NC0001422_Sutton Draft NPDES Comments_20170622

Strickland, Bev
From: Ogallo, LeToya Fields <[e-mail]>
Sent: Thursday, June 22, 2017 2:11 PM
To: SVC_DENR.publiccomments; Poupart, Jeff
Cc: Baker Jr, Richard E; Tyndall, Kent; Chernikov, Sergei
Subject: Sutton Draft NPDES Comments
Attachments: Duke_comments_on_draft_npdes_permit6-22.pdf
Duke Energy appreciates the opportunity to provide comments on the draft NPDES permit for the L.V. Sutton Energy
Complex. Our comments are attached.
Thank you,
Toya
Toya Cligallo I Environmental Specialist
Duke Energy NPDES Permitting and Compliance
4.10 Smah Wilming Lon SLreeL, Raleigh h Ow C 2760.1
ca: 9.19.546.6647 1 c: 9.19.608.1.793 1 f: 9.19.546.4409

DUKE
ENERGY.
PROGRESS
June 22, 2017
Mr. Jeffrey O. Poupart
NCDEQ-DWR, Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Duke Energy Progress, LLC.
L. V. Sutton Energy Complex NPDES Permit NC0001422
Comments on Draft NPDES Permit
Dear Mr. Chernikov:
L. V. Sutton Energy Complex
801 Sutton Steam Plant Rd
Wilmington, NC 28401
o: 910.341.4750
f: 910.341.4790
Duke Energy Progress, LLC (Duke Energy) has reviewed the draft permit for the L.V. Sutton Energy
Complex (Sutton). Duke Energy appreciates the opportunity to review the permit and has the following
comments on the draft.
In Section A(2), Duke Energy requests that the proposed compliance schedule for copper and
nickel also be provided for the new decreased lead limit. Although the previous permit also
included a lead limit, the limit has been reduced due to the newly adopted NC water quality
standards.
2. Pertaining to the Cape Fear mixing zone model referenced in Section A(1), A(2), and A(22); Duke
Energy requests that the Division clarify that a request to modify the permit to reflect dilution
modeling results, as allowed under this permit, will be processed by the Division as a minor
permit modification.
3. As you are aware, the Cape Fear estuary exhibits naturally high chloride levels during drought
scenarios. Duke Energy has provided historic chlorides data in the Cape Fear River and cooling
pond to illustrate this phenomenon. To accommodate this natural occurrence, Duke Energy
requests that the chloride footnote in Section A(2) be modified to state the following: "The
wastewater discharge from this facility shall not cause the chloride level in the Cape Fear River
to exceed 230 mg/L. This limit does not apply if elevated chloride levels are due to natural
conditions in the estuary."
4. Duke Energy continues to believe that the monitoring requirements in section A(5) are an exact
duplicate of the requirements in A(2). The same waste stream is regulated at outfall 001 under
Section A(2) and A(5). Therefore Duke Energy requests that page A(5) be deleted. However if
DEQ insists on maintaining both pages in the permit, Duke Energy requests that the footnotes
are in alignment. Specifically Section A(5) should reflect the 12 month compliance schedule

L. V. Sutton Electric Plant NPDES Permit NC0001422
Comments on Draft Permit
Page 2of2
which was granted for copper, nickel and lead at outfall 001. Also, Section A(5) footnotes 6 and
7 should be removed since they apply to a decanting scenario rather than the dewatering
scenario. Duke Energy also requests that the DEQ provide guidance on a -DMR reporting for the
duplicate requirements in A(2) and A(5). It appears that the draft permit will require the same
data to be reported in two locations.
5. In Section A(8), Duke Energy requests that monitoring for As, Se, Hg, and N be removed on the
basis that this is redundant to the monitoring requirements at outfall 008. There is no basis
provided in the fact sheet for these monitoring requirements at this internal outfall.
6. In Section A(10), the instream temperature monitoring requirements is a daily requirement
since the automated temperature recording station has been installed. The word "weekly" can
be removed. Duke Energy also requests that the Instream Temperature sample type be changed
to "Instantaneous" since this reading is performed by an automatic monitoring station.
Also in Section A(10), Duke Energy requests that the compliance schedule be applied to all new
water quality based limits (arsenic and selenium as well as copper).
Once again, Duke Energy appreciates the opportunity to comment on this draft permit. If there are any
questions regarding this submittal, please contact either:
Ms. Toya Ogallo, Environmental Specialist at our North Carolina Regional Headquarters, phone
[phone] or email [e-mail] or
Mr. Kent Tyndall, Environmental Professional for the L. V. Sutton Energy Complex Plant; phone
[phone] or e-mail [e-mail].
l 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. l am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
Sincerely,
J -we- !E � 1
Jesse E. Huntley, II
Station Manager