HomeMy WebLinkAboutNC0000396_Draft Permit Comments 2001_20010620r �
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Asheville Steam Electric Plant
Draft NPDES Permit Comments
1998 January <10 ppb
February <10 ppb
March <10 ppb
April <10 ppb
May <10 ppb
June <10 ppb
July 10 ppb **
August <10 ppb
September <10 ppb
October <10 ppb
November <10 ppb
December <10 ppb
1999 January <10 ppb
February <10 ppb
March <10 ppb
April <10 ppb
May <10 ppb
June <10 ppb
July <10 ppb
August <10 ppb
September <10 ppb
October <10 ppb
November <10 ppb
December <10 ppb
2000 January <10 ppb
February <10 ppb
March <10 ppb
April <10 ppb
May <10 ppb
June <10 ppb
July <10 ppb
August <10 ppb
September <10 ppb
October <10 ppb
November 23 ppb
December <10 ppb
2001 January <10 ppb
February <10 ppb
March <10 ppb
April <10 ppb
May <10 ppb
** Per the 1998 Environmental Monitoring Report,the French Broad River, upstream of the Asheville
Plant intake, had a concentration of 22 ppb in July when sampled. This intake of copper is the probable
cause for the higher than normal discharge from Outfall 002.
Copper condenser tubes were replaced with stainless steel tubes in 1994.
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Draft NPDES Permit Comments /� �e h' , I ,
Section A(7) Section 316(a) Thermal Variance Reapplication tPtl� �� °'� k -J
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ci°L.0 • The citation referenced in the fourth line cannot be found. The correct citation is Clio 0 /WO()
i le-t' probably Section 122.21(m) (6). &'kiwi%�-
Section A(8)—Stormwater Pollution Prevention Plan (a &tell )
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• This section of the permit appears to be the standard language for storm water program
`� M. development at industrial sites. However, the scope of the regulated storm water
discharges at the Asheville plant is certainly less significant than what was intended to
be addressed by the DWQ standard language. Any storm water program development
activities at the Asheville plant would address only the new and old access roads. All
other areas associated with industrial activity for the Asheville Plant drain to the ash
pond which is already permitted. CP&L believes that the storm water discharge
monitoring should suffice for addressing the storm water discharges from the roads.
CP&L, therefore, requests that this section of the permit be deleted or significantly
reduced in scope. We would be glad to meet with the DWQ staff to discuss this issue.
Section A(9)—Stormwater Minimum Monitoring and Reporting Requirements ( '/ki
(,4 a)
• Part a. of this section allows a facility to petition for representative outfall status. The six
stormwater outfalls for the Asheville Plant are substantially identical. CP&L, hereby
requests that SW-3 be used for representative stormwater monitoring.
• Part d. requires that monitoring results be submitted no later than January 31 for the
previous year in which sampling was required to be performed. Using the example in
Section A(4) above, CP&L understands that the monitoring results could be submitted
no later than January 31, 2003.
• Part f. (2) should contain the word "flushing" after"waterline and fire hydrant."
Additionally, it is believed that"habits"should be"habitats."
Part II Page 1 of 18
• DEM in item 2 needs to be replaced with DWQ.
Part II Page 10 of 18
• Item 11 - Signatory Requirements, paragraph a. (1) has been modified in the Federal
Regulations. This provision in the DWQ boilerplate should also be updated accordingly.
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North Carolina Department of Environment and Natural Resources
PO Box 29535, Raleigh, North Carolina 27626-0535/Phone: 733-5083