NC0001422_Industrial Stormwater Evaluation_20150302

(� DUKE
ENERGY.
PROGRESS
February 23, 2015
Mr. Bradley Bennett
NCDEMLR- Stormwater Permitting Program
1612 Mail Service Center
Raleigh, NC 27699 -1612
Subject: Duke Energy Progress, Inc.
L. V. Sutton Energy Complex
NPDES Industrial Stormwater Evaluation
Dear Mr. Bennett:
L. V. Sutton Energy Complex
801 Sutton Steam Plant Rd
Wilmington, NC 28401
o: 910.341.4750
f: 910.341.4790
RECEIVEDIDENRIDWR
MAR 0 2 2015
Water Quality
Permitting Section
This letter and the attached materials are provided in response to Tom Reeder's February 6th letter
which indicated that the Department of Environment and Natural Resources is preparing draft NPDES
permits for the L.V. Sutton Energy Complex (Sutton Plant). The draft would address NCDENR's
November 5, 2014 notice letter reclassifying Sutton Cooling Pond as "Waters of the State ".
Historically, Sutton Plant has not been required to obtain an individual industrial stormwater permit due
to the fact that all stormwater flows were comingled with wastewater and properly authorized under
the NPDES permit. Stormwater which was identified as being potentially influenced by industrial activity
(or materials) was routed to the ash ponds for treatment before being discharged into the cooling pond.
Other "exempt" stormwater flows were routed directly to the cooling pond, also comingled with
wastewater, and monitored through the requirements of the NPDES permit prior to being discharged
through outfall 001 to the Cape Fear River. NCDENR's intent to reclassify the cooling pond as "Waters of
the State" necessitated a review of all point source stormwater discharges to the cooling pond. Duke
Energy would then be required to apply for permit coverage for those distinct point - source outfalls to
waters of the state.
Enclosed, please find an assessment titled identification of Potential NPDES Permittable Discharge
Points. This assessment is the result of an evaluation commissioned by Duke Energy to identify all
potential point source discharges at the Sutton Plant. The evaluation considered existing site operations
as well as planned and future activities such as coal removal and ash pond excavation.
Although the assessment does identify several potential outfalls, those outfalls discharge to the Sutton
Plant's effluent channel. Duke Energy has submitted an application to the Division of Water Resources
to properly permit the effluent channel (which primarily consists of the site's recirculated water
discharge) as a comingled waste stream. This waste stream would be regulated as a new NPDES outfall
008 discharging into Sutton Cooling Pond.
Since all site stormwater is comingled with wastewater and will be authorized and regulated by the
NPDES wastewater permit, there are no point source discharges of stormwater requiring an individual
industrial stormwater permit. Therefore an application for an individual industrial stormwater permit
will not be submitted. As described in the excavation plan submitted for the Sutton Plant, Duke Energy

L V. Sullm Of - -'r P1MM NPW8 Partin NC0001422
Rup a @ b NCDENR Nola d IModNk@Vm
PaP2d2
will implement stormwater hest management practices, as applicable, found in Table 2 of the EPA
Sector "0" Industrial Stormwater Fact Sheet as an added measure of good faith.
Duke Energy respectfully request that NCDENR review the enclosed evaluation and provide a written
response as to your concurrence that no individual industrial storm water permit is required for existing
activities or the movement of materials (i,e, residual coal and /or ash) In the drainage areas flowing to
the wastewater effluent channel.
Thank you, in advance for your consideration of the above - requested items. If there are any questions,
please contact either:
• ML Toya Ogallo, Environmental Specialist at our North Carolina Regional Headquarters, phone
[phone] or email Wjova.Oeailo48duke- enerev.com, or
• Mr. Kent Tyndall, Environmental Professional for the L V. Sutton Energy Complex Plant; phone
(910) 341 -4775 ore -mall Kent.Tvndal19Dduke- enerRvv.com.
J certify, under penalty of law, that this docnnnent and all aunts were prepared under my
direction or supervision In accordance with a system designed to assure dot quagjled personnel
properly gather and evaluate the information submitted Based an my Inquiry a¢ the person or
persons who manage the system, or dwse persons &ecly respws9*f w gi g the
Information, the Information subm tted is, to the best of my kwwfedge and belief, tare,
accurate, and complete. l am aware that there are signifkant pernolties for submitting false
information, Including the possibility of fines and imprisonment for knowing violations.
Sincerely,
A-gvz--�
Allen A. Clare
Station Manager
Enclosures

