station Intake area on the pan
River. The release was contained by an oil boom and cleaned up.
2. On July 21, 2006 approximately 0.26 gallons of oil was released from a hydraulic motor In the station
Intake arta on the Dan Rhrer. The release was contained arse! cleaned up.
3. On February 27, 2006 approximately 10 gallons of diesel fuel released near Unit 3 onto rip rap. The
ane was cleaned up.
4. On October B, 2005 approximately S gallons of oil was released to the station Intake area on the Dan
River when the dredge machine sunk. The oil was contained and cleaned up.
EPA form 3610-2F rev. 1-92) Pape 2 of 3 CQatiaaed an Pap 3

COMMIld Iran Papa x
an a
Ya
EPA ID Nwibw &W ham Roan r orFomm it
Ps M YOU wmenety► tw or � as an � or Ind
na aury iarowiampa or rsaaao 00 oeasre tAae any► t�lolapNl feel
rfnp wafer In Mbtlon eb Ywx ds wpe WINn to face 3 y wa?
Yes Aw as suchb babwl
Yes (99 Ow n&VM ad*m awbAwhom n anwof. awpoNMiE *
PO Box 240543
Charlotte, NC 282214M
s
or
No
❑ No (VOID 8k9bn JV
Meals,
Narite#Nltrate,
Flotatde, Selenium,
TKN, P, Sulfate and
TSS
r ca wy wamr purreriy ur raw mer um aoaamenr arra au anacnmern were prepared under my demon or
supero Mw In accordance with a system designed to assures that quaNbd per=uWpmperty cher and evaluate
Me l 4brmatlon submllbd Based on my lnqullry of the person or persona who manage the sy&rn or those pen arcs
day responslWe for gagwft the kdbm at6on, the InAwnstlon subvrrlfted b, to the beat of my lvrowlete and
beftf, bw. accurate, and complete. l am aware that there am slgnllkont penalties Jbr submitting false kftmation,
lrlckrcibq MepaasR W ofAne and lwrfsanment forkwwAw vlolsitma
Gonia! Mana0er, Requlated Fosell Stations 1 704 2&kIM
EPA Form 35 {Rev_ 14q Pape 3 of 3

EPA to NWTit r (acpr hom tlarrr f oFFarm 1) Form Approved. OMB No. 20O001l13
...,.,.,..ftae Appravote1 1Pie0 ti314e
A - ou nrret Wavldr the ai one
krs6udlons far e*WrnW ft4d.
evriy
-
thb erre tuts fa
Pdk tart
And
CAS Number
(�awBsbtt)
NUM Mn
Vakm
— Vrnpe
vahm
Of
ob=
Everts
Swq*d
SoraossafMMY
Grab BMW@
Taken Durkrp
Fket 30
hMnutes
Flawwetphted
Compwb
Grob-
Trdcerl 0atnp
RM 30
Mkmfts
t weio k d
Cornpoalle
on 8 Green
- -
MA
WOO" ORYM
Denord V
15 nWL
14 mg/L
1
(;r4mfwokym
ownaw M
-c 50 &
1
TOW
sows SS
BY mgiL
3a0 mg/L
1
otat Cmaric
n
NA
NA
1
-
Total
Phm#w rm
OA4 mg-
AL
0.897 mg-
NL
1
pHM
_ -saft
MLffn
Mz*n UM
hart - Ultpatten# Dud Is lWwtmd in an +tar to or any pokftrrt I116a
Pa., for Os prooesa wastatrelw (N the fbcW4 b ape a& under an -1 Ind 9 NPM pemtl} Complete one table tar each outle t.
S" dre kratrrrdiorra for adcMkmW details and terrr,nVaMIMW ts.
Poauterrt
And
CAS Number
(7f ava<ablla)
Grab
Taken Dwt V
V
Ftow.waoW
corrrpoalte
Average Van Nuftleff
O[
B(m
Taken Oudnp Flow warted Evenb
Past 30 COMPO"
sourms Qf popubmts
Antenic, Tata) I
112 &w&
9.44
i
—01042
. To
0.381
0.83 m
1
Iran. Total 014US
4.524
3.469
Seler*^ total Ott<7
2155
TKN 00625
2.8
22 1MfL
1
224 mg-
ME
247 agpML
1
22.68 uw&
11.93 molL
0
EPA Form 3510,2F (Rev. 1-92) Pape VII -1 Continue as Revaw

