NCS000574_Cape Fear Add Info Letter_20140826

A'741
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
August 26, 2014
Mr. Harry Sideris
Senior Vice President, Environmental Health & Safety
Duke Energy
526 South Street
Charlotte, NC 28202
Subject: NPDES Stormwater Permit Application
Additional Information Request
Cape Fear Steam Electric Plant
Chatham County
Dear Mr. Sideris:
The Division of Energy, Mineral and Land Resources' Stormwater Permitting Program (SPP)
received an application for an NPDES stormwater permit for this facility on August 4, 2014. We need
additional information from Duke Energy Progress, Inc. ("Duke") to continue processing that
application and developing a draft permit.
The information submitted in August, 2014 (document signed on July 30, 2014) indicated
that the "stormwater watersheds no longer drain areas with industrial activity." Pursuant to 40 CFR
122.26 (b)(14) please confirm that no significant materials remain and there is no exposed materials
in areas where industrial activity took place in the past.
We understand that the site is undergoing demolition of the coal-fired plant. Please provide
a schedule and narrative description of the demolition activities that could impact stormwater
discharges. Our concern is that the conditions of the stormwater permit should anticipate changing
site conditions during the demolition period. We want to check whether conditional provisions
addressing the demolition should be written into the permit, and whether the provisions might be
structured so as to lapse when the demolition is accomplished.
Similarly, we anticipate that the closure of the site's ash ponds may soon be underway, and
that the activity may be begun and completed within the term of the stormwater permit. We would
expect that some aspects of the ash pond closure activity may present the potential for stormwater
pollution (for example, activities such as transport of ash along on-site haul roads.) In so far as is
possible at this point in time, please provide information on the ash pond closure that could inform
our drafting of the stormwater permit. Aspects such as the location of haul roads, time schedules,
and site modifications necessary to accomplish the undertaking would help us assess how the permit
should address the stormwater risks from the activity.
Please certify (signature required) the nonstormwater discharges on EPA Form 2F under
Section V for Nonstormwater Discharges.
Division of Energy, Mineral, and Land Resources
Energy Section • Geological Survey Section • Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-9200 / FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: http://portal.ncdenr.org/web/Irl
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Mr. Harry Sideris
August 26, 2014
Page 2 of 2
In accordance with item V of the EPA Form 2F application, please confirm that Duke has
observed all stormwater outfall conveyances on the site and that Duke has reason to conclude that
the observed flow is groundwater only. If any other outfalls were not observed, or they included
non-stormwater flows, please amend the EPA Form 2F. If any other discharges have occurred during
dry periods please indicate how those discharges are currently permitted.
Please provide details (dates, location on site, drainage area impacted, etc.) about the
presence or any past storage and/or releases of polychlorinated biphenyl compounds (PCBs) on site.
If there were any known releases, please discuss actions taken to remediate any areas affected.
Include information about what drainage areas might have been impacted by PCBs.
The application included a plan view of the Cape Fear Steam Electric Plant. The map did not
clearly delineate each drainage areas for the stormwater outfalls listed in the application. Please
provide a plan size (nominally 24" x 36") site drainage map clearly showing all drainage areas and
other items listed in Section III of EPA Form 2F.
Thank you for providing more recent copies of the annual certification all outfalls had been
inspected for non-stormwater discharges. All of the certifications indicated that no discharges were
occurring during periods of no precipitation. For future reference on other stormwater applications,
for this site and other Duke facilities, if any outfalls were not observed, or they included non-
stormwater flows, please amend your EPA Form 2F to report that. Also, if any discharges have
occurred during dry periods, be sure to indicate in the application how those discharges are or will
be permitted.
We are asking that you provide this information by September 22, 2014. Otherwise we will
return the application as incomplete. Also, please provide an electronic copy of all application
materials, including this additional information, along with your submittal. If you have any questions
about this matter, please contact me at [phone] or bradley.bennettOncdenr.govor or Mike
Randall at [phone] or [e-mail].
Sincerely
Original signed by Bradley Bennett
Bradley Bennett
Supervisor Stormwater Permitting Program
cc: John Velte, Duke Energy
Issa J. Zarzar, Director Demolition and Plant Retirement, Duke Energy
Raleigh Regional Office/ Attn: John Holley
DEMLR Stormwater Permitting Program Files
DWR Central Files