NC0005363_Comments on Draft Permit_20161102

Ir" - fa DUKE
ENERGY.
PROGRESS
October 18, 2016
Certified Mail # 7015 1520 0001 0801 5064 (2 copies)
Trupti Desai
North Carolina Division of Environmental Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Duke Energy Progress, LLC
Weatherspoon Plant
Comments on Draft Permit NC0005363
Dear Ms. Desai,
W. H. Weatherspoon Plant
491 Power Plant Rd
Lumberton, NC 28358
Mailing Address:
Kent Tyndall
L. V. Sutton Energy Complex
801 Sutton Steam Plant Rd
Wilmington, NC 28401
o: 910.341-4775
f: 910.341-4790
RECEIVE- DN "DE-000JR
Nov 0 2 2016
1I'We" L:tw�,iiiy
Permitting Section
Duke Energy Progress, LLC has received the draft NPDES wastewater permit for the W.H.
Weatherspoon Plant. Duke Energy appreciates the opportunity to review the permit and has the
following comments on the draft.
Title Page- the ownership entity for Weatherspoon Plant is Duke Energy Progress,
LLC.
2. Page 2- Duke Energy requests that the description of wastewater flows to the cooling
pond (in the first bullet) include the term "ash pond seepage".
3. Page 3, Section A(1). Duke Energy requests that footnote 1 be modified to remove
the statement `This discharge is permitted only in cases caused by extreme rainfall;
where unavoidable to prevent loss of life, severe property damage, or damage to the
cooling pond structure; or maintenance activities." The effluent limits of the permit
place appropriate limitations on the discharge to protect water quality during normal
operations and dewatering, therefore Duke Energy requests the flexibility to operate
this outfall, as needed.
4. Section A(2), footnotes 4 and 5. The Division has typically imposed automated TSS
and pH monitoring during decanting operations, as a control mechanism when
existing, treated bulk water is discharged from the ash pond with decanting pumps .
However, Weatherspoon Plant is required to install additional physical chemical
wastewater treatment for interstitial dewatering. The permit limits, as drafted, are
sufficient to protect water quality. Therefore Duke Energy requests that the
requirements for automated monitoring be removed as it is not applicable to
interstitial dewatering.

,T, ft-_ .
5. Section A(10) Instream Monitoring. Duke Energy requests that the semi-annual
instream monitoring requirement be waived if there has been no discharge within the
preceding semi-annual period. As the Division is aware, the cooling pond only
discharges in response to extreme storm events and Duke Energy plans to re-route
outfall 105.
6. Section A(12). This permit condition applies to the discharge of "domestic
wastewater treatment plant". As stated in the permit materials, the Weatherspoon
Plant has an onsite septic system with a leach field. There is no direct discharge (i.e.
a pipe) from this system to the cooling pond. Rather, this system is listed as a
contribution to the cooling pond due to its close proximity. Since there is no direct
discharge from this system, Duke Energy believes that condition A(12) has been
misapplied. We request that this condition be removed.
7. Section A(15). Duke Energy requests that the annual fish tissue monitoring
requirement not apply if there has not been a discharge from outfall 001 within the
preceding annual period.
Duke Energy appreciates the opportunity to provide comments on this draft permit. If there are
any questions, please contact either:
• Mr. Kent Tyndall, Environmental Professional for the W. H. Weatherspoon Plant;
phone [phone] or e-mail [e-mail]; or
• Ms. LeToya Ogallo, Environmental Specialist at our North Carolina Regional
Headquarters, phone [phone] or email [e-mail].
I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.
Sincerely,
Jason V. Haynes
Station Manager