datah and nmiornamts_ cnFrmw& mm bhta kr ueh e"w
Powmn!atuaa
And
CAB Number
(NavaImb)
Taken During
Fkst 30
mkWba
Avenmevaklft
Rw wmOted taken DWft
CWnposm Flrat 30
M
NUAW
of
FbrwrrNp Imd Everts
CarrpoSlla Sampled
Saacas d pd doff
MA
Pani5.
ttm Storm
s hr the
is =MOIL
t.
Date d
Storm
Event
1
Duration
of Stam Event
(in mbr "
3.
TOW raYn n
!
4.
NmbAm
Agin g d sof p maae-
begkv r of lours 4sl ow
orad and and of events
event
4.
Total lair Item
rein apron! gabas Grape* _
( 1
ors
240151.5 9dom
7.
a
Iha
rnSaaaesmni a te.
TiNOf Ural flow calculations were used to ostomate total flow from re}h event.
NO
9PA Form 3510-2F (Rev. 1-92) page VD -1 Coubmw an Reverse

EPAID Number (copy lion fienv f cUbmt 1)
Form App OVOL OMB No. 2040.0006
Approvals 53142
vas A - iw mwc pwmo aye ra7lnfs or a mm arra wryRs wr evwy ponnonr in r u value QvWoe arm m as for sear ounAL am
hntnretlans br ed SkaW dslaL
� v uses
Yah - -
Average na
Pdhft t
of
And Gcob sornow
Gab 3amPkl skxM
CAS Number Taken During Fkr*wdghted
Taken DUFkV Fk;w4retgtrted 3vw is
(Mava"k) Fkst 30 Compos"o
First 30 Carnpodle $wood
Unuhs
lArNll�s
Q F rMs
on 5 Grease -C c9
NfA
1
- «4 nn#L
14 MVE
1
ChomlM q Mg
a Mei-Donvand
�
Tom 01.0 mpg
90.0 MOIL
1
same
OW Orgark M4
M4TOW
-
00.1P/L
0.17 O-
4
Phosphorus
S . tttiat
an nt
ar arcy
for Ila proses- wastewater pf the tadk b
Pblulant
And
CAS Number Taken Due
(718vallaW) PROW
16i
IMM
Co<npostte T Rd 30
under an ardsting NPOES p=4 Compkft ane table for each cutlaL
storm
4AWlWd Events
CRMamp Sampled
EPA Fart 3510.2F (Rev. I -M Pop V13-1 Continue on Reverse

I--
CM&Hnd
from the RMA
art C - Usts"POMMdehowyou
add!lorral deme.
know a redaon
0"ete one table for each outlee.
pollubnt
And
CAS Nwnber
f� )
Taken
i P4930
mbudes
Values Amagm Values
Oft <N
f3tam
Flow.wa- - I Talose During Fbw-vmVftd Events
Corrpcsft MGM Co q=ke Sampled
Mtnales
ff umo of PdkAmnis
atone even a w, �. m,aaemum the l
ts
1.
Qafa of
Stam
Event
x.
Damson
of Storm Event
� Mho*?
Total rohrfaA
duing Stam event�
OF r+�J
<.
Nodw of Iowa between
t
mea mobble rain ware
Total kw hom
rain event
fvaftm or> rte!
4-78-
zoos
7120
.TT
182hours
5886.3
T, i�royide a dea
rraaaiaereerR
Thoorotical flow calculations were used to astimate total flow from rain went.
EPA Form 3510-2F (Rev. 1-92) Page VII -1 Coe>i m an Revem