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HomeMy WebLinkAboutNC0004961_Effluent Channel Request_20160415DUKE ENERGY® April 13, 2016 Jeffrey O. Poupart Water Quality Permitting Section Chief Division of Water Resources Department of Environmental Quality State of North Carolina 1617 Mail Service Center Raleigh, NC 27699-1617 Harry K. Sidens Senior Vice President Environmental, Health & Safety 526 S. Church Street Mail Code: EC3XP Charlotte, NC 28202 (704) 382-4303 RECEIVEDINCDEWWR APR 15 2016 Water Quality Permitting Section 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 for 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. Mr. Jeffrey O. Poupart Effluent Channel Request Page 2 Sincerely, Harry K. Sideris SVP, Environmental, Health & Safety