A. AlIp
A OF,
amec
foster
wheeler
February 20, 2015
Ms. Letoya Ogallo
Duke Energy NPDES Permitting and Compliance
NCRH 14
410 South Wilmington Street
Raleigh, North Carolina 27601
Subject: Identification of Potential NPDES Permittable Discharge Points
L.V. Sutton Energy Complex
New Hanover County, North Carolina
Dear Ms. Ogallo,
As authorized by Duke Energy Carolinas, LLC (Duke Energy), Amec Foster Wheeler
Environment & Infrastructure, Inc. (Amec Foster Wheeler) completed the identification of
potential National Pollutant Discharge Elimination System (NPDES) permittable discharge
points (both wastewater and industrial stormwater) at the L.V. Sutton Energy Complex. This
work was based upon the new classification of the Cooling Pond as "Waters of the State ".
The scope of work included Amec Foster Wheeler's identification site visit with Duke Energy
personnel, review of data and information on the history and nature of each potential NPDES
outfall, production of a new outfall map that identifies and locates each newly permittable outfall
(Appendix A), and this letter report.
Background Information
On November 5, 2014, the North Carolina Department of Environment and Natural Resources
(NCDENR) submitted a letter to Duke Energy detailing the reclassification of Sutton Lake
(Cooling Pond) as "waters" of the State, as defined in the North Carolina General Statute §143-
212(6). This reclassification necessitates a modification to the NPDES permit for the L.V. Sutton
Energy Complex (NC0001422).
There is one final permitted outfall and five internal outfalls that are identified in the current
NPDES permit for the Sutton Plant. However, there are additional outfalls to the Cooling Pond,
which may need to be permitted.
Existing Outfall Identification
Amec Foster Wheeler reviewed site reconnaissance data from archived design and as -built
plans, performed a site specific walk- through with Duke Energy personnel on 12 February 2015,
and used Graphic Information System (GIS) equipment to obtain the geodetic location of each
potential NPDES permittable outfall.
Correspondence:
Amec Foster Wheeler Environment & Infrastructure, Inc.
4021 Stirrup Creek Drive, Suite 100
Durham, North Carolina 27703
Tel [phone]
Fax [phone]
Lkensure: NC Engineering F -1253 NC Geology C -247

Duke Energy
February 20, 2015
Page 2
L V. Sutton Energy Complex
Amec Foster Wheeler identified the potential NPDES permittable outfalls (NPO) and presents
them in Table -1 below. The outfalls are graphically shown in the attached photolog and in
Appendix A.
Table4: Potential NPDES (Wastewater and Industrial Stormwater) Pennittable Outfalls
Outfall ID Outfall Description
Existing NPDES Outfall for the Cooling Pond Sluice Structure Discharge into the
001 Cape Fear River. This outfall also includes a 12" HOPE gravity bypass discharge
pipe from the 1984 Ash Pond Discharge Tower.
Existing NPDES Internal Outfall for the 1971 Ash Pond Riser Structure into the
002 Cooling Pond. This outfall currently receives pumped stormwater from the former
coal -fired generation site area.
Existing NPDES Internal Outfall for the 1984 Ash Pond Discharge Tower into the
004 Cooling Pond. The 1984 Ash Pond is planned to receive pumped water from the
1971 Ash Pond and the 1984 Ash Pond during ash removal.
Two 16 -inch Reinforced Concrete Pipes (RCP) outfalls that drain stormwater
NPO -1 runoff from the temporary laydown area and parking lot into the Discharge
Canal. The laydown area is covered under an existing ES &C Plan (Project ID:
NEWHA- 2014 -013).
6 -inch Ductile Iron Pipe (DIP) outfall that discharges pumped stormwater runoff
NPO -2 from the parking lot and Peaker Combustion Turbine (CT) area into the
Discharge Canal.
NPO -3 Two 16 -inch RCP outfalls that drain stormwater runoff from the parking lot area
into the Discharge Canal.
NPO-4 6 -inch DIP outfall that discharges pumped stormwater from the 115 Electrical
Switchyard area.
Heated water discharge flume for the Combined Cycle generation units. This
NPO -5 outfall structure includes the discharge pipe from the south wet detention basin
at the South of the Plant. The pipe size and location were not identified at the
time of the inspection, due to the level of water within the discharge canal.
NPO-6 Rip rap armored emergency spillway for the north infiltration basin that treats
stormwater from a parking lot and surrounding areas.
Future Outfall Identification
Amec Foster Wheeler discussed and reviewed future construction and operation plans for the
site with Duke Energy personnel on 12 February 2015. Amec Foster Wheeler discussed the
potential construction of new rail road spurs within the site and a new loading yard at the Ash
Pond sites. We also discussed potential groundwater management strategies and planned
Correspondence:
Amec Foster Wheeler Environment & Infrastructure, Inc.
4021 Stirrup Creek Drive, Suite 100
Durham, North Carolina 27703
Tel [phone]
Fax [phone]
Licensure: NC Engineering F -1253 NC Geology C -247

