NC0003425_Effluent Channel Request_20160418

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f" DUKE Harry K. Sideris
Senior Vice President
ENERGY® Environmental,Health&Safety
526 S. Church Street
Mail Code:EC3XP
Charlotte,NC 28202
[phone]
April 13, 2016
Jeffrey O. Poupart RECEIVED/NCDEQ/DWR
Water Quality Permitting Section Chief APR 15 2016
Division of Water Resources
Department of Environmental Quality Water Quality
State of North Carolina Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Effluent Channel Request—Duke Energy Carolinas, LLC and Duke Energy Progress, LLC
Dear Mr. Poupart:
Duke Energy requests that effluent channel status be evaluated for the thirteen Duke Energy Coal Ash sites
where we submitted NPDES wastewater permits that included locations of Areas of Wetness. Since the
remaining NPDES wastewater permits involve various regions, we request that a coordinated approach from
your office be implemented to optimize this process and enable consistent and timely evaluation efforts for all
of the AOWs.
15A NCAC 02B .0202 and .0228 provide in part that"effluent channel means a discernable confined and
discrete conveyance which is used far transporting treated wastewater to a receiving stream" and "effluent
channels shall be designated by the Director, such that the channels shall:
(1) be contained entirely on property owned (or otherwise controlled) by the discharger (to be demonstrated by
the discharger);
(2) not contain natural waters except when such waters occur in direct response to rainfall events by overland
runoff;
(3) be so constructed or modified as to minimize the migration of fish into said channel;
(4) be identified and designated on a case-by-case basis prior to permit issuance."
Duke Energy has completed a preliminary review of the Areas of Wetness present at the thirteen stations and
has concluded that we meet the above stated conditions in a significant number of cases. We recommend and
request that a series of site visits and reviews be conducted by NCDEQ and Duke Energy personnel to
evaluate the applicability of effluent channel status for each of the AOWs identified in the NPDES Wastewater
permit applications. Following the site visits and preliminary determination of effluent channel status, Duke
Energy would construct appropriate barriers to prevent fish migration and submit documentation to verify that
we meet all appropriate conditions.
Duke Energy is committed to providing the Department with additional information to facilitate the issuance of
new permits for these thirteen sites. The issues are complex and warrant thorough evaluation and
consideration. Should you have any questions or require additional information please contact Richard Baker,
Director CCP Environmental Programs at 704-382-7959. Thank you for your consideration of this important
issue and we look forward to working with you to schedule initial site evaluations soon.

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Mr. Jeffrey 0. Poupart
Effluent Channel Request
Page 2
Sincerely,
Harry K. Sideris
SVP, Environmental, Health & Safety