NC0003425_Additional Information Request_20160426

•
DUKE Harry K.Sideris
tb, Senior Vice President
ENERGY® Environmental,Health&Safety
526 S. Church Street
Mail Code:EC3XP
Charlotte, NC 28202
[phone]
April 26, 2016
Jeffrey O. Poupart RECEIVEDINCDEQIDWR
Water Quality Permitting Section Chief
Division of Water Resources APR i8 2016
Department of Environmental Quality
State of North Carolina Water Quality
1617 Mail Service Center Permitting Section
Raleigh, NC 27699-1617
Subject: February 26, 2016 Additional Information Request— Duke Energy Carolinas, LLC and
Duke Energy Progress, LLC
Dear Mr. Poupart:
This letter responds to the Additional Information Request sent by you to Duke Energy
Carolinas, LLC and Duke Energy Progress, LLC on February 26, 2016.
Our responses to your requests are as follows:
1) Maps that identify all seeps and their relationship to jurisdictional waters as determined by the
USACE.
Duke Energy does not yet have jurisdictional determinations from the US Army Corps of
Engineers (USACE) for the relevant areas at all of the twelve sites mentioned in your letter. As
you know, Duke Energy submitted applications for renewed or modified NPDES permits in the
spring, summer and fall of 2014. As your letter reflects, the identification of jurisdictional waters
as they relate to potential seeps became an issue for additional discussion following EPA's June
10, 2015 comment letter. Duke Energy promptly initiated wetland delineation studies and
submitted to USACE for jurisdictional determinations in September, October, and November
2015. Duke has since worked with USACE to schedule site visits, make any necessary
revisions to the information, and provide draft plats for approval. A table showing the date of the
application is presented below. Nonetheless, the timing of the approved jurisdictional
determinations is up to USACE and outside Duke control. To date, out of the twelve sites, only
Buck has an approved jurisdictional determination, but it does not yet have a signed plat. Given
the history of our discussions with the Department on these issues, Duke's efforts to obtain the
requested jurisdictional determinations, and the fact that Duke does not control USACE's
schedule on this point, Duke's inability to provide the final jurisdictional determinations in the
timeframe you have requested should not be a basis for returning our permit applications.
Duke will submit the maps you have requested for each site on a rolling basis, within a
reasonable period after the jurisdictional determinations are complete. In the interim, should
you desire, we are prepared to discuss the wetland delineations prepared by our consultants for
each of the stations and submitted to USACE with our applications for jurisdictional
determinations.

Table—Status of Jurisdictional Determination Requests
Plant Date of Request
October15,:20:15.__'� =:_:
Asheville August 27, 2015
=Belews',. ;°P ,,;;r;;Novembe�:25 20,15
Buck September 10, 2015
Cape:Fear;; ; November24,2015
Cliffside September 24, 2015
Dan River;;'"as:•..°:.September 4, 201'5=:�braf
HF Lee November 25, 2015
`';Marshall, ; September 10 '2015,.
Mayo November 25, 2015
jRoxboro; a a, .;November 25,'201,5 .
Weatherspoon November 25, 2015
Timing aside, we will not be able to state, based on topography alone, whether any identified
seeps have any relationship to the impoundments or represent point source discharges of
pollutants under the Clean Water Act.
2) Locations, including latitude and longitude, where seeps discharge or can potentially
discharge to the jurisdictional waters.
As set forth above, Duke Energy does not yet have jurisdictional determinations from USACE.
In previous submittals, including in our permit applications and the proposed Discharge
Assessment Plans submitted in 2014, Duke provided latitude and longitude of the location of the
Areas of Wetness/seeps. We cannot specifically identify where the seep potentially discharges
to jurisdictional waters without the USACE jurisdictional determination. In the interim, should
you desire, we are prepared to discuss locations based on wetland delineations prepared by our
consultants for each of the stations. Also, not all of the areas of wetness and seeps previously
identified discharge pollutants via point source to jurisdictional waters.
3) Background concentration of the following parameters for the jurisdictional waters where
seeps discharge or can potentially discharge: flow rate, hardness, Oil and Grease, COD,
Chloride, F, Sulfate, Hg, Al, Ba, B, Ca, Fe, Mg, Mn, Zn, Sb, As, Cd, Cr, Cu, Pb, Mo, Ni, Se, TI,
TDS, TSS, pH, temperature, and specific conductance.
For the larger receiving waters, upstream data from sampling associated with current NPDES
permits has been routinely submitted to DEQ and Duke's proposed Discharge Assessment
Plans submitted in 2014. For other potential jurisdictional water bodies, as set forth above,
Duke does yet have the final jurisdictional determinations from USAGE. Hence, there is no
information available for these yet to be determined water bodies. Additionally, these potentially
newly identified waters may not provide an opportunity for upstream sampling if they originate
and are contained fully on site or if the point of origin is characterized as the seep itself. For any
such features determined to be surface waters, it may be necessary to establish one or more

reference waterbodies in order to identify a generic background conditions. In addition, there
are significant background influences on these seeps and or their sample point from
groundwater, wetlands chemistry, flooding from major water bodies, and precipitation runoff
which impacts pH and other constituents. Thus, establishment of background concentrations will
likely require additional discussion between Duke Energy and the Department to ensure that
appropriate data are collected for this purpose.
Duke Energy is committed to providing the Department with additional information to facilitate
the issuance of new permits for these twelve sites. The issues are complex and require special
consideration, as illustrated by the time elapsed since the permit applications were submitted.
We look forward to working with you further to resolve the issues identified here on a mutually
acceptable schedule.
Sincerely,
arry Sideris
Senior Vice President
Environmental, Health and Safety