Duke Energy L V �Y Complex
Febru 2015 V. Sutbn En
Page 3
points of discharge into the discharge canal. We understand that neither the rail line nor the
groundwater management strategies have been designed.
Based upon our understanding of the rail line construction and the future ash removal plans,
Amec Foster Wheeler presents the future potential outfalls (FPO) that may need to be permitted
in Table -2 below.
Table -2: Future Potential NPDES Permittable Outfall Descriptions
Outfall ID Outfall Description
12 -inch DIP existing stormwater force main from the West Detention Basin is
planned to be rerouted to discharge flow directly into the discharge canal. In July
FPO -1 2014, Duke Energy applied for this discharge to be included in the NPDES
wastewater permit as internal outfall 007. This modification is currently in review
with the NCDENR.
12 -inch DIP existing stormwater force main from the tank farm may be rerouted
to discharge flow directly into the discharge canal. As disclosed in Duke
FPO -2 Energy's July 2014 permit modification request, this re-route would occur after
coal has been removed (coal pile runoff currently contributes to the tank farm
force main) and the area re- graded in accordance with the Erosion and
Sedimentation Control Plan.
Construction of the potential rail loading yard during the ash removal may require
stormwater collection and routing to either the discharge canal or one of the ash
FPO -3 basins for storage. The location of the potential outfall(s) has not been
determined and, based on review of preliminary design plans, no potential point
sources have been identified.
Conclusions
Amec Foster Wheeler identified a total of nine potential NPDES permittable outfalls for the
Sutton Plant based upon reclassification of Sutton Lake (Cooling Pond) as "waters" of the State.
Outfalls 001, 002, and 004 are existing NPDES permit outfalls from permit NC0001422 and
remain as permittable outfalls, based on the Sutton Lake reclassification. Outfalls NPO -1
through NPO-6 are existing outfalls into the discharge channel that could be considered
permittable, based on the Sutton Lake reclassification. Each of these outfall locations is
described in Table -1.
Through discussions with Duke Energy staff, Amec Foster Wheeler identified three possible
future permittable NPDES outfall locations. Future outfall FPO -1 is currently in review with the
NCDENR and pending approval. Future outfall FPO -2 is related to decommissioning and
outfalls FPO -3 is related to potential ash removal excavation and transportation activities. It is
Amec Foster Wheeler's understanding that the design plans for the future rail spurs and the
excavation plans have not been finalized or permitted.
Correspondence:
Amec Foster Wheeler Environment & Infrastructure, Inc.
4021 Stirrup Creek Drive, Suite 100
Durham, North Carolina 27703
Tel [phone]
Fax [phone]
Licensure: NC Engineering F -1253 NC GeoIogy C -247

