NC0001422_Notes_20040408

Michael Shawn Longfellow, Plant Manager
Progress Energy Carolinas, Inc.
Sutton Steam Plant
801 Sutton Steam Plant Road
Wilmington, NC 28401
On Thursday April 8, 2004, in a conversation between Mr. Reid Garrett, Senior
Environmental Specialist of Progress Energy and Mr. Mark Hale (title ?) of our staff, it
was brought to our attention that there exists some ambiguity regarding the Fish Study
and Monitoring requirement in the Sutton Plant National Pollutant Discharge Elimination
System Permit (NPDES) NC0001422. The requirement is to sample fish from the Cape
Fear River in association with discharge of an ash pond pipeline. This letter is intended
to clarify any confusion regarding this permit requirement.
The permit requires annual fish tissue analysis and reporting of contaminant data to the
State. However, there are conditions described in the original approved study plan
(1999) that must still be met prior to conducting any sampling. Specifically, the State
requires that Progress Energy sample fish on an annubasis from the Cape Fear River
per the study plan only after Outfall 004 has discharg or at least four consecutive
months (near continuous discharge) within each calendar year. If these conditions are
not met, then sampling is not required. In addition, use of the term "re- routing" found in
both the permit and the approved study plan means actual operation of the ash pond
pipeline or discharge from the ash pond via Outfall 004 to the Cape Fear River.
We understand that Progress Energy has not collected any fish samples and submitted
trace element (selenium) data since construction of the pipeline because the required
conditions have not been met. If you have any questions, please call......
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