Duke Energy
February 20, 2015
Page 4
Recommendations
L V. Sutton Energy Complex
Amec Foster Wheeler recommends an update of the NPDES permit (NC0001422) for the
Sutton Combined Cycle Station to reflect the 10 newly pennittable outfalls (Outfalls 001, 002,
004, NPO -1 through NPO-6, and FPO-1) into the Cooling Pond.
Until the design plans for the ash removal, rail spur extension and loading yard are completed
and the specific location of the outfalls identified, future outfall FPO -2 and FPO -3 cannot be
included in the NPDES permit update. The NPDES permit may need to be updated once the
final locations for FPO -2 and FPO -3 are finalized. It should be noted that FPO -3 may not be
needed if no point sources are identified with the rail loading yard.
It is our understanding that NCDENR on 11 February 2015 has defined the discharge canal as
an effluent channel that extends from the combined cycle power block to a location where the
dredged channel ends at Sutton Lake. Therefore, the change in classification of the discharge
canal to an effluent channel will likely eliminate the need for additional Stormwater NPDES
coverage and only require an update to the existing NPDES permit. It would also allow
additional flexibility for discharges during the decommissioning and ash removal projects at the
site. Ames Foster Wheeler also suggests possible construction of a level weir to isolate the
discharge channel from the Cooling Pond. While this would not provide additional storage for
retention purposes, it would provide a mechanism to separate the "waters" of the State and
provide a measure of outlet control during plant decommissioning activities and ash removal
projects.
Closing
Amec Foster Wheeler appreciates the opportunity to offer our services on this project. If you
have any questions concerning this response, please contact us.
Sincerely,
Amec Foster Wheeler Environment & Infrastructure, Inc.
Jason Carmine, P.E. Brian Lowther, P.E.
Senior Engineer Project Engineer
IVX
Ch E
e,",}1l11111►/I ryl
Attachments: Appendix A — NPDES Permittable Outfall Locations Map
Appendix B — Photographic Log
Corrsspondwoo:
Amec Foster Wheeler Environment & Infrastructure, Inc.
4021 Stirrup Creek Drive, Suite 100
Durham, North Carolina 27703
Tel [phone]
Fax [phone]
Licensure: NC Engineering F -1253 NC Geology C -247

amec
a
foster
wheeler
Appendix A
NPDES Permittable Outfall Locations Map
Correspondent.:
Amec Foster VNheeler Em*onment & Infrastructure, Inc.
4021 Stirrup Creek Drive, Suite 100
Durham, North Carolina 27703
Tel [phone]
Fax [phone]
Uoensure: NC Engineering F -1253 NC Geology 0-247

i;
- * '
is
III oa
PG EmeFgn&
DIPALh" 4Y
Irifilt(ati n
'orm i eh�rge Roy ^r /
r P ma ;t yiBe Plaro
NPO.6,
I i eo�and Nobm '.s2 - "�
LEGEND
:aZ= New Permittable Stormwater Outfall
Exsiting NPDES Outfall
A Point of Interest
NPR Approximate Drainage Areas
r into
FPO Future Potential Outfall
Drainage Area Information
NP41 :, Parking Lof/Laydown Yard
NPC-2 i CT Units/Yard Drainage
NPO 3 ( Parking Lot
NPOA -t Switch Yard Area
NP0.5 Combine Cycb Pleat
NP46 Parking Lot
Retired Coal Plant (punW to
FP0­1 I West Detention Pond and then
:to Outfal002)
1 Former Coal Storage
FPO-2 iArea/Tank Farm (Pumped to
Outfall 002)
FPC-3 Potential Rail System
in
Amec Foster Wheeler reviewed site reconnaissance
— data from archived design and as -built plans, perfor-
med a site specific walk- through with Duke Energy
personnel on 12 February 2015, and used GIS equip-
ment to obtain the geodetic location of each new
NPDES perrnittable outfall.
NEW PERMITTABLE
OUTFALL LOCATIONS
DUKE ENERGY PROGRESS
L.V. SUTTON ENERGY COMPLEX
GWILMINGTON, NC
Projection: NAD83 State Plane FIPS 3200 (US Feet)
Vertical Datum: NAVD88
FIGURE: 001 I DATE: 02 -20 -15

Appendix B
Photographic Log
Com spoadence:
AmecFosterWheeler'- 6tlt..i.. , .,,, ,hoc.
4021 Stirrup Creek Drive, Suite 100
Durham, North Carolina 27703
Tel [phone]
Fax [phone]
Lime: NC En&mrin8 F -1253 NC OwkW C -247
-41
amec
foster
wheeler

amec t
foster
wheeler
Client Name:
Duke Energy
Photo No. 1 Date:
02/1212015
Description:
NPO -1 - Two 16 -inch Reinforced
Concrete Pipes (RCP) outfalls that
drain stormwater runoff from the
laydown area and parking lot into the
Discharge Canal.
Location:
34.28453° N
77.983638° W
Photo No. 2
Description:
Date:
02112/2015
Inlet to NPO -1 that drain stormwater
from the laydown area and parking lot
into the Discharge Canal.
Location:
34.28453° N
77.983638° W
PHOTOGRAPHIC LOG
Site Location:
L.V. Sutton Energy Complex
kkk
- i•,j
V.

amec
foster
wheeler
Client Name:
Duke Energy
Photo No. 3 Date:
02/12/2015
Description:
NPO -2 - 6 -inch Ductile Iron Pipe (DIP)
outfall that discharges pumped
stormwater from the parking lot and
Combustion Turbine (CT) Towers area
into the Discharge Canal.
Location:
34.284205° N
77.983721 ° W
Photo No. 4 1 Date:
02/12/2015
Description:
NPO -3 - Two 16 -inch RCP outfalls that
drain stormwater runoff from the
parking lot area into the Discharge
Canal.
Location:
34.283519° N
77.983732° W
PHOTOGRAPHIC LOG
Site Location:
L.V. Sutton Energy Complex
0

amec
foster
wheeler
Client Name:
Duke Energy
Photo No. 5 Date:
02/12/2015
Description:
NPO -4 - 6 -inch DIP outfall that
discharges pumped stormwater from
the 115 Electrical Switchyard area.
Note: All oil containing areas of the
switchyard go to an OWS for
treatment.
Location:
34.28282° N
77.983971' W
Photo No. 6
Description:
Date:
02/12/2015
View of 115 Electrical Switchyard area
and lift station #10.
PHOTOGRAPHIC LOG
Site Location:
L.V. Sutton Energy Complex
..rte"

amec
foster
wheeler
Client Name:
Duke Energy
Photo No. 7 Date:
I 02/12/2015
Description:
8 inch DIP discharge - source currently
unknown. Capped and not in use.
Location:
34.282565° N
77.984019° W
Photo No. 8 1 Date:
02/12/2015
Description:
View of capped 8 inch DIP
Location:
34.282565° N
77.984019° W
PHOTOGRAPHIC LOG
Site Location:
L.V. Sutton Energy Complex

amec
foster
wheeler
Client Name:
Duke Energy
Photo No. 9 Date:
02/12/2015
Description:
NPO -5 - Heated water discharge flume
for the Sutton Combined Cycle Station.
This outfall structure includes the
discharge pipe from the stormwater
pond at the South of the Plant. The pipe
size and location were not identified at
the time of the inspection due to the
level of water within the discharge
canal.
Location:
34.282647° N
77.983456° W
Photo No. 10
Description:
Date:
02/1212015
NPO -6 - View of Rip rap armored
emergency spillway for the North
Infiltration Basin that treats stormwater
from a parking lot and surrounding
areas.
Location:
34.282773° N
77.98333° W
PHOTOGRAPHIC LOG
Site Location:
L.V. Sutton Energy Complex

amec
i
foster
wheeler
Client Name:
Duke Energy
Photo No. 11 1 Date:
02/12/2015
Description:
View of 6 -inch PVC eductor pipe for
back washing the inlet screen
(Recirculation)
Note: This pipe will be removed as part
of demolition of the coal site.
Location.
34.282024° N
77.986159° W
Photo No. 12 Date:
02/12/2015
Description:
Exisiting NPDES Outfall 001 Sampling
Point.
Location:
34.282617° N
77.988917° W
Site Location:
L.V. Sutton Energy Complex
PHOTOGRAPHIC LOG
�.
1�

IT
amec
foster
wheeler
Client Name:
Duke Energy
Photo No. 13 Date:
02/12/2015
Description:
1984 Discharge Tower Diverter
Structure
Location:
34.298853° N
77.992441° W
Photo No. 14 Date: _
02/ 1212015
Description:
1984 Ash Pond Outlet Stucture - Outfall
004
PHOTOGRAPHIC LOG
Site Location:
L.V. Sutton Energy Complex
i
;�
� r
L

amec
foster
wheeler
Client Name:
Duke Energy
Photo No. 15 Date:
02/1212015
Description:
1971 Ash Pond Discharge Pipe
Note: Approximate location (actually
about 10 feet to the east)
Location:
34.292545° N
77.993243° W
Photo No. 16 1 Date:
02/12/2015
Description:
1971 Ash Pond Outlet Structure -
Outfall 002
PHOTOGRAPHIC LOG
Site Location:
L.V. Sutton Energy Complex